STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL RiKe DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, Ys. DBPR Case No.; 2003-070663 STEPHEN LLOYD, Respondent. en ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against STEPHEN LLOYD, ("Respondent"), and says: 1. Petitioner is the state agency charged with regulating the practice of interior design 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 interior designer in the State of Florida, having been issued license number ID 2774. 3. Respondent's address of record is 35 SE5* Street, Boca Raton, Florida 33432. 4. Respondent was under contract with the Flonda Atlantic University Foundation to provide interior design services for the President’s new home. 5. On or about July 15, 2002, Respondent presented an invoice for consulting services, which were never performed, to the Florida Atlantic University Foundation for $42,000.00. ' 6.” ‘Respondent's invoice tor intétior design services was part of 4 scheme to diverc funds from the Florida Atlantic University Foundation, a tax exempt organization, to purchase a new automobile for the outgoing president. 7. On or about July 15, 2002, the Florida Atlantic University Foundation paid Respondent $42,000.00. 8. Respondent then paid Sara Catanese, the wife of the outgoing president, $42,000.00 to purchase the automobile. 9. On or about June 27, 2003, Respondent executed a Deferred Prosecution Agreement based on the criminal allegations of Aiding and Abetting Official Misconduct and Scheme to Defraud, as set forth in Sections, 839.25(1) and 817.034(4}(a), Florida Statutes. 10. Pursuant to the Deferred Prosecution Agreement, Respondent is requited to complete thitty (30) hours of community service. ML Section 481.2251(i), Florida Statutes, states disciplinary action may be taken for making deceptive, untrue, or fraudulent representations in the provision Of interior design services. 12. Based upon the foregoing, Respondent has violated Section 48i 2251 (i), Florida Statutes, by submitting an invoice for interior design services that the Respondent knew was deceptive, untrue, or fraudulent. WHEREFORE, Petitioner respectfully requests the Board enter an Order upposing one or more of the following penalties: Imposition of probation, reprimand the licensee, revoke, ta suspend, deny the issuance or renewal of the certificate or Tegistration, 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 the Board is authorized to impose pursuant to Chapters 481 and 455, Florida Statutes, and/or the rules promulgated thereunder. st Signed this 3/ dayof___ @etelae — , 2003. Cc = ID DAVID K. MINACCI Smith, Thompson, Shaw & Manausa, P.A. 2075 Centre Pointe Blvd. Tallahassee, FL 32308-4893 FL Bar No. 0056774 (850) 402-1570

Docket for Case No: 03-004400PL