STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, O 2. 1GS@ vs. DBPR Case No.: 2003-002640 2003-001382 RICK 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 RICK 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 481.223(1)(a), Florida Statutes. 3. Atall times material hereto, Respondent was not duly registered or certified to engage in the practice of interior design pursnant to Chapter 481, Florida Statutes. 4. Respondent's last known address is 160 S.W. 12" Avenue, Bay 104, Deerfield Beach, Florida 33442. 5. Interior Design Center & Manufacturing, does not have a certificate of 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 I. 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 effect, 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 a valid license. COUNT II 10. Petitioner realleges and incorporates paragraphs | through 5 as though fully stated in this Count II. Ll. Section 481.219(3), Florida Statutes, requires a certificate of authorization to practice interior design services through a corporation, partnership, or under a fictitious name. 12. 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. to 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 promu'gated thereunder. Pa Signed this_ 27 day of Ap-il Rood . 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 FILED Department of Business and Professional Regulation DEPUTY CLERK CLERK Michele oare_B = 72003 | Pcp: 4/24 2003

Docket for Case No: 03-001986