; STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULAT TON EFS COSMETOLOGY BOARD fo BBs ee 10095 AUG -2 A Ih 30 DEPARTMENT OF BUSINESS AND . PROFESSIONAL REGULATION, Petitioner, vs. Case No. 2005-011256 ISABEL RUSSELL, 05-2797 PL Respondent. ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION (“Department”), files this Administrative Complaint before the Board of Cosmetology, against ISABEL RUSSELL (“Respondent”), and says: 1. Petitioner is the state agency charged with regulating the practice of cosmetology pursuant to section 20.165, Florida Statute, and Chapters 455 and 477, Florida Statutes, and the rules promulgated thereto. 2. At all times material hereto, Respondent was unlicensed in the State of Florida to operate a cosmetology salon. 3. Respondent’s address of record is 59 East Palmetto Park Road, Boca Raton, Florida 33432. 4, On or about February 14, 2004, Petitioner Inspector, Louis Plocker, conducted a routine inspection of Madison Avenue Salon. 5. During the inspection, Petitioner Inspector observed Respondent’s business open and conducting business. 6. During the inspection, Department of Business and Professional Regulation records revealed Respondent was unlicensed as a cosmetology salon. 7. Subject stated in a letter, received by the Department on March 28, 2005, that she obtained a county license and was under the assumption that she could operate with that license. 8. Section 477.0265(1)(b)1, Florida Statutes, states that it is unlawful to “fo]wn, operate, maintain, open, establish, conduct, or have charge cf, either alone or with another person or persons, 4 cosmetology salon or specialty salon: which is not licensed.” 9. Based on the foregoing, Respondent violated section 477.0265(1)(b)1, Florida Statutes, by operating a cosmetology salon that was unlicensed and is thereby subject to discipline pursuant to sections 477.029(1)(b) and (2), Florida Statutes. WHEREFORE, Petitioner respectfully requests the Board of Cosmetology enter a Final Order imposing one or more of the following penalties: imposition of an administrative fine, revocation or suspension of Respondent’s license, issuance of a reprimand, placement of the Respondent on probation, restriction of Respondent’s practice, and or any other relief which the Board deems appropriate. th SIGNED this 2. 7 day of U Gat , 2005. Attorney for Petitioner: Charles F. Tunnicliff Chief Professions Attorney Florida Bar No. 153831 Department of Business and Professional Regulation 1940 North Monroe Street Tallahassee, Florida 32399-2202 Phone: (850) 487-9656 Facsimile: (850) 414-6749 CFT/wab May 13, 2005 Case # 2005-011256 CET 5-2Y 05 (Ua) 2- Peanut Charles F. Tunnicliff Chief Professions Attorney FILED Department of Business and Professional Regulation DEPUTY CLERK Berard Michele pare a eee

Docket for Case No: 05-002787PL