fos STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATHOAYy ae Le “f} ~7 DEPARTMENT OF BUSINESS AND Antiive, PROFESSIONAL REGULATION, Wy SO 7 ~ My OHS 4 Petitioner, 0 7 ~ 3s K“ sel le vs. DBPR Case No.: 2006-057672 NERIE ANNETTE PAGAN AND, TDI ARCHITECTURAL DESIGN SERVICES, | Respondents. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against NERIE ANNETTE PAGAN and TDI ARCHITECTURAL DESIGN SERVICES ("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 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. Respondents’ last known address is 10190 Boca Entrada Boulevard #111, Boca Raton, Florida 33428. 4. At all times material hereto, Respondents were not duly registered) or certified to engage in the practice of architecture or interior design pursuant to Chapter 481, Florida Statutes. 5. On or about April 20, 2006, Respondents contracted with Ann Ferrell to provide all drawings to obtain a permit from the building permit for a residential project. 6. Respondents are not licensed to practice architecture in the State of Florida and therefore cannot offer or provide architectural services including sealed drawings required to _ obtain a building permit. | . 7. Respondents received $1,425.00 pursuant to the above contract. 8. Respondents never produced the drawings required under the contract or returned the funds received. COUNT I 9. Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) ' _ asif fully set forth herein. 10. 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.” 11. Based upon the foregoing, Respondents have violated Section 481 223(1)), Florida Statutes, by practicing architecture ‘when they were not the. holder of a valid license by offering architectural services. COUNT Il 12. Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) as if fully set forth herein. . 13. 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.” 14. Based upon the foregoing, the Respondents have violated Section 481.223(1)(c), Florida Statutes, by using the name or title “architect”, when they were not the holder of a valid license. COUNT Til 15. Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) as if fully set forth herein. 16. Section 481.219(2), Florida Statutes, requires a certificate of authorization for a corporation, partnership, or fictitious name offering architectural services. 17. Based upon the foregoing, the Respondent, TDI Architectural Design Services, has violated Section 481.219(2), Florida Statutes, by offering architectural services without a 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. Poa Signed this & day of_Febsrvany , 2007. - FILED py, ” TS TUTY CLERK. — DAVID K. MINACCI , Smith, Thompson, Shaw & Manausa, P.A. Prandntlt Shcchel 2075 Centre Pointe Blvd. CLERK Tallahassee, FL 32308-4893 DATE Z- = 200 FL Bar No. 0056774 Ph: — (850) 402-1570 Fax: (850) 402-1508 PCP: B 0 5 2007 ae

Docket for Case No: 07-003585