2023A-03771-CHC-ROC AMENDED Notice of Hearing and packet MAILED

2023A-03771-CHC-ROC · Registrar of Contractors · 2023-11-09

REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA

Anita Lang , Case No. 2023-03771

COMPLAINANT, Docket No. 2023A-03771-CHC-ROC v. AMENDED NOTICE OF HEARING ON CONTESTED Richerson Manufacturing LLC CASE License No. ROC 185976,

RESPONDENT.

This Notice of Hearing is issued under A.R.S. § 41-1092.05(D).

HEARING INFORMATION The hearing is set for:

December 14, 2023 1:00 PM Velva Moses-Thompson Google Meet. A link will be provided directly from The Office of Administrative Hearings. Go to www.azoah.com to request to appear in-person.

If you have requested to appear in-person at the hearing, the hearing will

be held at 1740 W Adams Street, Phoenix, AZ 85007.

You must attend this hearing. This is an adversarial hearing before an administrative law judge, and is conducted in a similar manner as judicial proceedings. Thus, you must be prepared to present evidence, including witness testimony and documents, in support of your case.

STATEMENT OF LEGAL AUTHORITY AND JURISDICTION The State of Arizona has determined that the licensing and regulation of construction contractors is a proper state function, and has vested authority in the Registrar of Contractors

to administer Title 32, Chapter 10 of the Arizona Revised Statutes. A.R.S. §§ 32-1101 et seq.

All hearings for alleged violations of Title 32, Chapter 10 are conducted under Title 41,

Chapter 6, Article 10. A.R.S. § 32-1156.

The statutes and rules governing the hearing can be found at: Arizona Revised Statutes §§ 41-1092 to -1092.12, and Arizona Administrative Code R2-19-101 to -122. PARTICULAR ARIZONA STATUTES AND RULES INVOLVED The statutes and rules the Respondent is alleged to have violated are cited in the complaint and citation, which were served on the Respondent on October 20, 2023.

SHORT AND PLAIN STATEMENT OF THE MATTERS ASSERTED The complaint and citation allege that the Respondent committed the following act(s):

Charge: 1 A.R.S. § 32-1154(A)(3) - R4-9-108(a)

Charge: 2 A.R.S. § 32-1154(A)(22)

THE PARTIES TO THE ADMINISTRATIVE HEARING

Because Respondent is a licensee and is charged with an act(s) or omission(s) that is cause for the suspension or revocation of a license, Respondent is a party to this case and will be a party to the hearing. Because Complainant alleged Respondent committed an act(s) or omission(s) that is cause for the suspension or revocation of a license, Complainant is a party to this case and will be a party to the hearing.

Respondent and Complainant, as the parties to the hearing, will present evidence and

argument to the administrative law judge.

The Registrar’s assigned investigator will appear as a witness at the hearing.

RIGHT TO BE REPRESENTED The parties to the administrative hearing may choose to be represented by an attorney. A.R.S. § 41-1092.07(B). If one of the parties is a company, the company may be represented by an officer or employee if that person satisfies the conditions set forth in A.R.S. § 32- 1156(B).

CHANGE OF ADDRESS Each party must inform the Registrar and the Office of Administrative Hearings of any change of address within five (5) days of the change. A.R.S. § 41-1092.04.

HEARING PROCEDURES AND RULES The administrative hearing will be conducted in accordance with A.R.S. §§ 41-1092 to -1092.12, and A.A.C. R2-19-101 to -122. The parties should review the statutes, rules, and processes governing the administrative hearing. Copies of the statutes, rules, and articles regarding the administrative hearing process can be found at https://www.azoah.com/.

REGISTRAR’S APPEARANCE BY VIDEO CONFERENCE OR TELEPHONE The Registrar’s investigators, employees, and attorneys will appear at the hearing via video conference or telephone unless requested by a party to appear in-person. Requests for the Registrar’s investigators, employees, or attorneys to appear in-person must be filed with the Registrar and the Office of Administrative Hearings no later than seven (7) calendar days prior to the hearing date.

HEARING PACKET In the interests of administrative efficiency, the Registrar compiles and discloses

certain documents to the parties and the Office of Administrative Hearings. These documents

are attached to this Notice of Hearing as the “Hearing Packet.” If any party wishes to submit

additional evidence, they must do so during the hearing after completing a disclosure statement. See “Disclosure Statement” section below. SUBPOENAS FOR TESTIMONY FROM A WITNESS OR DOCUMENTS The parties to the hearing must be prepared to present evidence in support of their

case. If a party wants to obtain testimony from a witness or documents not in the party’s

possession, the party must prepare and file a written subpoena for the Administrative Law

Judge to review and sign, if approved. A.R.S. § 41-1092.07(C). Forms for requesting a

subpoena can be found on the Office of Administrative Hearings’ website at www.azoah.com. The party seeking a subpoena must serve notice on all the parties to the hearing, and on the Registrar. A.R.S. § 41-1092.04.

DISCLOSURE STATEMENT At least seven calendar days before the hearing, each party must prepare and serve a

disclosure statement on all other parties, and file it with the Office of Administrative Hearings.

A.A.C. R4-9-118; A.A.C. R2-19-108. The disclosure statement must include any exhibit the

party will use at the hearing. A party’s failure to timely disclose any witness or exhibit, without good cause, may result in the administrative law judge excluding those witnesses or exhibits from being used at the hearing. A.A.C. R4-9-118(C). A sample disclosure form is available on the Registrar’s website at https://roc.az.gov/content/prehearing-disclosure- statement.

CHANGING THE HEARING DATE

The date of the hearing may only be advanced or delayed on the agreement of the parties or on a showing of good cause. A.R.S. § 41-1092.05(C). The date of the hearing may be changed by filing a written agreement of the parties to change the date of the hearing. The written agreement must be filed with the Office of Administrative Hearings, directed to the assigned Administrative Law Judge, and transmitted to the Registrar and all other parties. The assigned Administrative Law Judge may be found on the Office of Administrative Hearings’ web portal at www.azoah.com If a party would like to move the date of the hearing without agreement of all parties, the party must file a written motion with the Office of Administrative Hearings, directed to the

assigned Administrative Law Judge, and transmit a copy to the Registrar and all other parties.

The motion must state in detail good cause for why the date of the hearing should be advanced

or delayed, and the position of all other parties regarding the advancement or delay.

A party may also file a motion asserting a right to an expedited hearing upon a showing of extraordinary circumstances or the possibility of irreparable harm. A.R.S. § 41-1092.05(E).

RESOLUTION SHORT OF ADJUDICATION

In any case which is resolved or settled by the parties, or which is withdrawn by the

Complainant without objection from Respondent after the Notice of Hearing is issued, the parties must notify the Office of Administrative Hearings of the resolution or settlement. Any such cases will be listed on the Registrar’s website and its records under the category: “Closed Complaints – Resolved/Settled/Withdrawn.” Dated November 13, 2023.

By: /s/ Erika Hoskin Erika Hoskin Legal Secretary Legal Department Arizona Registrar of Contractors Copy mailed via USPS First Class mail November 13, 2023 to:

Respondent(s) Richerson Manufacturing LLC 815 N 52nd St Apt 1270 Phoenix, AZ 85008 Michael S Dulberg Esq

BURCH & CRACCHIOLO P.A. 1850 N. Central Ave Suite 1700 Phoenix, AZ 85014

Complainant(s) Anita Lang 7429 E Lincoln Dr Scottsdale, AZ 85250 Page 6 of 7

Karl Pearson Esq. 4422 N Civic Center Plaza Ste. 101 Scottsdale, AZ 85251

Copy sent electronically this same date to:

Respondent at email address on record with the Registrar Respondent’s Attorney at email address of record with Registrar Complainant at email address on record with the Registrar Complainant’s Attorney at email address of record with Registrar

Case No. 2023-03771 /

Katie Hobbs, Governor Martin Quezada, Director

Hearing Packet FAQ What is the Hearing Packet?

The Hearing Packet is a packet of certain documents collected or issued by the Registrar over the course of its investigation.

Who gets the Hearing Packet?

The Hearing Packet is assembled and distributed to all parties and to the Office of Administrative Hearings (“OAH”) prior to an administrative hearing.

What types of cases does the Registrar prepare a Hearing Packet for?

The Registrar prepares a Hearing Packet for Complainant-Handled Cases and No-Pay Cases. Note: If the Docket Number on the Notice of Hearing contains a “CHC” or “NPC”, your case is a Complainant-Handled Case or a No-Pay Case.

What is in the Hearing Packet?

The Hearing Packet contains essential case-specific documents and at a minimum will include the following documents:

● Original complaint;

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Within AZ 877.692.9762 · Fax 602.542.1599 · roc.az.gov Hearing Packet FAQ

Katie Hobbs, Governor Martin Quezada, Director

● Citation; and ● Answer.

The Hearing Packet will also contain the following documents (if applicable):

● Jobsite inspection notices, notes, and photos; ● Written directives; and ● Compliance inspection notices, notes, and photos.

What if there are documents missing from the Hearing Packet?

If there is any evidence you submitted to the Registrar that are not included in the Hearing Packet it is your responsibility to introduce that evidence at the administrative hearing. Note: The administrative law judge assigned to your case does not have access to the entire Registrar record.

If there is additional evidence you submitted to the Registrar during the investigation that you also want to introduce as evidence during your hearing, it is your responsibility to:

● Properly disclose that evidence to the other party; and ● Introduce the evidence during your hearing.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Within AZ 877.692.9762 · Fax 602.542.1599 · roc.az.gov Hearing Packet FAQ

Katie Hobbs, Governor Martin Quezada, Director

How do I disclose evidence I intend to use at a Hearing?

You must properly disclose any and all documents and witnesses you intend to use at your hearing according to the Registrar’s Prehearing Disclosure Rules. See Arizona Administrative Code Section R4-9-118.

A sample prehearing disclosure form and instructions are provided to the parties by the Registrar.

How do I obtain documents I previously submitted to the Registrar?

If you previously submitted documents to the Registrar and need a copy of these documents, please contact the Registrar’s Legal Department or submit a public records request at https://roc.force.com/AZRoc/s/roc-public-request.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Within AZ 877.692.9762 · Fax 602.542.1599 · roc.az.gov Hearing Packet FAQ

Katie Hobbs, Governor Martín Quezada, Director

Complainant: Anita Lang 7429 E Lincoln Dr Scottsdale, AZ 85250

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Within AZ 877.692.9762 · Fax 602.542.1599 · roc.az.gov C008 05/21 Katie Hobbs, Governor Martín Quezada, Director

Respondent: Richerson Manufacturing LLC DBA: 815 N 52nd St Apt 1270 Phoenix, AZ 85008

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Within AZ 877.692.9762 · Fax 602.542.1599 · roc.az.gov C008 05/21 Katie Hobbs, Governor Martín Quezada, Director

April 6, 2023

Jobsite Inspection Notice Re: Complaint Number 2023-03771

Dear Complainant and Respondent:

A formal complaint has been filed with the Arizona Registrar of Contractors.

A jobsite inspection is scheduled for May 8, 2023 at 9:30 AM. The Complainant is required to be present. The Respondent’s attendance is requested and encouraged. The Registrar encourages both parties to make a good faith effort to resolve this complaint prior to the jobsite inspection.

COMPLAINANT: 1. Under A.R.S. § 32-1155(D)(1), the Respondent must be allowed, upon request, the opportunity to inspect the work complained of within fifteen (15) days of receiving this notice. If Respondent is not provided an opportunity to inspect the work within the fifteen (15) day time period, the Registrar may be prohibited from taking further action on this complaint. 2. The Registrar may also be precluded from taking further action on this complaint, if the work that is the subject of the complaint is subject to neglect, modification, or abnormal use. A.R.S. § 32-1155(D)(2) 3. You must provide safe access to any area to be inspected. If access to a roof or other elevated area is required, you must provide a means to safely access the area (ladder or manlift as appropriate). Additionally, please secure any animals.

RESPONDENT: 1. Enclosed is a copy of the complaint. Under A.R.S. § 32-1155(D) you must be allowed, upon request, the opportunity to inspect the work complained of within fifteen days of the date of receipt of this notice. 2. To assist the assigned investigator in evaluating the merits of the complaint, please submit a response to the enclosed complaint to the assigned investigator prior to the scheduled inspection. 3. If you do not attend the jobsite inspection, your absence may negatively impact the investigation, and your interests. 4. If a building permit(s) was required for this project, please have the building permit information available at the jobsite inspection. If either party needs to reschedule the jobsite inspection, please notify the assigned investigator at least three business days prior to the inspection date to schedule a new date and time. 1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Within AZ 877.692.9762 · Fax 602.542.1599 · roc.az.gov C008 05/21 Katie Hobbs, Governor Martín Quezada, Director

If the parties resolve the complaint prior to the inspection, please notify the assigned investigator in writing and by phone as soon as possible.

Sincerely, Mark Nipp Mark Nipp, Investigator (602) 771-6740 [email redacted] 1700 W Washington St, Suite 105 Phoenix, AZ 85007

CC: Complainant Respondent Complainant Attorney

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Within AZ 877.692.9762 · Fax 602.542.1599 · roc.az.gov C008 05/21 Katie Hobbs, Governor Martín Quezada, Director

A Guide to Jobsite Inspections Purpose of the Jobsite Inspection When the Registrar receives a complaint against a contractor’s license alleging poor workmanship, the Registrar generally schedules a Jobsite Inspection. The Jobsite Inspection serves two purposes: 1. To give the contractor an opportunity to inspect the complaint items; and 2. To give the Registrar an opportunity to determine if the contractor’s work violates Arizona law.

Jobsite Inspection Rights and Responsibilities Access to inspect: The property owner has complete control over who they allow on the property. However, if the Registrar’s investigator or the contractor cannot inspect the work, the Registrar will not move forward with a citation.

Cooperation: Arizona law enables injured parties to seek relief for damages through several paths. When dealing with a licensed contractor, the Registrar of Contractors’ administrative complaint process may serve as one of those possible paths. However, in order to use that path, the Registrar relies on the cooperation of all parties to a complaint.

Minimum workmanship: The Registrar investigates workmanship complaints for compliance with minimum workmanship and professional industry standards. The Registrar does not issue citations for work that meets these standards.

Scope: The scope of the Jobsite Inspection is limited to items listed in the complaint filed with the Registrar’s office. It is the complainant’s responsibility to point out the complaint item(s) and the Investigators role to review the item(s). If the complainant identifies additional workmanship items not listed in the original complaint, they must file an addendum to the complaint. The Registrar’s Investigator may identify additional administrative violations by the contractor (e.g. work performed out of scope of the license and failure to provide a contract that meets requirements set by Arizona law) at the time of the inspection.

The Role of the Investigator At the Jobsite Inspection, the Registrar’s investigator will: ● Only investigate the items listed on the complaint form filed with the Registrar. ● Will gather evidence to make an informed decision about the complaint items.

What to expect after a Jobsite Inspection After doing a Jobsite Inspection, the Registrar’s Investigator will leave the jobsite and review the evidence provided during the inspection. Generally, the investigator does not make any determination at the time of the jobsite inspection regarding whether the allegations listed in the complaint are supported. ● If the allegations are confirmed, the Registrar’s Investigator may issue a Written Directive telling the contractor to correct the poor or incomplete work. ● If the allegations are not confirmed, the Registrar’s Investigator will close the complaint.

Questions? If you have already filed a complaint and it was assigned to an investigator, you are encouraged to contact that investigator directly with the information listed in your jobsite inspection letter. If you have not filed a complaint yet or have not been assigned an investigator, you can reach the Registrar’s compliance department at (877) 692-9762.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Within AZ 877.692.9762 · Fax 602.542.1599 · roc.az.gov C008 05/21 Katie Hobbs, Governor Martín Quezada, Director

A Guide to Written Directives Purpose of the Jobsite Inspection When the Registrar receives a complaint against a contractor’s license, the Registrar generally schedules a Jobsite Inspection. The Jobsite Inspection serves two purposes: 1. To give the contractor an opportunity to inspect the complaint items; and 2. To give the Registrar an opportunity to determine if the contractor’s work violates Arizona law.

What to expect after a Jobsite Inspection After doing a Jobsite Inspection, the Registrar’s Investigator will determine whether the allegations listed in the complaint are supported. ● If the allegations are confirmed, the Registrar’s Investigator may issue a Written Directive telling the contractor to correct the poor or incomplete work. ● If the allegations are not confirmed, the Registrar’s Investigator will close the complaint.

Written Directives Access: In order to use the administrative process offered by the Registrar, a property owner must provide reasonable access to allow the contractor to fix their work as directed by the Registrar in a Written Directive. Complainants may not put any additional, unnecessary restrictions on the Respondent above and beyond the initial contract requirements agreed upon at the beginning of the project. Respondents are required to make repairs on items identified on any Written Directive, not otherwise restricted by local code or HOA limitations. Complainants must make access available to the Respondent to make the required repairs and failure to provide reasonable access may result in the Registrar dismissing the complaint.

Contractor obligations: The Written Directive will set a deadline for compliance. This is the period of time determined by the Investigator as necessary to complete the items listed in the Directive. ● The deadline for compliance assumes the contractor will promptly begin working on the items listed in the Directive. ● Do not wait. Both parties should communicate quickly to schedule the work.

Extensions: If good cause exists to extend this deadline, either party may submit a written request to the Investigator. The Registrar will review requests for extension and determine if the Directive should be extended.

Manner and method of performance: The Registrar does not provide specific instructions for how to correct poor work. A licensed contractor is expected to have the skill and professionalism to complete the work. Moreover, the complainant may not dictate the manner of repair. If the contractor fails to appropriately correct the work according to the contract, the Registrar will issue a citation.

Compliance Inspection: After the Written Directive expires, the Registrar’s Investigator will contact the complainant to determine if the contractor performed any corrective work. ● If the contractor did corrective work, the Investigator may schedule a Compliance Inspection to determine if the poor work is corrected. ● If the contractor did not perform any corrective work, the Registrar’s Investigator will not do a Compliance Inspection and will determine whether to issue a citation based on the administrative record.

Work performed after the directive ends: After the Directive period ends, a property owner may choose to allow the contractor to continue its work. The Registrar encourages parties to work cooperatively, but cannot 1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Within AZ 877.692.9762 · Fax 602.542.1599 · roc.az.gov C008 05/21 Katie Hobbs, Governor Martín Quezada, Director

require a homeowner to continue to allow a contractor access to the property after the Directive period ends in order for the administrative process to continue. Denying access after the Directive ends is not grounds to close or dismiss a complaint.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Within AZ 877.692.9762 · Fax 602.542.1599 · roc.az.gov C008 05/21 Katie Hobbs, Governor Martín Quezada, Director

Complainant’s Attorney: Karl Pearson 4422 N Civic Plaza, Ste 202 Scottsdale, AZ 85251

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Within AZ 877.692.9762 · Fax 602.542.1599 · roc.az.gov C008 05/21 Complaint #2023-03771 P 1 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 2 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 3 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 4 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 5 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 6 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 7 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 8 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 9 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 10 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 11 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 12 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 13 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 14 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 15 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 16 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 17 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 18 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 19 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 20 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 21 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 22 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 23 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 24 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 25 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 26 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 27 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 28 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 29 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 30 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 31 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 32 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 33 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 34 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 35 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 36 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 37 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 38 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 39 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 40 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 41 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 42 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 43 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 44 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 45 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 46 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 47 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 48 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 49 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 50 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 51 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 52 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 53 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 54 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 55 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 56 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 57 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 58 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 59 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 60 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 61 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 62 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Complaint #2023-03771 P 63 JSI Date 5/8/2023 at 9:30 AM JSI PHOTOS Katie Hobbs, Governor Martín Quezada, Director

Complainant: Anita Lang 7429 E Lincoln Dr Scottsdale, AZ 85250

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

Respondent: Richerson Manufacturing LLC DBA: 815 N 52nd St Apt 1270 Phoenix, AZ 85008

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

May 18, 2023

License No. ROC 185976

Re:Complaint No. 2023-03771

WRITTEN DIRECTIVE FROM THE REGISTRAR

Dear Respondent:

After investigation, the Registrar determined that you failed to meet the requirements of A.R.S. § 32-1154(A), and now issues this Directive requiring you to take appropriate corrective action. Failure to comply with this Directive constitutes a violation of A.R.S. § 32-1154(A)(22) and may result in the issuance of a citation, discipline of your license, and a civil penalty pursuant to A.R.S. § 32-1154(E) of up to $500.00. You must notify the Registrar’s assigned Investigator of your compliance with this Directive prior to 5:00 p.m. on June 5, 2023.

RESTRICTIONS  You may not perform or hire other contractors to perform work that is outside the scope of your license.  If your license is currently suspended for administrative reasons1, or is inactive, expired, or cancelled, you may not perform any corrective work nor contract in any manner, which includes hiring other contractors to perform work, until the suspension of your license(s) has been lifted or your license(s) has been reactivated.

DIRECTIVE REQUIREMENTS You are directed to remedy the following violations by the appropriate means:

This means the license is suspended for lack of qualifying party, lack of bond, nonrenewal, Recovery Fund payout, or for any reason listed in A.R.S. § 32-1124(F).

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

ROC Workmanship Standards for Licensed Contractors (June 2009) states, missing or damaged weather stripping is not acceptable. The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference Picture(s) 3-25 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner. Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R4-9-108(B); in part, A contractor shall perform all work in accordance with any applicable building codes and professional industry standards…a contractor shall use such skills, prudence, and diligence in performing and completing tasks… Governing Rule: A.R.S. § 32-1154(A)(1) Abandonment of a contract or refusal to perform after submitting a bid on work without legal excuse for the abandonment or refusal. Compliance Item #3: Steel Windows and Doors - All grills need to be cleaned, touch up finish, and installed at windows. Investigator’s Observation: Verified Both parties agreed that the window ‘grills’ have not been installed and will need to be cleaned/touched up prior to install. I saw the window ‘grills’ were stacked against the side yard fence. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A.R.S. § 32-1154(A)(1) Abandonment of a contract or refusal to perform after submitting a bid on work without legal excuse for the abandonment or refusal. The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference Picture(s) 2,

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner. Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R4-9-108(B); in part, A contractor shall perform all work in accordance with any applicable building codes and professional industry standards…a contractor shall use such skills, prudence, and diligence in performing and completing tasks… Governing Rule: A.R.S. § 32-1154(A)(1) Abandonment of a contract or refusal to perform after submitting a bid on work without legal excuse for the abandonment or refusal. Compliance Item #4: Steel Windows and Doors - Some hinges are missing at doors. Investigator’s Observation: Verified I saw that there were multiple doors where all or part of the weld-on hinges were missing. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A contractor shall perform all work in a professional and workmanlike manner. The contractor should identify all locations where this condition exists and the respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference Picture(s) 26-28 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner. Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R4-9-108(B); in part, A contractor shall perform all work in accordance with any applicable building codes and

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

professional industry standards…a contractor shall use such skills, prudence, and diligence in performing and completing tasks… Governing Rule: A.R.S. § 32-1154(A)(1) Abandonment of a contract or refusal to perform after submitting a bid on work without legal excuse for the abandonment or refusal. Compliance Item #6: Steel Windows and Doors - Many areas that are scuffed and damaged need to be remedied. Investigator’s Observation: Verified Both parties agreed that the windows/doors that have been installed require touch up paint to correct the scuffs/dings/scratches that occurred during installation. I saw the installed windows/doors had various scuffs/dings/scratches throughout the home. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A contractor shall perform all work in a professional and workmanlike manner. The contractor should identify all locations where this condition exists and the respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference Picture(s) 29-38 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner. Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R4-9-108(B); in part, A contractor shall perform all work in accordance with any applicable building codes and professional industry standards…a contractor shall use such skills, prudence, and diligence in performing and completing tasks… Governing Rule: A.R.S. § 32-1154(A)(1) Abandonment of a contract or refusal to perform after submitting a bid on work without legal excuse for the abandonment or refusal.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

Compliance Item #10: Canopy and Awnings - These were not delivered by Richerson Manufacturing; He promised to return the $30,000 deposit. There is a sample of the work incorrectly done that needs to be removed from property. Investigator’s Observation: Verified The canopies have been completed by another contractor. The registrar may not issue a citation for poor workmanship if the contractor’s work has been subject to neglect, modification, or abuse (A.R.S. § 32-1155(D). The awnings have not been installed. Both parties agreed that there was a discrepancy in the prototype delivered by the Respondent. Both parties agree that the Respondent was supposed to install the awnings, once manufacturing was complete. The Respondent should complete the project as agreed. The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference Picture(s) 46-52 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner. Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R4-9-108(B); in part, A contractor shall perform all work in accordance with any applicable building codes and professional industry standards…a contractor shall use such skills, prudence, and diligence in performing and completing tasks… A.R.S. § Governing Rule: 32-1154(A)(1) Abandonment of a contract or refusal to perform after submitting a bid on work without legal excuse for the abandonment or refusal. Compliance Item #11: Lily Pad (Pool Seating) - Requires some touch up on front of metal which was damaged during delivery and installation, wood screws popping on decking.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

Investigator’s Observation: Verified I saw there were wood screw heads raised above the lily pad decking. I also noted there was visible corrosion on the front of the lily pad. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A contractor shall perform all work in a professional and workmanlike manner. Paint should adequately cover the surface. The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference Picture(s) 53-55 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner. Compliance Item #13: Added at Jobsite Inspection with Approval of the Respondent – Great room door sagging Investigator’s Observation: Verified There is a visible sag in the great room doors. The middle of the doors are almost touching the ground while the edges are as much as one inch above the floor. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A contractor shall perform all work in a professional and workmanlike manner. The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference Picture(s) 57-58 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner. Compliance Item #14: Added at Jobsite Inspection with Approval of the Respondent – Pool bath door uneven gaps at top and sides Investigator’s Observation: Verified

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

I saw the door had uneven gaps on the top, bottom, and side. I measured the gaps on the side (left = 3/8 inch and right = ¾ inch. The top of the door had an uneven gap left to right as well. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A contractor shall perform all work in a professional and workmanlike manner. Doors should have a 1/8 inch gap on the top and sides. The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference Picture(s) 59-63 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner.

ITEMS NOT REQUIRING CORRECTION The following complaint items require no action by the Respondent:

Compliance Item #2: Steel Windows and Doors - Windows need appropriate caulking inside and out and correctly applied. Investigator’s Observation: Combined with Compliance Item #1 See Compliance Item #1 Compliance Item #5: Steel Windows and Doors - All doors are missing the mechanical sweep. Investigator’s Observation: DUPLICATE of Complaint Item #1 See Compliance Item #1 Compliance Item #7: Steel Windows and Doors - Door locks missing or locks that are not applied correctly. Investigator’s Observation: Not Verified – Although the conditions described are present, they are not verified as the responsibility of the respondent.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

The Complainant explained that none of the doors/windows had locking devices so she hired another contractor to install temporary locking device. I noted that the locks are unusual (cane bolts) and must be welded onto the door/window frame. The registrar may not issue a citation for poor workmanship if the contractor’s work has been subject to neglect, modification, or abuse (A.R.S. § 32-1155(D). No further action is required. Reference Picture(s) 39 Governing Rule: N/A Compliance Item #8: Steel Windows and Doors - Pivot windows need weatherproofing, handles, locks, and a mechanism to hold open. Investigator’s Observation: Not Verified – Although the conditions described are present, they are not verified as the responsibility of the respondent. The Complainant explained that none of the doors/windows had locking devices so she hired another contractor to install temporary locking device. I noted that the locks are unusual (cane bolts) and must be welded onto the door/window frame. The registrar may not issue a citation for poor workmanship if the contractor’s work has been subject to neglect, modification, or abuse (A.R.S. § 32-1155(D). No further action is required. Reference Picture(s) 39 Governing Rule: N/A Compliance Item #9: Steel Windows and Doors - Missing 11 panes of glass. (We desperately need to secure project) Investigator’s Observation: Not Verified – Although the conditions described are present, they are not verified as the responsibility of the respondent. The Complainant explained that she hired another contractor to install the missing panes of glass. The registrar may not issue a citation for poor workmanship if the

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

contractor’s work has been subject to neglect, modification, or abuse (A.R.S. § 32- 1155(D). No further action is required. Reference Picture(s) 39 Governing Rule: N/A Compliance Item #12: Staircase – Structural Support was poorly installed; missing welds, missing or improper bolts; stairs wobble and not secure. This is holding up project as stair treads and glass cannot be installed and holding up move in Investigator’s Observation: Not Verified – Although the conditions described are present, they are not verified as the responsibility of the respondent. The Complainant explained that she had another contractor correct this item. The registrar may not issue a citation for poor workmanship if the contractor’s work has been subject to neglect, modification, or abuse (A.R.S. § 32-1155(D). No further action is required. Reference Picture(s) N/A Governing Rule: N/A

Please direct all questions regarding this Directive to the undersigned Investigator.

Sincerely,

Mark Nipp Mark Nipp, Investigator 602 7716740 [email redacted] 1700 W Washington St, Suite 105 Phoenix, AZ 85007

CC: Complainant Respondent

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

Jobsite Inspection Notes

Case No.: 2023-03771 Investigator: Mark Nipp Inspection Date: May 8, 2023 Inspection Time: 9:30 AM

Complainant: Anita Lang Respondent: Richerson Not Present: Manufacturing LLC (Steve Richerson) Not Present:

Jobsite General Notes: The Respondent stated that he stopped working on the Complainant’s project because he was losing money, almost losing his business. The Respondent also stated there were personality conflicts with the Complainant.

Compliance Item #1: Steel Windows and Doors - Need appropriate weather proofing at all windows and doors. Windows need appropriate caulking inside and out and correctly applied. Investigator’s Observation: Verified The Respondent agrees that the sealing/weather stripping has not been completed. I saw there was no weather stripping or sealing at the glazed portion of the windows or door stops or thresholds throughout the entire house. ROC Workmanship Standards for Licensed Contractors (June 2009) states, missing or damaged weather stripping is not acceptable. The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference Picture(s) 3-25 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov RCC100 08/19

Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R4-9-108(B); in part, A contractor shall perform all work in accordance with any applicable building codes and professional industry standards…a contractor shall use such skills, prudence, and diligence in performing and completing tasks… Governing Rule: A.R.S. § 32-1154(A)(1) Abandonment of a contract or refusal to perform after submitting a bid on work without legal excuse for the abandonment or refusal. Compliance Item #2: Steel Windows and Doors - Windows need appropriate caulking inside and out and correctly applied. Investigator’s Observation: Combined with Compliance Item #1 See Compliance Item #1 Compliance Item #3: Steel Windows and Doors - All grills need to be cleaned, touch up finish, and installed at windows. Investigator’s Observation: Verified Both parties agreed that the window ‘grills’ have not been installed and will need to be cleaned/touched up prior to install. I saw the window ‘grills’ were stacked against the side yard fence. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A.R.S. § 32-1154(A)(1) Abandonment of a contract or refusal to perform after submitting a bid on work without legal excuse for the abandonment or refusal. The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference Picture(s) 2, Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner. Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R4-9-108(B); in part, A contractor shall perform all work in accordance with any applicable building codes and

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov RCC100 08/19

professional industry standards…a contractor shall use such skills, prudence, and diligence in performing and completing tasks… Governing Rule: A.R.S. § 32-1154(A)(1) Abandonment of a contract or refusal to perform after submitting a bid on work without legal excuse for the abandonment or refusal. Compliance Item #4: Steel Windows and Doors - Some hinges are missing at doors. Investigator’s Observation: Verified I saw that there were multiple doors where all or part of the weld-on hinges were missing. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A contractor shall perform all work in a professional and workmanlike manner. The contractor should identify all locations where this condition exists and the respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference Picture(s) 26-28 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner. Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R4-9-108(B); in part, A contractor shall perform all work in accordance with any applicable building codes and professional industry standards…a contractor shall use such skills, prudence, and diligence in performing and completing tasks… Governing Rule: A.R.S. § 32-1154(A)(1) Abandonment of a contract or refusal to perform after submitting a bid on work without legal excuse for the abandonment or refusal. Compliance Item #5: Steel Windows and Doors - All doors are missing the mechanical sweep. Investigator’s Observation: DUPLICATE of Complaint Item #1 See Compliance Item #1

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov RCC100 08/19

Compliance Item #6: Steel Windows and Doors - Many areas that are scuffed and damaged need to be remedied. Investigator’s Observation: Verified Both parties agreed that the windows/doors that have been installed require touch up paint to correct the scuffs/dings/scratches that occurred during installation. I saw the installed windows/doors had various scuffs/dings/scratches throughout the home. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A contractor shall perform all work in a professional and workmanlike manner. The contractor should identify all locations where this condition exists and the respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference Picture(s) 29-38 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner. Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R4-9-108(B); in part, A contractor shall perform all work in accordance with any applicable building codes and professional industry standards…a contractor shall use such skills, prudence, and diligence in performing and completing tasks… Governing Rule: A.R.S. § 32-1154(A)(1) Abandonment of a contract or refusal to perform after submitting a bid on work without legal excuse for the abandonment or refusal. Compliance Item #7: Steel Windows and Doors - Door locks missing or locks that are not applied correctly. Investigator’s Observation: Not Verified – Although the conditions described are present, they are not verified as the responsibility of the respondent. The Complainant explained that none of the doors/windows had locking devices so she hired another contractor to install temporary locking device.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov RCC100 08/19

I noted that the locks are unusual (cane bolts) and must be welded onto the door/window frame. The registrar may not issue a citation for poor workmanship if the contractor’s work has been subject to neglect, modification, or abuse (A.R.S. § 32-1155(D). No further action is required. Reference Picture(s) 39 Governing Rule: N/A Compliance Item #8: Steel Windows and Doors - Pivot windows need weatherproofing, handles, locks, and a mechanism to hold open. Investigator’s Observation: Not Verified – Although the conditions described are present, they are not verified as the responsibility of the respondent. The Complainant explained that none of the doors/windows had locking devices so she hired another contractor to install temporary locking device. I noted that the locks are unusual (cane bolts) and must be welded onto the door/window frame. The registrar may not issue a citation for poor workmanship if the contractor’s work has been subject to neglect, modification, or abuse (A.R.S. § 32-1155(D). No further action is required. Reference Picture(s) 39 Governing Rule: N/A Compliance Item #9: Steel Windows and Doors - Missing 11 panes of glass. (We desperately need to secure project) Investigator’s Observation: Not Verified – Although the conditions described are present, they are not verified as the responsibility of the respondent. The Complainant explained that she hired another contractor to install the missing panes of glass. The registrar may not issue a citation for poor workmanship if the contractor’s work has been subject to neglect, modification, or abuse (A.R.S. § 32- 1155(D). No further action is required. Reference Picture(s) 39 Governing Rule: N/A

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov RCC100 08/19

I saw there were wood screw heads raised above the lily pad decking. I also noted there was visible corrosion on the front of the lily pad. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A contractor shall perform all work in a professional and workmanlike manner. Paint should adequately cover the surface. The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference Picture(s) 53-55 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner. Compliance Item #12: Staircase – Structural Support was poorly installed; missing welds, missing or improper bolts; stairs wobble and not secure. This is holding up project as stair treads and glass cannot be installed and holding up move in Investigator’s Observation: Not Verified – Although the conditions described are present, they are not verified as the responsibility of the respondent. The Complainant explained that she had another contractor correct this item. The registrar may not issue a citation for poor workmanship if the contractor’s work has been subject to neglect, modification, or abuse (A.R.S. § 32-1155(D). No further action is required. Reference Picture(s) N/A Governing Rule: N/A Compliance Item #13: Added at Jobsite Inspection with Approval of the Respondent – Great room door sagging Investigator’s Observation: Verified There is a visible sag in the great room doors. The middle of the doors are almost touching the ground while the edges are as much as one inch above the floor. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A contractor shall perform all work in a professional and workmanlike manner.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov RCC100 08/19

The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference Picture(s) 57-58 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner. Compliance Item #14: Added at Jobsite Inspection with Approval of the Respondent – Pool bath door uneven gaps at top and sides Investigator’s Observation: Verified I saw the door had uneven gaps on the top, bottom, and side. I measured the gaps on the side (left = 3/8 inch and right = ¾ inch. The top of the door had an uneven gap left to right as well. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A contractor shall perform all work in a professional and workmanlike manner. Doors should have a 1/8 inch gap on the top and sides. The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference Picture(s) 59-63 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov RCC100 08/19

6/1/23, 2:47 PM State of Arizona Mail - Complaint no. 2023-03771

Mark Nipp <[email redacted]>

Complaint no. 2023-03771 messages

Nicholas Cantone <[email redacted]> Thu, Jun 1, 2023 at 10:07 AM To: [email redacted]

Mr. Nipp, I have been informed by my attorney Mike Delbert, that I misinterpreted the June 5 2023 completion date as the start of my work. Mike suggested a possible extension of my completion of the remaining work at the Lang residence. I have to hire new people for this job. Please let me know your decision. Thank you Clyde Steven Richerson.

Sent from my iPhone

Mark Nipp <[email redacted]> Thu, Jun 1, 2023 at 2:47 PM To: Nicholas Cantone <[email redacted]>

I received your voicemail as well as this email requesting an extension. In your voicemail, you asked for a 6-week extension. I am reviewing your request and have an answer for you soon. [Quoted text hidden] --

Regards,

Mark Nipp Investigator #223 Arizona Registrar of Contractors 1700 West Washington St., Ste. 105 Phoenix, AZ 85007 Work Phone: (602) 771-6740 E-mail: [email redacted]

Fill out AZ ROC’s survey to let us know how we’re doing and how we can better serve you!

Fill out AZ ROC's survey to let us know how we're doing and how we can better serve you!

CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message.

https://mail.google.com/mail/u/0/?ik=6b738c81a6&view=pt&search=all&permthid=thread-f:[number redacted]&simpl=msg-f:[number redacted]… 1/1 Katie Hobbs, Governor Martín Quezada, Director

Complainant: Anita Lang 7429 E Lincoln Dr Scottsdale, AZ 85250

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

Respondent: Richerson Manufacturing LLC DBA: 815 N 52nd St Apt 1270 Phoenix, AZ 85008

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

June 08, 2023

License No. ROC 185976

Re:Complaint No. 2023-03771

WRITTEN DIRECTIVE FROM THE REGISTRAR - AMENDED

Dear Respondent:

DIRECTIVE REQUIREMENTS You are directed to remedy the following violations by the appropriate means:

This means the license is suspended for lack of qualifying party, lack of bond, nonrenewal, Recovery Fund payout, or for any reason listed in A.R.S. § 32-1124(F).

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

ITEMS NOT REQUIRING CORRECTION The following complaint items require no action by the Respondent:

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

Please direct all questions regarding this Directive to the undersigned Investigator.

Sincerely,

Mark Nipp Mark Nipp, Investigator 602 7716740 [email redacted] 1700 W Washington St, Suite 105 Phoenix, AZ 85007

CC: Complainant Respondent

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

Complainant: Anita Lang 7429 E Lincoln Dr Scottsdale, AZ 85250

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

Respondent: Richerson Manufacturing LLC DBA: 815 N 52nd St Apt 1270 Phoenix, AZ 85008

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

July, 13 2023

License No. ROC 185976

Re:Complaint No. 2023-03771

WRITTEN DIRECTIVE FROM THE REGISTRAR - AMENDED

Dear Respondent:

DIRECTIVE REQUIREMENTS You are directed to remedy the following violations by the appropriate means:

This means the license is suspended for lack of qualifying party, lack of bond, nonrenewal, Recovery Fund payout, or for any reason listed in A.R.S. § 32-1124(F).

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

ITEMS NOT REQUIRING CORRECTION The following complaint items require no action by the Respondent:

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

Please direct all questions regarding this Directive to the undersigned Investigator.

Sincerely,

Mark Nipp Mark Nipp, Investigator 602 7716740 [email redacted] 1700 W Washington St, Suite 105 Phoenix, AZ 85007

CC: Complainant Respondent

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

Complainant: Anita Lang 7429 E Lincoln Dr Scottsdale, AZ 85250

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

Respondent: Richerson Manufacturing LLC 815 N 52nd St Apt 1270 Phoenix, AZ 85008

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

August 3, 2023

License No. ROC 185976

Re:Complaint No. 2023-03771

WRITTEN DIRECTIVE FROM THE REGISTRAR - AMENDED

Dear Respondent:

DIRECTIVE REQUIREMENTS You are directed to remedy the following violations by the appropriate means:

This means the license is suspended for lack of qualifying party, lack of bond, nonrenewal, Recovery Fund payout, or for any reason listed in A.R.S. § 32-1124(F).

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

ITEMS NOT REQUIRING CORRECTION The following complaint items require no action by the Respondent:

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Katie Hobbs, Governor Martín Quezada, Director

Please direct all questions regarding this Directive to the undersigned Investigator.

Sincerely,

Mark Nipp Mark Nipp, Investigator 602 7716740 [email redacted] 1700 W Washington St, Suite 105 Phoenix, AZ 85007

CC: Complainant Respondent

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Complainant: Anita Lang 7429 E Lincoln Dr. Scottsdale, AZ 85250

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 4/21 Respondent: Richerson Manufacturing LLC 815 N 52nd St Apt 1270 Phoenix, AZ 85008

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 4/21 Case No.: 2023-03771 Investigator: Mark Nipp Inspection Date: October 11, 2023 Inspection Time: 11:00 AM

Compliance Jobsite General Notes: All parties were present at the Compliance Jobsite Inspection. All parties agreed that the work was not complete or the corrective work required corrections.

Compliance Findings:

Compliance Item #1: Steel Windows and Doors - Need appropriate weather proofing at all windows and doors. Windows need appropriate caulking inside and out and correctly applied. Investigator’s Observation: Verified Compliance Jobsite Inspection Conducted on 10/11/2023 @ 11:00 AM Both parties agreed that the weather-stripping and caulking was partially complete and that some of the completed corrective work required further work. I saw the weather-stripping and caulking was partially complete. I saw there were still minor corrections to be made on the work that had been completed.

Jobsite Inspection Conducted on 05/08/2023 @ 09:30 AM: The Respondent agrees that the sealing/weather stripping has not been completed. I saw there was no weather stripping or sealing at the glazed portion of the windows or door stops or thresholds throughout the entire house. ROC Workmanship Standards for Licensed Contractors (June 2009) states, missing or damaged weather stripping is not acceptable. The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference JSI Picture(s) 3-25 Reference CJSI Picture(s) 2-12

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 4/21 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner.

Compliance Item #3: Steel Windows and Doors - All grills need to be cleaned, touch up finish, and installed at windows. Investigator’s Observation: Verified Compliance Jobsite Inspection Conducted on 10/11/2023 @ 11:00 AM Both parties agreed some of the window grills are ill-fitting and need touch up paint. I saw that there were 3-4 window grills that were ill-fitting with gaps over ¼ inch. I also saw that some of the window grills had areas of inadequate paint coverage.

Jobsite Inspection Conducted on 05/08/2023 @ 09:30 AM: Both parties agreed that the window ‘grills’ have not been installed and will need to be cleaned/touched up prior to install. I saw the window ‘grills’ were stacked against the side yard fence. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A.R.S. § 32- 1154(A)(1) Abandonment of a contract or refusal to perform after submitting a bid on work without legal excuse for the abandonment or refusal. The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference JSI Picture(s) 2, Reference CJSI Picture(s) 13-14 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner.

Compliance Item #4: Steel Windows and Doors - Some hinges are missing at doors. Investigator’s Observation: Corrected by the Respondent

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 4/21 Compliance Jobsite Inspection Conducted on 10/11/2023 @ 11:00 AM Both parties agreed this compliance item has been corrected by the Respondent and the Complainant is satisfied with the work.

Jobsite Inspection Conducted on 05/08/2023 @ 09:30 AM: I saw that there were multiple doors where all or part of the weld-on hinges were missing. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A contractor shall perform all work in a professional and workmanlike manner. The contractor should identify all locations where this condition exists and the respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference JSI Picture(s) 26-28 Reference CJSI Picture(s) N/A Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner.

Compliance Item #6: Steel Windows and Doors - Many areas that are scuffed and damaged need to be remedied. Investigator’s Observation: Verified Compliance Jobsite Inspection Conducted on 10/11/2023 @ 11:00 AM Both parties agreed that there is minor paint touch up required throughout the project. I saw that there was visible rust and areas that had inadequate paint throughout the project. This is something that would normally be completed at the end of the project.

Jobsite Inspection Conducted on 05/08/2023 @ 09:30 AM: Both parties agreed that the windows/doors that have been installed require touch up paint to correct the scuffs/dings/scratches that occurred during installation.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 4/21 I saw the installed windows/doors had various scuffs/dings/scratches throughout the home. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A contractor shall perform all work in a professional and workmanlike manner. The contractor should identify all locations where this condition exists and the respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference JSI Picture(s) 29-38 Reference CJSI Picture(s) 13 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner.

Jobsite Inspection Conducted on 05/08/2023 @ 09:30 AM: The canopies have been completed by another contractor. The registrar may not issue a citation for poor workmanship if the contractor’s work has been subject to neglect, modification, or abuse (A.R.S. § 32-1155(D). The awnings have not been installed. Both parties agreed that there was a discrepancy in the prototype delivered by the Respondent. Both parties agree that the Respondent was supposed to install the awnings, once manufacturing was complete. The Respondent should complete the project as agreed.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 4/21 The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference JSI Picture(s) 46-52 Reference CJSI Picture(s) N/A Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner.

Compliance Item #11: Lily Pad (Pool Seating) - Requires some touch up on front of metal which was damaged during delivery and installation, wood screws popping on decking. Investigator’s Observation: Corrected by the Respondent Compliance Jobsite Inspection Conducted on 10/11/2023 @ 11:00 AM Both parties agreed this compliance item has been corrected by the Respondent and the Complainant is satisfied with the work.

Jobsite Inspection Conducted on 05/08/2023 @ 09:30 AM: I saw there were wood screw heads raised above the lily pad decking. I also noted there was visible corrosion on the front of the lily pad. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A contractor shall perform all work in a professional and workmanlike manner. Paint should adequately cover the surface. The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference JSI Picture(s) 53-55 Reference CJSI Picture(s) N/A Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 4/21 Compliance Item #13: Added at Jobsite Inspection with Approval of the Respondent – Great room door sagging Investigator’s Observation: Corrected by the Respondent Compliance Jobsite Inspection Conducted on 10/11/2023 @ 11:00 AM Both parties agreed this compliance item has been corrected by the Respondent and the Complainant is satisfied with the work.

Jobsite Inspection Conducted on 05/08/2023 @ 09:30 AM: There is a visible sag in the great room doors. The middle of the doors are almost touching the ground while the edges are as much as one inch above the floor. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A contractor shall perform all work in a professional and workmanlike manner. The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference JSI Picture(s) 57-58 Reference CJSI Picture(s) N/A Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner.

Compliance Item #14: Added at Jobsite Inspection with Approval of the Respondent – Pool bath door uneven gaps at top and sides Investigator’s Observation: Verified Compliance Jobsite Inspection Conducted on 10/11/2023 @ 11:00 AM Both parties agreed that there had been no change to this compliance item. I saw that the door had uneven gaps on the top, bottom, and sides. The gaps measured the same as at the Jobsite Inspection.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 4/21 Jobsite Inspection Conducted on 05/08/2023 @ 09:30 AM: I saw the door had uneven gaps on the top, bottom, and side. I measured the gaps on the side (left = 3/8 inch and right = ¾ inch. The top of the door had an uneven gap left to right as well. ROC Workmanship Standards for Licensed Contractors (June 2009) states, A contractor shall perform all work in a professional and workmanlike manner. Doors should have a 1/8 inch gap on the top and sides. The respondent should correct by appropriate means, pursuant to the contract, applicable building codes, and within the scope of their license. Reference JSI Picture(s) 59-63 Reference CJSI Picture(s) 15 Governing Rule: A.R.S. § 32-1154(A)(3); Violation of any rule adopted by the registrar; Namely R 4-9-108(a): A contractor shall perform work in a professional and workmanlike manner.

Note: Please review the complaint items listed above. If any of the items have not been corrected at the time of the compliance inspection this complaint will be forwarded to the Registrar’s legal department and a citation may be issued.

If all items are corrected after receipt of this letter, please notify the Registrar’s legal department by sending a notice of compliance signed by the complainant to fax number (602) 364-0416 or by mail to: Arizona Registrar of Contractors, P.O. Box 18244, Phoenix, Arizona 85005-8244. Sincerely,

Mark Nipp Mark Nipp, Investigator 602 7716740 [email redacted] 1700 W Washington St, Suite 105 Phoenix, AZ 85007

CC: Complainant Respondent Complainant Attorney 1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 4/21 Complainant Attorney: Karl Pearson 4422 N Civic Plaza, Ste. 202 Scottsdale, AZ 85251

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 4/21 REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA

Anita Lang, Case No. 2023-03771 COMPLAINANT, v. Richerson Manufacturing LLC CITATION License No. ROC 185976,

RESPONDENT.

The Registrar issues this Citation to Richerson Manufacturing LLC (“Respondent”) under A.R.S. § 32-1155(A). If Respondent fails to answer this Citation by November 4, 2023, then under A.R.S. § 32-1155(C), Respondent’s failure to answer may be deemed an admission of the act or acts charged in the underlying complaint, and the Registrar may then suspend or revoke Respondent’s license(s). THE WRITTEN COMPLAINT On March 30, 2023, Anita Lang (“Complainant”) filed a written complaint with the Registrar. A copy of that Complaint is attached to this Citation. A FORMAL STATEMENT OF THE CHARGES AGAINST RESPONDENT The Registrar investigated this matter and finds cause to charge Respondent with violation(s) of Title 32, Chapter 10 of the Arizona Revised Statutes. Respondent is charged with violating: Charge :1 A.R.S. § 32-1154(A)(3) - R4-9-108(a) Violation of any rule adopted by the Registrar; Namely A.A.C. R4-9-108(a): A contractor shall perform all work in a professional and workmanlike manner. of 5

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg101 8/21 Charge :2 A.R.S. § 32-1154(A)(22) Failure to take appropriate corrective action to comply with this chapter or with rules adopted pursuant to this chapter without valid justification within a reasonable period of time after receiving a written directive from the Registrar. The written directive shall set forth the time within which the contractor is to complete the remedial action. The time permitted for compliance shall not be less than fifteen days from the date of issuance of the directive. A license shall not be revoked or suspended nor shall any other penalty be imposed for a violation of this paragraph until after a hearing has been held.

If the matter proceeds to a hearing and the administrative law judge determines that any of the charges listed above are supported by a preponderance of the evidence, then Respondent’s license(s) may be subject to suspension or revocation, and Respondent may be subject to other penalties provided by law, including civil penalties under A.R.S. §§ 32-1154(E) and (F). FILING A WRITTEN ANSWER Respondent must appear by filing with the Registrar a written answer to the citation and complaint showing cause, if any, why Respondent’s license(s) should not be suspended or revoked. A.R.S. § 32-1155(A). Respondent’s written answer should contain the heading “Written Answer to Citation and Complaint” and should include the case number, which is Case No. 2023-03771. How to File a Written Answer: Respondent’s written answer may be submitted in the following ways: In-Person: 1700 W. Washington St., Ste. 105, Phoenix, Arizona, 85007-2812 Mail: P.O. Box 18244, Phoenix, Arizona, 85005-8244 Email: [email redacted] of 5

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg101 8/21 The Registrar’s normal office hours are 8:00 a.m. to 5:00 p.m., Monday through Friday. If Respondent submits a written answer by mail, it is not filed with the Registrar until the Registrar actually receives it. Deadline for Filing a Written Answer: Respondent must file a written answer with the Registrar no later than November 4, 2023. This deadline is calculated under A.R.S. §§ 32-1155(A) and (B), which provides a deadline ten days after service of the Citation. Service of the Citation and Complaint is complete five days after the Registrar mails a copy of the Citation and Complaint to Respondent’s latest address of record in the Registrar’s office. Consequences for Failing to File a Written Answer: If Respondent fails to answer, Respondent’s failure may be deemed an admission of the act or acts charged in the written complaint. A.R.S. § 32-1155(C). The Registrar may then suspend or revoke Respondent’s license(s). THE ADMINISTRATIVE HEARING If Respondent files a timely written answer contesting any charges in the Complaint, then the Registrar will request the Office of Administrative Hearings set a date for an administrative hearing and will notify all the parties at least 30 days before that hearing. A.R.S. § 41-1092.05(D). INVESTIGATOR’S APPEARANCE AS A WITNESS The Registrar’s assigned investigator will appear as a witness at the hearing. If either party demands the attendance at the hearing of any other person, that party must obtain and serve a subpoena in compliance with the rules and processes established by the Office of Administrative Hearings. RESPONDENT’S RIGHT TO REQUEST AN INFORMAL SETTLEMENT CONFERENCE Under A.R.S. § 41-1092.06, if Respondent submits a request to the Registrar for an of 5

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg101 8/21 informal settlement conference, the Registrar must hold a conference within 15 days after receiving the request. Respondent’s request for an informal settlement conference must be in writing and must be filed no later than 20 days before the administrative hearing. A.R.S. § 41- 1092.06(A). The Registrar will not close or settle any case without both parties’ appearance at the Settlement Conference. The parties participating in the settlement conference must have the authority to settle the case and must waive their right to object to the participation of the Registrar’s settlement conference representative in the final administrative decision. A.R.S. § 41-1092.06(B). Any statements, either written or oral, made by the parties at the conference, including a written document, created or expressed solely for the purpose of settlement negotiations, are inadmissible in the administrative hearing. A.R.S. § 41-1092.06(B). RESPONDENT’S PRIOR RECORD Under A.A.C. R4-9-117, in determining the appropriate discipline, the administrative law judge and the Registrar may consider not only facts in the current case, but also facts in prior cases and any documents regarding Respondent on file with the Registrar. Respondent’s prior disciplinary record and current license(s) status may be considered as a mitigating or aggravating factor in determining the appropriate discipline. EVIDENTIARY DISCLAIMER By issuing this Citation, the Registrar is directing Respondent to file a written answer to the Citation and Complaint, showing cause, if any, why Respondent’s license(s) should not be suspended or revoked. A.R.S. § 32-1155(A). This Citation does not constitute proof that any charge or allegation in Complainant’s written complaint is in fact true. This Citation does not constitute proof that Respondent violated any statutory provision or rule adopted by the Registrar. of 5

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg101 8/21 Dated October 20, 2023. By: /s/ Tedi Quezada Tedi Quezada Legal Assistant Legal Department Arizona Registrar of Contractors COPY of the foregoing mailed by Certified Mail, Return Receipt Requested, October 20, 2023 to:

Respondent Certified Mail No: [number redacted]

Richerson Manufacturing LLC 815 N 52nd St Apt 1270 Phoenix, AZ 85008-6734 Copy mailed by USPS First Class mail this same date to:

Respondent Richerson Manufacturing LLC 815 N 52nd St Apt 1270 Phoenix, AZ 85008-6734

Complainant Anita Lang 7429 E Lincoln Dr. Scottsdale, AZ 85250

Complainant’s Attorney Karl Pearson Esq. Pearson Law PLC 4422 N Civic Center Plaza Ste. 101 Scottsdale, AZ 85251 Copy sent electronically this same date to:

Respondent at email address on record with the Registrar Complainant at email address on record with the Registrar Complainant’s Attorney at email address of record with Registrar of 5

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg101 8/21 Licensed Complaint Form Departmental Use Only For Current or Suspended Licensees

Person Filing Complaint Full Name (First Middle Last) Business Name (if a licensed contractor or supplier) ROC License Number(s) (if any)

Anita Lang Mailing Address (Enter jobsite in Contract/Project section) City State Zip

7429 E Lincoln Dr Scottsdale Arizona 85250 Phone Number Email

480-970-8979 [email redacted] I consent to receive communications electronically in connection with this case Name of Attorney (if any)

Karl Pearson Street Address of Attorney City State Zip

4422 N Civic Plaza Ste 202 Socttsdale Arizona 85251 Phone Number of Attorney Email of Attorney

480-820-1800 [email redacted] Contractor Information Name (as shown on contract/invoice) ROC License Number(s)

Richerson Manufacturing LLC ROC 185976 Street Address City State Zip

3316 E Washington St Phoenix Arizona 85034 Phone Number Email

602-301-6588 Name of Person(s) Representing License

Steve Richerson Contract/Project Information Contract Date Contract Amount Amount Paid

September 1, 2021 $257,760.55 $208,406.25 Date Work Started Date Work Stopped Date Work Was Completed

September 15, 2021 March 11, 2023 Close of Escrow (New Home) Move-In Date (New-Home)

Jobsite Street Address City State Zip

7429 E Lincoln Dr Scottsdale AZ 85250 Name of Construction Site Owner Construction Site Name (if applicable)

Phone Number of Construction Site Owner Email of Construction Site Owner

480-229-1725 [email redacted] This complaint is for Abandonment;Poor Work I have contacted the contractor by Phone/Text;Letter Have you filed a complaint in court? No

RCC099 12/05/18 Page 1 of 2 Licensed Complaint Form Departmental Use Only For Current or Suspended Licensees

Has any work been corrected? No

The contract was Oral All change orders were Written This project was Residential This project involved Remodel

A building permit was obtained by Contractor 276973 Scottsdale List and briefly describe each complaint item (Please do not write "see attached" or use additional pages unless necessary to further describe issues or list more complaint items) (limited to 100 characters per line)

Steel Windows and Doors Need appropriate weather proofing at all windows and doors. Windows need appropriate caulking inside and out and correctly applied. All grills need to be cleaned, touch up finish, and installed at windows. Some hinges are missing at doors. All doors are missing the mechanical sweep. Many areas that are scuffed and damaged need to be remedied. Door locks missing or locks that are not applied correctly. Pivot windows need weatherproofing, handles, locks, and a mechanism to hold open. Missing 11 panes of glass. (We desperately need to secure project) Canopy and Awnings These were not delivered by Richerson Manufacturing; He promised to return the $30,000 deposit. There is a sample of the work incorrectly done that needs to be removed from property. Lily Pad (Pool Seating) Requires some touch up on front of metal which was damaged during delivery and installation, wood screws popping on decking. Staircase – Structural Support Was poorly installed; missing welds, missing or improper bolts; stairs wobble and not secure. This is holding up project as stair treads and glass cannot be installed and holding up move in

Signature I declare under penalty of perjury that the information and documents contained on this Complaint Form, included with this complaint, or hereafter submitted in support of this complaint are true and accurate to the best of my knowledge. I will assist in the investigation or in the prosecution of the contractor or other parties, and will, if necessary, attend hearings and testify to facts. Printed Name Signature Date

Anita Lang \complainant1\ \complainantd1\

RCC099 12/05/18 Page 2 of 2 4422 N Civic Center Plaza, Ste 202 Scottsdale, AZ 85251 Phone: (480) 820-1800 Fax: (480) 707-5011 [email redacted]

October 20, 2023

Via Hand-Delivery

Mr. Steve Richerson Richerson Manufacturing, LLC 3316 E. Washington St Phoenix, AZ 85034

Mr. Steve Richerson Richerson Manufacturing, LLC 815 N. 52nd St., Apt 1270 Phoenix, AZ 85008

Re: Anita Lang 7429 E. Lincoln Drive

Dear Mr. Richerson:

To date, RM has been paid a total $201,406.25, but the job has suffered from endless delays and is far from complete. Ms. Lang has made numerous payments after you promised to finish the job promptly. Unfortunately, you have chosen to devote your attention to other jobs rather than complete work at the Residence.

In early December, Ms. Lang provided you with a list of open items and you agreed to dedicate your full resources to complete the job. Ms. Lang paid an additional $7,000 to RM in reliance on this promise. Once again, however, RM has failed to dedicate meaningful resources to finish the job. The delay is holding up other work on the Residence.

Therefore, on behalf of Ms. Lang, we hereby demand that RM complete the window related items and the Lily Pad by the end of January. I am attaching a punch list Mr. Steve Richerson Richerson Manufacturing, LLC January 20, 2023

______________________________

with the open items. In addition, we demand that you unequivocally commit to installing the awnings and canopies by the end of February. Upon completion of all items and providing lien releases from all suppliers, Ms. Lang will pay the remaining balance of $___________.

In the event you refuse to commit to the timely completion of the remaining work, we demand that you return the deposits for the items not started such as the canopies. Ms. Lang will then hire another metal fabricator and deduct the cost for completion from any amount you claim is owed. If the cost of completion exceeds your bill, you will be responsible for such amounts.

Please respond on or before Wednesday, January 25, 2023. In the event you refuse Ms. Lang’s demands, Ms. Lang reserves all legal rights including filing a lawsuit or a complaint with the Arizona Registrar of Contractors.

Very truly yours,

PEARSON LAW, PLC

/s/ Karl S. Pearson Karl S. Pearson, Esq.

Enclosures 4422 N Civic Center Plaza, Ste 202 Scottsdale, AZ 85251 Phone: (480) 820-1800 Fax: (480) 707-5011 [email redacted]

October 20, 2023

Via Hand-Delivery

Mr. Steve Richerson Richerson Manufacturing, LLC 3316 E. Washington St Phoenix, AZ 85034

Mr. Steve Richerson Richerson Manufacturing, LLC 815 N. 52nd St., Apt 1270 Phoenix, AZ 85008

Re: Anita Lang 7429 E. Lincoln Drive

Dear Mr. Richerson:

This law firm represents Anita Lang who is the owner of the residence located at 7429 E. Lincoln Drive, Scottsdale, AZ 85250 (the “Residence”). In December 2021, Ms. Lang contracted with Richerson Manufacturing, LLC (“RM”) to provide metal work at the Residence including the fabrication and installation of custom windows and awnings. Ms. Lang has previously attempted to work with you to complete the Project, but her efforts have been to no avail. She has been left with no choice but to retain counsel to assist in securing performance of the contract.

You previously committed to finish the project in October, only to make excuses. In early December, Ms. Lang provided you with a list of open items and you agreed to dedicate your full resources to complete the job. Ms. Lang paid an additional $7,000 to RM in reliance on this promise. Once again, however, RM has failed to dedicate meaningful resources to finish the job. The delay is holding up other work on the Mr. Steve Richerson Richerson Manufacturing, LLC January 20, 2023

______________________________

Residence. Other contractors are not able to complete their work due to the delays. Furthermore, the project has been left vulnerable to the elements as the windows have not been weather proofed.

Therefore, on behalf of Ms. Lang, we hereby demand that RM complete the window related items and the Lily Pad by the end of January. I am attaching a punch list with the open items. In addition, we demand that you unequivocally commit to installing the awnings and canopies by the end of February. Upon completion of all items and providing lien releases from all suppliers, Ms. Lang will pay the remaining balance.

Our goal and intention is to resolve this matter amicably. To that end, we would appreciate an affirmative response on or before Wednesday, January 25, 2023. However, in the event you will not commit to her requests, Ms. Lang reserves all legal rights including filing a lawsuit or a complaint with the Arizona Registrar of Contractors.

Very truly yours,

PEARSON LAW, PLC

/s/ Karl S. Pearson Karl S. Pearson, Esq.

Enclosures Writen Statement by Anita Lang

I entered into an agreement with Steve Richerson, owner of Richerson Manufacturing on 9/15/21. He was referred to me by an acquaintance that had used Richerson for some doors on his home and metal work in his oﬃce building. Steve is very old school and didn’t have an email and limited use of technology. He would use an acquaintance’s email but seemed to have a working knowledge of metal fabrica�on.

I paid deposits over the period of working with him for the windows and doors, awnings & canopies, stair support structure, and lily pad (pool sea�ng).

He did not provide a contract but would start his process with a handwriten es�mate that I then would approve. O�en that es�mate would be turned into an invoice by a person named Chad who I have not met and sent to us. However, at �mes items the invoice include items discussed but not approved. This part has not been an issue as Steve would just note that he knew that and would move forward accordingly.

I would only provide deposits for work that was approved, and we were moving forward with that item. As work progressed Steve would ask for a progress payment which I would provide. I would issue a check and he would always collect in person. Towards the end, Steve would request a payment, but the work was not yet completed or there were issues with the work that needed repair.

The process would be as such; I would provide concept drawings that would reﬂect the goals. Steve would then do hand drawn sketches for approval which he would base on site measures. This seemed to work in the beginning. When items were made wrong based on some measuring or other internal mistake, he would ﬁx his work. This happened on several occasions, but he would ﬁx the issue ﬁrst.

The general contractor also has a list of issues that have been caused by the Richerson team and in the end sincerely asked me to ﬁnd another op�on as the situa�on with Richerson has been very detrimental to the project with monies spent to correct work, and �me delays.

On December 9th, I sat down with Steve and provided a recap of all the invoices approved with the balances due. I proposed the payments that would be provided as he completed each part. (this doc is included) He agreed to this and promised to ﬁnish the work.

When I was not able to have Steve keep his commitments, I engaged an atorney to sit with us to come to an agreement. Steve had promised to complete the outstanding items per the due date of Feb 28,2023 yet again he has failed to do so. (this leter form the atorney is also included)

As of March 11th, no one from his team has been at the job site and it appears he has abandoned the project and has not returned calls.

Steve agreed to return the $30,000 deposit I had provided for the awnings and the canopy since this work had not been completed in any meaningful fashion. He had promised this several �mes but has not returned the deposit. I have retained another metal fabricator for this por�on who is comple�ng the work and need this returned immediately.

I would then like Steve to correct the issues on the project as quickly as possible or to refund my monies to the extent that I can hire another fabricator that can do so. Received 10/31/2023 ROC Legal Received 10/31/2023 ROC Legal Received 10/31/2023 ROC Legal Received 11/1/23, 8:02 AM State of Arizona Mail - Anita Lang v. Richerson Manufacturing, LLC 10/31/2023 ROC Legal

Answers - AZROC <[email redacted]>

Anita Lang v. Richerson Manufacturing, LLC message

Stacey Doran <[email redacted]> Tue, Oct 31, 2023 at 11:52 AM To: "[email redacted]" <[email redacted]> Cc: Mike Dulberg <[email redacted]>

Good afternoon,

Please find attached Respondent’s Written Answer to Citation & Motion to Dismiss.

Thank you,

Stacey Doran Legal Assistant to Amy D. Howland, Michael Dulberg & Casey S. Blais

602-234-8732 Direct | 602-344-3732 Fax

[email redacted]

Burch & Cracchiolo, P.A.

1850 N. Central Ave., Ste. 1700, Phoenix, AZ 85004

Respondent's Written Answer to Citation & Motion to Dismiss.pdf 561K

https://mail.google.com/mail/b/AEoRXRSvGbDkdUXt5A5lq56kaKJbskwH7BezHSCPbG-zjqHbe4WJ/u/0/?ik=581c53cf5c&view=pt&search=all&permth… 1/1 Mediation Notice

Mediation Services Mediation services are available to the parties. What is Mediation? Mediation is a method of resolving disputes where the parties can end conflict without the expense and time associated with the full administrative process. Who Participates in During mediation, a mediator will attempt to help the Mediation? parties find an optimal solution to the conflict. Both parties must agree to participate in mediation, and both parties must bring a representative to mediation that has full authority to settle the entire matter. Mediation Is Not Neither the Registrar nor the Office of Administrative Mandatory Hearings will penalize a party for not agreeing to mediation. Where do the Parties The parties will meet at the Office of Administrative Meet for Mediation? Hearings to participate in mediation.

The Office of Administrative Hearings is located at 1400 West Washington, Suite 101, Phoenix, Arizona 85007. When does Mediation can occur after the Registrar issues a citation, but Mediation Occur? before the administrative hearing. Why Should Parties Mediation can be an alternative to the full administrative Consider Mediation? process. Mediation is beneficial because it is (1) time- efficient, (2) cost-effective, (3) confidential, and (4) capable of providing flexible solutions to complex problems. How to Request If the parties wish to mediate this case, they must file a Joint Mediation Request for Mediation with the Office of Administrative Hearings. A Joint Request for Mediation is included with this Mediation Notice. REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA _________________________ Case No. _______________ COMPLAINANT,

v. JOINT REQUEST FOR MEDIATION _________________________ RESPONDENT.

REQUEST

The parties jointly request that this matter be referred to mediation in the Office of Administrative Hearings (OAH). ☐ This matter is set for hearing on __________________(date). ☐ This matter is not currently set for hearing. MEDIATION AGREEMENT By requesting this mediation and signing below, the parties understand, represent, and agree: 1. The parties are prepared to commence mediation and will be ready for mediation on _____________________(date); 2. The parties will participate in the mediation process in good faith; 3. This request for mediation is not intended to hinder or delay administrative proceedings; 4. No party will contend that the mediation limits the power of OAH and its administrative law judges to conduct an administrative hearing and issue decisions under A.R.S. §§ 41-1092 – 1092.12; 5. The parties will be courteous and respectful throughout the mediation process to all participants; 6. The mediation is completely voluntary and the principal purpose is to allow the parties a full and fair opportunity to discuss settlement; of 3 REGISTRAR OF CONTRACTORS 1700 W. Washington St. Suite 105 – PHOENIX, AZ 85007-2812 Telephone (602)542-1525 1-877-692-9762 7. The mediator may conduct joint and separate meetings with the parties and may suggest resolutions to the parties’ dispute, but the mediator has no authority to impose a settlement upon the parties; 8. The mediation process is confidential. Communications made, material created for or used during, and acts occurring during mediation are confidential and may not be discovered or admitted into evidence in any proceeding except as provided by A.R.S. § 12-2238; 9. The mediator is not subject to service of process or a subpoena to produce evidence or to testify regarding any evidence or occurrence relating to the mediation except as provided in A.R.S. § 12-2238(C); 10. Neither the mediator, nor the Registrar of Contractors, nor the Office of Administrative Hearings is subject to civil liability for any act or omission in connection with any mediation service or activity except for acts involving

intentional misconduct or reckless disregard of a substantial risk of injury to the rights of others; 11. Throughout the mediation process, each party must have a representative present who will have full settlement authority to settle all claims at issue in the administrative

proceeding. 12. The mediation process will terminate when: a. The parties reach settlement; b. The mediator determines that further efforts at mediation are no longer likely

to achieve a settlement; or c. One of the parties withdraws from mediation. _____________________________________ _______________________ Complainant (or representative) Date

_____________________________________ _______________________ Respondent (or representative) Date

of 3 REGISTRAR OF CONTRACTORS 1700 W. Washington St. Suite 105 – PHOENIX, AZ 85007-2812 Telephone (602)542-1525 1-877-692-9762 PREHEARING DISCLOSURE STATEMENT INSTRUCTIONS ***DO NOT SUBMIT THESE INSTRUCTIONS WITH THE PREHEARING DISCLOSURE FORM***

ADMINISTRATIVE RULES A copy of the Arizona Administrative Code’s Rules for the Registrar of Contractors can be located on the Registrar’s Website.

PREHEARING DISCLOSURE REQUIREMENT Under A.A.C. R4-9-118(A), before a hearing, the parties must prepare a disclosure statement. The disclosure statement must contain: • A list of all the witnesses the party will call to testify, including the witnesses’ contact information and a brief description of the subject matter of the witnesses’ expected testimony; and • A list of all the exhibits that the party will use at the hearing.

FILE PREHEARING DISCLOSURE STATEMENTS • The Prehearing Disclosure Statements and Exhibits may be submitted to the Arizona Office of Administrative Hearings using any of the following: • Electronically: https://portal.azoah.com/submission/ • In-Person or by Mail: 1740 West Adams Street, Lower Level, Phoenix, Arizona 85007

EXCHANGING DISCLOSURE STATEMENTS AND EXHIBITS Under A.A.C. R4-9-118(B) (effective November 5, 2017), a party to the hearing must serve on every other party and file with the Office of Administrative Hearings a copy of: • The disclosure statement; and, • Any exhibit that the party will use at the hearing. Service: The disclosure statement and exhibits must be served on all parties in accordance with Arizona Administrative Code R2-19-108 Filing Documents. Under A.A.C. R2-19-108, service is completed by: • Personal delivery; • 1st class, certified or express mail; or • Facsimile. Timing: The disclosure statement and the exhibits must be served and filed not less than seven calendar days before the date of the hearing. Under A.A.C. R2-19-108, a document is served on a party: • On the date it is personally served; • Five days after it is mailed by express or 1st class mail; • On the date of the return receipt if it is mailed by certified mail; or • On the date indicated on the facsimile transmission.

CONSEQUENCES FOR FAILING TO DISCLOSE Under A.A.C. R4-9-108(C), if a witness or an exhibit is not timely disclosed as required the rules, and good cause for the failure to disclose is not shown, then the administrative law judge may: • Order that certain witnesses or exhibits not be used at the hearing; • Order that a particular fact is or is not established for the record; or, • Order that a charge, a defense, a claim, or some portion thereof, be dismissed.

Form RC-L-800A Prehearing Disclosure Statement Rev. 10/08/2019 Instructions Form PREHEARING DISCLOSURE STATEMENT FORM RC-L-800A

PART 1: WITNESS LIST DOCKET NO. Under A.A.C. R4-9-118(A), before a hearing, a party must prepare a disclosure statement containing a list of all the witnesses the party will call to testify, including the witnesses’ contact information and a brief description of the subject matter of the witnesses’ expected testimony. If you need additional space to list all witnesses, complete and attach additional Witness Lists. Example 1. Name 2. Telephone Number 3. Email Address

John Doe (123) 456-7890 [email redacted] 4. Subject Matter of Expected Testimony

John Doe will testify regarding the poor workmanship and poor installation of the Garage Door. Mr. Doe will also testify regarding the invoices and change orders for the project.

Witness 1. Name 2. Telephone Number 3. Email Address

4. Subject Matter of Expected Testimony

Witness 1. Name 2. Telephone Number 3. Email Address

4. Subject Matter of Expected Testimony

Witness 1. Name 2. Telephone Number 3. Email Address

4. Subject Matter of Expected Testimony

Witness 1. Name 2. Telephone Number 3. Email Address

4. Subject Matter of Expected Testimony

Form RC-L-800A Prehearing Disclosure Statement Rev. 1/15/2019 Page 1 of 3 PART 2: EXHIBIT LIST DOCKET NO. Under A.A.C. R4-9-118(A), before a hearing, a party must prepare a disclosure statement containing a list of all the exhibits that the party will use at the hearing. Note: All exhibits listed below must be provided to all parties to the hearing. See A.A.C. R4-9-118(B). If you need additional space to list all witnesses, complete and attach additional Exhibit Lists. Example Contract for new garage door. Invoice #10001 – Cost for garage door replacement.

Exhibit Exhibit Name

Form RC-L-800A Prehearing Disclosure Statement Rev. 1/15/2019 Page 2 of 3 PART 3: ACKNOWLEDGEMENT & SIGNATURE I certify that the above information is true and correct and that I will serve a copy of this disclosure statement and any exhibits listed in Part 2 to all parties to the hearing in accordance with A.A.C. R4-9-118. I acknowledge and understand that if I fail to properly disclose a witness or exhibit, the administrative law judge may: • Order that certain witnesses or exhibits not be used at the hearing; • Order that a particular fact is or is not established for the record; or, • Order that a charge, a defense, a claim, or some portion thereof, be dismissed.

I am the (check one):  Complainant  Respondent Docket No.

Print Name Signature Date

Form RC-L-800A Prehearing Disclosure Statement Rev. 1/15/2019 Page 3 of 3