STATE OF FLORIDA ofp DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION hep” 4 / DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, vs. DBPR Case No-:.2003-070575 SANDRA SUAREZ, Respondent. / ADMINISTRATIVE COMPLAINT. Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against SANDRA SUAREZ, ("Respondent"), and says: 1. Petitioner is the state agency charged with regulating the practice of architecture pursuant to Section 20.165, Florida Statutes, and Chapters 455 and 481, Florida Statutes. 2. The Department of Business and Professional Regulation has jurisdiction over the unlicensed practice of architecture and interior design pursuant to Section 455.228(1), and Section 481.223(1)(a), Florida Statutes. 3. At all times material hereto, Respondent was not duly registered or certified to engage in the practice of architecture pursuant to Chapter 481, Florida Statutes. 4. Respondent's last known address is 341 W. 59" Street, Hialeah, FL 33012. 5. On or about May 16, 2003, Respondent signed an Affidavit of Probable Construction Cost for the Gran Central Corp Review Committee as the Architect of Record. 6. On or about December 2, 2002, Respondent prepared a set of plans which contain a title block that holds herself out as an architect and contains the license number of an ‘architectural firm of which she has no association. COUNT I 7. Petitioner hereby realleges and incorporates paragraphs one (1) through six (6) as if fully set forth herein. 8. Section 481.223(1)(a), Florida Statutes, states that a person may not knowingly “practice architecture unless the person is an architect or a registered architect.” 9. Based upon the foregoing, Respondent has violated Section 481.223(1)(a) by practicing architecture when they were not the holder of a valid license. COUNT I 10. Petitioner hereby realleges and incorporates paragraphs one (1) through six (6) as if fully set forth herein. 11. Section 481.223(1)(c), Florida Statutes, states that a person may not knowingly “use the name or title ‘architect’ or ‘registered architect’ or words to that effect, when the person is not then the holder of a valid license.” 12. Based upon the foregoing, the Respondent has violated Section 481.223(1)(c), * Florida Statutes, by using the name or title “architect”, when she was not the holder of a valid license. COUNT Hi 13. Petitioner hereby realleges and incorporates paragraphs one (1) through six (6) as if fully set forth herein. 14. Section 481.223(1)(d), Florida Statutes, states that a person may not knowingly “present as his or her own the license of another.” 15. Based upon the foregoing, the Respondent has violated Section 481.223(1)(d), Florida Statutes, by using the license number of a licensed architectural firm of which she has no soe \. association. ‘ WHEREFORE, Petitioner respectfully requests the Board enter an Order imposing an administrative fine not to exceed $5,000 per count, assess costs associated with investi gation and prosecution, impose any or all penalties delineated within Section 455.227(2), Florida Statutes, and/or any other relief that the Board is authorized to impose pursuant to Chapters 481 and 455, Florida Statutes, and/or the rules promulgated thereunder. ” : Signed this ___/¢ day of_ Perce mbe — »oee3 . Department of Business and Professional Regulation 2» JS Bo DEPUTY CLERK DAVID K. MINACCI Smith, Thompson, Shaw & Manausa, P.A. cuerx Beard! Tlcchels 2075 Centre Pointe Blvd. Tallahassee, FL 32308-4893 DATE | Z | -2 003 FL Bar No. 0056774 ‘ Ph: (850) 402-1570 Fax: (850) 402-1508 PoP: [D308 Redngy Wik Lads

Docket for Case No: 04-000470