FILED Department of Business and Professional Regulation. Deputy Ageney Clerk STATE OF FLORIDA Evelte Lawsen-Proctor DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULA]| pase 9739/2047 Fite # DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, BOARD OF ARCHITECTURE AND INTERIOR DESIGN, — Petitioner, vs. . CASE NO.: 2015-015897 SUINGLIO J. ESPEJO AND, SJE DESIGN & CONSTRUCTION, Respondents. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against SUINGLIO J. ESPEJO and SJE DESIGN & CONSTRUCTION, (“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 48 1.223( 1)(@), Florida Statutes. 3. Respondents’ last known address is 644 Wiley Street, Hollywood, FL 33023. 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, 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 Dan Pacheco to provide architectural services for a restaurant addition. 6. | Respondents held themselves out as architects on their business card. 7. Respondents abandoned the project after being paid $10,000.00. 8. Respondents are not licensed to practice architecture in the State of Florida and therefore cannot provide architectural drawings for a commercial project or use the title architect. 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 IL . 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.” 14. Based upon the foregoing, the Respondents have violated Section 481.223(1}{c), Florida Statutes, by using the name or title “architect”, when they were not the holder of a valid license. 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. Mey + Signed this 29" day of Avyes 2017. S35 po_ DAVID K. MINACCI . Smith, Thompson, Shaw, Minacci, Colén & Power, 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: August 28, 2017 Hail Smith Rodriguez

Docket for Case No: 17-006687