TEP pe PILED Hert Bains # O6 SEP 29 PH 3:2] DIVISION ge STATE OF FLORIDA ADMINISTRATIVE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATIONZ ARies ‘ DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, ys. DBPR Case No.: 2005-063289 TRACY A. GREGORY AND TAG FOR DESIGN, Ob & - ab ss Respondents. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against TRACY A. GREGORY AND TAG FOR DESIGN, (“Respondents”), and says: 1, Petitioner is the stale agency charged with regulating the practice of architecture 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 2396 Orangepoint Avenue, Palm Harbor, Florida 34683. 4, 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. 5, On or about November 16, 2005, Respondents made a presentation to the Tampa City Historic Preservation Architectural Review Committee for a proposed renovation of the Floridan Hotel. 6. Respondents prepare drawings for the proposed renovations and presented the drawings to the committee. 7. One of the required documents to make such a presentation to the committee was an architectural site plan. 8. Respondent told the committee that she was an architectural designer. 9, Respondent is not licensed in the State of Florida as an architect and therefore cannot perform design services for a commercial project or hold herself out an architectural designer. COUNT I 10. Petitioner hereby realleges and incorporates paragraphs one (1) through nine (9) as if fully set forth herein, ll. 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.” 12. Based upon the foregoing, Respondents have violated Section 481.223(1)(a), Florida Statutes, by offering and providing architectural services. COUNT I 13. Petitioner hereby realleges and incorporates paragraphs one (1) through nine (9) as if fully set forth herein. 14, 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 Respondents have violated Section 481.223(1)(c), Florida Statutes, by using the name or title “architect”, when they were not the holder of a valid license. COUNT LI 16: Petitioner hereby realleges and incorporates paragraphs one (1) through nine (9) as if fully set forth herein. 17. Section 481.219(2), Florida Statutes, requires a certificate of authorization for a corporation, partnership, or fictitious name offering architectural services. 18. Based upon the foregoing, the Respondent, TAG for Design has violated Section 481.219(2), Florida Statutes, by offering architectural services 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. , | . Signed this 27 dayof_ Aus ea b , 2006. 7 SN I 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 | FILED Dopartment of Business and Professional Regulation DEPUTY CLERK CLERK Prardnt Tihele DATE 9-5-2006 -

Docket for Case No: 06-003655