Dec 8 2008 13:20 1l2/ae/28ee 14:19 8584146749 DEPR OGA PAGE STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION BARBERS’ BOARD DEPARTMENT .OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, vs. Case No. 2008-003039 PLATINUM CUTS, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSTONAL REGULATION (“Department”), files this Administrative Complaint before the Barbers’ Board, against PLATINUM curs (“Respondent”), and says: 1. Petitioner is the state agency charged with regulating the practice of barbering pursuant to Section 20.165, Florida Statutes, and Chapters 455 and 476, Florida Statutes, and the rules promulgated thereto. 2. Respondent’s address of record is 3232 West Oakland Park Blwd., Lauderdale Lakes, FL 33311. 3, At all times material hereto, Respondent was licensed as a barbershop in the State of Florida, having been issued license number BS 1078140. GAOGC Professions Boards\Barbers\ACMenniffer Simpson\Platinum Cuts 2008-003039 .194(1)(¢)2 (3 counts)\ac.doc ad/ag Dec 8 2008 13:20 1l2/ae/28ee 14:19 8584146749 DEPR OGA PAGE @5/@8 4. On or about March 5, 2008, Fetitioner’s inspector visited Respondent barber shop. 5. During the inspection, Petitioner’s. inspector observed three (3) individuals practicing barbering without licenses and cutting hair for compensation. 6. During the inspection, Petitioner’s inspector requested that the individuals produce identification. None of the individuals were able to show any form of identification. COUNT ONE 7. Petitioner re-alleges: and incorporates the allegations set forth in paragraph one through six (6) as though fully set forth herein. 8. Section 476.194 (1) (a) 2, Florida Statutes, provides that it is unlawful for any person to “[O]wn, operate, maintain, open, establish, conduct, or have charge of, either alone or with anothar person or persons, 4 barbershop: In which a person not licensed as a barber is permitted to perform services.” 9. Based on the foregoing, Respondent violated Section 476.194(1) (e)2, Florida Statutes, by permitting the first unlicensed individual to practice barbering without a license, and is therefore subject to disciplinary action by GAOGC\Professions Boards\Barbers\AC\Venniffer Simpson\Platinum Cuts 2008-003039 ,194(1}(c}2 (3 counts)iac.doc 2 Dec 8 2008 13:20 1l2/ae/28ee 14:19 8584146749 DEPR OGA PAGE 86/88 the Barbers’ Board pursuant to Section 476.204(2), Florida Statutes. COUNT Two 10. Petitioner re-alleges and incorporates the allegations set forth in paragraph one through six (6) as though fully set forth herein. 11. Section 476.194(1) (e)2, Florida Statutes, provides that it is unlawful for any person to “[Ojwn, operate, maintain, open, establish, conduct, or have charge of, either alone or with another person or persons, 4 barbershop: In which a person not licensed as a barber is permitted to perform services.” 12. Based on the foregoing, Respondent violated Saction 476,194(1) (¢)2, Florida Statutes, by permitting the second unlicensed individual to practice barbering without a license, and is therefore subject to disciplinary action by the Barbers’ Board pursuant to Section 476.204 (2), Florida Statutes. COUNT THREE 13. Petitioner re-alleges and incorporates the allegations set forth in paragraph one through six (6) as though fully set forth herein. 14. Section 476.194(1) (e)2, Florida Statutes, provides that it is unlawful for any person to “{O] wn, GAQOGC\Professions Boards\Barbers\A CUenniffer Simpson\Platinum Cuts 2008-003039 .194(1)(e)2 (2 counts)\ac.doc 3 Dec & 2008 13:21 1l2/ae/28ee 14:19 8584146749 DEPR OGA PAGE @7/ae operate, maintain, open, establish, conduct, or have charge of, either alone or with another person or persons, @ barbershop: In which a person not licensed as a barber is permitted to perform services.” 15. Based on the foregoing, Respondent violated Section 476.194(1) (e)2, Florida Statutes, by permitting the third unlicensed individual to practice barbering without a license, and is therefore subject to disciplinary action by the Barbers’ Board pursuant to Section 476.204(2), Florida Statutes. WHEREFORE, Petitioner respectfully requests the Barbers’ Board enter a Final Order imposing one or more of the following penalties: imposition of an administrative Fine, revocation or suspension of the Respondent's license, issuance of a reprimand, placement of the Respondent on probation, restriction of Respondent’s practice, and or any other relief which the Board deems appropriate. SIGNED this day of , 2008. GAOGC\Professions Boards\Barbers\ACUenniffer Simpson\Platinum Cuts 2008003039 .194(1)e)2 (3 countts)\ac.doc 4 Dec & 2008 13:21 1l2/ae/28ee 14:19 8584146749 DEPR OGA PAGE @8/ae Philip Francis Monte III Assistant General Counsel Florida Bar No.: 580406 Department of Business and Professional Regulation 1940 North Monroe Street Tallahassee, Florida 32399- 2202 Phone: (850) 487-8435 Facsimile: (850) 414-6749 PFM/ jas D PCR : 10]4 log CET ae aan etn aun Paedet ide ome 10-27-2008 GAOGC\Professions Boarde\Barbers\A CUlenniffer Simpson\Platinum Cuts 2008-03039 19401 Wey2 (3 counts)\ac.dae 5

Docket for Case No: 08-006106