a an? eu é é STATE OF FLORIDA “tp fo a DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION? y ° { | : ikon, Me. DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, OX 10 Ky Petitioner, vs. CASE NO.: 2007-041433 VIKKI L. KEMP, INTERIOR DYNAMICS DESIGN STUDIO, INC., Respondents. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against VIKKI L. KEMP and INTERIOR DYNAMICS DESIGN STUDIO, INC., (“Respondents”), and says: 1. | -Petitioner is the state agency charged with regulating the practice of 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 interior design pursuant to Section 455.228(1), and Section 481.223(1)(a), Florida Statutes. 3. Respondents’ last known address is 11231 North US Hwy 1, Suite 112, North Palm Beach, Florida 33408. . 4. At all times material hereto, Respondents were not duly registered or certified to engage in the practice of interior design in the State of Florida pursuant to Chapter 481, Florida Statutes. “5. On or about September 11, 2003, in response to a Notice and Order to Cease and Desist, Responderits signed an affidavit agreeing to change her advertisement to delete all - references to interior design or word to that effect. 6. As of July 24, 2007, Respondents continue to hold themselves out as interior designers and offer interior design services. 7. In a magazine advertisement, the Respondents offer interior design services. 8. Respondents are not licensed to practice interior design in the State of Florida and therefore cannot offer or provide interior design services. 9, Respondent Interior Dynamics Design Studio, Inc., does not have a certificate of authorization to offer interior design services in the State of Florida. COUNT I 10. Petitioner hereby realleges and incorporates paragraphs one (1) through nine (9) as if fully set forth herein. li. ) Section 481.223(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. 12. 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 of a valid license, COUNT II 13. Petitioner hereby realleges and incorporates paragraphs one (1) through nine (9) as if fully set forth herein. 14. 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. 15. Based upon the foregoing, Respondents have violated Section 481.219(3), Florida Statutes, by offering interior design services through Interior Dynamics Design Studio, Inc., 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. +t Signed this. ¢"" _dayof_ Aebrva- 7. , 2008. ae Requiation DAVID K. MINACCI Smith, Thompson, Shaw & Manausa, P.A. . 3520 Thomasville Road, Fourth Floor /V Nicholl Tallahassee, Florida 32309 4nandm ‘ FL Bar No. 0056774 CLERK 9 B- 2008 Ph: (850) 402-1570 _ 5 al Department of BeDUTY CLERK DATE Fax: (850) 558-1613 PCP:

Docket for Case No: 08-001088