Qo : STATE OF FLORIDA o wae DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION Ze oe By e4 ‘ DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, vs. Case No.: 2004-027260 REINER SANCHEZ AND RAS CONSTRUCTION CORP., Respondents. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against REINER SANCHEZ AND RAS CONSTRUCTION CORP., ("Respondents"), and says: . 1. Peutioner 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 Business and Professional Regulation has jurisdiction over the unlicensed practice of architecture pursuant to Section 455.228(1), and Section 481.223(1)(a), Florida Statutes. 3. At all times material hereto, Respondents were not duly registered or certified to engage in the practice of architecture in the State of Florida pursuant to Chapter 481, Florida Statutes, 4, Respondents’ last known address is 214 Goldenrod Road, Suite A-6, Orlando, Florida 32807. 5. On or about July 25, 2003, Respondents contracted with Dr. Michelle Charles to perform architectural services for a doctor’s office located at 544 N. Semoran Bivd., Orlando, Florida. 6. The contract specifically provides the following: a. The contract contains a “Design Develop. Phase & Consultant Coordination” and a“Construction Documents Phase”. b. Respondents will “prepare construction documents for the Dr. Office Addition based upon the schematic plans provided by Owner.” c. The contract also charges for a Project Architect in the amount of $90.00 an hour. 7. On or about February 2, 2004, Respondents submitted an invoice for “Architecture Plans” in the amount of $14,240.00. 8. On or about February 2, 2004, Respondents submitted an invoice for “Architectural Services” in the amount of $7,000.00. 9. Further, Respondent, Reiner Sanchez, held himself as an architect to numerous employees of Dr. Michelle Charles. COUNT I 10. Petitioner realleges and incorporates paragraphs 1 through 9 as though fully stated in this Count 1. 11. Section 481.223(1)(a), Florida Statutes, states that a person may not knowingly “practice architecture unless the person is an architect or a registered architect.” we 12. Based upon the foregoing, the Respondents have violated Section 481.223(1)(a), Florida Statutes, by practicing architecture when they were not the holder of a valid license. COUNT IT 13. Petitioner realleges and incorporates paragraphs 1 through 9 as though fully stated in this Count Il. h4. 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 effect, when the person is not then the holder of a valid license.” 15. Based upon the foregoing, the Respondent Reiner Sanchez has violated Section 481.223(1)(c), Florida Statutes, by using the name or title “architect”, when he was not the holder of a valid license. COUNT DT 16. Petitioner realleges and incorporates paragraphs | through 9 as though fully stated in this Count H1. V7. Section 481.219(2), Florida Statutes, states a corporation, partnership, or a person practicing under a fictitious name, offering architectural services to the public must obtain a certificate of authorization, 18. Based upon the foregoing, Respondent, RAS Construction Corp. has violated Section 481.219(2), Florida Statutes, by offering architectural services when it was not the holder of a valid certificate of authorization. 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 lo Chapters 481 and 455, Florida Statutes, and/or the rules promulgated thereunder. + . Signed this __/ ‘ day of De com k ee , 2005. aS dK DAVID K. MINACC1 Smith, Thompson, Shaw & Manausa, P.A. 2075 Centre Pointe Blvd. Tallahassee, F] 32308-4893 FL Bar No. 0056774 Ph: (850) 402-1570 Fax: (850) 402-1508 pce: Li aelus \ APs ee FILED Ku) Ko Department of Business and Professional Regulate = AGENCY CLERK CLERK Sua pAa Z. (ex Awen ewig sate p22 BIOS

Docket for Case No: 06-000056