STATE OF FLORIDA lig _ DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION“? « aw Age! Yis 44 ray 4 DEPARTMENT OF BUSINESS AND _ nf oy 6 ? PROFESSIONAL REGULATION, a \- 112 ap R ayha Th . live Petitioner, . vs. DBPR Case No.: 2007-048803 - MARY P. COLLINS, d/b/a MPC DESIGN, Respondents. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, (“Petitioner”), files this Administrative Complaint before the Board of Architecture and Interior Design against MARY P. COLLINS d/b/a MPC DESIGN, (“Respondents”), and says: 1. Petitioner is the state agency charged with regulating the practice of interior . design pursuant to Section 20.165, F lorida 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 1462 Talbot Avenue, Jacksonville, Florida 32305. | 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 March 21, 2005, Respondents contracted with Mark Rubin to perform interior design services for a commercial project known as The Accubuild Companies new office space. 6: The contract specifically states that Respondents will provide interior design services. 7. The scope of services for the above referenced contract includes floor and wall fi nishes, placement of furniture, selection of new furniture, selection of decorative lighting, and consultation of al! design elements with client. 8. Respondents are not licensed as interior designers in the State of Flotida and therefore cannot offer or provide interior design services. 9. Respondents are offering interior design services through a fictitious name without a certificate of authorization. COUNT I 10. Petitioner hereby realleges and incorporates paragraphs one (1) through nine (9) as if fully set forth herein. 11. Section 481.223(1)(b), Florida Statutes, states that @ person may not knowingly practice interior design, when the person is not then the holder of a valid license. 12. 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 II 13. Petitioner hereby realleges and i mcorporates paragraphs one (1) through r nine (9) as if fully set forth herein, 14, . 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. 15. -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 Ht 16. Petitioner hereby realleges and incorporates paragraphs one (1) through nine (9) as if fully set forth herein. 17. Section 481.2193), Florida Statutes, requires a certificate of ‘authorization to practice interior design services through a corporation, partnership, or under a fictitious name. 18. ‘Based upon the foregoing, Respondents have violated Section 481.219(3), Florida Statutes; by offering interior design services through MPC Design, 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. . ; + Signed this ¢” day of Ecienn of , 2008. ELL Eden Sy DAVID K. MINACCI at pain ce 1 Aichlt Smith, Thompson, Shaw & Manausa, P.A. A: . 3520 Thomasville Road, Fourth Floor . Prsedeng 0 _ Tallahassee, Florida 32309 eRK FL Bar No. 0056774 “ ) See Ph: (850) 402-1570 DATE Fax: (850) 241-0161 Per: | \}28] 08 | a

Docket for Case No: 08-001723