2023A-09065-NPC-ROC Notice of Hearing and Packet MAILED

2023A-09065-NPC-ROC · Registrar of Contractors · 2023-10-17

REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA Rova Roofing LLC, Case No. 2023-09065 COMPLAINANT, Docket No. 2023A-09065-NPC-ROC v. NOTICE OF HEARING ON CONTESTED CASE LUMINOUS BUILDERS LLC DBA: Luminous Energy License Nos. ROC 335707, 336265,

RESPONDENT.

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

HEARING INFORMATION The hearing is set for:

December 4, 2023 1:00 PM Kay Abramsohn 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 24, 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 17, 2023.

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

Copy mailed via USPS First Class mail October 17, 2023 to: Respondent(s) LUMINOUS BUILDERS LLC DBA: Luminous Energy 1445 W McDowell Rd Ste D 104 Goodyear, AZ 85395 Jeffrey L. Laskin, Esq. 1212 E Osborn Rd Ste 2 Phoenix, AZ 85014

Complainant(s) Rova Roofing LLC 2420 S Power Rd Ste 104 Mesa, AZ 85209

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

Case No. 2023-09065 /

Douglas A. Ducey, Governor Jeffrey L. Fleetham, 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

Douglas A. Ducey, Governor Jeffrey L. Fleetham, 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

Douglas A. Ducey, Governor Jeffrey L. Fleetham, 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

August 10, 2023

Via U.S. Mail and Email

Complainant Rova Roofing LLC 2420 S Power Rd Ste 104 Mesa, AZ 85209

Rova Roofing LLC 3134 E McKellips Rd #69 Mesa, AZ 85213

Via U.S. Mail and Email

Respondent LUMINOUS BUILDERS LLC 1445 W McDowell Rd Ste D 104 Goodyear, AZ 85395

Re: Complaint No. 2023-09065

Dear Complainant and Respondent:

The Registrar received a complaint filed against LUMINOUS BUILDERS 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 August 17, 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, AZ 85005-8244 In-Person: 1700 W. Washington St., Ste. 105, Phoenix, AZ 85007-2812 Email: [email redacted]

The Registrar will not issue a citation before August 17, 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.

1700 W. Washington Street, Suite 105 · Phoenix, AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg100 4/21 Sincerely,

/s/ Katelyn Rolling Katelyn Rolling Legal Assistant II Legal Department Arizona Registrar of Contractors

1700 W. Washington Street, Suite 105 · Phoenix, AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg100 4/21 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Katelyn Rolling <[email redacted]>

Follow Up on Response 2023-09065 message

Katelyn Rolling <[email redacted]> Thu, Aug 17, 2023 at 9:58 AM To: "Jeffrey L. Laskin, Esq." <[email redacted]>

Hello Mr. Laskin,

I have reviewed the Response you filed on behalf of your client, LUMINOUS BUILDERS LLC DBA: Luminous Energy, in the complaint that was filed by Rova Roofing LLC. I have a couple of follow up questions for you, as I did for Rova Roofing LLC. First, do you have documentation that would show your client told Rova Roofing LLC they did not want to use Rova Roofing LLC's services for the 15316 W Roma Ave job (estimate 3702 / invoice 1815). Second, do you have documentation showing your client has attempted to pay Rova Roofing LLC for invoice 1889?

Katelyn Rolling Legal Assistant II Arizona Registrar of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007 (602) 542-1525 RECEIVED 08/18/2023 ROC LEGAL Katelyn Rolling <[email redacted]>

Reply to ROC in Luminous Builders adv. Rova Roofing; 2023-09065 message

Jeffrey L. Laskin, Esq. <[email redacted]> Fri, Aug 18, 2023 at 5:19 PM To: [email redacted] Cc: [email redacted]

Registrar,

Pursuant to the request of the ROC, by and through Katelyn Rolling, Legal Dept.,for a reply to her email of yesterday, August 17, 2023, attached please find Luminous' detailed reply.

Thank you.

Jeffrey L. Laskin, Esq. JEFFREY L. LASKIN, P.C. 1212 EAST OSBORN ROAD, STE. 2 PHOENIX, AZ 85014 P 602-266-9207 F 602-266-0603 [email redacted]

This is an attempt to collect a debt and any information obtained will be used for that purpose. This message and any attachments may contain confidential information that is protected by the attorney-client and/or work product privilege. Unless you are the addressee, you may not use, copy or disclose to anyone any information contained herein. If received in error, please reply and delete.

Luminous Builders reply to ROC re Rova Roofing complaint 8-18-23.pdf 98K RECEIVED 08/18/2023 ROC LEGAL

JEFFREY L. LASKIN, P.C. Attorney at Law 1212 East Osborn Road, Suite 2 Phone (602) 266-9207 Phoenix, Arizona 85014 Fax (602) 266-0603 [email redacted]

August 18, 2023

Via email to [email redacted] and [email redacted]

Registrar of Contractors 1700 W. Washington St., Ste. 105 Phoenix, AZ 85007

Re: Luminous Builders LLC adv. Rova Roofing LLC; Complaint 2023-09065

Registrar,

This letter is in reply to the Registrar’s email request for additional information made yesterday.

Luminous Builders LLC (“Luminous”), absent a written agreement to the contrary, pays its bills on a net sixty (60) day basis. Rova Roofing (“Rova”) submitted its invoice for the Roma job on April 3, 2023. Shortly before the net 60-day mark for payment of invoices by Luminous, the company’s Accounts Payable and Contract Resolutions Department was unable to match the invoice with a contract for that job. Subsequently, upon deeper investigation, Luminous was unable to locate any semblance of a contract tendered by Rova, signed by Rova or Luminous, including not locating a purported signed revised estimate, or any other form of authorization whatsoever, to Rova to proceed on the Roma job.

A review of the emails submitted with Rova’s complaint do not contain a single mention that Rova ever reported to Luminous that they resolved the changes to the materials, tile colors, and scope of work on the Roma job that clearly superseded the estimate dated January 10, 2023. Rova also failed to include that new estimate in its complaint. The emails readily show that Rova quit communicating with Luminous altogether and whatsoever on the Roma job from February until sending the invoice on April 3, 2023. Months had gone by with zero communication on Roma and Luminous was not even aware that Rova had purportedly worked on the Roma roof. Rova did the RECEIVED 08/18/2023 ROC LEGAL

work with no contract, no authorization, and certainly not in keeping with the terms of its estimate it is now shamefully and wrongly trying pass-off as a contract.

The “Special Instructions” on page two of Rova’s sham alleged contract/estimate specifically state and insist in the Section labeled “ADDENDA/CHANGE ORDERS:” that “[a]ny changes or additions to the original work order must be mutual and contractually agreed upon between Rova Roofing and the customer, prior to any changes or additional work can be completed”. Rova has not produced, nor can it, any documentation reflecting Luminous’ and Rova’s mutual and contractual agreement on the myriad of changes that were required on the Roma job following the initial estimate on January 10th. Given Rova never presented Luminous with anything showing Rova’s compliance with all the homeowner’s requested changes to the original estimate, it is impossible for Rova to have complied with its own Special Instructions. Therefore, and moreover, Luminous was never given the chance to provide a mutual and contractual assent to the job. The material aspects of the job were never finalized with Luminous. Several months later, however, it gets confronted with the drummed-up invoice. Rova, as with the two smaller jobs, Moreland and Windrose, which Rovat clearly arranged with Jill Barry, who is not affiliated with or authorized to enter into contracts by Luminous, is trying to stick Luminous with the bill. There, Luminous, as in Roma, had initial contact with Rova on doing the jobs, but lost contact with Luminous due to unfulfilled and agreed to changes, long passage of time, and no communication from Rova. Luminous, until having the invoices dumped on it, had no idea Rova was out there doing the work under the quixotic fantasy and fraudulent guise it was at the mutual contractual agreement of Rova and Luminous.

Rova further fails to adhere to its own Special Instructions under the Section called “Payment:” wherein it states “[a]ll work estimated over $4,000. Payment to be made as follows. 40% down, 40% upon completion of dry-in and stack and the final 20% once the job is complete”. There was no down payment made on Roma; not even a scintilla of a reference or request by Rova to Luminous to make a 40% deposit before Rova commenced work. So…, we have Rova trying to enforce an early estimate that was clearly superseded by numerous changes to the job, zero consent to the changes by Luminous (contrary to the express language requirement of the Special Instructions), no proof of Rova supplying the final and completed changes to Luminous for approval before starting the job, no deposit requested from Luminous by Rova (contrary to the express requirement of the Special Instructions), and Rova literally disappearing from Luminous’ radar on the Roma job for several months until it pops up with its ridiculous invoice in April. The Roma claim is purely a con. It is bad enough that Luminous lost a large remodel and solar job on Roma due to Rova’s amateur business practices completely souring the homeowner as to anything remotely having a nexus with Rova.

As further detail, on or about June 15, 2023, Cris Arroyo and Aldo Arroyo established telephonic contact with Kari Petterson, after receiving her email late in the evening the day before. Her email is informing Messrs. Arroyo that she had not heard from them in a while and there appeared to be an outstanding invoice. RECEIVED 08/18/2023 ROC LEGAL

During this telephonic conversation, Aldo Arroyo specifically asked Kari Petterson for all "Contracts" signed by Luminous Builders LLC and clarified to her that Luminous Energy, whom the invoices named, did NOT participate in or get involved in the contracting of "roofing" jobs. Luminous Builders is the construction division and Luminous Energy the solar division. Further, Aldo Arroyo informed Kari that neither Luminous Builders LLC nor Luminous Energy had any contracts, either active or inactive, for ANY of the invoices she was alleging and pushing.

Further, during this discussion Cris Arroyo upon informing Kari that none of the invoices she was forwarding to Luminous Builders LLC pertained to Luminous Builders LLC, Kari commented, to the effect, "I think they are all owed by Luminous Energy." In turn, Aldo Arroyo again informed Kari that made absolutely no sense, as NO contracts were ever signed with any Contractor nor Sub-Contractor as Luminous Energy, as it was not involved in any of the construction work. Still, Aldo Arroyo firmly requested Kari provide him all signed contracts by "Luminous Energy" and/or Luminous Builders LLC she was alleging were owed upon.

Despite the poignant request, Messrs. Arroyo did NOT hear back from Kari any further, until on or about June 28, 2023, Kari made an unexpected and unannounced visit to Luminous’ office in Goodyear, AZ. During this uninvited visit to the office, Kari was met with the staff, who reported Kari appeared "distressed" and "disturbed". After Luminous’ staff advised Kari that neither Aldo or Cris Arroyo were available, as they were not typically in the office to handle unplanned visits on a Walk-in basis, the staff reported Kari became vulgar and unprofessional, utilized foul language and demanded to speak to "someone in charge".

As a result, rather than choosing to escort Kari out of the building, Kari met with Luminous’ Business Operations Manager, Esmeralda Rosario and its Business Relations/Finance Manager, Jennifer Hazen. According to both ladies, Kari was informed no record existed of ANY “open jobs" on any of the alleged addresses. Once more, Kari brought up that the invoices were owed by "Luminous Energy". In turn, both employees quickly advised Kari that ALL General Contracting work was completed under Luminous Builders LLC, NOT Luminous Energy. Nevertheless, Luminous’ staff asked Kari to provide them ALL of the signed contracts pertinent to the alleged invoices. At that request, Kari became hostile towards them and changed her demands, now in telling them she would not show them "Anything" until she spoke to either, "Aldo or Cris."

Once more, Kari was reminded by staff that neither Aldo Arroyo or Cris Arroyo were present at the office, and again asked her to provide them all signed contracts, as they were actually the employees who handled Accounts Payable and Contract Resolutions on behalf of Luminous Builders LLC. Kari exited the office stating she would retrieve the "documents" from her vehicle; however, remarkably, she never returned or produced the contracts. RECEIVED 08/18/2023 ROC LEGAL

On or about June 29, 2023, Kari sent Cris and Aldo Arroyo a Demand for Payment, inclusive of all 4 invoices. However, once more, she did NOT provide the signed contracts Luminous had been asking for since the beginning. Consequently, Cris Arroyo contacted Kari by telephone and once more asked her to please forward Luminous ALL documents supporting her alleged invoices. Kari advised Cris Arroyo to the effect of, "I have to dig those up". Still, Cris Arroyo informed Kari he did recognize one of the invoices, the Colter St. project, and informed her he clearly remembered them speaking about it, under Luminous Builders LLC, weeks earlier, although he never received any documentation about it. He did recall speaking to her on the phone and sending her an email "authorizing the work".

In turn, Cris advised Kari, it was precisely the reason why he did NOT agree with ANY of the other 3 invoices based on precedent of actions with her. The ONLY time when he gave clear and concise authorization for a project, without a signed contract, was by that one email on Colter. Nevertheless, Cris asked Kari if she had ANY documents that proved either he or Aldo authorized the 3 other jobs in writing. Kari stated to the effect of, "I should", and added she would forward them once located. Of course, that never came to fruition.

During this same conversation, Cris, informed Kari that in her demand letter she noted her intent to file a ROC Claim and/or send "Luminous Energy" to collections, even though she had failed to provide Luminous ANY written contract to date. Kari maintained the demand letter was generic and would follow-up once she located the documents supporting her claim. Cris terminated the phone call by advising Kari that Luminous Builders LLC was willing and able to issue payment for the Colter St. project in the amount of $5,200.00, as the agreed price, immediately; however, Kari ignored the offer and maintained, inexplicably, such project might still be under Rova's "Net Terms" (example Net 30, Net 60) and added she was more concerned about the Roma Ave project. That was the last time any employee and/or other representative of Luminous Builders LLC had ANY contact with Kari with, still, with no production of signed contracts from Luminous.

The offer to pay Kari on Colter St. was reiterated last week in writing and set forth in a detailed and fact (true facts) driven Settlement Communication to Kari/Rova Roofing under Rule 408, Arizona Rules of Evidence1. Luminous’ written offer to pay her what the parties agreed to for performance of the work was rejected by Kari without any reason provided, except that she wants it included in the ROC “process”. As explained in my earlier response dated August 16th, Kari is using the one job Luminous agreed to, has offered to pay her for multiple times, and she refuses payment for, as the beacon to sustain the ROC Complaint and to hold out some hope to be a prevailing party in the matter because she can prevail on at least one of her four claims.

Reason for not attaching copy hereto. Do not wish to violate the sanctity of settlement communications. RECEIVED 08/18/2023 ROC LEGAL

For the foregoing reasons and those set forth in the response it filed with the Registrar on August 16th, Luminous reiterates it request that the complaint be denied, and no citation issued. Alternatively, the Registrar either: (i) deny the complaint but with the comment to Rova that it may file an amended complaint that excludes the Colter job; or, (ii) should the Registrar decide to issue a citation, the Colter job should be excised from the complaint, and the matter proceed on the first three items.

Very truly yours,

JEFFREY L. LASKIN, P.C.

Jeffrey L. Laskin Jeffrey L. Laskin

JL/ch cc: Luminous Builders LLC REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA

Rova Roofing LLC, Case No. 2023-09065 COMPLAINANT, v.

LUMINOUS BUILDERS LLC, CITATION DBA: Luminous Energy, License Nos. ROC 335707, 336265, RESPONDENT.

The Registrar issues this Citation to LUMINOUS BUILDERS LLC, dba Luminous Energy, (“Respondent”) under A.R.S. § 32-1155(A). If Respondent fails to answer this Citation by September 8, 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 August 7, 2023, Rova Roofing LLC (“Complainant”) filed a written complaint with the Registrar against Respondent. 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 licensee proves that the licensee lacks 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 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. 2023-09065. 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, AZ 85007-2812 Mail: P.O. Box 18244, Phoenix, AZ 85005-8244 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 September 8, 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

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 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 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

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 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 24, 2023. By: /s/ Margaret Lindsey Margaret Lindsey Assistant General Counsel Legal Department Arizona Registrar of Contractors

COPY of the foregoing mailed by Certified Mail, Return Receipt Requested, August 24, 2023 to: Respondent Certified Mail No: [number redacted] LUMINOUS BUILDERS LLC DBA: Luminous Energy 1445 W McDowell Rd Ste D 104 Goodyear, AZ 85395 Copy mailed by USPS First Class Mail this same date to:

Respondent LUMINOUS BUILDERS LLC DBA: Luminous Energy 1445 W McDowell Rd Ste D 104 Goodyear, AZ 85395 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 Respondent’s Attorney Jeffrey L. Laskin, Esq. Jeffrey L Laskin PC 1212 E Osborn Rd Ste 2 Phoenix, AZ 85014

Complainant Rova Roofing LLC 2420 S Power Rd Ste 104 Mesa, AZ 85209

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 Case No. 2023-09065 / KR

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 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 1740 W Adams St., Lower Level, 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 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 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received by Investigations 08/07/2023 2023-09065 Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 09/08/2023 ROC Legal Received 9/11/23, 8:18 AM 09/08/2023 State of Arizona Mail - Answer to Citation and Complaint; Request to Dismiss; 2023-09065; Lumi nous Builders adv. Rova Roofing ROC Legal

Answers - AZROC <[email redacted]>

Answer to Citation and Complaint; Request to Dismiss; 2023-09065; Lumi nous Builders adv. Rova Roofing message

Jeffrey L. Laskin, Esq. <[email redacted]> Fri, Sep 8, 2023 at 3:58 PM To: [email redacted] Cc: [email redacted], [email redacted]

Re: Written Answer to Citation and Complaint; Request to Dismiss ROC Case No.2023-09065 Luminous Builders LLC adv. Rova Roofing LLC

Registrar:

Attached for filing and action thereon is Respondent's Written Answer to Citation and Complaint and Request to Dismiss in the above-referenced matter.

Please do not hesitate to contact counsel below with any questions.

Thank you.

Jeffrey L. Laskin, Esq. JEFFREY L. LASKIN, P.C. 1212 EAST OSBORN ROAD, STE. 2 PHOENIX, AZ 85014 P 602-266-9207 F 602-266-0603 [email redacted]

Luminous Builders Answer to Citation and Request to Dismiss with Exhibits 2023-09065 9-8-23.pdf 1176K

https://mail.google.com/mail/b/AEoRXRRCTsDTwCUL8Adw_KUpVHao8e-LysYJar3LdQFfDgqxqagS/u/0/?ik=581c53cf5c&view=pt&search=all&permth… 1/1 Mediation Notice

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

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