STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULA File # DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, BOARD OF ARCHITECTURE AND INTERIOR DESIGN, Petitioner, vs. DBPR Case No.: 2014-023954 NOREEN SACHS, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against NOREEN SACHS, ("Respondent"), and says: 1. Petitioner is the state agency charged with regulating the practice of interior design pursuant to Section 20.165, Florida Statutes, and Chapters 455 and 481, Florida Statutes. 2. Respondent is, and has been at all times material hereto, a licensed interior designer in the State of Florida, having been issued license number ID 4428. 3. Respondent's address of record is 364 Golfview Road, Apt. 508A, North Palm Beach, FL 33408. 4. Section 481.215(3), Florida Statutes, states that no license renewal shall be issued to an architect or an interior designer by the department until the licensee submits proof satisfactory to the department that, during the 2 years prior to application for renewal, the Department of Business anid Professkmal Regulation Deputy Agency Clerk CLERK Evetie Lawson-Proctor Date 2/25/2015 licensee participated per biennium in not less than 20 hours of at least 50 minutes each per biennium of continuing education approved by the board. 5. Respondent renewed her license for the March 1, 2011 though February 28, 2013 biennium. 6. By renewing her license, the Respondent affirmed her compliance with Section 481.215(3), Florida Statutes, and that she had completed twenty hours of continuing education. 7. On or about May 2, 2013 the Respondent was selected to participate in a continuing education random audit to determine compliance with the continuing education requirements for the March 1, 2011 through February 28, 2013, reestablishment period. 8. Respondent has not been able to provide proof of completing twenty hours of continuing education during the period of March 1, 2011 through February 28, 2013. 9. Section 481.2251(1)(g), Florida Statutes, states disciplinary action can be taken for failing to perform any statutory or legal obligation placed upon a licensed interior designer. 10. Based upon the foregoing, Respondent has violated Section 481.2251(1)(g), Florida Statutes by affirming her compliance with the continuing education requirements when she renewed her license, although she had not completed the statutory requirement. WHEREFORE, Petitioner respectfully requests the Board enter an Order imposing one or more of the following penalties: Imposition of probation, reprimand the licensee, revoke, suspend, deny the issuance or renewal of the certificate or registration, require financial restitution to a consumer, impose an administrative fine not to exceed $5,000 per count, require continuing education, 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. -J Signed this_ 22° ~ day of Eskounry , 2015. PCP: February 13, 2015 Hall Shore Costoya Rivers BSP DAVID K. MINACCI Smith, Thompson, Shaw, Minacci & Colon, 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

Docket for Case No: 15-003161PL