STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGUL ita App O 94 DEPARTMENT OF BUSINESS AND ee PROFESSIONAL REGULATION, Petitioner, OX 020 | vs. DBPR Case No.: 2006-028883 NATASHA YOUNTS AND GABLES INTERIORS, INC., Respondents. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against NATASHA YOUNTS and GABLES INTERIORS, INC., (“Respondents”), and says: 1. Petitioner is the state agency charged with regulating the practice of 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 5255 Collins Avenue, #10E, Miami, FL 33240. 4. At all times material hereto, Respondents were not duly registered or certified to engage in the practice of interior design or architecture in the State of Florida pursuant to Chapter 481, Florida Statutes. 5. On or about December 19, 2003, Respondents received a Notice and Order to Cease and Desist from the Board of Architecture and Interior Design for offering interior design services without a license. 6. On or about January 20, 2004, Respondents executed an affidavit agreeing to change it advertisements and delete any references to interior design. 7. As of May 24, 2006, Respondents website states that it is an award winning interior design firm. 8. The website also offers architectural services. 9. In an advertisement in the Lincoln Road Magazine, the Respondents are offering interior design services, 10. Respondents are not licensed in the State of Florida as architects or interior designers and therefore cannot offer or provide such services. COUNT I 11. Petitioner hereby realleges and incorporates paragraphs one (1) through ten (10) as if fully set forth herein. 12. 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. 13. 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 II 14. Petitioner hereby realleges and incorporates paragraphs one (1) through ten (10) as if fully set forth herein. 15. 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. 16. 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 I 17. Petitioner hereby realleges and incorporates paragraphs one (1) through ten (10) as if fully set forth herein. 18. 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.” 19. Based upon the foregoing, Respondents have violated Section 481.223(1)(a), Florida Statutes, by offering architectural services when they were not the holder of a valid license. COUNT IV 20. Petitioner hereby realleges and incorporates paragraphs one (1) through ten (10) as if fully set forth herein. 21. — Section 481.223(1)(c), Florida Statutes, prohibits a person from using the title architect or words to that effect unless the person is a registered architect. 22. Based upon the foregoing, the Respondents have violated Section 481.223(1)(c), Florida Statutes, by holding themselves out as architects when they were not the holder of a valid license, COUNT V 23. Petitioner hereby realleges and incorporates paragraphs one (1) through ten (10) as if fully set forth herein. 24. 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. 25. Based upon the.foregoing, Respondents have violated Section 481 219(3), Florida Statutes, by offering interior design services through Gables Interiors, 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. gh Signed this 27 dayof_—- Oc te be , 2006. Bee DAVID K. MINACCI Smith, Thompson, Shaw & Manausa, P.A. 2075 Centre Pointe Blvd. Tallahassee, FL 32308-4893 FL Bar No. 0056774 Ph: (850) 402-1570 Fax: (850) 402-1508 PCP: T 2 3 2006 F i cue rendu! Llcholy ore_I1-2= 200

Docket for Case No: 08-000207