STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION G AS DEPARTMENT OF BUSINESS AND Se i, PROFESSIONAL REGULATION, Ey ee Petitioner, ZO" vs. DBPRCaseNo.: —-2005- 0214005 ~ aa) RYANALEXANDER GROUP, INC. AND PAMELA DITOMASO, Y Respondents. O (-l 44 / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design agains’ RYANALEXANDER GROUP, INC. and PAMELA DITOMASO ("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. Respondents’ last known address is 512] Ocean Boulevard, Siesta Key, Florida 34242, 4, At all times material hereto, Respondents were not duly registered or certified to engage in the practice of architecture or interior design pursuant to Chapter 481, Florida Statutes. 5. Respondents were offering interior design services in the March 2005 issue of the Sarasota Magazine. COUNTI 6. Petitioner hereby realleges and incorporates paragraphs one (1) through five (5) as if fully set forth herein. 7. Section 481.223(1)(c), Florida Statutes, prohibits a person from using the title interior designer or words to that effect unless the person is a registered interior designer. 8. Based upon the foregoing, the Respondents have violated Section 481.223(1)(c), Florida Statutes, by holding themselves out as interior designers when they were not the holder of a valid license. COUNT II 9. Petitioner hereby realleges and incorporates paragraphs one (1) through five (5) as if fully set forth herein. 10. 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. 11. Based upon the foregoing, Respondents have violated Section 481.219(3), Florida Statutes, by offering interior design services through RyanAlexander Group, Inc., without a 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 to Chapters 481 and 455, Florida Statutes, and/or the rules promulgated thereunder. ea Signed this 2 ‘7 day of Feb, ow +f , 2006. DAVID K. MINACCI Smith, Thompson, Shaw & Manausa, P.A. Pager O06 2075 Centre Pointe Blvd. CLERK 7, o FI Tallahassee, FL 32308-4893 pATE FL Bar No. 0056774 Ph: (850) 402-1570 Fax: (850) 402-1508 Fh . pepatan ABE TY cLeERK ! 2S. 7

Docket for Case No: 06-001998