FILED Department of Susiness and Professional Regulation Deputy Agency Clerk CLERK Evette L Proctor Date 8/25/2010 File # STATE OF fri IDAY f° DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION 2010 0; DEPARTMENT OF BUSINESS AND OT yp 2 th PROFESSIONAL REGULATION, BOARD OF ARCHITECTURE Agu Te {OF AND INTERIOR DESIGN, HE ARIN is ive lO- ~q Petitioner, vs. CASE NO.: — 2009-046898 TARLOS & ASSOCIATES, INC., AND CHUNGSUN KANG, Respondents. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against TARLOS & ASSOCIATES, INC. and CHUNGSUN KANG, (“Respondents”), and says: 1. 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 and interior design pursuant to Section 455.228(1), and Section 481.223(1)(a), Florida Statutes. 3. Respondents’ last known address is 17802 Mitchell Narth, Irvine, Ca 92614. 4, At all times material hereto, Respondents were not duly registered or certified to engage in the practice of architecture or interior design pursuant to Chapter 481, Florida Statutes. 5. Respondents entered into a contract with to provide architectural services for a commercial project in Orange County, Florida. 6. Respondents prepared drawings for the project. 7. Respondents than began soliciting Florida licensed architects to sign and seal the drawings. 8. Respondents are not licensed to practice architecture in the State of Florida and therefore cannot offer or provide architectural services for a commercial property. 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.” 1. 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 I 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.” COUNT II 5. Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) as if fully set forth herein. 6. Section 481.219(2), Florida Statutes, requires a certificate of authorization for a corporation, partnership, or fictiious name offering architectural services. 7. Based upon the foregoing, the Respondent, Tarlos & Associates, Inc., 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 455.227(2), Florida Statutes, and/or any other relicf that the Board is authorized to impose pursuant to Chapters 481 and 455, Florida Statutes, and/or the rules promulgated thereunder. q Signed this /7 , day of A “3 ws © , 2010. 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) 241-0161 PCP: August 18, 2010 Radriguez Wirtz Gustafson

Docket for Case No: 10-009435