STATE OF FLORIDA oO. ae DEPARTMENT OF BUSINESS AND PROFESSIONAL REGSLATION DEPARTMENT OF BUSINESS AND a re “tt, PROFESSIONAL REGULATION, Cie % = Petitioner, O T- Y Ke Gee %, vs. CaseNo.: — 2007- 008754 MORRIS & KALM, INC., AND MEGAN MORRIS, Respondents, / ADMINISTRATIVE,COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ‘("Petitioner"), files ‘this Administrative Complaint before the Board of Architecture and Interior ‘Design against MORRIS & KALM, INC. and MEGAN MORRIS, ("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 interior design pursuant to Section 455. 228(1), and Section 481 230K Florida Statutes. 3. At all times material hereto, Respondents were not duly registered or certified to ' engage in the practice of interior design in the State of Florida pursuant to Chapter 481, Florida Statutes. 4. Respondents’ last known address is P.O. Box 456, Windermere, FL, 34786. 5. On invoices dated December 26, 2006 and January 16, 2007, to Patsi Peacock, the Respondents are offering interior design services on their letterhead. 6. On Respondents’ brochure it states they have over fifteen years of experience in interior design and are members of the American Society of Interior Designers. 7. On Respondents’ web site, it offers “Interior Redesign” services. 8. Respondents are offering interior design services through a corporation without a certificate of authorization. 9. Respondents are not licensed to practice interior design in the State of Florida and - therefore cannot offer or provide interior design services. COUNT I 10. Petitioner hereby realleges and incorporates paragraphs one (1) through nine (9) as if fully set forth herein. ll. Section 481.223(1)(b), Florida Statutes, states that‘a person may not knowingly practice interior design, when the person is not then the holder of a valid license. 12. Based upon the foregoing, the Respondents have violated Section 481.223(1)(b), Florida Statutes, by practicing interior design, when they were not the holder of a valid license. COUNT I 13. Petitioner hereby realleges and incorporates paragraphs one (1) through nine (9) as if fully set forth herein. 14. Section 481.223(1)(c), Florida Statutes, prohibits a person from using the title interior designer or words to that effect unless the person is a registered interior designer. 15. Based upon the foregoing, the Respondents have violated Section 481.223(1)(c), Florida Statutes, by holding themselves out as interior designers when they were not the holder of a valid license. COUNT II 16. Petitioner hereby realleges and incorporates paragraphs one (1) through nine (9) as if fully set forth herein. 17. Section 481.219(3), Florida Statutes, requires a certificate of authorization to practice interior design services through a corporation, partnership, or under a fictitious name, 18. Based upon the foregoing, Respondents have violated Section 481.219(3), Florida Statutes, by offering interior design services through Morris & Kalm, Inc., 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. Signed this a2¢°* dayof__ Sua’ _-, 2007. Department of Business and Professional Regulation = Sad KA * DEPUTY CLERK BOS Fe _ DAVID K. MINACCI 7 re, sterde Ti 7 J, Smith, Thompson, Shaw & Manausa, P.A. . CLERK Prardn f Wickets. 3520 Thomasville Road, Fourth Floor pate 6-27-2007 Tallahassee, Florida 32309 FL Bar No. 0056774 Ph: (850) 402-1570 Fax: (850) 558-1613 PCP:

Docket for Case No: 07-004826