STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, vs. Case No.: 2006-0081101 SIMMONS AND SARAY INTERIORS GROUP, INC. AND LAUREN SIMMONS, () 6-195 Respondents. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against LARUEN SIMMONS and SIMMONS AND SARAY INTERIORS GROUP, INC., ("Respondents"), and says: 1. Petitioner 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 and interior design 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 interior design in the State of Florida pursuant to Chapter 481, Florida Statutes, 4. Respondents’ last known address is 683 1090 Jupiter PK Drive, Suite 201, Jupiter, Florida 33458. 5. On December 6, 2005, Respondents prepared interior design drawings for a commercial project known as Cline Resources. 6. The drawings depict a reception area and a boardroom. 7. The Respondents’ title block appears on both pages of the drawings. 8. The Respondents are not licensed to perform interior design services in the State of Florida and therefore cannot provide design services for commercial property. COUNT I 9. Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) as if fully set forth herein. 10, Section 481.223(1)(b), Florida Statutes, states that a person may not knowingly practice interior design, when the person is not then the holder of a valid license. 11. Based upon the foregoing, the Respondents have violated Section 481.223(1)(b), Florida Statutes, by practicing interior design, when they were not the holder of a valid license. COUNT II 12. Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) as if fully set forth herein. 13. 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. 14. Based upon the foregoing, Respondents have violated Section 481.219(3), Florida Statutes, by offering interior design services through Simmons and Saray Interiors Group, Inc., without a certificate of authorization. i) 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 to Chapters 481 and 455, Florida Statutes, and/or the rules promulgated thereunder. Signed this aan day of Ap ci l , 2006, DAVID K. MINACCI 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 } D ye FUELED sm ae Department ot BY eee Regu MN fichele

Docket for Case No: 06-001921