FILED Department of Busiriess and Professional Reputation Deputy Agency Clerk STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULAY cee T3002 File # DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, BOARD OF ARCHITECTURE AND INTERIOR DESIGN, Petitioner, vs. CASE NO.: 2011-044504 RUBEN J. PUJOL and RUBEN J. PUJOL ARCHITECTURAL P.A,, Respondents. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION. ("Petitioner"), files this Administrative Complaint before the Board of Archilecture and Interior Design against RUBEN J. PUJOL and RUBEN J. PUJOL ARCHITECTURAL PA. (“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. Respondents are and have been at all times material hereto, a licensed architect and architectural firm in the State of Florida, having been issued license number AR 10458 and AA 26002479. 3. Respondents’ address of record is 12237 SW 204 Terrace, Miami. Florida 33177. 4, Respondents entered into a contract to provide architectural services for a church project known as Redeemed Pentecostal Church of the Living God located at 1930 SW 213 Street, Miami, Florida. . { i EXHIBIT A wn Respondents prepared drawings for the project. 6. Respondents signed and sealed the drawings for the purpose of obtaining a building permit 7, In preparation of the plans and drawings, Respondent was negligent in that he failed to exercise due care to conform acceptable standards of architectural practice in such a manner as to be detrimental to the public 8. The plans and drawings were not of sufficiently high standard to clearly and accurately indicate or illustrate all essential parts of the work to which they refer COUNT I 9 Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) as if fully set forth herein. 10. Section 481.225(1)(g), Florida Statutes, states in pertinent part that committing any act of fraud, deceit, negligence, in competency, or misconduct in the practice of architecture constitutes grounds for disciplinary action. - 11. Based upon the foregoing, Respondents have violated Section 481.225(1)(g), Florida Statutes by performing services that do not conform to acceptable standards of architectural practice, COUNT It 12, Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) as if fully set forth herein. 13. Section 481.221(8), Florida Statutes, states final construction documents or instruments of service which include plans, drawings, specifications, or other architectural documents prepared by a registered architect as part of her or his architectural practice shall be of a sufficiently high standard to clearly and accurately indicate or illustrate all essential parts of the work to which they refer. 14 Based upon the foregoing, Respondents have violated Section 481 .221(8), Florida Statutes by signing and sealing plans that are not sufficiently detailed COUNT I 15. Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) as if fully set forth herein. 16. Section 481.225(1)(j), Florida Statutes, states in pertinent part that disciplinary action may be taken for failing to perform any statutory or legal obligation placed upon a registered architect. 17. Based upon the foregoing, Respondents have violated Section 481.225(1)Q), Florida Statutes by committing misconduct in the practice of architecture. WHEREFORE. Petitioner respectfully requests the Board enter an Order imposing one or more of the following penalties: Imposition of probation, reprimand the licensee, revoke, suspend, deny the issuance or renewal of the certificate or registration, require financial restiution to a consumer, impose an administrative fine not to exceed $5,000 per count, require continuing education, 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 _/ ar day of AJawr Ark von , 2012 PCP: October 22, 2012 Hall, Shore, Gozdz 5 V4 pe DAVID K. MINACCI Smith, Thompson, Shaw, Minacci & Colén, P.A. 3520 Thomasville Road. Fourth Floor Tallahassee, Florida 32309 FL Bar No. 0056774 Ph: (850) 402-1570 Fax: (850) 558-1613 davidm@stslaw com

Docket for Case No: 13-000579