May 4 2006 9:24 Fax sent by : 9585218521 FL BOARD 65-84-86 48:13 Py: STATE OF FLORIDA FLORIDA BOARD OF PROFESSIONAL ENGINEERS ; i : ELORIDA ENGINEERS ; | MANAGEMENT CORPORATION, | _ Petitioner, i v. FEMC Case No. 2009042579 MING ZEN HUANG, P.E.. i Respondent. . | ¥ i i ADMINISTRATIVE COMPLAINT Petitioner, the Florida Engineers Management Corporation, files this'l Administrative Complaint before the Board of Professional Engineers against Respondent, Mi 2 Zen Huang, P.E. This Administrative Complaint is issued pursuant to Sections 120.60 and 4 Statutes. Any procedding conceming this complaint shall be conducted p 1. Petitioner is charged with providing administrative, inv prosecutorial services to the Board of Professional Engineers pursuant to Florida Statutes. The Board of Professional Engineers is charged with regulating the practice of engineering pursuant to Chapter 455, Florida Statutes. 2. Respondent is and has been at all time material hereto a licensed professional engineer in the State of Florida, having been issued license number PE 53856, Ribspondent’s last { known address is 18119 Colonnades Place, San Diego, CA 92128. 2/14 May 4 2006 9:24 Fax sent by : 9585218521 FL BOARD 65-84-86 48:14 Pg: S SF 3. On or about July 22, 2004, Respondent signed and sealed 4 sh i of plans for a swimming pool to be built in Palm Beach County, at 10681 Oak Meadow Lane, eworth. 4, The plans signed and sealed by Respondent for 10681 Oak Meltiow Lane had been drawn by The Pool People, Inc. | 5. . The Pool People, Inc., had prepared the plans for 10681 Oak! i Meadow Lane pursuant to a contract to construct a pool on the site for an owner, Shelby Homes, 6. Under the terms of its contract with Shelby Homes, The Pool People, Inc., agreed to obtain the necessary building permits and any professional engineering required for such permits for the pool at 10681 Oak Meadow Lane. | 7. Respondent did not have a contract with Shelby Homes to ‘prowéde engineering services for the pool at 10681 Oak Meadow Lane, , 8. Respondent signed and sealed the plans for the pool at 10681 O: pursuant to his employment by The Pool People, Inc. 9. During the time in which he signed the plans for the 10681 O. Meadow Lane pool, Respondent received compensation from The Pool People, Inc., based o and not on a per job or.per project basis. | 10. The Pool People, Inc., does not have and has never had conicat of Authorization to provide engineering services in the State of Florida. | { CO ONE i 11, Petitioner realleges and incorporates paragraphs one (1) oe ten (10) as if i fully set forth in this Count One. Hi i I 12, Based on the foregoing, Respondent violated Section enabayy Florida ; a Statutes, affixing or permitting to be affixed his seal, name, or signature to final drawings that Ming Z. Hoang, PE, 2005042579 2 4 & weekly rate, 3414 May 4 2006 9:24 Fax sent by : 9585218521 FL BOARD : 65-84-86 48:14 Py: 4/714 i { i - i were not prepared by him or under his.responsible supervision, direction, or contr l. COUNT TWO 13, Petitioner realleges and incorporates paragraphs one re5) through ten (10) as if { fully set forth in this Count Two. 14. Based on the foregoing Respondent violated Section 471.03 1{a), Florida Statutes, by violating Section 455.227(1)q), Florida Statutes, by aiding - assisting an unlicensed entity, The Pool People, Inc., to practice engineering, WHEREFORE, the Petitioner respectfully requests the Board of Professional Engineers to enter an order imposing one or more of the following penalties: permanert revocation or suspension of the Respondent’s license, restriction of the Respondent's practice, #nposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, the any other relief that the Board deems appropriate. SIGNED this Ad aay of Liha 08 | FILED Department Ques ant Prolene Remulsin Paul J. Martin ¢ GCEPUTY CLERK Executive Director ieee! Ming Z. Husng, P.E., 2005042579 3 May 4 2006 9:25 Fax sent by : 9585218521 FL BOARD 65-84-86 48:14 Py: 5/14 6 oS COUNSEL FOR FEMC: Bruce A. Campbell Prosecuting Attorney Florida Engineers Management Corporation 2507 Callaway Road, Suite 200 Tallahassee, Florida 32303 Florida Bar No. 191163 ; PCP: January 19, 2006 PCP Members: Matthews, Burke, Seckinger Ming Z, Huang, P.E., 2005042579 4

Docket for Case No: 06-001581PL

Orders for Case No: 06-001581PL