ao. &f Be Se & STATE OF FLORIDA y “A DEPARTMENT OF BUSINESS AND PROFESSIONAL: REGULISTION 4 Kgisey , A DEPARTMENT OF BUSINESS AND Cae. Ge ? PROFESSIONAL REGULATION, “OSM Petitioner, O | . 74 Q vs. CASE NO.:. 2006-047619 DAVID RANDELL YOUNG AND , ARCHITECTURAL DRAWINGS, LTD. CO., Respondents. / . ADMINISTRATIVE COMPLAINT . Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, '("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior . Design against DAVID RANDELL YOUNG and ARCHITECTURAL DRAWINGS, LTD. co. _ ("Respondents"), and says:' . | 1. Petitioner is the state 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 904 Richards Avenue, Clearwater, Florida 33755. 4. At all times material hereto, Respondents were not duly registered or certified to engage in the practice of architecture pursuant to Chapter 481, Florida Statutes. 5. Respondents contracted with David Staruch to prepare architectural drawings for a condominium project known as Palm of Maderia Resort Condominiums located at 14715 Gulf Boulevard, Madiera Beach, Florida. . 6. Respondents prepared drawings for the project which contain their title block. 7. Respondents’ title block is offering services as “Architectural Drawings, LTD”. 8. Respondents are not licensed architects in the State of Florida and therefore * cannot prepare architectural drawings fora condominium project-or do business as Architectural . Drawings, LTD. " COUNTI .%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 pil 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.” 14. 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 15. Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) . as if fully 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, Architectural Drawings, Ltd. Co., 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 45 5 .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. Ww Signed this yr t __dayof__ “16 a “00. FILED ie a Department of Business and Pete Regu! — ; ye fl DEPUTY © DAVID K. MINACCI Smith, Thompson, Shaw & Manausa, P.A. , Pragati deche 3520 Thomasville Road, Fourth Floor CLERK 9.007 Tallahassee, Florida 32309 DATE yw FL Bar No. 0056774 Ph: (850) 402-1570 Fax: (850) 558-1613 ‘PCP: = MAY 1 4 2007

Docket for Case No: 07-003998