STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, vs, DBPR Case No.: JUDY GRAHAM AND GRAHAM INTERIORS, Respondents. / ADMINISTRATIVE COMPLAINT See AINE COMPLAINT. Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against JUDY GRAHAM AND GRAHAM INTERIORS, ("Respondents"), and says: I. Petitioner is the state agency charged with regulating the practice of architecture and inlerior 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 455.2281), and Section 481.223(1)(a), Florida Statutes, 3 Atall times material hereto, Respondents were not duly registered or certified to engage in the practice of interior design pursuant to Chapter 481, Florida Statutes. EXHIBIT 4 4, Respondent's last known address is 50 South Palm Avenue, Sarasota, Florida 34236. 5. Respondent was previously a licensed interior designer in the State of Florida, having been issued license number ID 777. 6. As of February 28, 2003, Respondent's license was placed in a null and void status for failing to renew. 7. On or about March, 2005, Respondents offered to provide commercial design services in an advertisement in the Sarasota Magazine. 8. Respondent also holds herself out as member of the American Society of Interior Designers. COUNT I 9. Petitioner realleges and incorporates paragraphs | through 8 as though fully stated in this Count L. 10. Section 481.223(1)(c), Florida Slatutes, 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.” Hl. Based upon the foregoing, the Respondent has violated Section 48].223(1)(c), Florida Statutes, by using the name or title and “interior designer”, when she was not the holder of a valid license. COUNT I 12. Petitioner realleges and incorporates paragraphs | through 8 as though fully stated in this Count 1. 13. Respondent is offering to provide interior design services. to 14, Section 481.223(1)(b), Florida Statutes, states that a person may not knowingly “practice interior design unless the person is an interior designer or a registered interior designer,” 15. Based upon the foregoing, the Respondent has violated Section 481.223(1)(b), Florida Statutes, by offering to provide interior design services. COUNT II 16. Petitioner realleges and incorporates paragraphs | through 8 as though fully stated in this Count HI. 17. 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. 18. Based upon the foregoing, Respondent has violated Section 481.2] 9(3), Florida Statutes, by practicing interior design services through Graham Interiors without a certificate of authorization. Py WHEREFORE, Petitioner respectfully requesis the Board enter an Order imposing an administrative fine not to exceed $5,000 per count, assess costs associated with investigation and prose€cution, impose any or all penaities 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 promulgated thereunder. Signed this “7 dayof December , 2005, “BS oe 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: IW >glos Kod mays Ay FILED cs Skee, Oenartment of Business end Professional Rerutatiun, AGENCY CLERK CLERK S04 wy ra [ourben

Docket for Case No: 06-000052