STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION... DEPARTMENT OF BUSINESS AND “* “PROFESSIONAL REGULATION, TE 2 dee amatet gam BOARD OF ARCHITECTURE AND INTERIOR DESIGN, q 7 Petitioner, 0 0 | vs. ; DBPR Case No.: 2008-011579 ADOLPHO PEREZ-LLANA, AND APL, Respondents. ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against ADOLPHO PEREZ-LLANA and APL, ("Respondents"), and says: 1, Petitioner is the state agency charged with regulating the practice of architecture 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 pursuant to Section 455.228(1), and Section 481.223(1)(a), . Florida Statutes. . | 3, Respondents? last known address is P, O. Box 2524, Ocala, Florida 34478. 4, At all times material hereto, Respondents Adlopho. Perez-Llana and APL were not duly registered or certified to engage in the practice of architecture in the State of Florida pursuant to Chapter 481, Florida Statutes. s-4eFl rida 34480, aoa 7 ow eheemmess ITT STENT 5. On or about March 27, 2006, Respondents prepared a proposal to ‘provide ‘architectural services for the County Club of Ocala, located at 6823 S.E. 12 Circle, Ocala, 6. The proposal specifically offers “Architectural Construction Documents”, qe Respondents are offering architectural services through the business entity of APL without a certificate of authorization. 8. Respondents are not licensed to practice architecture in the State of. Florida and | therefore cannot offer or provide architectural services. COUNTI 9. Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) as if fully set forth herein. 10. Section 481 .223(1)(a), F lorida 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)(a), Florida Statutes, by practicing architecture when they were not the holder of a valid license by offering architectural services. COUNT II 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 "wens, Uo asset nee eae ed COUNT III 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, APL, 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 atithorized to impose pursuant to Chapters 481 and 455, Florida Statutes, and/or the rules promulgated thereunder. . w Signed this 24%* ~ dayof_ A/evembe— , 2008. LL ED sagan Sa g, and Pro DAVID K. MINACCI ; pepartrnent of BIT CLERK ’ Smith, Thompson, Shaw & Manausa, P.A. 3520 Thomasville Road, Fourth Floor Tallahassee, Florida 32309 FL Bar No. 0056774 Ph: (850) 402-1570 Fax: (850) 558-1613 PCP: Rodriguez, Wirtz, Gustafson November 13, 2008

Docket for Case No: 09-000171