STATE OF FLORIDA " DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATIO: DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, es Petitioner, vs. Case No.: 20005791 1 ROBERT L. CARELLI AND, DRAFTWORKS DESIGN ASSOCIATES, . OS 3884 Respondents. / ADMINISTRATIVE COMPLAINT. Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against ROBERT L. CARELLI and DRAFTWORKS DESIGN ASSOCIATES, ("Respondents"), and says: 1. Petitioner is the state agency charged with regulating the practice of architecture and interior design pursuant to Section 20.165, Florida Statutes, and Chapters 455 and 481, Florida Statutes, 2. The Departinent of Business and Professional Regulation has jurisdiction over the unlicensed practice of architecture pursuant to Section 455.228(1), and Section 481,223(1)(a), Florida Statutes. 3. At all times material hereto, Respondents were not duly registered or certified to engage in the practice of architecture in the State of Florida pursuant to Chapter 481. Florida Statutes. 4, Respondent’s last known address is 311 South Woodland Boulevard, Deland, Florida 32720. 5. Respondents entered into a contract with Paul Holland to provide architectural services for a project known as the Northside Physical Therapy and Rehab, Inc., located at 724 Plymouth Avenue, Deland, Florida. 6. Respondents prepared plans for the project which were submitted to the City of Deland Architectural Review Committee on November I, 2004. 7. The plans are copyrighted by Respondent Draftworks Design Associates. 8. Respondents name appears in the title block of the plans. 9. On or about September 30, 2004, Respondents submitted an invoice to Paul Holland for building design and site plan design in the amount of $6,500.000. COUNT I 10. Petitioner hereby realleges and incorporates paragraphs one (1) through nine (9) as if fully set forth herein. HH. 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.” 12. Based upon the foregoing, Respondents, have violated Section 481.223(1)(a), Florida Stautes, by practicing architecture when they were not the holder of a valid license by contracting to provide architectural services and accepting payment for architectural services involving commercial property for the Northside Physical Therapy and Rehab project. COUNT II 13. Petitioner hereby realleges and incorporates paragraphs one (1) through nine (9) as if fully set forth herein. to 14. Section 481.219(2), Florida Statutes, states a corporation, partnership, or a person practicing under a fictitious name, offering architectural services to the public must obtain a certificate of authorization. 15. Based upon the foregoing, Respondent, Draftwork Design Associates has violated Section 481.219(2), Florida Statutes, by offering architectural services when it was not the holder of a valid certificate of authorization. WHEREFORE, Petitioner respectfully requests the Board enter an Order imposing an administrative fine not to exceed $5,000 per count, assess costs associated with investigation and prosecution, impose any or all penalties delineated within Section 455.227(2), Florida Statutes, and/or any other relief that the Board is authorized to impose pursuant to Chapters 481 and 455, Florida Statutes, and/or the rules promulgated thereunder. Signed this __2 rch day of _§$ Dena , 2005. FILED 2 “Sten Department of Business and Professional Regulation DAVIDK.MINACC] DEPUTY CLERK Smith, Thompson, Shaw & Manausa, P.A. . 2075 Centre Pointe Blvd. cue tarde Thichet Tallahassee, Fl 32308-4893 =‘ fo 00s FL Bar No. 0056774 DATE _©@-7-2005 Ph: (850) 402-1570 Fax: (850) 402-1508

Docket for Case No: 05-002884