FILED Department of Business and Professional Regulation Deputy Agency Clerk STATE OF FLORIDA CLERK vette Lawson-Proctor DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULA] °** 4/20/2018 File # DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, BOARD OF ARCHITECTURE AND INTERIOR DESIGN, Petitioner, vs. CASE NO.: 2017-011047 KHANH QUOC LE AND KL ENGINEERING, INC., Respondents. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against KHANH QUOC LE and KL ENGINEERING, INC., (“Respondents”), and says: 1. Petitioner is the state agency charged with regulating the practice of architecture and interior design 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 and interior design pursuant to Section 455.228(1), and Section 481,223(1)(a), Florida Statutes. 3. Respondents’ last known address is 427 Palm Crest Lane, Lake Mary, FL 32748. 4. At all times material hereto, Respondents were not duly registered or certified to engage in the practice of architecture pursuant to Chapter 481, Florida Statutes. 5. On or about July 7, 2016, Respondent signed and sealed drawings with his Professional Engineer seal for a project know as Panama City Assisted Living Facility located at 711 West Beach Road, Panama City, Florida. 6. The drawings consisted of-primarily architectural drawings which the Respondent is not licensed perform and he may not sign and seal unless such drawings are incidental to his engineering drawings. 7. The drawings consist of a cover a sheet, a one page demolition plan, three pages of architectural drawings, and one detail page. 8. There were no mechanical, electrical, or ‘plumbing sheets included in the drawings. 9. Respondents are not licensed to practice architecture in the State of Florida and therefore cannot sign and seal architectaral plans that are not incidental to his engineering drawings. 10. Respondents provided architectural services through a business entity without a certificate of authorization. COUNTI 11. Petitioner hereby realleges and incorporates paragraphs one (1) through ten (10) as if fully set forth herein. 12, Section 481.223(1)(a), Florida Statutes, states that a person may not knowingly “practice architecture unless the person is an architect or a registered architect.” 13. 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 providing architectural services. COUNT II 14. Petitioner hereby realleges and incorporates paragraphs one (1) through ten (10) as if fully set forth herein. 15. Section 481.219(2), Florida Statutes, requires a certificate of authorization for a corporation, partnership, or fictitious name offering architectural services. 16. Based upon the foregoing, the Respondent, KL Engineering, Inc., 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 authorized to impose pursuant to Chapters 481 and 455, Florida Statutes, and/or the rules promulgated thereunder. y Signed this 14° day of A ez | -, 2018. =p a DAVID K. MINACCI Smith, Thompson, Shaw, Minacci, Colon & Power, 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: April 12,2018 Rodriguez Rivers

Docket for Case No: 18-004230