FILED Department of Business and Professional Reguiation Deputy Agency Clerk STATE OF FLORIDA Evette Lawson-Proctor DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULAT 5/29/2015 DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, Vv. Case No. 2014-030046 ALINA NUNEZ, Respondent. / ADMINISTRATIVE COMPLAINT The Department of: Business : and Professional » Regulation (“Petitioner”} files this Administrative Complaint against Alina Nunez (“Respondent”), and alleges: ds Petitioner is the state agency. charged with regulating the .practice of -home inspection services pursuant. ‘to “section 20.165, -Florida Statutes, and chapters 455.‘and 468, part. XV, Florida Statutes, 2. At all times material hereto, Respondent was .licensed as a Certified Home Inspector in the State of Florida, having been issued license number HI 2342, 3. Respondent's address of record is 13240 Ortega Lane, North Miami, Florida 33181. 4. On or. about June 19, 2014, Respondent pled guilty with adjudication withheld to one ‘count of .organized. fraud in .Case Number F-12-012065-C in the Circuit Court of the 11° Judicial Circuit, in and for Miami Dade County, Florida. 5. On or about June 19, 2014, Respondent pled guilty with adjudication withheld to seven counts of first. degree insurance fraud in Case Number F-12-012065-C in the Circuit Court of the 11 Judicial Circuit, in and for Miami Dade County, Florida. 6. On.or about June 19, 2014, Respondent pled guilty with adjudication withheld .to .six counts of second degree insurance fraud.in.Case Number .F-12-012065-C in the Circuit Court of ‘the 11% Judicial Circuit, in and for Miami Dade County, Florida. 7. On or about June 19, 2014,..Respondent pled guilty with adjudication. withheld to ten. counts of ..communications fraud in Case -Number ‘F-12-012065-C .in- the. Circuit: Court of the . 11% Judicial Circuit, in and for.Miami Dade County, Florida. 8. Section 468.832(1)(d), Florida Statutes, subjects a licensee to discipline for, being ‘convicted or..found guilty of, or ‘entering a plea of nolo contendere to, ‘regardless of adjudication, a crime in any jurisdiction that directly relates to the practice of home inspection services or. the ability to practice home inspection services. 9. Based upon the foregoing, Respondent violated section 468.832(1)(d), Florida Statutes, by being convicted or found guilty of, or entering a plea of nolo contendere to, regardless of adjudication, a crime. in .any..jurisdiction which directly relates to the practice of home inspection services or the ability to practice home inspection services. WHEREFORE, .Petitioner respectfully . requests .the .Department of Business and professional Regulation enter an Order. imposing one or more of the following penalties: place on probation, reprimand the licensee, revoke, suspend, deny the issuance or renewal of the certificate or registration, impose an administrative .fine not to exceed $5,000 per violation, 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 468, 455, .Florida Statutes, and/or the rules: promulgated thereunder. (SIGNATURE :PAGE FOLLOWS) Signed this 19° day of May, 2015. KEN LAWSON, Secretary Department of Business and Professional Regulation By: Daniel Brackett Daniel Brackett Assistant General Counsel Florida Bar No. 90919 Department of Business and Professional Regulation Office of the. General Counsel 1940 N. Monroe Street, ‘Ste. . 42 Tallahassee, ‘FL. 32399-2202 (850) 717-1237. Telephone (850) 921-9186 Facsimile Probable Cause Found: 5/19/2015 By: Department. DB 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: 15-004418PL