Deputy Agency Clerk. STATE OF FLORIDA vette Lawson-Proctor DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULA’ 40/2014 DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, BOARD OF ARCHITECTURE : AND INTERIOR DESIGN, ~ Petitioner, vs. CASE NO.: 2013-022025 TWENTY FIRST CENTURY ENGINEERING CORP., AND JOHN M. CARROLL, Respondents, / ADMIN. ISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against’ TWENTY FIRST CENTURY ENGINEERING CORP. and JOHN M. CARROLL, (“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 836 Bougainvillea Lane, Vero Beach, FL 32963. 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, On or about October 5, 2011, Respondents entered into a contract with Susan Pedersen to provide architectural documents for her single family residence located in Fort ; Lauderdale, Florida. 6. Respondents’ web site offers architectural services, 7. Respondents’ flyer offers architectural design services. 8. Respondents are not licensed to practice architecture in the State of Florida and therefore cannot offer or provide architectural services. ) COUNT I 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,” 11. 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 IT 12, Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) as if fully set forth herein. 13. Section 481.219(2), Florida Statutes, requires a certificate of authorization for a corporation, partnership, or fictitious name offering architectural services. 14, Based upon the foregoing, the Respondent, Twenty First Century Engineering Corp., 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 relief that the Board is authorized to impose pursuant to Chapters 481 and 455, Florida Statutes, and/or the rules promulgated thereunder. i Signed this 7 + day of A pr . J , 2014, SN) e—_ DAVID K. MINACCI Smith, Thompson, Shaw, Minacci & Coldn, P.A. 3520 Thomasville Road, Fourth Floor Tallahassee, Florida 32309 FL Bar No. 0056774 Ph: (850) 402-1570 Fax: (850) 241-0161 davidm@stslaw.com PCP: April 2, 2014 Rodriguez Shore Costoya

Docket for Case No: 14-002098