uaparungat of Buetana wid Professional farpulation Daputy Agency Clark CLERK Brandan Nichols Orie 3/5/2009 STATE OF FLORIDA File # DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATI COSMETOLOGY BOARD LEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, Vv. Case Na, 2008-023517 HUE NGOC MAT, Respondent. i ADMINISTRATIVE COMPLAINT Petitionsr, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION (“Department”), files ‘this Administrative Complaint before the Board of Cosmetology, against Hue Ngoc Mai (“Respondent’), and says: t. Petitioner is the state agency charged with regulating the practice of cosmetology pursuant to Section 20.165, Florida Statutes, and Chapters 455 and 477, Florida Statutes, and the rules promulgated thereto. 2. Respondent’s address of record is 2818 Rockmont Street, Jacksonville, Florida 32207. 3. Respondent is licensed in the State of Florida as a Full Specialist having license rs §64649. 4, In or about September 2007, the Department of Business and Professional Reguletion (“Department”) initiated an investigation into Respondent after receiving information that Orange Parx Beauty Academy supplied Cosmetology Diplomas and ' cefPa Fd FOO sda 6pé9oPTpags 45:98 Tee /82/Pa 60:ZT oOToz 6Z dy Certificates to urjicensed persens whe did not attenc the school in wmchange for money. 5. On or aboul August 10, 2007, Loan Kiem Nguyen paid Respondent $560 for a Nail Specialist Diploma and Certificate from the Orange Park Beauty Academy indicating that Loan Kiem Nguyen completed the necessary hours of course instruction for a Nail Specialist license. 6. Loan Kiem Nguyen never attended Orange Park Beauty Academy and did not complete the alleged hours of instruction. 7, On or about August 24, 2007, Respondent submitted Loan Kiem Nguyen’s application for a Nail Specialist license on to the Department using the Diploma and Certificate he obtained from Orange Park Beauty Academy. By On September 19, 2007, Loan Kiem Nguyen was issued a Nail Specialist license, license number FV 9558842, from the Department . Q. on or about cetober 4, 2007, Ngee Lieng Thi Nguyen paid Respondent an undisclosed amount of money for a Full Specialist Diploma and Certificate from the Orange Park Beauty Academy indicating that Ngee Lieng Thi Nguyen completed the necessary hours of course instruction for a Facial Specialist license. 10.° Ngoc Lieng Thi Nguyen never attended Orange Park Beauty Academy and did not complete the alleged hours of instruction. GaOGC\Professions Boards\Cosmetology\AC\LeChes Parson's Law Clerks\Cherhann Granston\Mai, Hue Ngo 2008-02351 7\AC.doe 2e/G8 Fovd FOO dad 6régp Tress 5:98 @lb2/8e/Pra 60:21. OT0Z 62 dy Jl. On or about October 4, 2007, Respondent submitted an Ngoc Lieng Thi Nguyen’s application for a Facial Specialist license to the Department using the Diploma and Certificate he obtained from Orange Park Beauty Academy. 12. On November §, 2007, Ngoc Lieng Thi Nguyen was issued a Facial Specialist license, license number FB 9729367, from the Department. 13. On or about May 21, 2007, Ban Thi Tran paid Respondent _ 6450 for a Full Specialist Diploma and Certificate from the Orange Park Heauty Academy indicating that Ban Thi Tran completed the necessary hours of course instruction for a Full Specialist license. 14. Ban Thi Tran never attended Orange Park Beauty Academy and did not complete the alleged hours of instruction. 15. On or about May 21, 2007, Respondent submitted Ban Thi Tran’s application for a Full Specialist license ta the Department using the Diploma and Certificate he obtained from Orange Park Beauty Academy. 16. On dune §, 2007, Ban Thi Tran was issued a Full Specialist license, jicense number FS 71836, from the Department. 17. On or about June 6, 2007, Ngo Hanh Thi Thai paid Respondent $535 for a Nail Specialist Diploma and Certificate from the Orange Park Beauty Academy indicating that Ngec Hanh GAOGCMrufessions Bourds\Cosmetology\AC\LeC hea Parson's Law Clerks\(Cheri-annt Granston\Mai, Hue Ngoc 2008-02351 7\AC doe ce/9e Fed FOO sda 6pé9oPTpags 45:98 Tee /82/Pa 60:ZT oOToz 6Z dy Thi Thai cempleted the necessary hours of course instruction far a Nail Specialist license. 18. Ngec Hanh Thi Thai never attended Orange Park Beauty Academy and did not complete the alleged hours of instruction. 15. On or about June 20, 2007, Respondent submitted Ngoc Hanh Thi Thai’s application for 4 Nail Specialist license to the Department using the Diploma and Certificate he obtained from Orange Park Beauty Academy. 20. On July 10, 2007, Ngoc Hanh Thi Thai was issued a Nail Specialist license, license number FV 9558162, from the Department. 21. On or about May 25, 2007, Sopheap Kim paid Respondent $560 for a Mail Specialist Diploma and Certificate from the Orange Park Beauty Academy indicating that Sopheap Kim completed the necessary hours of course instruction for a Nail Specialist 22, Soheap Kim never attended Orange Park Beauty Academy and did net complete the alleged hours of instruction. 23. On or about June 20, 2007, Respondent submitted Soheap Kim’s application for a Nail Specielist license to the Department using the Diploma and Certificate he obtained from Orange Park Beauty Academy. 24. On July 10, 2007, Soheap Kim was issued a Nail Specialist license, license number FV 9558162, from the Department. GAOGC\Prafessions Bourds\Cosmetology\AC\LeChea Parson's |.aw Clecks'\Cheri-ann Grangron\Mai, Hug Ngoo 2008-0255 17\AC.doc cefée Fd FOO sda 6pé9oPTpags 45:98 Tee /82/Pa 60:21. OT0Z 62 dy 25. On or about February 17, 2007, Thanh Tra Nhu Le paid Respondent $560 for a Nail Specialist Diploma and Certificate from the Orange Park Beauty Academy indicating that Thanh Tra Nhu Le completed the necessary hours of course instruction for a Nail Specialist license. 26, Thanh Tra Nhu Le never attended Orange Fark Beauty Academy and did not complete the alleged hours of instruction. 27. On or about February 17, 2007, Respondent submitted Than Tra Nhu Le’s application for a Nail Specialist license to the Department using the Diploma and Certificate he obtained from Orange Park Beauty Academy. 28, On March 30, 2007, Thanh Tra Nhu Le was issued a Nail Specialist license, license number EV 9556986, from the Department. 29, On or about July 31, 2007, Huong Thi Nguyen paid Respondent an undisclosed amount of money for a Nail Specialist Diploma and Certificate from the Orange Park Beauty Academy indicating that Huong Thi Nguyen completed the necessary hours of course instruction for a Nail Specialist license. 30. Huong Thi Nguyen never attended Orange Park Beauty Academy and did not complete the alleged hours of instruction. 31. On or about August 15, 2007, Respondent submitted Hueng Thi Nguyen’s application for a4 Nail Specialist license to the Department using the Diploma and Certificate he obtained from Orange Park Beauty Academy. GAOGCAProfessions Boards\Cogmetology\AC\LeChea Parson's Law Clerks\Cheri-ann Cranston\Mai, Hue Ngoc 200802351 7\AC. dae ce/se Fd FOO sda 6pé9oPTpags 45:98 Tee /82/Pa 60:21. OT0Z 62 dy 32. On September 11, 2007, Hueng Thu Nguyen was issued a4 Nail Specialist license, license numer FY 9558636, from the Department. 33. On or about August 23, 2007, Chunh K. Tran paid Respondent $560 for a4 Nai] Specialist Piplema and Certificate from the Orange Park Beauty BReademy indicating that Chunh &. Tran completed the necessary hours of course instruction for a Nail Specialist license. 34. Chunh K. Tran never attended Orange Park Beauty Aeademy and did not complete the alleged hours of instruction. 35. On or about September 24, 2007, Respondent submitted Chunh K. Tran’s application fer a Nail Specialist license to the Department using the Diploma and Certificate he obtained from Qrange Park Beauty Academy. 36. On October 12, 2007, Chunh KX. Tran was issued a Nail Specialist license, license number FV 9559209, from the Department. 37. On or about September 17, 2007, during an undercover sting operation, Touckay Laochareun (“Laochareun”), an ABT undercover agent, paid Hue Nguyen 21,480 in exchange for a Full Specialist Diploma and Certificate from the Orange Park Beauty Academy. 38. Hue Nguyen gave the $1,480 to Respondent and Respondent obtained a Diploma and Certificate from the Orange Park Beauty Academy indicating that Laochareun completed the GAOGC\ Professions Boards\Cosmetology\AC\LeChea Parson's Law Clerks\Cheri-ann Granston\Mai, Hue Ngoc 2YO8-0293 TAC doe ce/6e Fd FOO sda Ob:Z1 OlOz 62 dy Bp29P Tress Q5:98 Tae /8e/ra necessary hours of course instruction for a buil Specialist ¥ license. 49. Laochareun never altended Orange Park Beauty Academy and did not complete the alleged fheurs of instruction. 40. The Diploma - and Certificate reflected Laochareun'’s undercover fictitious name, Kristy Tal. 41. On or about September 21, 2007, Respondent submitted Laochareun’s application for a-.Full Specialist license to the Department using the Diploma and Certificate he obtained from Orange Park Beauty Academy. 42. On September 27, 2007, the Department received Lacchareun’s completed application for a Full Specialist license along with the Diploma and Certificate obtained from Orange Park Beauty Academy. 43. Jeannie Chin is the owner of Orangé Park Beauty Academy. 44. Jeannie Chin provided all the documentation Respondent submitted to the Department for licensure. 45, Respondent obtained the documentation by forwarding the funds received from the unlicensed individuals to Jeannie Chin. 46. Petitioner realleges and incorporates by reference the allegations set forth in paragraphs one (1) through forty five (45) as though fully set forth herein. GAOGC\ Professions Boards\Cosmetology\AC\LeChea Parson's Law Clerks\Cheri-ann Granston\Mai, Hue Ngoc 20080233) VAC. doc cefET Fed FOO sda 6pé9oPTpags 45:98 Tee /82/Pa Ob:Z1 OlOz 62 dy 47. Seetion 477.0265(1) (e), Florida Statutes, slates that it is unlawful for any person to obtein or attempt to obtain a license or registration for money, other than the required fee, or any other thing of value or by fraudulent misrepresentations.” 49. Based on the foregoing, Respondent violated Section 477.0265(1) (e), Florida Statutes, by using a falsified Diploma and Certificate to obtain a Nail Specialist license for Loan Kiem Nguyen in exchange for $560. COUNT TWO 49, Petitioner realleges and incorporates by reference the allegations get forth in paragraphs one (1) through forty five (45) as though fully set forth herein. 50. Section 477.0265(1) (6), Florida Statutes, states that ‘it is unlawful for any person to obtain or attempt to obtain a license or registration for money, other than the required fee, ar any other thing of value or by fraudulent misrepresentations.” 51. ‘Based on the foregoing, Respondent violated Section 477.0265(1) (e), Florida Statutes, by using a falsified Diploma and Certificate to obtain a Facial Specialist license for Ngoc Lieng Thi Nguyen in exchange for an undisclosed amount of money. COUNT THREE GAOGC Professions Boards\Cosmetalogy\AG\LeChea Parson's Law Clerks\Cheri-ann Granston\Mai, Hue Neer 2008-02351 7\AC doc cefTT Fed FOO sda 6pé9oPTpags 45:98 Tee /82/Pa O:ZE oOtoz 6Z dy 52. Patitioner realleges and incorporates by yeference the allegations set forth in paragraphs one (1) through forty five (45) as theugh fully set forth herein. 53, Section 477.0268(1)(e), Florida Statutes, states that S$t is unlawful for any person to obtain or attempt to obtain a license or registration for money, other than the required Tee, ~ or any other thing af value ar by fraudulent misrepresentatioans.” 54. Based on the foregoing, Respondent violated Section 477.0265(1) le), Florida Statutes, by using 2 falsified biplome and Certificate to obtain a Full Specialist license for Ban Thi Tran in exchange for $450. COUNT FOUR 55. Patitioner realleges and incorporates by reference the allegations set forth in paragraphs one (1) through forty five (45) as though fully set forth herein, 56. Section 477.0265(1)(e), Florida Statutes, states that it ds unlawful for any person to obtain or attempt to obtain 4 license or registration for money, other than the required fee, Gr any other thing of value or by fraudulent misrepresentations.” 57. Based on the foregoing, Respondent violated Section 477.0268 (1) (@), Florida Statutes, by using a falsified Diploma and Certificate to obtain a Naii Specialist license for Ngoc Hanh Thi Thai in exchange for $435. GAOGCAProfessions Boards\Cosmelology\AC\LeChea Parson's Law Clerks\Cheri-ann Granston\Mai, Hue Ngoc 2008-0235 INAC.doe cefelt Fed FOO sda 6pé9oPTpags 45:98 Tee /82/Pa O:ZE oOtoz 6Z dy éafet COUNT FIVE 59. Petitioner realleges end incorporates by reference the allegations set forth in paragraphs one (1) through forty five (45) as though fully set forth herein. 59. Section 477.0265(1) (6), Florida Statutes, states that “¢t is unlawful for any person te obtain or attempt to obtain a license or registration for money, other than the required fee, or any other thing of value Or by fraudulent misrepresentations.” 60. Based on the foregoing, Respondent violated Section 477.0265(1) (8), Florida Statutes, by using a falsified Diploma and Certificate to obtain a Nail Specialist license for Soheap Kim in exchange for $560. COUNT SIX 61. Petitioner realleges and incorporates by reference the allegations set forth in paragraphs one (1) through forty five (45) as though fully set forth herein. 62. Section 477.0265(1) (e), Florida Statutes, states that “it is unlawful for any person to obtain or attempt te obtain a license or registration for money, other than the required fee, ar any other thing of value or by fraudulent misrepresentations.” 63. Based on the foregoing, Respondent violated Section 477,0265(1)(e), Florida Statutes, by using a falsified Diploma and Certificate to obtain a Nail Specialist license for Thanh GA0GC\Professions Boards\Cosmetoloay\AC\LeChea Parson's Law Clerks\Cheri-antt Granston\Mai, Hue Ngoc 200841235 LAC. doc Fad FOO sda 6pé9oPTpags 45:98 Tee /82/Pa TE:Zl otoz 62 dy Tra Nhu Le in exchange for $560. COUNT SEVEN 64. Petitioner realleges and incorporates by reference the allegations set forth in paragraphs one (1) through forty five (45) as though fully set forth herein. 6%. Section 477.0265(1)(e), Florida Statutes, states that “it is unlawful for any person to obtain or attempt to obtain a license or registration for money, other than the required fee, or any ather thing of value or by Fraudulent misrepresentations.” 66. Based on the foregoing, Respondent violated Section 477.0265t1) te), Florida Statutes, by using a falsified Diploma and Certificate to obtain a Nail Specialist license for Muong Thi Nguyen in exchange for an undisclosed amount of money. COUNT EIGHT 57. Petitioner reslleges and incorporates by reference the allegations set forth in paragraphs one tl) through forty five (45) as though fully set forth herein. 68. Section 477.0265(1) (e}, Florida Statutes, states that “it ig unlawful for any person to obtain or attempt to obtain a license or registration for money, other than the required fee, or any other thing of value or by fraudulent misrepresentations.” 69. Based on the foregoing, Respondent violated Section 477.0265(1) le), Florida Statutes, by using 4 falsified Diploma GAOGC\Professions Boards\Cosmetology\AC\LeChea Parson's Law Clerks\Cheri-ann Granston\Mai, Hue Ngoc 2008-02351 7\AC.doe 1] cefPT Fed FOO sda 6pé9oPTpags 45:98 Tee /82/Pa TE:Zl otoz 62 dy and Certificate to obtain a Nail Specialist license for Chunh KR. Tran in exchange for $560. COUNT NINE 70. Petitioner realleges and incorporates by reference the allegations set forth in paragraphs one (1) through forty Tive (45) as though fully set forth herein. Fl. Section 477.0265(1)(e), Florida Statutes, states that “it is unlawful for any person to obtain or attempt to obtain a license or registration for money, other than the required fee, or any other thing of value or by fraudulent misrepreséntatioans.” 72. Besed on the foregoing, Respondent violated Section 477.0265(1) le), Florida Statutes, by using a falsified Diploma and Certificate to obtain a Full Specialist license for Touckay Laochareun in exchange for $1,480. COUNT TEN 73. Petitioner realleges and incorporates by reference the Ee allegations set forth in paragraphs one ( ) through forty five (45) as though fully set forth herein. 74. Section 455.227(1} (4), Flerida Statutes, states that “aiding, assisting, procuring, employing, or advising any unlicensed person or entity to practice a profession contrary to this chapter, the chapter regulating the profession, or the rules of the department or the board shall constitute grounds for which the disciplinary actions specified in subsection (#) GACGCA\Professions Boards\Cosmetology\AC\LeChea Parson's Law Clerks\Cheri-aim GranstorsMai, Hue Ngoc 2008-0235 17\AC doc cef/ST Fed FOO sda 6pé9oPTpags 45:98 Tee /82/Pa TE:Zl otoz 62 dy may be taken.” Based on the foregoing, Respondent violated Section un 455.9297 (1) (4), Florida Statutes, by aiding Loan Kiem Nguyen, 4&n unlicensed person, in obtaining a Nail Specialist license contrary to Section 477.0265 (1) (e), Florida Statutes. 76. Petitioner realleges and incorporates by reference the allegations set forth in paragraphs one (1) through forty five (45) as though fully set forth herein. 77. Section 455.227(1) (4), Florida Statutes, states that “aiding, assisting, procuring, employing, ox advising any unlicensed person or entity to practice a profession contrary to this chapter, the chapter regulating the profession, or the rules of the department or the board shall constitute grounds ‘ for which the disciplinary actions specified in subsection {2) may be taken.” 79. Based on the foregoing, Respondent violated Section 455,.227(1) (3), Florida Statutes, by aiding Ngoc Lieng Toni Nguyen, an unlicensed person, in obtaining a Facial Specialist license contrary to Section 477.0265 (1) (€), Florida Statutes. COUNT TWELVE 79, Petitioner realleges and incorporates by reference the allegations set forth in paragraphs one (1) through forty five (45) as though fully set forth herein. 80. Section 455.227(1) (4), Florida Statutes, states that GAOGC Professions Boards\Gosmetology\AC\LeChea Parson's Law Clerks\Cheri-ann Granston\Mai, Hue Neoc 2008-02351 7\4C doc eef9T Fed FOO sda 6pé9oPTpags 45:98 Tee /82/Pa Th:2l oto 62 4dy “siding, assisting, procuring, employing, of advising any unlicensed person or entity to practice a profession contrary To this chapter, the chapter regulating the profession, or the rules of the department or the board shall constitute grounds for which the disciplinary actions specified in subsection (2) may be taken.” a1. Based on the foregoing, Respondent violated Section 455,227(1) (}), Florida Statutes, by aiding Ban Thi Tran, an unlicensed person, in obtaining a Full Specialist license contrary to Section 477.0265 (1) (a), Florida Statutes. COUNT THIRTEEN 32. Petitioner realleges and incorporates by reference the allegations set forth in paragraphs one (1) through forty five (45) as though fully set forth Ferein, 83. Section 455.227(1) (4), Florida Statutes, states that “aiding, assisting, procuring, employing, or advising any unlicensed parson or entity to practice a profession contrary to this chapter, the chapter regulating the profession, or the rules of the department or the board shall constitute grounds for which the disciplinary actions specified in subsection (2) may be taken. 84. Based on the foregoing, Respondent violated Section 455,227(1)(j), Florida Statutes, by aiding Ngoc Hanh Thi Thai, an unlicensed person, in obtaining a Nail Specialist license contrary to Section 477.0265(1) (es), Florida Statutes. GAOGC\Frofessions Boards\Cosmetology\AC\LeChea Parson's Law Clerks\Cherkeann Granston\Mai, Hue Ngoc 2008-02351 AC duc cefeT Fed FOO sda 6pé9oPTpags 45:98 Tee /82/Pa TE:Zl otoz 62 dy ée/ot COUNT ao. Petitioner realleges and incorporates by POURTELM reference the allegations set forth in paragraphs one (1) through forty five (45) as though fully set forth he 86. Section 455.227(1) (4), “aiding, assisting, procuring, unlicerised person or entity te this chapter, the chapter regulat amploying, rein. Florida Statutes, states Lhat or advising any practice a profession contrary to ing the profession, or the rules of the department or the board shall constitute grounds for which the disciplinary action may be taken.” 87. Based on the foregeing, 455 ica) unlicensed person, in obtaining a contrary to Section 477.0265 (1) (@ COUNT F ag. allegations set forth in paragrap s specified in subsection (2) Respondent violated Section .227(1) (4), Florida Statutes, by aiding Sopheap Kim , an Nail Specialist license }, Plorida Statutes. | TEEN Petitioner realleges and incorporates by reference the (1) through forty five ns one (45) as though fully set forth herein. 89. Section 455.227(1) (9), Florida Statutes, states that “aiding, assisting, procuring, employing, or advising any unlicensed person or entity to practice a profession contrary to this chapter, the chepter regulating the profession, or the rules of the department or the board shall constitute grounds for which the disciplinary actions specified in subsection (2) GAOGC\Professions Buards\Cosmetolugy\AQ\LeChea Parson's Law Clerks\Cheri-ann Granston\Mai, Hue Ngag 2008-0235 17\AC.doc and YOO sddd ZE:ZTL Otoz 6Z dy 15 Bp29P Tress QS:98 Tae /8e/ra may be taken. 90. Based on the foregoing, Respondent violated Section 455.227(1) (7), Florida Statutes, py aiding Thanh Tra Nhu Le, an unlicensed person, in obtaining @ Nail Specialist license contrary =o section 477.0265{1) (e), Florida Statutes. COUNT SIXTEEN 9], Petitioner realleges and incorporates by reference the allegations set forth in paragraphs one (1) through forty five (45) ag though fully set forth herein. go, Section 455.227(1) (4), Florida Statutes, states that “aiding, assisting, procuring, employing, oF advising any unlicensed person or entity te practice a profession contrary to this chapter, the chapter regulating the profession, or the rules of the department or the board shall constitute grounds for which the disciplinary actions specified in subsection (2) may be taken.” 93. Based on the foregoing, Respondent violated Section 455.227(1) (4), Florida Statutes, by aiding Huong Thi Nguyen, an unlicensed person, in obtaining a Nail Specialist license contrary to Section 477.0265(1) (e), Florida Statutes. COUNT SEVENTEEN 94, Petitioner realleges and incorporates by reference the allegations get forth in paragraphs one (1) through forty five (45) as though fully set forth herein. 98. Section 455.227(1) (]), Florida Statutes, states that GAOGC\Professions Boards\Cosmetology\AtsLeChea Parson's Law Clerks\Cherisann Granston\Mai, Hug Ngoc 2008-02351 7.AC.das éc/6T Javtd YOO sddd 6pé9oPTpags 45:98 GT ZE:ZTL Otoz 6Z dy Beis “aiding, assisting, procuring, employing, of advising any unlicensed persen or entity te practice 4 profession contrary to this chapter, the chapter regulating the profession, or the rules of the department or the board shall constitete grounds for which the disciplinary actions specified in subsection (2) may be taken.” $6. Based on the foregoing, Respondent violated Section 455,227(1) (4), Florida Statutes, by aiding Chunh K, Tran, an unlicensed person, in obtaining a Nail Specialist license contrary to Section 477.0265(1) (@), Florida Statutes. COUNT EIGHTEEN 97. Petitioner realleges and incorporates by reference the allegations set forth in paragraphs one (1) through forty five (45) as though fully set forth herein. 98. Section 455.227(1) (5), Florida Statutes, states that “siding, assisting, procuring, employing, or advising any unlicensed person or entity te practice a profession contrary to this chapter, the chapter regulating the profession, or the rules of the department or the board shail constitute grounds for which the disciplinary actions specified in subsection (2) may be taken.” 99. Based on the foregoing, Respondent violated Section 455.227(1) (4), Florida Statutes, by aiding Touckay Laochareun, an unlicensed person, in obtaining a Full Specialist license contrary to Section 477.0265(1) (e), Plorids Statutes. GAOGC\Professions Boards\Cosmetology\AC\LeC hea Parson's Law Cletks\Cheri-ann Granston\Mui, Hue Ngoc 2008-023517\AC. doe 17 cefae Fd FOO sda 6pé9oPTpags 45:98 Tee /82/Pa ZE:ZTL Otoz 6Z dy oe /TS “aiding, assisting, procuring, employing, or advising any unlicensed person or entity to practice a profession contrary te this chapter, the chapter regulating the profession, or the rules of the department or the beard shall constitute grounds for which the disciplinary actions specified in subsection (2) may be taken.” 96, Based on the foregoing, Respondent violated Section 455,.227(1) (4), Florida Statutes, by aiding Chunh K. Tran, an unlicensed person, in obtaining a Nail Specialist license contrary to Section 477.0265(1) (@), Florida Statutes. COUNT EIGHTEEN a7. Petitioner realleges and incorporates by reference the allegations set forth an paragraphs one (1) through forty five (45) as though fully set forth herein. 98. Section 455.227(1) (3), Florida Statutes, states that “aiding, assisting, procuring, employing, or advising any unlicensed person or entity te practice a profession contrary to this chapter, the chapter regulating the profession, or the rules of the department or the board shall constitute grounds for which the disciplinary actions specified in subsection (2) may be taken.” 99. Based on the foregoing, Respondent violated Section 455.227(1) (3), Florida Statutes, by aiding Touckay baochareun, an unlicensed person, in obtaining a Full Specialist license contrary to Section 477.0265(1) (e), Florida Statutes. CAOGC\Prafessions Boards\Cusmetology\ACALeChea Parson's Law Clerks\Cherieann Granston\Mai, Hue Ngoc 2008-02351 TAC. doc 1? Fad FOO sda 6pé9oPTpags 45:98 Tee /82/Pa ZE:ZTL Otoz 6Z dy WKERFFORE, Petitioner respectivully requests the Board of Cosmetology enter 4 Final Order imposing one or more of the following penalties: imposition of an administrative fine, revocation or suspension of the Respondent's jicense, issuance of 4 reprimand, placement of the Respondent on probation, restriction of Respondent's practice, and or any other relief which the Board deems appropriate. Signed this 3 day of “VEN id , 2009, CHARLES W. DRAGO, Secretary Department of Business and professional Regulation LeChea Parson Assistant General Counsel Florida Bar No. 0016869 Department of Business and Professional Regulation 1940 North Monroe Street Tallahassee, FPL 32399-2202 Telephone: (850) 410-1537 Facsimile: (850) 414-6749 PCP Date: PCP Members: LP/eag ePo Be: GAOCC\Profeysions Boards\Cosmetology\AC\LeChea Parson's Law Clerks\Cheri-ann Granston\Mai, Hue Ngoc 2008-0235) 7\AC.doe éa/f/ea Fovd YOO sddd 6pé9oPTpags @o:9a Clizl Ol0Z 62 dy Bree reese

Docket for Case No: 10-002380PL