FILED Geputy Agency Clerk Grandon Nichols 2/16/2010 ee er, STATE Ot ; DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DEPARTMENT OF BUSINESS AND 208 C&T 15 P i239 PROFESSIONAL REGULATION, BOARD OF ARCHITECTURE AND INTERIOR DESIGN, Petitioner, [0 . q Te VS. CASE NO.: 2009-054083 RAJA BUCHANAN AND, BUCHANAN P.E, CONSULTING, ING., Respondents. t i ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Intenor Design against’ RAJA BUCHANAN and BUCHANAN P.E. CONSULTING, INC, (‘Respondents’), and says: 1. Petitioner is the state agency charged with regulating the pracice of architecture and interior design pursuant to Section 20.165, Florida Statutes, and Chapters 45S: 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 1s 619] W. Atlantic Blvd, Suite 2, Margate, Florida 33063 Deparunent of Business and Protesras.ai Hep. 's 4, At all times material hereto, Respondents were not duly registered or certified to engage in the practice of architecture pursuant to Chapter 481, Florida Statutes. 5. Respondents entered into a contract with Southwest Broward Theaters Holdings, LTD, to provide architectural services for a commercial project known as Searfone's Coal Fired Pizza, located in Davie, Fiorida. 6. Respondents prepared the architectural drawings for the proicct ~ On or about September 30, 2009, Respondents signed and sealed the architectural drawings using their professional engineer seal. 8. Respondents are not licensed to practice architecture in the Slaic oF Florida and therefore cannot offer or provide architectural services for a commercial property 9. Petitioner hereby realleges and incorporates paragraphs one (1) through cight (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.” It. 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. . 12. Petitioner hereby realleges and incorporates paragraphs one (1) trough eight (8) as if fully set forth herein. 3, Section 481.223(1)(b), Florida Statutes, states that a person may not knowingly practice interior design, when the person is not then the holder of a valia [cense. ” l4. Based upon the foregoing, the Respondents have violated Section 48) 223¢1 jb), Florida Statutes, by practicing interior design, when they were not the holder of a valid license. COUNT AY 15, Section 481,219(2), Florida Statutes, requires a certificate of authorization for a corporation, partnership, or fictitious name offering archilectural services. 16. Based upon the foregoing, the Respondent, Buchanan PE. Consulting, ine. has violated Section 481.219(2), Florida Statutes, by offering architectural services without a certificate of authorization. WHEREFORE, Petitioner respect ‘ully requests the Board enter an Order imposing an administrative fine not to exceed $5,000 per counl, 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 4 * day of Febres of. 2010 DAVID K MINACCI Smith, Thempson, Shaw & Manausa, PA. 3520 Thomasville Road, Fourth Floor Tallahassee, Florida 32309 FL Bar No. 0056774 Ph: (850) 402-1570 Fax: ($50) 241-0161 PCP: Rodngnez, Wirtz, Gustafson January 27, 2010

Docket for Case No: 10-009676