Ps i™ ; i STATE OF FLORIDA Ser SA 4 DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION dy . Age Vis a DEPARTMENT OF BUSINESS AND ys On On 48 PROFESSIONAL REGULATION, Ca pAlts My, BOARD OF ARCHITECTURE AND " GSE INTERIOR DESIGN, “1-4O06O Petitioner, O : Yeo CASE NO.: 2006-066428 PATIENCE HALLIBURTON, Respondent. _/ _ ADMINISTRATIVE COMPLAINT ” Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, (*Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against PATIENCE HALLIBURTON, ("Respondent"), and says: . lL 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 pursuant to Section 455.228(1), and Section 481.223(1)(a), Florida Statutes. 3. At all times material hereto, Respondent was not duly registered or certified to -engage in the practice of architecture in the State of Florida pursuant to Chapter 481, Florida Statutes. 4. Respondent’s last known address is P.O. Box 848008, Pembroke Pines, Florida 33084. - . 5. Respondent contracted with Abraham Rabah to provide signed and sealed drawings for a residential project. located at 745 N.E. 1749" Terrace, North Miami Beach, Florida. . | 6. Respondent is not licensed. to practice. architecture and therefore cannot offer to provide signed and sealed drawings. 7. Respondent contracted with Miguel Ravelo to provide signed and sealed Grawings : for a residential project located at 12995 N.W. 182nd Street, Miami, Florida. | 8. Respondent is not’ licensed to practice architecture and therefore cannot offer to - provide signed and sealed drawings. . . 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 a registered architect.” | 11. Based upon the foregoing, Respondent has violated Section 481. 223(1)(a), Florida . Statutes, by practicing architecture when she was not the holder of a valid license by offering architectural services to Abraham Rabah. | coUNT 12. Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) as if fully set forth herein. 13. Section 481 -223(1)(), Florida Statutes, states.that a person may not knowingly “practice architecture unless the person is an architect or a registered architect.” 14, Based-upon the foregoing, Respondent has violated Section 481.223(1)(2); Florida Statutes, by practicing architecture when she was not the holder of a valid license by offering architectural services to Miguel Ravelo. - WHEREFORE, Petitioner respectfully requests the Board enter an Order imposing an administrative fine not to exceed $5,000 per count, assess costs associated with investigation and ; prosecution, impose.any or all penalties delineated’ within Section 455.227(2), Florida Statutes, and/or any other relief that the Board is authorized to impose pursuant to Chapters 481 and 455, Florida Statutes, and/or the rules promulgated thereunder. ak : Signed this 24° day of Pins ,Qoe7, } =f) C$ DAVID K. MINACCI Smith, Thompson, Shaw & Manausa, P.A. 3520 Thomasville Road, Fourth Floor Tallahassee, Florida 32309 FL Bar No. 0056774 Ph: (850) 402-1570 Fax: (850).558-1613

Docket for Case No: 07-004000