STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION 2 “ Oo aus _ DEPARTMENT OF BUSINESS AND Q PROFESSIONAL REGULATION, Se eT Ki Petitioner, GPO, 2 oe: Zoo & vs. Case No: 2005-04752 = a DUFFY COMPLETE RELOCATION AND CHRISTOPHER JOHN CLARKSON a/k/a STEVE W. DUFFY, 0) (5 ° Uf 20 O Respondents. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against DUFFY COMPLETE RELOCATION and CHRISTOPHER JOHN CLARKSON a/k/a STEVE W. DUFFY ("Respondents"), and says: 1. Petitioner is the state agency charged with regulating the practice of interior design and 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 knawn address is 4000 Hollywood Boulevard, Suite 165 South, Hollywood, Florida 33021. RECEIVED SEP 05 2006 DBPR Agency Clerk 4. At all times material hereto, Respondents were not duly registered or certified to engage in the practice of interior design or architecture pursuant to Chapter 481, Florida Statutes. 5. Respondents’ brochure offers to provide architectural! and interior design services. 6. Respondents’ brochure also lists 22 commercial projects in which services were provided. 7. ‘As of September 13, 2005, Respondents’ website offers interior design, space planning and architectural services. COUNT I 8. Petitioner hereby realleges and incorporates paragraphs one (1) through seven (7) as if fully set forth herein. _ 7 9. Section 481.223(1)(b), Florida Statutes, statés that a person may not knowingly practice interior design, when the person is not then the holder of a valid license. 10. 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 IL 11. Petitioner hereby realleges and incorporates paragraphs one (1) through seven (7) as if fully set forth herein. 12. Section 48 1.223(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. 13. 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 ofa valid license, COUNT Til 14. Petitioner hereby realleges and incorporates paragraphs one (1) through seven (7) as if fully set forth herein. 15, Section 481.223(1)(c), Florida Statutes, prohibits a person from using the title architect or words to that effect unless the person is a registered architect. 16. Based upon the foregoing, the Respondents have violated Section 481.223(1){(c), Florida Statutes, by holding themselves out as architects when they were not the holder of a valid license. COUNT IV 17. Petitioner hereby realleges and incorporates paragraphs one (1) through seven (7) as if fully set forth herein. 18. 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.” 19. Based upon the foregoing, Respondents, have violated Section 481.223(1)(a), Florida Stautes, by practicing architecture when they were not the holder of a valid license. COUNT V 20. Petitioner hereby realleges and incorporates paragraphs one (1) through seven (7) as if fully set forth herein. 21. 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. 22. Based upon the foregoing, Respondents have violated Section 481 .219(3), Florida Statutes, by offering interior design services through Duffy Complete Relocation, 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. : : ~ we , Signed this 3 / day of 4 weg ed T , 2006. 7 Ny 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 pcp: & las Dapartment of Business and Professional Regulation Sy t OEPUTY CLERK M thichole CLERK DATE ~ -~2006

Docket for Case No: 06-004200

Issue Date	Proceedings
Jan. 09, 2007	Order Closing File. CASE CLOSED.
Jan. 08, 2007	Motion to Hold Case in Abeyance filed.
Jan. 03, 2007	Undeliverable envelope returned from the Post Office.
Nov. 16, 2006	Undeliverable envelope returned from the Post Office.
Nov. 08, 2006	Order Directing the Filing of Exhibits.
Nov. 08, 2006	Order of Pre-hearing Instructions.
Nov. 08, 2006	Notice of Hearing by Video Teleconference (hearing set for January 16, 2007; 9:00 a.m.; Miami and Tallahassee, FL).
Nov. 07, 2006	Petitioner`s Response to Initial Order filed.
Nov. 01, 2006	Initial Order.
Oct. 31, 2006	Notice of Filing Petitioner`s First Set of Interrogatories, First Requests for Production and Requests for Admission filed.
Oct. 31, 2006	Election of Rights filed.
Oct. 31, 2006	Administrative Complaint filed.
Oct. 31, 2006	Referral Letter filed.
Feb. 20, 2006	Undeliverable envelope returned from the Post Office.