2023A-07143-NPC-ROC Notice of Hearing and Packet MAILED

2023A-07143-NPC-ROC · Registrar of Contractors · 2023-10-26

REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA

Lonestar Drywall LLC, Case No. 2023-07143 COMPLAINANT, Docket No. 2023A-07143-NPC-ROC v. NOTICE OF HEARING ON CONTESTED CASE Precision Blueprint Remodeling LLC License No. ROC 334211,

RESPONDENT.

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

HEARING INFORMATION The hearing is set for:

December 20, 2023 9:00 AM Amy Haley 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 August 16, 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)(10)

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.

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 October 25, 2023.

By: /s/ Erika Hoskin Erika Hoskin Legal Secretary Legal Department Arizona Registrar of Contractors

Copy mailed via USPS First Class mail October 25, 2023 to: Respondent(s) Precision Blueprint Remodeling LLC 449 E Cheyenne Rd San Tan Valley, AZ 85143

Thomas E. Raccuia, Esq. 7243 North 16th Street Phoenix, AZ Complainant(s) Lonestar Drywall LLC Po Box 1048 Litchfield Park, AZ 85340

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

Case No. 2023-07143 /

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

July 11, 2023 Via U.S. Mail and Email

Complainant Lonestar Drywall LLC PO Box 1048 Litchfield Park, AZ 85340

Respondent Precision Blueprint Remodeling LLC 449 E Cheyenne Rd San Tan Valley, AZ 85143

Re: Complaint No. 2023-07143

Dear Complainant and Respondent:

The Registrar received a complaint filed against Precision Blueprint Remodeling LLC for non-payment of materials or services rendered. This complaint is complete and will be substantively reviewed by the Registrar.

Respondent is free to raise any issue or affirmative defense to this complaint by filing a response with the Registrar by July 18, 2023. Please reference the complaint number listed above if you file a response. Respondent may file a response by:

Mail: P.O. Box 18244, Phoenix, Arizona, 85005-8244 In-Person: 1700 W. Washington St., Ste. 105, Phoenix, Arizona, 85007-2812 Email: [email redacted]

The Registrar will not issue a citation before July 18, 2023, and will review Respondent’s response, if one is submitted.

Please be advised that a response to the complaint is not the same as a written answer. If the Registrar issues a citation Respondent must file a written answer to that citation in accordance with A.R.S. § 32-1155.

Sincerely,

/s/ Tedi Quezada _________________ Tedi Quezada Legal Department 1700 W Washington St. Ste. 105 Phoenix, AZ 85007 1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg100 4/21 Non-Payment Complaint Form Departmental Use Only Complaint Number: Mail to: Registrar of Contractors P.O. Box 18243 Phoenix, AZ 85005-8243

Person Filing Complaint (Payee) Business Name Full Name (First Middle Last) ROC License Number(s) (if any) ALDO RAMOS Street Address City State Zip Code 591 E PLAZA CIR,PO BOX 1048 Litchfield Park Arizona 85340 Phone Number Email Address [number redacted] [email redacted] I consent to receive communications electronically in connection with this case

Name of Attorney (if any)

Attorney’s Street Address City State Zip Code

Attorney’s Phone Number Attorney’s Email Address

Licensee Information (Payer) Name (as shown on contracts, invoices, etc.) ROC License Number(s) Precision Blueprint Remodeling LLC ROC 334211 Street Address City State Zip Code

Phone Number Email Address

Name of Person(s) Representing License RAUL AARON BANUELOS JR Complaint Information Principal Amount Due (excluding interest and fees) Contract Date (if applicable) $14,198.00 October 6, 2022 Have you filed a civil complaint?

List all specific invoices which have not been paid. Attach additional pages if necessary. INV0056; INV0059

Certification I certify, upon information and belief, that the above-named licensee has failed to pay monies in excess of seven hundred fifty dollars when due for materials or services rendered in connection with the licensee’s operations as a contractor. I further certify, upon information and belief, that the above-named licensee has the capacity to pay, or has received sufficient monies as payment for the particular construction work project or operation for which the services or materials were rendered or purchased. A.R.S. § 32-1154(A)(10). Printed Name Signature Date ALDO RAMOS Declaration & Signature I am the Complainant in this Complaint Form or Complainant’s duly authorized representative. I declare under penalty of perjury that the information contained in this Form is true and correct to the best of my knowledge. I further certify that any documents submitted in support of this complaint are true and correct copies of the originals and are 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 ALDO RAMOS LONEST ONESTAR AR DRYW DRYWALL ALL LL LLC C INV INVOICE OICE INV0056 Business Number ROC CR-10#328838 CR-7#337697 DATE 591 PLAZA CIRCLE,PO BOX 1688 Oct 6, 2022 LITCHFIELD PARK DUE 85340 On Receipt [number redacted] [email redacted] BAL BALANCE ANCE DUE USD $12,720.00

BILL T TO O

PRECISION BLUEPRINT REMODELING LL LLC C 449 E CHEYENNE RD SAN TAN VALLEY,AZ 85143 480-395-6044 [email redacted]

DESCRIPTION RA RATE TE QTY AMOUNT

AUGUST 5 T TOO 11- 11-2022 2022 $30.00 94 $2,820.00 hang\frame; 64 hrs taping\texture; 24 hrs material delivery\supervision;6

AUGUST 13 T TO O 18- 18-2022 2022 $30.00 13 $390.00 hang\frame; 0 taping\texture;11 material delivery\supervision;2

AUG 19 TTO O 25- 25-2022 2022 $30.00 60 $1,800.00 hang\frame; 12 hrs taping\texture; 45 hrs material delivery\supervision; 3 hrs

AUGUST 26 T TO O SEPTEMBER 1- 1-2022 2022 $30.00 80 $2,400.00 hang\frame;28 hrs taping\texture; 48 hrs material delivery\supervision;4 hrs

SEPTEMBER 2 T TOO 8- 8-2022 2022 $30.00 85 $2,550.00 hang\frame; 36 hrs taping\texture; 45 hrs material delivery\supervision;4 hrs

DESCRIPTION RA RATE TE QTY AMOUNT

SEPTEMBER 9 T TOO 15- 15-2022 2022 $30.00 64 $1,920.00 hang\frame; 0 hrs taping\texture; 58 hrs material delivery\supervision;6 HRS

SEPTEMBER 23 T TO O 29- 29-2022 2022 $30.00 68 $2,040.00 hang\frame; 32 hrs taping\texture; 32 hrs material delivery\supervision;4HRS

SEPTEMBER 30 T TO O OCT OCTOBER OBER 9- 9-2022 2022 $30.00 15 $450.00 hang\frame; 0hrs taping\texture; 12 hrs material delivery\supervision;3HRS

MATERIAL $2,500.00 1 $2,500.00

OVERHEAD 15 % $2,530.00 1 $2,530.00

MARKUP $5,820.00 1 $5,820.00

SUBT SUBTO OTAL $25,220.00 TAX ((0 0%) $0.00

TOTAL $25,220.00 PAID -$12,500.00 Nov 10, 2022

BAL BALANCE ANCE DUE USD $12,720. $12,720.00

PROJECT ADDRESS; 5360 E ROCKRIDGE RD PHOENIX,AZ 85018

LONEST ONESTAR AR DRYW DRYWALL ALL LL LLC C INV INVOICE OICE INV0059 Business Number ROC CR-10#328838 CR-7#337697 DATE 591 PLAZA CIRCLE,PO BOX 1688 Oct 28, 2022 LITCHFIELD PARK DUE 85340 On Receipt [number redacted] [email redacted] BAL BALANCE ANCE DUE USD $1,478.00

BILL T TO O

PRECISION BLUEPRINT REMODELING LL LLC C 449 E CHEYENNE RD SAN TAN VALLEY,AZ 85143 480-395-6044 [email redacted]

DESCRIPTION RA RATE TE QTY AMOUNT

hangers exterior drywall hang oct-8 $30.00 4 $120.00

tapers patching work , kitchen,office,living room and exterior drywall $30.00 18 $540.00 tape and first coat oct-9

taper patches 2nd coat $30.00 4 $120.00

tapers sanding patches, touch up and clean up $30.00 8 $240.00

materials $100.00 1 $100.00

overhead 10% $112.00 1 $112.00

markup 20% $246.00 1 $246.00

SUBT SUBTO OTAL $1,478.00 TAX ((0 0%) $0.00

TOTAL $1,478.00

BAL BALANCE ANCE DUE USD $1,47 $1,4788.00

PROJECT ADDRESS;

5360 E ROCKRIDGE RD PHOENIX,AZ 85018

approximately price by hour total; $43.00 by hour ( standard hour rate for this kind of jobs its $60.00 by hour)

Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS; 88 ROCKRIDGE AUG-5 to AUG-11 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 5-Aug FRIDAY rockridge 2 workers demolition and frame 16 FRIDAY FRIDAY 6-Aug SAT/SUN rockridge 2 workers demolition,frame and hang 16 8-Aug MONDAY rockridge 2 workers frame,demo, and hang 16 MONDAY MONDAY 9-Aug TUESDAY rockridge 2 hangers hanging kitchen and demo 16 TUESDAY 3 tapers taping kitchen 24 TUESDAY 10-Aug WEDNESDAY WEDNESDAY WEDNESDAY 11-Aug THURSDAY THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS; 11 ROCKRIDGE aug-13 to aug 18 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate FRIDAY FRIDAY FRIDAY 14-Aug SAT/SUN rockridge 1 taper kitchen work 2 MONDAY MONDAY MONDAY TUESDAY TUESDAY TUESDAY WEDNESDAY WEDNESDAY WEDNESDAY 18-Aug THURSDAY rockridge 1 taper kitchen work 9 THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS;57HRS ROCKRIDGE aug-19 to aug-25 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 19-Aug FRIDAY ROCKRIDGE 1 taper kitchen work,bathroom 9 FRIDAY FRIDAY SAT/SUN 22-Aug MONDAY ROCKRIDGE 1 taper kitchen work,bathroom 9 MONDAY MONDAY 23-Aug TUESDAY rockridge 1 taper kitchen work,bathroom\bedroom 10 TUESDAY 2 hangers patching bathroom\bedroom 12 TUESDAY 24-Aug WEDNESDAY ROCKRIDGE 1 taper kitchen,bathroom,beddroom 9 WEDNESDAY WEDNESDAY 25-Aug THURSDAY rockridge 1 taper kitchen bathroom,bedrooms 8 THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS ; 76hrs ROCKRIDGE aug-26 to sep-1 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 26-Aug FRIDAY rockridge 1 taper working on closets,basement, bedrooms 8 FRIDAY 2 hangers doing patches and frame 12 FRIDAY 27-Aug SAT/SUN rockridge 1 taper working on closets,basement, bedrooms 9 29-Aug MONDAY rockridge 1 taper working on closets, bathrooms 9 MONDAY MONDAY 30-Aug TUESDAY rockridge 1 taper, basement sanding, 1st floor bathroom, pantry 1st coat 9 TUESDAY TUESDAY 31-Aug WEDNESDAY rockridge 1 taper texture 1st floor room 4 WEDNESDAY WEDNESDAY 1-Sep THURSDAY rockridge 2 hangers working on living room ceiling 16 THURSDAY 1 taper ,sanding 1st floor room ,2nd coat pantry 9 THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS.- 12 HRS ROCKRIDGE OCT-7 TO OCT-13 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 7-Oct FRIDAY rockridge FRIDAY FRIDAY 9-Oct SAT/SUN rockridge 2hangers hanging exterior drywall board 4hrs 9-Oct SATURDAY rockridge 2 tapers,kitchen patches,living area,hallway patches ,office patches ,exterior 18hrs 10-Oct MONDAY rockridge 1 taper sanding and 2nd coat patches 4hrs MONDAY 11-Oct TUESDAY rockridege 2 tapers sanding and touch up patches ,clean up 8hrs TUESDAY TUESDAY 12-Oct WEDNESDAY rockridge WEDNESDAY WEDNESDAY 13-0ct THURSDAY rockridge THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS;81 hrs ROCKRIDGE sep-2 to sep-8 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 2-Sep FRIDAY rockridge 2hangers working on living room ceiling 9hr each 18 FRIDAY 1 taper working pantry c\b, kitchen patches 9 FRIDAY 3-Sep SATURDAY rockridge 2 hangers finishing ceiling living room 9hrs\each 18 SATURDAY rockridge 1 taper taping office ceiling and first coat both ceilings 9 5-Sep MONDAY rockridge no work MONDAY 6-Sep TUESDAY rockridge 1 taper leveling joints with box and screws mud coating 9 TUESDAY TUESDAY 7-Sep WEDNESDAY rockridge 1 taper doing 2nd box run on joints and screws 9 WEDNESDAY WEDNESDAY 8-Sep THURSDAY rockridge 1 taper sanding, patches and clean up level 3\4 tape 9 THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL;58 hrs ROCKRIDGE SEP-9 TO SEP-15 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 9-Sep FRIDAY rockridge 1 taper touch up ceilings living room and office 9 FRIDAY FRIDAY 10-Sep SAT/SUN rockridge 1 taper touch up living room walls 9 12-Sep MONDAY rockridge 2 tapers texture living area, moving stuff and cleaning 18 MONDAY MONDAY 13-Sep TUESDAY rockridge 2 tapers sanding texture, and touch up, moving stuff,cleaning 22 TUESDAY TUESDAY 14-Sep WEDNESDAY WEDNESDAY WEDNESDAY THURSDAY THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID ROCKRIDGE SEP-16 TO SEP-22 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate FRIDAY FRIDAY FRIDAY SAT/SUN MONDAY MONDAY MONDAY TUESDAY TUESDAY TUESDAY WEDNESDAY WEDNESDAY WEDNESDAY THURSDAY THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS;64 hrs ROCKRIDGE SEP-23 TO SEP-29 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 23-Sep FRIDAY rockridge 2 hangers drywall windows patching 16 FRIDAY FRIDAY 24-Sep SAT/SUN rockridge 2 hangers drywall windows patching 16 26-Sep MONDAY MONDAY MONDAY 27-Sep TUESDAY rockridge 2 tapers ,patches, cornerbead inst,baseboard touch up 18 TUESDAY and first coat windows area TUESDAY 28-Sep WEDNESDAY WEDNESDAY WEDNESDAY 29-Sep THURSDAY rockridge 2 tapers, sanding ,2nd coat, and clean up windows area 14 THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS.- 12 HRS ROCKRIDGE SEP-30 TO OCT-6 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 30-Sep FRIDAY rockridge 2 tapers sanding windows area, touch up and clean up 12 FRIDAY FRIDAY 1-Oct SAT/SUN 3-Oct MONDAY MONDAY MONDAY 4-Oct TUESDAY TUESDAY TUESDAY 5-Oct WEDNESDAY WEDNESDAY WEDNESDAY 6-Oct THURSDAY THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: 7/13/23, 2:18 PM Received Legal Precision Blueprint Development Mail - Aldo Response - Budget explanation

07/17/2023 Accounting User <[email redacted]>

Aldo Response - Budget explanation Taylor Hagberg <[email redacted]> Thu, Jul 13, 2023 at 2:18 PM To: Accounting User <[email redacted]>, Raul Banuelos <[email redacted]>

The original drywall budget for the Head remodel included a subcontractor payout amount of $12,500. Once the project started. There were changes to the amount of work and it brought the payout total to $14,900. There was a total of 40 sheets of new drywall added to the project that required a level 4 smooth finish. There was also roughly 1000 wall square footage of patch work throughout. This total scope of work, regardless of the amount of time it should have taken, should be no more than $10,000-$12,000 total. Precision Blueprint Remodeling charged the client a little more because of the items in place that we had to work around, the timing of some of the work and access to certain work changes at certain times. Aldo is charging Precision Blueprint Remodeling well over double the value of the work that was completed; again, regardless of the amount of time the work took we hired a drywaller for the quantity, and not per hour. Lonestar Drywall completed a commercial Tenant Improvement project for Precision Blueprint Remodeling 2 months prior to starting the Head Remodel. This project required over 100 sheets of drywall up to 10’ and was a combination of 5/8” drywall, ¼” drywall, acoustic ceiling tiles and painting ceiling tiles. This project was easily twice the labor, twice the material and twice the value ($23,500) in terms of the scopes provided by Lonestar drywall but he is charging roughly the same amount of money for the Head Remodel project. Lonestar Drywall, also, did not complete the ceiling tile paint even though he was paid for it. This scope had a value of $1,500 so he overpaid this amount. Another project, Precision Blueprint Remodeling, hired Lonestar drywall for 2 weeks after the tenant improvement project required over 60 sheets of drywall and was a 2-story complete drywall project. Lonestar charged us $11,943 and again, was much more work than the project attached to the complaint, but he charged much less than half that amount. In my opinion, it appears that once Lonestar Drywall owner, Aldo, recognized the status of the homeowner for the Head Remodel, he felt he could charge more for that fact alone. There is not enough work involved in the Head Remodel project to justify the amount they are charging. That is evident not only in the numbers but in the experience that Precision Blueprint Remodeling has had with the relationship with Lonestar drywall during the previous projects. There were also multiple complaints from the homeowner for the head remodel that involved Lonestar Drywall wasting a lot of time standing around and not working. We took these complaints seriously and now recognize the bad faith and business practices presented by Lonestar Drywall. My advice, along with many others, was for Precision Blueprint Remodeling to quit using Lonestar Drywall. [Quoted text hidden]

https://mail.google.com/mail/u/1/?ik=d616c33204&view=pt&search=all&permmsgid=msg-f:[number redacted]&simpl=msg-f:[number redacted] 1/1 7/13/23, 1:26 PM Account Detail - Wells Fargo Received Legal 07/17/2023 Check Details

Item 140 of 200 Show partial image Print

Check Number 1906

Date Posted 10/07/22

Check Amount $12,500.00

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For your security, information like account numbers, signatures, and the ability to view the backs of checks have been removed from the images. You can see full or partial fronts and backs of the images by using the link at the top of the window.

Equal Housing Lender

https://connect.secure.wellsfargo.com/accounts/start?p1=yes&SAMLart=AAQCG%2BoEQCR14WDgSxaU4QNGCHpGcoS1YqKHOTgiqAI6RrvacjUby… 1/1 LONESTAR DRYWALL LLC Received Legal INVOICE Business Number ROC#328838 07/17/2023INV0047 591 PLAZA CIRCLE,PO BOX 1688 DATE

LITCHFIELD PARK Aug 16, 2022

85340 DUE [number redacted] On Receipt [email redacted] BALANCE DUE USD $0.00

BILL TO

PRECISION BLUEPRINT REMODELING LLC 449 E CHEYENNE RD SAN TAN VALLEY,AZ 85143 480-395-6044 [email redacted]

DESCRIPTION RATE QTY AMOUNT

FRAMING\DRYWALL\ACT $23,500.00 1 $23,500.00 5\8" type x drywall on new framing interior walls

1\4" drywall on demising walls

coats of taping mud on new drywall

skip texture on new drywall and on drywall repairs

drywall repairs on existing drywall to remind

Acoustical grid ceiling frame repair where walls will be removed

damaged ceiling tiles replacement

flat black paint on acoustical ceiling tile and grid

ceiling high

ADITIONAL WORK; multiple holes on demising walls

drywall strip patch bellow all existing drywall

ft of xp mold resistant drywall installation on bathrooms

https://app.invoicesimple.com/v/eQoPuiOlAH 1/2 7/13/23, 1:49 PM Invoice INV0047 Received Legal DESCRIPTION RATE 07/17/2023 QTY AMOUNT

EXTRA: more ceiling repairs than the estimate before

Extra repairs on bathrooms

Door frame

Fire wall patching for inspection above act

SUBTOTAL $23,500.00 TAX (0%) $0.00

TOTAL $23,500.00 PAID -$23,500.00 Sep 6, 2022

BALANCE DUE USD $0.00

PROJECT ADDRESS; 888 S GREENFIELD RD Gilbert, AZ 85296

INCLUDED; DRYWALL\ CEILING TILE SYSTEM LABOR MATERIAL NOT ONLINE PAYMENTS CLEANING ANY REPAIRS OR PUCH JOB WILL BE DO IT AFTER 90% OF THE SUM ON THE CONTRACT ITS PAID IN FULL EXTRA REPAIRS WILL BE CHARGED AT $45.00 DLS BY HOUR

https://app.invoicesimple.com/v/eQoPuiOlAH 2/2 Received Legal 07/17/2023 7/18/23, 10:47 AM State of Arizona Mail - Fwd: Response from Precision Blueprint Remodeling - Case 2023-07143

Legal New Mail - AZROC <[email redacted]>

Fwd: Response from Precision Blueprint Remodeling - Case 2023-07143 message

Raul Banuelos <[email redacted]> Mon, Jul 17, 2023 at 2:59 PM To: [email redacted], [email redacted]

Thank you for the time Raul Banuelos Precision Blueprint Remodeling LLC KB-2 Dual Residential and Small Commercial ROC 334211 480-395-6044 [email redacted] Precision Blueprint Remodeling Instagram

---------- Forwarded message --------- From: Raul Banuelos <[email redacted]> Date: Thu, Jul 13, 2023 at 2:26 PM Subject: Response from Precision Blueprint Remodeling - Case 2023-07143 To: <[email redacted]> Cc: <[email redacted]>

To whom it may concern:

This email is in response to ROC case 2023-07143.

We received the above listed complaint July 11th, 2023.

In October of 2022, Aldo Ramos, owner/operator of Lonestar Drywall, provided us with an invoice well over the budgeted amount that we provided him. The budgeted amount had been discussed with Aldo and the homeowner. Aldo had explained that he had fallen on hard times, so we wrote him a check for $12,500.00, which was the original budget amount. At one point in time, we were advised by the owner of Lonestar Drywall that he thought we, as Precision Blueprint Remodeling, needed to charge the homeowner more money to account for his work due to the homeowner's status of wealth and location of the dwelling. This is a poor business practice that we do not take part in. Shortly thereafter, we discontinued our relationship with Lonestar Drywall. In doing this, there was leftover work to be completed that Lonestar did not finish. Because of this, we incurred additional costs in having to hire a new drywall contractor.

We have attached an explanation of the budget from our estimator, Taylor. The other attachments are the check provided to Lonestar a month before the date of the invoice in question, as well as an extra $2,400.00 Zelle that was sent for patchwork. We have also attached another invoice from Lonestar Drywall from a job he completed for us (2) months previous. The job completed for the $23,500.00 (which was paid in full) was for commercial grade materials, which do cost more than residential. This scope was roughly three times the amount of work as the disputed invoice. We have provided this invoice as a comparison to the amount of work completed.

By our accounting, Lonestar Drywall has been paid in full.

Thank you for the time Raul Banuelos Precision Blueprint Remodeling LLC KB-2 Dual Residential and Small Commercial ROC 334211 480-395-6044 [email redacted] Precision Blueprint Remodeling Instagram

attachments

https://mail.google.com/mail/b/AAW1or81R9oeuAbEo2pmfxnLLsZK3czQa3_zo2Mf-r6gaiYoHpL2/u/0/?ik=d3afebeda9&view=pt&search=all&permthid=t… 1/2 7/18/23, 10:47 AM State of Arizona Mail - Fwd: Response from Precision Blueprint Remodeling - Case 2023-07143

Lonestar Drywall Zelle 10.28.22.png 20K Check to Lonestar.pdf 87K Lonestar contender invoice.pdf 224K Aldo Response - Budget explanation.pdf 84K

https://mail.google.com/mail/b/AAW1or81R9oeuAbEo2pmfxnLLsZK3czQa3_zo2Mf-r6gaiYoHpL2/u/0/?ik=d3afebeda9&view=pt&search=all&permthid=t… 2/2 REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA

Case No. 2023-07143 Lonestar Drywall LLC,

COMPLAINANT, v. CITATION Precision Blueprint Remodeling LLC License No. ROC 334211,

RESPONDENT.

The Registrar issues this Citation to Precision Blueprint Remodeling LLC (“Respondent”) under A.R.S. § 32-1155(A). If Respondent fails to answer this Citation by August 31, 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 June 24, 2023, Lonestar Drywall LLC (“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)(10) — Failure by a licensee or agent or official of a licensee to pay monies in excess of $750 when due for materials or services rendered in connection with the licensee's operations as a contractor unless the 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 licensee proves that the licensee lacks the capacity to pay and has not received sufficient monies as payment for the particular construction work project or operation for which the services or materials were rendered or purchased.

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. 2023-07143. 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 Fax: (602) 364-0416 Email: [email redacted] 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 August 31, 2023. 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 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). 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 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 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 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. Dated August 16, 2023. By: /s/ Robert Stirling Robert Stirling Assistant General Counsel Legal Department Arizona Registrar of Contractors COPY of the foregoing mailed by Certified Mail, Return Receipt Requested, August 16, 2023 to:

Respondent Certified Mail No: [number redacted]

Precision Blueprint Remodeling LLC 449 E Cheyenne Rd San Tan Valley, AZ 85143 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 Copy mailed by USPS First Class mail this same date to: Respondent Precision Blueprint Remodeling LLC 449 E Cheyenne Rd San Tan Valley, AZ 85143 Complainant Lonestar Drywall LLC PO Box 1048 Litchfield Park, AZ 85340 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 Case No. 2023-07143/tq

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 ARIZONA REGISTRAR OF CONTRACTORS

Douglas A. Ducey, Governor Jeff Fleetham , Director

Form REQUEST TO CLOSE CASE RC-Lg-701A

Instructions Complete this form to request that the Registrar close a case where the Registrar previously issued a citation. Before the Registrar issues an order closing a case that resulted in citation, both parties must agree to the closure. After consideration, the Registrar may approve the request.

If both parties do not demonstrate their willingness for the Registrar to issue an Order of Closing by completing this form, then the matter will continue to proceed to administrative resolution. This means that, if not already done so:

The Respondent will be required to: 1. Submit a written answer as directed by the Citation and required under A.R.S. § 32-1155(A). o Failure to timely submit an answer may result in the admission of the allegations contained within the citation. A.R.S. § 32-1155(B); and 2. Request a settlement conference under A.R.S. §41-1092.06, if desired.

The Complainant will be required to establish, before the administrative law judge, the merits of their claim.

A. CASE INFORMATION 1. Case Number 2. Complainant 3. Respondent

B. PARTIES ACKNOWLEDGMENT & SIGNATURE Complainant acknowledges that by signing and submitting this Request to Close Case, if the Registrar grants this request: 1. The Registrar may decline to reopen this case; and 2. Complainant’s future remedies, if any, may be limited to another forum. Respondent acknowledges that by signing and submitting this Request to Close Case, if the Registrar grants this request: 1. Respondent’s license record will have a “Closed Case” designation associated with this case; and 2. This case will appear on the Respondent’s public license record available through the Registrar of Contractors’ website as a “Resolved/Settled/Withdrawn” case for a period of seven years.

_____________________ _____________________ ______________ Complainant’s Name Complainant’s Signature Date

_____________________ _____________________ ______________ Respondent’s Name Respondent’s Signature Date

1700 W. Washington Street, Suite 105 ● Phoenix AZ 85007-2812 602.542.1525 ● Within AZ 877.692.9762 ● Fax 602.542.1599 ● www.roc.az.gov

Form RC-Lg-701A Request to Close Case Rev 1/18/2019 Page 1 of 1 01231456ÿ0822ÿ9 ÿÿ9 ÿ ÿÿ8ÿ ÿ445235ÿÿÿ Received ÿ  Legal 3456ÿ89408/11/2023 :;5;ÿ<=456>?94:;5;@ABC>;:>DBEF

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! 811 "##"$1 1%11&'()5$*$+$420,-.( , $!( ,  !/(! /8505022**04505**1#825*+54000030*2 212 Received Legal 08/11/2023 01231456ÿ0824ÿ9 ÿÿ9 ÿ ÿÿ8ÿ ÿ445235ÿÿÿ Received ÿ  Legal 3456ÿ89408/11/2023 :;5;ÿ<=456>?94:;5;@ABC>;:>DBEF

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! 811 "##"$1 1%11&'()5$*$+$420,-.( , $!( ,  !/(! /8505022**04505**1#825*+343050*004*4*2 212 July 11, 2023 Via U.S. Mail and Email

Complainant Lonestar Drywall LLC PO Box 1048 Litchfield Park, AZ 85340

Respondent Precision Blueprint Remodeling LLC 449 E Cheyenne Rd San Tan Valley, AZ 85143

Re: Complaint No. 2023-07143

Dear Complainant and Respondent:

The Registrar received a complaint filed against Precision Blueprint Remodeling LLC for non-payment of materials or services rendered. This complaint is complete and will be substantively reviewed by the Registrar.

Respondent is free to raise any issue or affirmative defense to this complaint by filing a response with the Registrar by July 18, 2023. Please reference the complaint number listed above if you file a response. Respondent may file a response by:

Mail: P.O. Box 18244, Phoenix, Arizona, 85005-8244 In-Person: 1700 W. Washington St., Ste. 105, Phoenix, Arizona, 85007-2812 Email: [email redacted]

The Registrar will not issue a citation before July 18, 2023, and will review Respondent’s response, if one is submitted.

Please be advised that a response to the complaint is not the same as a written answer. If the Registrar issues a citation Respondent must file a written answer to that citation in accordance with A.R.S. § 32-1155.

Sincerely,

/s/ Tedi Quezada _________________ Tedi Quezada Legal Department 1700 W Washington St. Ste. 105 Phoenix, AZ 85007 1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg100 4/21 Non-Payment Complaint Form Departmental Use Only Complaint Number: Mail to: Registrar of Contractors P.O. Box 18243 Phoenix, AZ 85005-8243

Person Filing Complaint (Payee) Business Name Full Name (First Middle Last) ROC License Number(s) (if any) ALDO RAMOS Street Address City State Zip Code 591 E PLAZA CIR,PO BOX 1048 Litchfield Park Arizona 85340 Phone Number Email Address [number redacted] [email redacted] I consent to receive communications electronically in connection with this case

Name of Attorney (if any)

Attorney’s Street Address City State Zip Code

Attorney’s Phone Number Attorney’s Email Address

Licensee Information (Payer) Name (as shown on contracts, invoices, etc.) ROC License Number(s) Precision Blueprint Remodeling LLC ROC 334211 Street Address City State Zip Code

Phone Number Email Address

Name of Person(s) Representing License RAUL AARON BANUELOS JR Complaint Information Principal Amount Due (excluding interest and fees) Contract Date (if applicable) $14,198.00 October 6, 2022 Have you filed a civil complaint?

List all specific invoices which have not been paid. Attach additional pages if necessary. INV0056; INV0059

Certification I certify, upon information and belief, that the above-named licensee has failed to pay monies in excess of seven hundred fifty dollars when due for materials or services rendered in connection with the licensee’s operations as a contractor. I further certify, upon information and belief, that the above-named licensee has the capacity to pay, or has received sufficient monies as payment for the particular construction work project or operation for which the services or materials were rendered or purchased. A.R.S. § 32-1154(A)(10). Printed Name Signature Date ALDO RAMOS Declaration & Signature I am the Complainant in this Complaint Form or Complainant’s duly authorized representative. I declare under penalty of perjury that the information contained in this Form is true and correct to the best of my knowledge. I further certify that any documents submitted in support of this complaint are true and correct copies of the originals and are 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 ALDO RAMOS LONEST ONESTAR AR DRYW DRYWALL ALL LL LLC C INV INVOICE OICE INV0056 Business Number ROC CR-10#328838 CR-7#337697 DATE 591 PLAZA CIRCLE,PO BOX 1688 Oct 6, 2022 LITCHFIELD PARK DUE 85340 On Receipt [number redacted] [email redacted] BAL BALANCE ANCE DUE USD $12,720.00

BILL T TO O

PRECISION BLUEPRINT REMODELING LL LLC C 449 E CHEYENNE RD SAN TAN VALLEY,AZ 85143 480-395-6044 [email redacted]

DESCRIPTION RA RATE TE QTY AMOUNT

AUGUST 5 T TOO 11- 11-2022 2022 $30.00 94 $2,820.00 hang\frame; 64 hrs taping\texture; 24 hrs material delivery\supervision;6

AUGUST 13 T TO O 18- 18-2022 2022 $30.00 13 $390.00 hang\frame; 0 taping\texture;11 material delivery\supervision;2

AUG 19 TTO O 25- 25-2022 2022 $30.00 60 $1,800.00 hang\frame; 12 hrs taping\texture; 45 hrs material delivery\supervision; 3 hrs

AUGUST 26 T TO O SEPTEMBER 1- 1-2022 2022 $30.00 80 $2,400.00 hang\frame;28 hrs taping\texture; 48 hrs material delivery\supervision;4 hrs

SEPTEMBER 2 T TOO 8- 8-2022 2022 $30.00 85 $2,550.00 hang\frame; 36 hrs taping\texture; 45 hrs material delivery\supervision;4 hrs

DESCRIPTION RA RATE TE QTY AMOUNT

SEPTEMBER 9 T TOO 15- 15-2022 2022 $30.00 64 $1,920.00 hang\frame; 0 hrs taping\texture; 58 hrs material delivery\supervision;6 HRS

SEPTEMBER 23 T TO O 29- 29-2022 2022 $30.00 68 $2,040.00 hang\frame; 32 hrs taping\texture; 32 hrs material delivery\supervision;4HRS

SEPTEMBER 30 T TO O OCT OCTOBER OBER 9- 9-2022 2022 $30.00 15 $450.00 hang\frame; 0hrs taping\texture; 12 hrs material delivery\supervision;3HRS

MATERIAL $2,500.00 1 $2,500.00

OVERHEAD 15 % $2,530.00 1 $2,530.00

MARKUP $5,820.00 1 $5,820.00

SUBT SUBTO OTAL $25,220.00 TAX ((0 0%) $0.00

TOTAL $25,220.00 PAID -$12,500.00 Nov 10, 2022

BAL BALANCE ANCE DUE USD $12,720. $12,720.00

PROJECT ADDRESS; 5360 E ROCKRIDGE RD PHOENIX,AZ 85018

LONEST ONESTAR AR DRYW DRYWALL ALL LL LLC C INV INVOICE OICE INV0059 Business Number ROC CR-10#328838 CR-7#337697 DATE 591 PLAZA CIRCLE,PO BOX 1688 Oct 28, 2022 LITCHFIELD PARK DUE 85340 On Receipt [number redacted] [email redacted] BAL BALANCE ANCE DUE USD $1,478.00

BILL T TO O

PRECISION BLUEPRINT REMODELING LL LLC C 449 E CHEYENNE RD SAN TAN VALLEY,AZ 85143 480-395-6044 [email redacted]

DESCRIPTION RA RATE TE QTY AMOUNT

hangers exterior drywall hang oct-8 $30.00 4 $120.00

tapers patching work , kitchen,office,living room and exterior drywall $30.00 18 $540.00 tape and first coat oct-9

taper patches 2nd coat $30.00 4 $120.00

tapers sanding patches, touch up and clean up $30.00 8 $240.00

materials $100.00 1 $100.00

overhead 10% $112.00 1 $112.00

markup 20% $246.00 1 $246.00

SUBT SUBTO OTAL $1,478.00 TAX ((0 0%) $0.00

TOTAL $1,478.00

BAL BALANCE ANCE DUE USD $1,47 $1,4788.00

PROJECT ADDRESS;

5360 E ROCKRIDGE RD PHOENIX,AZ 85018

approximately price by hour total; $43.00 by hour ( standard hour rate for this kind of jobs its $60.00 by hour)

Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS; 88 ROCKRIDGE AUG-5 to AUG-11 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 5-Aug FRIDAY rockridge 2 workers demolition and frame 16 FRIDAY FRIDAY 6-Aug SAT/SUN rockridge 2 workers demolition,frame and hang 16 8-Aug MONDAY rockridge 2 workers frame,demo, and hang 16 MONDAY MONDAY 9-Aug TUESDAY rockridge 2 hangers hanging kitchen and demo 16 TUESDAY 3 tapers taping kitchen 24 TUESDAY 10-Aug WEDNESDAY WEDNESDAY WEDNESDAY 11-Aug THURSDAY THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS; 11 ROCKRIDGE aug-13 to aug 18 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate FRIDAY FRIDAY FRIDAY 14-Aug SAT/SUN rockridge 1 taper kitchen work 2 MONDAY MONDAY MONDAY TUESDAY TUESDAY TUESDAY WEDNESDAY WEDNESDAY WEDNESDAY 18-Aug THURSDAY rockridge 1 taper kitchen work 9 THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS;57HRS ROCKRIDGE aug-19 to aug-25 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 19-Aug FRIDAY ROCKRIDGE 1 taper kitchen work,bathroom 9 FRIDAY FRIDAY SAT/SUN 22-Aug MONDAY ROCKRIDGE 1 taper kitchen work,bathroom 9 MONDAY MONDAY 23-Aug TUESDAY rockridge 1 taper kitchen work,bathroom\bedroom 10 TUESDAY 2 hangers patching bathroom\bedroom 12 TUESDAY 24-Aug WEDNESDAY ROCKRIDGE 1 taper kitchen,bathroom,beddroom 9 WEDNESDAY WEDNESDAY 25-Aug THURSDAY rockridge 1 taper kitchen bathroom,bedrooms 8 THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS ; 76hrs ROCKRIDGE aug-26 to sep-1 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 26-Aug FRIDAY rockridge 1 taper working on closets,basement, bedrooms 8 FRIDAY 2 hangers doing patches and frame 12 FRIDAY 27-Aug SAT/SUN rockridge 1 taper working on closets,basement, bedrooms 9 29-Aug MONDAY rockridge 1 taper working on closets, bathrooms 9 MONDAY MONDAY 30-Aug TUESDAY rockridge 1 taper, basement sanding, 1st floor bathroom, pantry 1st coat 9 TUESDAY TUESDAY 31-Aug WEDNESDAY rockridge 1 taper texture 1st floor room 4 WEDNESDAY WEDNESDAY 1-Sep THURSDAY rockridge 2 hangers working on living room ceiling 16 THURSDAY 1 taper ,sanding 1st floor room ,2nd coat pantry 9 THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS.- 12 HRS ROCKRIDGE OCT-7 TO OCT-13 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 7-Oct FRIDAY rockridge FRIDAY FRIDAY 9-Oct SAT/SUN rockridge 2hangers hanging exterior drywall board 4hrs 9-Oct SATURDAY rockridge 2 tapers,kitchen patches,living area,hallway patches ,office patches ,exterior 18hrs 10-Oct MONDAY rockridge 1 taper sanding and 2nd coat patches 4hrs MONDAY 11-Oct TUESDAY rockridege 2 tapers sanding and touch up patches ,clean up 8hrs TUESDAY TUESDAY 12-Oct WEDNESDAY rockridge WEDNESDAY WEDNESDAY 13-0ct THURSDAY rockridge THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS;81 hrs ROCKRIDGE sep-2 to sep-8 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 2-Sep FRIDAY rockridge 2hangers working on living room ceiling 9hr each 18 FRIDAY 1 taper working pantry c\b, kitchen patches 9 FRIDAY 3-Sep SATURDAY rockridge 2 hangers finishing ceiling living room 9hrs\each 18 SATURDAY rockridge 1 taper taping office ceiling and first coat both ceilings 9 5-Sep MONDAY rockridge no work MONDAY 6-Sep TUESDAY rockridge 1 taper leveling joints with box and screws mud coating 9 TUESDAY TUESDAY 7-Sep WEDNESDAY rockridge 1 taper doing 2nd box run on joints and screws 9 WEDNESDAY WEDNESDAY 8-Sep THURSDAY rockridge 1 taper sanding, patches and clean up level 3\4 tape 9 THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL;58 hrs ROCKRIDGE SEP-9 TO SEP-15 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 9-Sep FRIDAY rockridge 1 taper touch up ceilings living room and office 9 FRIDAY FRIDAY 10-Sep SAT/SUN rockridge 1 taper touch up living room walls 9 12-Sep MONDAY rockridge 2 tapers texture living area, moving stuff and cleaning 18 MONDAY MONDAY 13-Sep TUESDAY rockridge 2 tapers sanding texture, and touch up, moving stuff,cleaning 22 TUESDAY TUESDAY 14-Sep WEDNESDAY WEDNESDAY WEDNESDAY THURSDAY THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID ROCKRIDGE SEP-16 TO SEP-22 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate FRIDAY FRIDAY FRIDAY SAT/SUN MONDAY MONDAY MONDAY TUESDAY TUESDAY TUESDAY WEDNESDAY WEDNESDAY WEDNESDAY THURSDAY THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS;64 hrs ROCKRIDGE SEP-23 TO SEP-29 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 23-Sep FRIDAY rockridge 2 hangers drywall windows patching 16 FRIDAY FRIDAY 24-Sep SAT/SUN rockridge 2 hangers drywall windows patching 16 26-Sep MONDAY MONDAY MONDAY 27-Sep TUESDAY rockridge 2 tapers ,patches, cornerbead inst,baseboard touch up 18 TUESDAY and first coat windows area TUESDAY 28-Sep WEDNESDAY WEDNESDAY WEDNESDAY 29-Sep THURSDAY rockridge 2 tapers, sanding ,2nd coat, and clean up windows area 14 THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: Ti me Car d Week Ending: Employee Name Employee ID TOTAL HRS.- 12 HRS ROCKRIDGE SEP-30 TO OCT-6 Gross Pay:

Time and Wage Reporting Note: All overtime must pre-aprproved by your manager Date Day: Job Number Job Adress or Description Coast Code HOURS Hourly Rate 30-Sep FRIDAY rockridge 2 tapers sanding windows area, touch up and clean up 12 FRIDAY FRIDAY 1-Oct SAT/SUN 3-Oct MONDAY MONDAY MONDAY 4-Oct TUESDAY TUESDAY TUESDAY 5-Oct WEDNESDAY WEDNESDAY WEDNESDAY 6-Oct THURSDAY THURSDAY THURSDAY Signatures Sign and print your name. Sign for receint of check Employee Signature By sisning, I certify to the best of my knowledge the information I provided is accurate and true an that complied whit Employee Signature certifying receipt of all safety rules; regulations and company policies. check and approval

Approval signature of Superrintend/Manager Date Check received: 01231456ÿ22892ÿ ÿÿÿ ÿÿ8ÿÿÿÿÿ Received !ÿÿ"ÿ49459Legal 32#5 08/17/2023 2345ÿ7839:4:ÿ;<345=>839:4:?@AB=:9=CADE

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$ 811%!!%11191&'()5*+420,-.(,$(, $($ 8233##*03*42+420/33203"!8+20+25+59530##0024*1 414 7/13/23, 2:18 PM Received Legal Precision Blueprint Development Mail - Aldo Response - Budget explanation

08/17/2023 Accounting User <[email redacted]>

Aldo Response - Budget explanation Taylor Hagberg <[email redacted]> Thu, Jul 13, 2023 at 2:18 PM To: Accounting User <[email redacted]>, Raul Banuelos <[email redacted]>

The original drywall budget for the Head remodel included a subcontractor payout amount of $12,500. Once the project started. There were changes to the amount of work and it brought the payout total to $14,900. There was a total of 40 sheets of new drywall added to the project that required a level 4 smooth finish. There was also roughly 1000 wall square footage of patch work throughout. This total scope of work, regardless of the amount of time it should have taken, should be no more than $10,000-$12,000 total. Precision Blueprint Remodeling charged the client a little more because of the items in place that we had to work around, the timing of some of the work and access to certain work changes at certain times. Aldo is charging Precision Blueprint Remodeling well over double the value of the work that was completed; again, regardless of the amount of time the work took we hired a drywaller for the quantity, and not per hour. Lonestar Drywall completed a commercial Tenant Improvement project for Precision Blueprint Remodeling 2 months prior to starting the Head Remodel. This project required over 100 sheets of drywall up to 10’ and was a combination of 5/8” drywall, ¼” drywall, acoustic ceiling tiles and painting ceiling tiles. This project was easily twice the labor, twice the material and twice the value ($23,500) in terms of the scopes provided by Lonestar drywall but he is charging roughly the same amount of money for the Head Remodel project. Lonestar Drywall, also, did not complete the ceiling tile paint even though he was paid for it. This scope had a value of $1,500 so he overpaid this amount. Another project, Precision Blueprint Remodeling, hired Lonestar drywall for 2 weeks after the tenant improvement project required over 60 sheets of drywall and was a 2-story complete drywall project. Lonestar charged us $11,943 and again, was much more work than the project attached to the complaint, but he charged much less than half that amount. In my opinion, it appears that once Lonestar Drywall owner, Aldo, recognized the status of the homeowner for the Head Remodel, he felt he could charge more for that fact alone. There is not enough work involved in the Head Remodel project to justify the amount they are charging. That is evident not only in the numbers but in the experience that Precision Blueprint Remodeling has had with the relationship with Lonestar drywall during the previous projects. There were also multiple complaints from the homeowner for the head remodel that involved Lonestar Drywall wasting a lot of time standing around and not working. We took these complaints seriously and now recognize the bad faith and business practices presented by Lonestar Drywall. My advice, along with many others, was for Precision Blueprint Remodeling to quit using Lonestar Drywall. [Quoted text hidden]

https://mail.google.com/mail/u/1/?ik=d616c33204&view=pt&search=all&permmsgid=msg-f:[number redacted]&simpl=msg-f:[number redacted] 1/1 7/13/23, 1:26 PM Account Detail - Wells Fargo Received Legal 08/17/2023 Check Details

Item 140 of 200 Show partial image Print

Check Number 1906

Date Posted 10/07/22

Check Amount $12,500.00

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For your security, information like account numbers, signatures, and the ability to view the backs of checks have been removed from the images. You can see full or partial fronts and backs of the images by using the link at the top of the window.

Equal Housing Lender

https://connect.secure.wellsfargo.com/accounts/start?p1=yes&SAMLart=AAQCG%2BoEQCR14WDgSxaU4QNGCHpGcoS1YqKHOTgiqAI6RrvacjUby… 1/1 LONESTAR DRYWALL LLC Received Legal INVOICE Business Number ROC#328838 08/17/2023INV0047 591 PLAZA CIRCLE,PO BOX 1688 DATE

LITCHFIELD PARK Aug 16, 2022

85340 DUE [number redacted] On Receipt [email redacted] BALANCE DUE USD $0.00

BILL TO

PRECISION BLUEPRINT REMODELING LLC 449 E CHEYENNE RD SAN TAN VALLEY,AZ 85143 480-395-6044 [email redacted]

DESCRIPTION RATE QTY AMOUNT

FRAMING\DRYWALL\ACT $23,500.00 1 $23,500.00 5\8" type x drywall on new framing interior walls

1\4" drywall on demising walls

coats of taping mud on new drywall

skip texture on new drywall and on drywall repairs

drywall repairs on existing drywall to remind

Acoustical grid ceiling frame repair where walls will be removed

damaged ceiling tiles replacement

flat black paint on acoustical ceiling tile and grid

ceiling high

ADITIONAL WORK; multiple holes on demising walls

drywall strip patch bellow all existing drywall

ft of xp mold resistant drywall installation on bathrooms

https://app.invoicesimple.com/v/eQoPuiOlAH 1/2 7/13/23, 1:49 PM Invoice INV0047 Received Legal DESCRIPTION RATE 08/17/2023 QTY AMOUNT

EXTRA: more ceiling repairs than the estimate before

Extra repairs on bathrooms

Door frame

Fire wall patching for inspection above act

SUBTOTAL $23,500.00 TAX (0%) $0.00

TOTAL $23,500.00 PAID -$23,500.00 Sep 6, 2022

BALANCE DUE USD $0.00

PROJECT ADDRESS; 888 S GREENFIELD RD Gilbert, AZ 85296

INCLUDED; DRYWALL\ CEILING TILE SYSTEM LABOR MATERIAL NOT ONLINE PAYMENTS CLEANING ANY REPAIRS OR PUCH JOB WILL BE DO IT AFTER 90% OF THE SUM ON THE CONTRACT ITS PAID IN FULL EXTRA REPAIRS WILL BE CHARGED AT $45.00 DLS BY HOUR

https://app.invoicesimple.com/v/eQoPuiOlAH 2/2 Received Legal 08/17/2023 Received 08/31/2023 ROC Legal

Jonathan A. Dessaules, State Bar No. 019439 Michael R. Perry, State Bar No. 007478 Thomas E. Raccuia, State Bar No. 035630 DESSAULES LAW GROUP 7243 North 16th Street Phoenix, Arizona 85020 602.274.5400 tel 602.274.5401 fax [email redacted] [email redacted] [email redacted] Attorneys for Respondent REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA Lonestar Drywall, LLC Case No. 2023-07143 Complainant, v. WRITTEN ANSWER TO CITATION AND COMPLAINT Precision Blueprint Remodeling LLC License No. ROC 334211, Respondent. Respondent Precision Blueprint Remodeling LLC, hereby submits its Written Answer to the Citation and Complaint as follows: Charge 1: A.R.S. § 32-1154(A)(10) – Failure by a licensee or agent or official of a licensee to pay monies in excess of $750 when due for materials or services rendered in connection with the licensee’s operations as a contractor unless the licensee proves that the licensee lacks the capacity to pay and has not received sufficient monies as payment for the particular construction work project or operation for which the services or materials were rendered or purchased. Answer to Charge 1: Respondent denies Charge 1, inter alia, on the basis that the monies Complainant alleges Respondent failed to pay are not “due.” Respondent paid Complainant the full amount it received from the homeowner for Complainant’s work. See A.R.S. § 32-1183. Received 08/31/2023 ROC Legal

Complainant’s invoices reflect hourly billing contrary to the budget agreed upon by the parties and the homeowner. Additionally, Complainant and Respondent’s established course of dealing does not include hourly billing. See AROK Const. Co. v. Indian Const. Serv., 174 Ariz. 291, 298 (App. 1993). Complainant staffed the job with excessive manpower and invoiced hourly for personnel who were either not on site for the hours claimed or, if present, were not actually performing work. Complainant deliberately inflated its labor costs because of its perception of the homeowner’s wealth. Finally, Complainant failed to complete its scope of work, and Respondent incurred costs hiring another contractor to do so. Respondent reserves the right to assert additional defenses in advance of and/or at any administrative hearing in this matter. WHEREFORE, having answered the Citation and Complaint, Respondent requests this Citation be dismissed in its entirety. DATED this 31st day of August 2023. DESSAULES LAW GROUP By: /s/ Thomas E. Raccuia Jonathan A. Dessaules Michael R. Perry Thomas E. Raccuia Attorneys for Respondent Received 9/1/23, 7:58 AM 08/31/2023 State of Arizona Mail - Case No. 2023-07143: Written Answer to Citation and Complaint ROC Legal

Answers - AZROC <[email redacted]>

Case No. 2023-07143: Written Answer to Citation and Complaint message

Valerie Kennedy <[email redacted]> Thu, Aug 31, 2023 at 11:09 AM To: "[email redacted]" <[email redacted]> Cc: Thomas Raccuia <[email redacted]>, Michael Perry <[email redacted]>

Good Morning:

Attached please find Respondent’s Written Answer to Citation and Complaint.

Valerie Kennedy Paralegal [email redacted] 602-753-3866 (direct) | 602-274-5400 (Main) 7243 N. 16th St., Phoenix, AZ 85020

This email is for the intended recipient only. If you believe you have received this e-mail in error, we ask that you notify the sender and then delete the email.

20230830 Written Ans to Citn and Cx.pdf 112K

https://mail.google.com/mail/b/AEoRXRRdJTZWyEphHARHxrXhvJEzvyzBtazgCl8lokKkwYuhrwpp/u/0/?ik=581c53cf5c&view=pt&search=all&permthid… 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