. Deputy Agenoy Clerk STATE OF FLORIDA CLERK vette Lawson-Proctor DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULA pn. 5/49/2015 File # DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, BOARD OF ARCHITECTURE AND INTERIOR DESIGN, Petitioner, VS. | CASE NO.: 2014-008444 EMILIO JOSE AGRENOT, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against EMILIO JOSE AGRENOT, ("Respondent"), 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. Respondent, is and has been at all times material hereto, a licensed architect in the State of Florida, having been issued license number AR 15411. 3. Respondent’s address of record is 14636 Balgowan Road, Hialeah; FL 34445.- 4. Respondent entered into a contract with Joan Lamm to provide architectural services for a residential addition located at 22420 S.W. 172 Ct., Miami, Florida. 5. The coritract specifically provides preparing construction documents for the “purpose of obtaining a permit.” 6. The Respondent wase paid for his services but failed to provide completed ' construction documents that could be permitted in a timely manner. 7. Ms, Lamm has hired a collection agency to recoup the payments she made to the Respondent. 8. Further, Respondent has failed to comply with the terms of a Final Order entered by this Board on July 31, 2014. 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, Respondent has violated Section 481.225(1)(g), Florida Statutes by committing misconduct in the practice of architecture. COUNT I 12. Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) as if fully set forth herein. 13. Section 481.225(1)@), Florida Statutes, states disciplinary action can be taken for failing to perform any statutory or legal obligation placed upon a registered architect. 14. Based upon the foregoing, Respondent has violated Section 48 1.225(1)(j), Florida. Statutes because he failed to provide completed construction documents that could be permitted in a timely manner. COUNT II 15. Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) asif fully set forth herein. 16. Section 455.227(1)(q), Florida Statutes, prohibits a person from failing to comply with a lawful order of the Board. * 17. The Subject, a licensed architect, has failed to comply with the terms of a Final Order that was entered on July 31, 2014 by failing to pay the fine and costs. . 18. Based upon the foregoing, Respondent has violated Section 455.227(1)(q), Florida Statutes, by failing to comply with a lawful order of the Board. 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 restitution 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. iw Signed this_ 18 * ~ day of M ae ,2015. DAVID K. MINACCI ‘Smith, Thompson, Shaw, Minacci & Coldn, P.A. 3520 Thomasville Road, Fourth Floor Tallahassee, Florida 32309 FL Bar No. 0056774 Ph: (850) 402-1570 Fax: (850) 241-0161 davidm@stslaw.com PCP: May 6, 2015 Hall Shore Rodriguez Rivers

Docket for Case No: 15-004622PL