STATE OF FLORIDA DEPARTMENT OF BUST DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION Petitioner, = _- 4 OD 118Y VS. DBPR Case No.: 2003-002389 2003-050456 RAMI ARGOV and INTERIOR DESIGN CENTER & MANUFACTURING, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION. ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against RAMI ARGOV and INTERIOR DESIGN CENTER & MANUFACTURING, ("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 48 1.223(1)(a), Florida Statutes. 3. Atall imes material hereto. Respondent was not duly registered or certified to engage in the practice of interior design pursuant to Chapter 481, Florida Statutes. 4. Respondent's ast Known address is 160 SW 12" Avenue, Bay 104. Deerfield Beach, Florida 33442 5. Interior Design Center & Manufacturing. does not have a ceruiticate ot authorization to offer or practice interior design services. COUNT I 6. Petitioner realleges and incorporates paragraphs | through 5 as though fully stated in this Count 1. 7. Respondent held himself out as an interior designer in business cards and brochures. 8. Section 481.223(1)(c), Florida Statutes, states that a person may not knowingly “use the name or title ‘interior designer’ or ‘registered interior designer’ or words to that ¢frect. when the person is not then the holder of a valid license.” 9. Based upon the foregoing, the Respondent has violated Section 481.223(1)(c), Florida Statutes, by using the name or title “interior designer”, when he was not the holder of 2 v-'" license. COUNT II 0. Petitioner realleges and incorporates paragraphs | through 5 as though fully stated in this Count IT. I. Section 481.219(3), Florida Statutes, requires a certificate of authorization to practice interior design services througli a corporation, partnership. or under a fictitious name. 2. Based upon the foregoing, Respondent has violated Section 481.219(3), Florida Statutes, by practicing interior design services through Interior Design Center & Manufacturing without a certificate of authorization. COUNT Ul Ia. Pettuioner realleges aid Meorporates paragraphs {through 5 as though fully stated tn this Count (Hf, 4. On or about November 7, 2002. Respondent contracted with Juan and Diedre Perez to perform interior design services on residential property located at 8430 NW 45" Manor. Coral Springs, Florida. {S. Section 48 1.223(1)(b), Flovida Statutes, states that a person may not knowingly “practice interior design unless the person is an interior designer or a registered interior designer.” 16. Based upon the foregoirg, the Respondents have violated Section 481.223(1)(b) by practicing interior design when ke was not the holder of a valid license by contracting to provide interior design services, 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 penaliies 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. th . Signed this 27 _ day of Aspe il 2 i DAVID K. MINACCI Smith, Thompson, Shaw & Manausa, P.A, 2075 Centre Pointe Blvd. Tallahassee, FL. 32308-4893 FL. Bar No. 0056774 Ph: (850) 402-1570 Fax: (850) 402-1508 PCP

Docket for Case No: 03-001984