STATE OF FLORIDA : “! DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION ae DEPARTMENT OF BUSINESS AND re PROFESSIONAL REGULATION, Petitioner, v. Case Number 2001-05958 ERIC R. COPENHAGEN, Respondent. ) ADMINISTRATIVE COMPLAINT AYUMLN OA EA EEE Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, (“Petitioner”), files this Administrative Complaint before the Electrical Contractors Licensing Board, against respondent, and says: 1. Petitioner is the state agency charged with regulating the practice of electrical contracting pursuant to Section 20.165, Florida Statutes, and Chapters 455 and 489, Part II, Florida Statutes. 2. Respondent is, and has been at all times material hereto, a licensed CERTIFIED ELECTRICAL CONTRACTOR in the State of Florida, having been issued license number EC 1394 on February 25, 1995. 3. Respondent’s address of record is 15016 Southwest 148th Street, Miami, Florida 33196. 4. In approximately November 1995, the Respondent entered a joint venture Agreement (hereinafter, “joint venture”) with Dade Electric and Electronic Contractors, Inc. and/or Pablo H. Llanes (hereinafter, “Llanes”). 5. Pursuant to the terms of the aforementioned joint venture, the Respondent is responsible for signing all permits and would receive remuneration for each permit as a fee. 6. Pursuant to the terms of the aforementioned joint venture, Llanes was responsible for supplying licensed manpower, payroll, taxes, permit costs and insurance. 7. On or about March 22, 2001, Dade Electric and Electronic Company entered a contract with Eduardo Guerra for installation of an alarm system at 4455 Soutwest 2nd Street, Miami, Florida 33134. The aforementioned contract included the Respondent's license number and was signed by Llanes. The work to be performed pursuant to the contract with Guerra was never completed. 8. Llanes issued business cards for Dade Electric and Electronic Contracting, Inc. with the Respondent's license number affixed thereon. 9. At no time material hereto was Pablo Llanes licensed or certified to practice electrical contracting in the State of Florida. 10. Respondent knew or had reasonable basis and opportunity to know that Llanes was not a licensed electrical contractor in the State of Florida 11. Atno time material hereto was Dade Electric and Electronic Contracting, Inc. licensed or certified to practice electrical contracting in the State of Florida. 12. Atno time material hereto was Pablo Llanes an employee of the Respondent as defined in Subsection 489.503(1)(b) Florida Statutes. 13. Atno time material hereto has the Respondent been the licensed qualifier for Dade Electric and Electronic Contracting, Inc., pursuant to Sections 489.521 and 489.522, Florida Statutes. COUNT ONE 14. Petitioner realleges and incorporates by reference the allegations contained in the foregoing paragraphs one (1) through thirteen (13) as if fully stated herein. 15. Based upon the foregoing, the Respondent has violated Subsection 489.533(1)G), Florida Statutes, by performing an act that assists a person or entity in engaging in the prohibited uncertified and unregistered practice of electrical contracting. COUNT TWO 16. Petitioner realleges and incorporates by reference the allegations contained in the foregoing paragraphs one(1) through thirteen (13) as if fully stated herein. 17. Based upon the foregoing, the Respondent has violated Subsection 489.533(1)(k), Florida Statutes, by knowingly combining or conspiring with another person by allowing his certificate to be used by an uncertified person with the intent to evade the provisions of Chapter 489, Part II, Florida Statutes. WHEREFORE, Petitioner respectfully requests the Electrical Contractors” Licensing Board enter an Order imposing one or more of the following penalties: place on probation, reprimand the licensee, revoke, suspend, deny the issuance or renewal of the certificate or registration, require correction, impose an administrative fine not to exceed $5,000 per violation, require continuing education, assess costs associated with investigation and prosecution, impose any or all penalties delineated within Sections 455.227(2) and 489.533(2) Florida Statutes, and/or any other relief that the Board is authorized to impose pursuant to Chapters 489 and 455, Florida Statutes, and/or the rules promulgated thereunder. _ Cv Signed this [ -—~__ day of April, 2003. ail Scott-Hill Chief Professions Attomey Counsel for Department: Gail Scott-Hill Assistant General Counsel Florida Bar Number 0909287 Department of Business and Professional Regulation Office of the General Counsel Northwood Centre 1940 North Monroe Street, Suite 60 Tallahassee, Florida 32399-2202 PCP: 11/20/02 fF jepartment of Business and Professional Regulation A GENCY CLERK can Sey foe

Docket for Case No: 04-001839PL

Orders for Case No: 04-001839PL