FILED Department of Business and Professional Regulation STATE OF FLORIDA Deputy Agency Clerk DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULAT] Clerk — Evette Lawson-Proctor Date 5117/2013 DEPARTMENT OF BUSINESS AND Fle# PROFESSIONAL REGULATION, Petitioner, Vv. Case No. 2012-009335 CHRISTOPHER LATCHMANSIGH, Respondent. ADMINISTRATIVE COMPLAINT Department of Business and Professional Regulation (Petitioner) files this Administrative Complaint before the Barbers’ Board (Board) against Christopher Latchmansigh (Respondent) and alleges: 1. Petitioner is the state agency charged with regulating the practice of barbering pursuant to Section 20.165, Florida Statutes (2011), and Chapters 455 and 476, Florida Statutes (2011). 2. Respondent was issued barber’s license number’ BB 8894963. 3. Respondent's address of record is 3005 Rockville Lane Royal Palm Beach, FL 33411. GENERAL ALLEGATIONS OF FACT 4, On or about May 16, 2011, Respondent submitted an application to the Florida Barbers’ Board for licensure as a barber. 5. The Florida Barbers’ Board requires that applicants for a barber’s license certify successful completion of the required training for the level of licensure, registration, or certification sought prior to the Florida Barbers’ Board granting licensure. 6. The Florida Barbers’ Board requires that applicants obtain 1,200 hours of training at an approved school prior to licensure as a barber. 7. Included with Respondent's Florida licensure application, Respondent submitted documentation purportedly prepared by Educational Perspectives certifying that Respondent completed his AIDS/HIV certificate and had a student transcript from the Caribbean Beauty and Technical Institute in 2010 in Puerto Rico. 8. The evaluation report purportedly prepared by Educational Perspectives, indicated that Respondent completed 1350 hours at the above mentioned school. 9. On or about December 19, 2011, the Department received documentation from Kenneth Warren, President of Educational Perspectives, stating that Respondent’s evaluation report is not valid. 10. Respondent submitted falsified documentation when he applied for a Florida barber’s license indicating that he received the required training at an approved school, that he is licensed as a barber in Puerto Rico ll. Based on the falsified documentation, Respondent obtained licensure as a barber in the State of Florida from the Department of Business and Professional Regulation. COUNT ONE 12. Petitioner realleges and incorporates by reference the allegations set forth in paragraphs one (1) through eleven (11) as though fully set forth herein. 13. Section 455.227(1) (h), Florida Statutes (2011), provides that “[a]ttempting to obtain, obtaining, or renewing a license to practice a profession by bribery, by fraudulent misrepresentation, or through an error of the department or board” constitutes grounds for disciplinary action. 14. Based on the facts set forth above, Respondent violated Section 455.227(1) (h), Florida Statutes (2011), by obtaining a license to practice barbering by fraudulently misrepresenting that he received the training required for licensure as a barber, that he is licensed as a barber in Puerto Rico. COUNT TWO 15. Petitioner realleges and incorporates by reference the allegations set forth in paragraphs one (1) through fourteen (14) as though fully set forth herein. 16. Section 476.194(1) (c), Florida Statutes (2011), provides that “[i]lt is unlawful for any person to . . . [o]btain or attempt to obtain a license for money other than the required fee or any other thing of value or by fraudulent misrepresentations.” 17. Based on the facts set forth above, Respondent violated Section 476.194(1)(c), Florida Statutes (2011), by obtaining a license to practice barbering by fraudulently misrepresenting that he received the training required for licensure as a barber, that he is licensed as a barber in Puerto Rico. COUNT THREE 18. Petitioner realleges and incorporates by reference the allegations set forth in paragraphs one (1) through seventeen (17) as though fully set forth herein. 19. Section 476.204 (1) (e), Florida Statutes (2011), provides that “[i]t is unlawful for any person to .. . [glive false or forged evidence to the department in obtaining any license provided for in this chapter.” 20. Based on the facts set forth above, Respondent violated Section 476.204(1)(e), Florida Statutes (2011), in one or more of the following ways: a. By giving a false and/or forged evaluation report from Educational Perspectives to the Department of Business and Professional Regulation in order to obtain licensure as a barber in the State of Florida. b. By giving a false and/or forged certification indicating that Respondent is licensed to practice barbering in Puerto Rico in order to obtain licensure as a barber in the State of Florida. WHEREFORE, Petitioner respectfully requests that the Barbers’ Board enter an order imposing one or more of the following penalties: permanent revocation or suspension of Respondent’s license, restriction of practice, imposition of an administrative fine, issuance of a reprimand, placement of Respondent on probation, assessment of costs, corrective action and/or any other relief that the Board deems appropriate. SIGNED this 7th day of May , 2013. KEN LAWSON, Secretary Department of Business and Professional Regulation Erin R, Hennigan Erin R. Hennigan Assistant General Counsel Florida Bar No. 99450 Department of Business and Professional Regulation Office of the General Counsel 1940 North Monroe St., Ste. 42 Tallahassee, Florida 32399-2202 (850) 488-0062 Telephone (850) 488-5700 Facsimile PC Found: 05/07/2013 PC Found By: Erin R. Hennigan ERH/jdg NOTICE OF RIGHTS Please be advised that mediation under section 120.573, Florida Statutes, is not available for administrative disputes involving this type of agency action. Please be advised that Respondent has the right to request a hearing to be conducted in accordance with sections 120.569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call and cross-examine witnesses and to have subpoenas and subpoenas duces tecum issued on his or her behalf if a hearing is requested. Any request for an administrative proceeding to challenge or contest the charges contained in the administrative complaint must conform to Rule 28-106.2015, Florida Administrative Code. Rule 28-106.111, Florida Administrative Code, provides in part that if Respondent fails to request a hearing within 21 days of receipt of an agency pleading, Respondent waives the right to request a hearing on the facts alleged. NOTICE REGARDING ASSESSMENT OF COSTS Respondent is placed on notice that Petitioner has incurred costs related to the investigation and prosecution of this matter. Pursuant to section 455.227(3) (a), Florida Statutes, the Board, or the Department when there is no Board, may assess costs related to the investigation and prosecution of the case excluding costs associated with an attorney's time, against Respondent in addition to any other discipline imposed.

Docket for Case No: 13-002156PL