STATE OF FLORIDA 07 y hs fo ps DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DEPARTMENT OF BUSINESS AND _ PROFESSIONAL REGULATION, Petitioner, vs. DBPR Case No.: 2006-019813 ' VERNON THOMPSON AND - PARADISE DESIGN & CONSTRUCTION, . O 7 _ | q4 (y Respondents. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, : ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design agains) VERNON THOMPSON AND PARADISE DESIGN & CONSTRUCTION, ("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 4121 Dijon Drive, Orlando, Flonda 32808. 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. EXHIBIT A 5. On or about May 25, 2005, Respondents contracted with Tim Lincoln to provide signed and sealed architectural plans for a residential project located at 12554 S. John Young Parkway, Orlando, Florida 32837 6. Respondents’ held themselves out as architects to Tim Lincoin. 7. Respondents. are offering these services through a business entity without a certificate of authorization. . | . 8. Respondents are not licensed to practice architecture in the State of Florida and therefore cannot offer.or provide architectural services. . 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)(a), Florida Statutes, states that a person may not knowingly “practice architecture unless the person is an architect or a registered architect.” 11. ° Based upon the foregoing, Respondents have violated Section 481.223(1)(a), Florida Statutes, by practicing architecture when they were not the holder of a valid license by offering architectural services. . | COUNT i 12. Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) as if fully set forth herein. 13. 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.” 4, Based upon the foregoing, the Respondents have violated Section 481.223(1)(c), F lorida Statutes, by using the name or title “architect”, when they were not the holder ofa valid license. . COUNT TIT 1s. ~~ Petitioner hereby realleges and incorporates paragraphs one (1) through eight ® as. if fly set forth herein. 16. _ Section 481.219(2), Florida Statutes, requires a certificate of authorization for a corporation, partnership, or fictitious name offering architectural services. 17. Based upon the foregoing, the Respondent, Paradise Design & Construction, 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. ; u _ ; Signed this &" dayof /ebrea - o , 2007." . F | L E D -S Jer, ‘ ; Department of Business and Professional Regulation — DL Zoe DEPUTY CLERK DAVID K. MINACCI Prardnt 4; l / Smith, Thompson, Shaw & Manausa, P.A. 2075 Centre Pointe Blvd. Tallahassee, FL 32308-4893 DATE cmt = } a- 2007 FL Bar No. 0056774 Ph: — (850) 402-1570 Fax: (850) 402-1508 PCP: FEB 0 5 2007 Roding — WwW do)

Docket for Case No: 07-001996