STATE OF FLORIDA ~ 4 DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION iy. 4 9: vy é yeil ef / DEPARTMENT OF BUSINESS AND Caps Pa. PROFESSIONAL REGULATION, ‘ AG ee Petitioner, 9 acy Lo i) 3 ia » VS. DBPR Case No.: 2003-045236 JOHNNY MOORE and, QUICK DRAW DESIGNS, INC. Respondents. / ADMINISTRATIVE COMPLAINT SE VE COMPLAINT Petitioner, DEPARTMENT QF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architc: Wath ena Design against JOHHNY MOORE and QUICK DRAW DESIGNS, INC., (“Respondents anc says: L. 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 Busiiess and Professional Regulation has Jurisdictioa over the unlicensed practice of architecture pursuant to Section 455.228(1), and Section 481.2230 ad, Florida Statutes. 3. At all umes material hereto, Respondent was not duly registered or certified to engage in the practice of architecture pursuant to Chapter 481, Morida Statutes. RI PES Smt eau REE RE fe FLING -Ser Cshee eeNR BeYSN DAAeem Am Hoes 4, Respondents’ last known address is 1451 Oakfield Drive, Brandon, Florida 33511. 5S. Quick Draw Designs. Inc., does not have a certificate of authorization to perform architectural services. 6. On or about May 18, 2001, Respondent contracted with Nathan Vaccaro to perform architectural services for an ofi:ce complex. 7. As of May 9, 2003, Respondent was offering architectural services over the Internet. COUNT I 8. Petitioner hereby realleges and incorporates paragraphs one (1) through seven (7) as if fully set forth herein. 9. Section 48 1.223(1)(a), Florida Statutes, states that a person may not knowingly “practice architecture unless the person is an architect or a registered architect.” 10. Based upon the foregoing, Respondent, has violated Section 481.223(1)(a) by practicing architecture when he was not the holder of a valid license by contracting to provide architectural services and accepting payment for architectural services involving commercial property. COUNT I Uf. Petitioner hereby realleges and incorporates paragraphs one (1) through seven (7) as if fully set forth herein. 12. Section 481.223(1)(c). Florida Statutes, states that a person may not knowingly “use the name or title ‘architect’ or ‘registered architect’ or words to that cffeet, when the person is not then the holder ofa valid license.” C c 13. Based upon the foregoing, the Respondent has violated Section 48 1.22301 )(c), Florida Statutes, by using the name or title “architect” on the Internet. when he was not the holder of a valid license. ‘ 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. $M Signed this__/3 dayof__D-ac. , 2003. nS as See ff 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: 03-002526