2023A-11453-CHC-ROC Notice of Hearing & Packet MAILED 2023-11453.pdf

2023A-11453-CHC-ROC · Registrar of Contractors · 2024-07-31

REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA

Laura Strangio , Case No. 2023-11453

COMPLAINANT, Docket No. 2023A-11453-CHC-ROC

v. NOTICE OF HEARING ON CONTESTED CASE North Construction LLC License No. ROC 305312,

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

HEARING INFORMATION The hearing is set for:

September 16, 2024 9:00 AM 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 May 28, 2024. 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)(2)(b) Charge: 2 A.R.S. § 32-1154(A)(3) - R4-9-108(c)

Charge: 3 A.R.S. § 32-1154(A)(22)

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

be a party to the hearing.

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

argument to the administrative law judge.

The Registrar’s assigned investigator will appear as a witness at the hearing. RIGHT TO BE REPRESENTED The parties to the administrative hearing may choose to be represented by an attorney.

A.R.S. § 41-1092.07(B). If one of the parties is a company, the company may be represented

by an officer or employee if that person satisfies the conditions set forth in A.R.S. § 32-

1156(B).

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

HEARING PROCEDURES AND RULES The administrative hearing will be conducted in accordance with A.R.S. §§ 41-1092

to -1092.12, and A.A.C. R2-19-101 to -122. The parties should review the statutes, rules, and processes governing the administrative hearing. Copies of the statutes, rules, and articles regarding the administrative hearing process can be found at https://www.azoah.com/.

REGISTRAR’S APPEARANCE BY VIDEO CONFERENCE OR TELEPHONE

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

HEARING PACKET

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

certain documents to the parties and the Office of Administrative Hearings. These documents are attached to this Notice of Hearing as the “Hearing Packet.” If any party wishes to submit additional evidence, they must do so during the hearing after completing a disclosure statement. See “Disclosure Statement” section below.

SUBPOENAS FOR TESTIMONY FROM A WITNESS OR DOCUMENTS

The parties to the hearing must be prepared to present evidence in support of their

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

possession, the party must prepare and file a written subpoena for the Administrative Law Judge to review and sign, if approved. A.R.S. § 41-1092.07(C). Forms for requesting a

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

DISCLOSURE STATEMENT

At least seven calendar days before the hearing, each party must prepare and serve a disclosure statement on all other parties, and file it with the Office of Administrative Hearings. A.A.C. R4-9-118; A.A.C. R2-19-108. The disclosure statement must include any exhibit the party will use at the hearing. A party’s failure to timely disclose any witness or exhibit, without good cause, may result in the administrative law judge excluding those witnesses or exhibits from being used at the hearing. A.A.C. R4-9-118(C). A sample disclosure form is available on the Registrar’s website at https://roc.az.gov/forms/RC-L-800A%20- %20Prehearing%20Disclosure%20Statement%2020191007v4.pdf

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 July 31, 2024.

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

Copy mailed via USPS First Class mail July 31, 2024 to:

Respondent(s) North Construction LLC 4826 W Country Sky Dr. Tucson, AZ 85742

Respondent's Attorney Justin D. Castillo, Esq. 4574 N 1st Ave Ste. 150 Tucson, AZ 85718 Complainant(s) Laura Strangio 445 E Glenhurst Dr Oro Valley, AZ 85704 Complainant's Attorney Evan L. Thompson, Esq. 3430 E Sunrise Dr Ste 110 Tucson, AZ 85718 Copy sent electronically this same date to: Respondent at email address on record with the Registrar Respondent’s Attorney at email address of record with Registrar Complainant at email address on record with the Registrar Complainant’s Attorney at email address of record with Registrar

Case No. 2023-11453 /

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

Complainant: Laura Strangio 445 E Glenhurst Dr Oro Valley, AZ 85704

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C008 05/21 Respondent: North Construction LLC DBA: 4826 W Country Sky Dr Tucson, AZ 85742

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C008 05/21 October 11, 2023

Jobsite Inspection Notice Re: Complaint Number 2023-11453

Dear Complainant and Respondent:

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

A jobsite inspection is scheduled for November 1, 2023 at 1:00 PM. The Complainant is required to be present. The Respondent’s attendance is requested and encouraged. The Registrar encourages both parties to make a good faith effort to resolve this complaint prior to the jobsite inspection.

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

RESPONDENT: 1. Enclosed is a copy of the complaint. Under A.R.S. § 32-1155(D) you must be allowed, upon request, the opportunity to inspect the work complained of within fifteen days of the date of receipt of this notice. 2. To assist the assigned investigator in evaluating the merits of the complaint, please submit a response to the enclosed complaint to the assigned investigator prior to the scheduled inspection. 3. If you do not attend the jobsite inspection, your absence may negatively impact the investigation, and your interests. 4. If a building permit(s) was required for this project, please have the building permit information available at the jobsite inspection.

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C008 05/21 If either party needs to reschedule the jobsite inspection, please notify the assigned investigator at least three business days prior to the inspection date to schedule a new date and time.

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

Sincerely, Jason Simpson Jason Simpson, Investigator 602 7716753 [email redacted] 1700 W Washington St, Suite 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 C008 05/21 A Guide to Jobsite Inspections

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

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

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

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

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

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

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

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C008 05/21 If you have not filed a complaint yet or have not been assigned an investigator, you can reach the Registrar’s compliance department at (877) 692-9762.

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C008 05/21 A Guide to Written Directives Purpose of the Jobsite Inspection When the Registrar receives a complaint against a contractor’s license, the Registrar generally schedules a Jobsite Inspection. The Jobsite Inspection serves two purposes: 1. To give the contractor an opportunity to inspect the complaint items; and 2. To give the Registrar an opportunity to determine if the contractor’s work violates Arizona law.

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

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

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

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

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

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

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C008 05/21 Work performed after the directive ends: After the Directive period ends, a property owner may choose to allow the contractor to continue its work. The Registrar encourages parties to work cooperatively, but cannot require a homeowner to continue to allow a contractor access to the property after the Directive period ends in order for the administrative process to continue. Denying access after the Directive ends is not grounds to close or dismiss a complaint.

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

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C008 05/21 10/30/23, 2:39 PM State of Arizona Mail - ROC Complaint

Jason Simpson <[email redacted]>

ROC Complaint messages

JERAMY NORRIS <[email redacted]> Wed, Oct 25, 2023 at 8:15 PM To: "[email redacted]" <[email redacted]>, "[email redacted]" <[email redacted]>

Hi Laura, I hope you are doing well. I am submitting a formal response to your complaint withing the fifteenth days from receipt of the notice.

On October 12th 2022 I checked myself into a rehab facility after many life issues had brought me to a point where I had no other option. I asked my father to reach out to you and let you know that I would be in there for the next 30 days. You sent me an email (see attached) acknowledging this and told me you were praying for me. I appreciate that very much. While I was in rehab regaining control of my life, which had spiraled after my divorce from my wife of 25 years, you decided to continue the work on your home outside of my company. Up to that point I was paid, by you, for the work that I had completed...which included demo, framing, and a beam install. All other work was performed by people in whom do not work for me, I did not hire, I did not pay, and I did not contract with. All of these workers were hired by you. You made the choice that you did not want to obtain a permit for any of the work. Once you decided to continue the work on your home outside of the contract you had with North Construction LLC you also made the decision to hire people to do the work that I am not responsible for and have no way of verifying their competence or their quality of work. There are many items on your complaint form that were not even included in the original contract with North Construction. As soon as I finished my treatment I called you and I came to your home and met with you to discuss the project going forward. You made it clear that you had it handled and as I looked around I saw a lot of work completed by individuals that were hired directly by you. These are individuals I know nothing about and did not hire to work on your project. Therefore I am not sure why you are now requesting me to warranty work that was not completed by me or anyone in my company. These were people hire by you because you couldn't wait for me to continue after I took a very important timeout for my health. I do not regret doing the right thing and checking myself into treatment and my life is much better now for having done that. My clients are very important to me and the quality of my work is very important to me as it is how I have provided for my family for the last 23 years. I agree we have a contractual issue as you hired subcontractors to perform work without going through the proper steps that are stated within the contract that you signed, however, being that I have no idea who you hired to do the work in your house I do not believe it is reasonable for you to expect me to warranty their work. I am willing to meet with you and offer my help to work towards any possible solution where it is possible. I will make myself available to meet with you if you let me know what time works best for you.

Thank you,

Jeramy Norris Owner North Construction LLC

Sent from my T-Mobile 5G Device Get Outlook for Android

https://mail.google.com/mail/u/0/?ik=e5380e38a6&view=pt&search=all&permthid=thread-f:[number redacted]&simpl=msg-f:[number redacted]… 1/2 10/30/23, 2:39 PM State of Arizona Mail - ROC Complaint

Screenshot_20231025_201323_Outlook.jpg 228K

Jason Simpson <[email redacted]> Thu, Oct 26, 2023 at 7:22 AM To: JERAMY NORRIS <[email redacted]>

Received thank you [Quoted text hidden]

https://mail.google.com/mail/u/0/?ik=e5380e38a6&view=pt&search=all&permthid=thread-f:[number redacted]&simpl=msg-f:[number redacted]… 2/2 Complainant: Laura Strangio 445 E Glenhurst Dr Oro Valley, AZ 85704

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C010 04/21 Respondent: North Construction LLC DBA: 4826 W Country Sky Dr Tucson, AZ 85742

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C010 04/21 November 29, 2023

Re: Complaint Number 2023-11453

Dear Complainant and Respondent:

The jobsite inspection originally scheduled for November 1, 2023 has been rescheduled for November 30, 2023 at 1:30 PM.

If either party is unable to attend, the Registrar requires 36-hours advance notice for cancellation or continuance.

Complainant: Safe access is required to any area to be inspected.

Should you have any questions regarding the above, please contact me.

Sincerely,

James Carter James Carter, Investigator 602 7716770 [email redacted] 1700 W Washington St, Suite 105 Phoenix, AZ 85007

CC: Respondent Complainant Complainant Attorney

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C010 04/21 Complainant Attorney: Evan L. Thompson, Esq. 3430 E Sunrise Dr Ste 110 Tucson, AZ 85718

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C010 04/21 12/1/23, 1:32 PM State of Arizona Mail - RE: Strangio v. North Construction

James Carter <[email redacted]>

RE: Strangio v. North Construction message

Evan Thompson <[email redacted]> Fri, Dec 1, 2023 at 1:12 PM To: James Carter <[email redacted]>

Thank you for the response. The window issue is not a financial issue it is a scope of work issue. Mr. North told you that he did the demolition and only installed the beam that is not the truth. He demolished HVAC, Electrical and Plumbing and moved the same he also did the windows and doors as evidenced by the pictures you were sent. My point was this should all have been part of the permitting process. After he completes his correction if he does not get permits and inspections to cover the entirety of his scope we will seek a compliance inspection and if necessary a compliance hearing.

As far as the issue with aiding and abetting this was not an issue until Mr. North stated what he did at the inspection. We will file a new complaint to cover this.

Thank you again for your time in addressing the issues.

Evan Thompson Admitted in Arizona, Colorado & Texas

Thompson•Krone, P.L.C. 3430 East Sunrise Drive. Suite 110

Tucson, Arizona 85718 p: (520) 884-9694 f: (520) 323-4613

Tucson | Phoenix ThompsonKrone.com

CONFIDENTIALITY NOTICE: This e-mail from the Thompson•Krone, P.L.C. law firm contains confidential information intended only for the addressee(s). Information in or attached to it may be privileged, confidential or protected by law. If you are not the addressee (or a person responsible for delivering this transmission to the addressee) you are strictly prohibited from reading, copying, disseminating or distributing it. If you have received this e-mail in error, please notify me by replying to this message or calling me collect at 520.884.9694, then delete this e-mail from your system and destroy any print outs you may have made. Thank you.

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https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-f:[number redacted]… 1/3 12/1/23, 1:32 PM State of Arizona Mail - RE: Strangio v. North Construction

From: James Carter <[email redacted]> Sent: Friday, December 1, 2023 11:45 AM To: Evan Thompson <[email redacted]> Subject: Re: Strangio v. North Construction

Evan

Thank you for the pictures

At the conclusion of our meeting yesterday it was my understanding the only thing we were going to be addressing was the permit which I indicated to all parties I would be issuing that directive. As for the invoice for the windows, that is not something the Registrar would be addressing. For one the Registrar does not handle financial disputes and two no issues of workmanship were brought up at our meeting because we were only discussing the permit. As for the statement on Juan again the only thing I was investigating was the permit issue as I was told all other matters were being addressed outside of the Registrar. Had I been advised there that you or your client were going to bring up unlicensed work there would have been additional questions I would have asked Mr. North. The complaint itself does not mention unlicensed work. In order for me to be able to even issue him a warning letter there is additional information I need other than just the statement he made. Mr. North also has a right to know what allegations are being made as he requested to be present if any other items were going to be discussed, which at the meeting all parties agreed there were no other items to discuss. I will issue the directive by the end of business today for the need for the permit.

James Carter Investigator #229 Arizona Registrar Of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007 Phone(602) 771-6770 E-mail [email redacted]

On Thu, Nov 30, 2023 at 2:44 PM Evan Thompson <[email redacted]> wrote:

Mr. North:

Thank you for your time today. Per your request I have attached two PDF’s. One is the proof of the sale of the windows and doors to North despite his claim all he did was demo and the beam. His crew did the framing of the windows and doors you can see the pictures show this work. Our client paid North for the windows and doors that were installed by his crew. Secondly you can see by the balance of the pictures that North performed demo on the electrical, plumbing and HVAC systems. All of this requires plans and permits. We would ask that this be included as part of your directive.

The second issue is to address the statement Mr. North made that Juan was not his employee and he is not responsible for his work. He stated that Juan is a “framer he hires to do side work on the weekends”. If he is not an employee or someone he is responsible for then North has violated A.R.S. §32-1154(A)(9)(a) by aiding and abetting an unlicensed person. Please consider this when issuing your order.

Thank you again for your attention to this matter and please confirm your receipt.

https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-f:[number redacted]… 2/3 12/1/23, 1:32 PM State of Arizona Mail - RE: Strangio v. North Construction

Evan Thompson Admitted in Arizona, Colorado & Texas

Thompson•Krone, P.L.C. 3430 East Sunrise Drive. Suite 110

Tucson, Arizona 85718 p: (520) 884-9694 f: (520) 323-4613

Tucson | Phoenix ThompsonKrone.com

https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-f:[number redacted]… 3/3 Jobsite Inspection Notes

Case No.: 2023-11453 Investigator: ROC Admin Inspection Date: November 30, 2023 Inspection Time: 1:30 PM

Complainant: Laura Strangio Respondent: North Construction Not Present: LLC Not Present:

Jobsite General Notes: JSI photos and audio taken with my agency issued Google Pixel Phone camera. JSI photos and audio have been placed into the ROC complaint file. Complainant was present along with her attorney Evan Thompson. Jeramy Norris was present for the Respondent. Prior to the JSI both parties advised that the only matter remaining to discuss was the lack of a permit for the work that Respondent had done. Which was demo worth which included moving electrical outlets on the wall in the main room and the installation of a beam across the room. All other work was done by someone else hired by the Complainant when Respondent was unavailable.

Complaint Item: 1 - Items listed below need verification that permits were obtained, as necessary, and that all work was completed to code by licensed professionals : * Install of new beam and beam support posts Investigator’s Observation: The Respondent will obtain a permit, correct any deficiencies required by the county/city, and pass final permit inspection. Governing Rule: Violation of any rule adopted by the Registrar; Namely A.A.C. R4-9-108(a): A contractor shall perform all work in a professional and workmanlike manner.

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov RCC100 08/19

Complaint Item: 2 - A/C ductwork - HVAC not cooling sq footage, diminished out-put of cool air, incorrect parts used and installed, ductwork damaged. Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Complaint Item: 3 - All electrical throughout remodel Investigator’s Observation: The Respondent will obtain a permit, correct any deficiencies required by the county/city, and pass final permit inspection. Governing Rule: Violation of any rule adopted by the Registrar; Namely A.A.C. R4-9-108(a): A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item: 4 - Gas redirected Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Complaint Item: 5 - Plumbing - toilet and sink pipes not installed to contract measurement, install of outside shower plumbing/electrical, existing outside water lines/connections are not working Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Complaint Item: 6 - Install of 4 trapezoid fixed glass windows - mismeasured, framing warped during install, incomplete stucco/sheetrock/drywall/paint repair Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov RCC100 08/19

completed by others prior to the JSI Governing Rule:

Complaint Item: 7 - Install of a 4-pane 4-panel patio door - mismeasured, misaligned, framing warped during install, track installed incorrectly, small pieces/parts not installed, incomplete stucco/sheetrock/drywall/paint repair Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Complaint Item: 8 - Concrete floors - cracks, not level, mis-stamped, un- uniform color stain Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Complaint Item: 9 - Complete re-roof Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Complaint Item: 10 - 4 book-matched prefabricated stone slabs were purchased; however, mismatched stone slabs were installed Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Complaint Item: 11 - Stucco/sheetrock/drywall/tape/texture/primer/paint of ceiling and all walls - visible seams throughout ceiling, gaps noted surrounding 1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov RCC100 08/19

recessed can lighting/outlets/switches, texture/paint of walls showed varing degrees of visual/physical imperfections (waves, rough spots, powdery to touch, translucent paint spots) not per contracted "smooth finish" Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Complaint Item: 12 - Install of wall base to all walls - showed varing degrees of visual/physical imperfections (open seams, angles not at 45-degrees, messy caulking, rough to touch) Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Complaint Item: 13 - Install of recessed can lighting not per North Construction blueprint/contract Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Complaint Item: 14 - Install of light pendants/ceiling fans not per North Construction blueprint/contract Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Complaint Item: 15 - Install of new data box in ceiling - open, unsecured wires Investigator’s Observation: Unable to verify, no evidence to prove or

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov RCC100 08/19

disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Complaint Item: 16 - Install of new R30 insulation to all ceiling areas - unsure if installed Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Complaint Item: 17 - Install of central vac floor sweep pan not completed Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov RCC100 08/19

Complaint #2023-11453 Inspection Date 11/30/2023 1:30 PM Photo Page 1 Complaint #2023-11453 Inspection Date 11/30/2023 1:30 PM Photo Page 2 Complainant: Laura Strangio 445 E Glenhurst Dr Oro Valley, AZ 85704

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Respondent: North Construction LLC DBA: 4826 W Country Sky Dr Tucson, AZ 85742

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 December 1, 2023

License No. ROC 305312

Re:Complaint No. 2023-11453

WRITTEN DIRECTIVE FROM THE REGISTRAR

Dear Respondent:

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

RESTRICTIONS • You may not perform or hire other contractors to perform work that is outside the scope of your license. • If your license is currently suspended for administrative reasons 1, or is inactive, expired, or cancelled, you may not perform any corrective work nor contract in any manner, which includes hiring other contractors to perform work, until the suspension of your license(s) has been lifted or your license(s) has been reactivated.

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

Compliance Item: 1 - Items listed below need verification that permits were obtained, as necessary, and that all work was completed to code by licensed professionals : * Install of new beam and beam support posts Investigator’s Observation: The Respondent will obtain a permit, correct any deficiencies required by the county/city, and pass final permit inspection.

This means the license is suspended for lack of qualifying party, lack of bond, nonrenewal, Recovery Fund payout, or for any reason listed in A.R.S. § 32-1124(F). 1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Governing Rule: Violation of any rule adopted by the Registrar; Namely A.A.C. R4-9-108(a): A contractor shall perform all work in a professional and workmanlike manner.

Compliance Item: 3 - All electrical throughout remodel Investigator’s Observation: The Respondent will obtain a permit, correct any deficiencies required by the county/city, and pass final permit inspection. Governing Rule: Violation of any rule adopted by the Registrar; Namely A.A.C. R4-9-108(a): A contractor shall perform all work in a professional and workmanlike manner.

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

Compliance Item: 2 - A/C ductwork - HVAC not cooling sq footage, diminished out-put of cool air, incorrect parts used and installed, ductwork damaged. Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Compliance Item: 4 - Gas redirected Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Compliance Item: 5 - Plumbing - toilet and sink pipes not installed to contract measurement, install of outside shower plumbing/electrical, existing

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 outside water lines/connections are not working Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Compliance Item: 6 - Install of 4 trapezoid fixed glass windows - mismeasured, framing warped during install, incomplete stucco/sheetrock/drywall/paint repair Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Compliance Item: 7 - Install of a 4-pane 4-panel patio door - mismeasured, misaligned, framing warped during install, track installed incorrectly, small pieces/parts not installed, incomplete stucco/sheetrock/drywall/paint repair Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Compliance Item: 8 - Concrete floors - cracks, not level, mis-stamped, un- uniform color stain Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Compliance Item: 9 - Complete re-roof Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Compliance Item: 10 - 4 book-matched prefabricated stone slabs were purchased; however, mismatched stone slabs were installed Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Compliance Item: 11 - Stucco/sheetrock/drywall/tape/texture/primer/paint of ceiling and all walls - visible seams throughout ceiling, gaps noted surrounding recessed can lighting/outlets/switches, texture/paint of walls showed varing degrees of visual/physical imperfections (waves, rough spots, powdery to touch, translucent paint spots) not per contracted "smooth finish" Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Compliance Item: 12 - Install of wall base to all walls - showed varing degrees of visual/physical imperfections (open seams, angles not at 45-degrees, messy caulking, rough to touch) Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Compliance Item: 13 - Install of recessed can lighting not per North Construction blueprint/contract Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Compliance Item: 14 - Install of light pendants/ceiling fans not per North Construction blueprint/contract Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Compliance Item: 15 - Install of new data box in ceiling - open, unsecured wires Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

Compliance Item: 16 - Install of new R30 insulation to all ceiling areas - unsure if installed Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 Compliance Item: 17 - Install of central vac floor sweep pan not completed Investigator’s Observation: Unable to verify, no evidence to prove or disprove complaint item is the responsibility of the Respondent as item was completed by others prior to the JSI Governing Rule:

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

Sincerely,

James Carter James Carter, [email redacted] [number redacted] 1700 W Washington St, Suite 105 Phoenix, AZ 85007

CC: Respondent Complainant

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

602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 04/21 5/22/24, 2:09 PM State of Arizona Mail - Re: Inspections

James Carter <[email redacted]>

Re: Inspections message

James Carter <[email redacted]> Wed, May 22, 2024 at 2:05 PM To: JERAMY NORRIS <[email redacted]> Cc: Laura Strangio <[email redacted]>

Good afternoon Laura I understand the frustration in the delay in getting this completed, however the time frame in which the permits are approved and scheduling of the Town of Oro Valley is out of the control of the ROC. I have been in contact with them at the beginning of this process and they made every indication to me they were in no hurry to address this. That being said, now that they have approved this and are willing to go out and inspect it is imperative that we get a schedule confirmation. Please let Jeramy know when you are available to schedule these inspections. If there is no access for them to inspect I will have to close the complaint.

James Carter Investigator #229 Arizona Registrar Of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007 Phone(602) 771-6770 E-mail [email redacted]

On Wed, May 22, 2024 at 5:52 AM JERAMY NORRIS <[email redacted]> wrote: Good morning Laura,

I sent this email back on the 16th and did not receive a response. I had inspections scheduled yesterday but canceled them due to no response from you. I would like to schedule these inspections again but I need to have you confirm. Is there a particular day this week that works best for you?

Thanks,

Jeramy Norris Owner North Construction LLC ROC 305312 520-280-2160

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From: JERAMY NORRIS <[email redacted]> Sent: Thursday, May 16, 2024 11:10:06 AM To: Laura Strangio <[email redacted]> Subject: Inspections

Laura

I have six inspections scheduled for Tuesday 5/21. I am required to call oro valley on the morning of the inspections to receive a time window.

Jeramy Norris Owner https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-a:r-[number redacted]… 1/2 5/22/24, 2:09 PM State of Arizona Mail - Re: Inspections North Construction LLC

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https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-a:r-[number redacted]… 2/2 5/22/24, 2:10 PM State of Arizona Mail - Re: Oro Valley

James Carter <[email redacted]>

Re: Oro Valley message

James Carter <[email redacted]> Tue, May 21, 2024 at 4:24 PM To: JERAMY NORRIS <[email redacted]>

Jeramy Email her again requesting access for the inspections and copy me on it please

James Carter Investigator #229 Arizona Registrar Of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007 Phone(602) 771-6770 E-mail [email redacted]

On Tue, May 21, 2024 at 10:44 AM JERAMY NORRIS <[email redacted]> wrote: James

I had 6 inspections scheduled today for Laura Strangio. I reached out to her on 5/16 and have yet to hear a response. I have canceled all six inspections until she responds to me with a confirmation that I have permission to be in her house. Not sure why I am spending so much of my time in making such a huge effort when she doesn't even bother responding to me.

Jeramy

Jeramy Norris Owner North Construction LLC

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From: James Carter <[email redacted]> Sent: Thursday, May 16, 2024 11:10:24 AM To: JERAMY NORRIS <[email redacted]> Subject: Re: Oro Valley

Ok please let me know the outcome

James Carter Investigator #229 Arizona Registrar Of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007

https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-a:r-[number redacted]… 1/6 5/22/24, 2:10 PM State of Arizona Mail - Re: Oro Valley

Phone(602) 771-6770 E-mail [email redacted]

On Thu, May 16, 2024 at 11:09 AM JERAMY NORRIS <[email redacted]> wrote: James I have six inspections scheduled for Tuesday 5/21

Jeramy Norris Owner North Construction LLC

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From: James Carter <[email redacted]> Sent: Wednesday, May 15, 2024 3:28:40 PM To: JERAMY NORRIS <[email redacted]> Subject: Re: Oro Valley

Jeramy I need an update please

James Carter Investigator #229 Arizona Registrar Of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007 Phone(602) 771-6770 E-mail [email redacted]

On Wed, Apr 24, 2024 at 2:25 PM JERAMY NORRIS <[email redacted]> wrote: Hi James Oro Valley has finally issued the permit. I am working on scheduling an initial inspection in order to find out what they will require me to do or possibly redo. I will coordinate the inspections with Laura Strangio

Jeramy Norris

Jeramy Norris Owner North Construction LLC

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From: JERAMY NORRIS <[email redacted]> Sent: Thursday, April 11, 2024 8:33:01 AM To: James Carter <[email redacted]> Subject: Re: Oro Valley

Will do as soon as I hear something

https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-a:r-[number redacted]… 2/6 5/22/24, 2:10 PM State of Arizona Mail - Re: Oro Valley Jeramy Norris Owner North Construction LLC

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From: James Carter <[email redacted]> Sent: Thursday, April 11, 2024 8:28:45 AM To: JERAMY NORRIS <[email redacted]> Subject: Re: Oro Valley

Please let me know right away

James Carter Investigator #229 Arizona Registrar Of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007 Phone(602) 771-6770 E-mail [email redacted]

On Wed, Apr 10, 2024 at 7:03 AM JERAMY NORRIS <[email redacted]> wrote: James I have provided everything they have asked for. I'm still waiting for the approval. My engineer pointed out that whoever installed the windows on the east wall did not install them properly and has compromised the structure of the entire shear wall....I'm not sure how OV is going to handle that. They may not issue my permit until she addresses that. I am waiting to find out.

Jeramy Norris Owner North Construction LLC

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From: James Carter <[email redacted]> Sent: Tuesday, April 9, 2024 3:07:38 PM To: JERAMY NORRIS <[email redacted]> Subject: Re: Oro Valley

Jeramy Any updates from the city

James Carter Investigator #229 Arizona Registrar Of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007 https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-a:r-[number redacted]… 3/6 5/22/24, 2:10 PM State of Arizona Mail - Re: Oro Valley

Phone(602) 771-6770 E-mail [email redacted]

On Wed, Mar 20, 2024 at 4:02 PM JERAMY NORRIS <[email redacted]> wrote: Hi James I just got off the phone with Dave Willet at oro valley. They everything except my cost breakdown because I didn't have costs for demo on there. I explained to him that at the time I took the job the homeowners had already removed the existing walls. I resubmitted the valuation sheet explaining that fact. He said he will keep an eye out for my resubmittal....whatever the hell that means. This whole thing is ridiculous. I'll let you know as soon as I hear anything

Jeramy Norris Owner North Construction LLC

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From: James Carter <[email redacted]> Sent: Friday, March 8, 2024 4:24:57 PM To: JERAMY NORRIS <[email redacted]> Subject: Re: Oro Valley

Thank You

James Carter Investigator #229 Arizona Registrar Of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007 Phone(602) 771-6770 E-mail [email redacted]

On Fri, Mar 8, 2024 at 1:52 PM JERAMY NORRIS <[email redacted]> wrote: He did not give a time frame, however he said he would look at it as soon as he receives it. I sent the corrections today

Jeramy Norris Owner North Construction LLC

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From: James Carter <[email redacted]> Sent: Friday, March 8, 2024 9:23:31 AM To: JERAMY NORRIS <[email redacted]> Subject: Re: Oro Valley

Did they say how long after you return it they will be

https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-a:r-[number redacted]… 4/6 5/22/24, 2:10 PM State of Arizona Mail - Re: Oro Valley

James Carter Investigator #229 Arizona Registrar Of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007 Phone(602) 771-6770 E-mail [email redacted]

On Thu, Mar 7, 2024 at 5:27 PM JERAMY NORRIS <[email redacted]> wrote: Hi James I received a request for plan corrections from oro valley today. They are minor wording corrections and my draftsman should have it to me by tomorrow

Jeramy Norris Owner North Construction LLC

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From: James Carter <[email redacted]> Sent: Wednesday, March 6, 2024 4:35:35 PM To: JERAMY NORRIS <[email redacted]> Subject: Re: Oro Valley

Thank you

James Carter Investigator #229 Arizona Registrar Of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007 Phone(602) 771-6770 E-mail [email redacted]

On Wed, Mar 6, 2024 at 4:22 PM JERAMY NORRIS <[email redacted]> wrote: Hi James I actually just got off the phone with Oro Valley. The plans examiner is still running behind but he told me he is planning on getting to our plan this week and told me he should have it done no later than Monday

Jeramy Norris Owner North Construction LLC

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https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-a:r-[number redacted]… 5/6 5/22/24, 2:10 PM State of Arizona Mail - Re: Oro Valley

From: James Carter <[email redacted]> Sent: Wednesday, March 6, 2024 4:19:55 PM To: JERAMY NORRIS <[email redacted]> Subject: Re: Oro Valley

Jeramy Any updates?

James Carter Investigator #229 Arizona Registrar Of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007 Phone(602) 771-6770 E-mail [email redacted]

On Thu, Feb 29, 2024 at 3:44 PM JERAMY NORRIS <[email redacted]> wrote: Hi James

The permit application is still in review at the town of oro valley. The homeowner (or anyone) has the same access to this information as I do. I am a small construction company and have very little weight or pull in order to get them to put our project in front of others. Hurry up and wait.

Jeramy Norris Owner North Construction LLC

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https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-a:r-[number redacted]… 6/6 5/24/24, 10:22 AM State of Arizona Mail - Fwd: Inspections

James Carter <[email redacted]>

Fwd: Inspections message

JERAMY NORRIS <[email redacted]> Wed, May 22, 2024 at 2:11 PM To: James Carter <[email redacted]>

James Laura's attorney sent this to me this morning and I did not see it until about an hour ago. It has been a very busy day. The inspector did make it there before I canceled. I fully expected them to fail the inspections as I needed to get them out there in order to determine the next steps forward. I am in contact with Oro Valley now

Jeramy Norris Owner North Construction LLC

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From: Evan Thompson <[email redacted]> Sent: Wednesday, May 22, 2024 8:00:54 AM To: [email redacted] <[email redacted]> Subject: Inspections

Mr. Norris:

Our client forwarded your messages below. Previously our client had instructed you to communicate through our office moving forward please make sure to follow that protocol in the future.

As far as the inspections with Oro Valley they were held yesterday at 9:00 am. The inspections all failed and will require a great deal more information be provided to the town as well as much destructive opening of walls before they will inspect again.

Evan Thompson Admitted in Arizona, Colorado & Texas

Thompson•Krone, P.L.C. 3430 East Sunrise Drive. Suite 110

Tucson, Arizona 85718 p: (520) 884-9694 f: (520) 323-4613

Tucson | Phoenix ThompsonKrone.com

https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-f:[number redacted]… 1/3 5/24/24, 10:22 AM State of Arizona Mail - Fwd: Inspections

From: JERAMY NORRIS <[email redacted]> Date: May 22, 2024 at 5:52:17 AM MST To: Laura Strangio <[email redacted]>, James Carter <[email redacted]> Subject: Fwd: Inspections

Good morning Laura,

Thanks,

Jeramy Norris

Owner

North Construction LLC

ROC 305312

520-280-2160

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From: JERAMY NORRIS <[email redacted]> Sent: Thursday, May 16, 2024 11:10:06 AM To: Laura Strangio <[email redacted]> Subject: Inspections

Laura

https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-f:[number redacted]… 2/3 5/24/24, 10:22 AM State of Arizona Mail - Fwd: Inspections I have six inspections scheduled for Tuesday 5/21. I am required to call oro valley on the morning of the inspections to receive a time window.

Jeramy Norris

Owner

North Construction LLC

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https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-f:[number redacted]… 3/3 5/24/24, 10:21 AM State of Arizona Mail - Re: Inspections

James Carter <[email redacted]>

Re: Inspections message

Laura Strangio <[email redacted]> Wed, May 22, 2024 at 6:20 PM To: James Carter <[email redacted]>, [email redacted] Cc: "Attorney at Law Evan L. Thompson (House)" <[email redacted]>

Good evening James,

I’ve cc’d Brian and Evan. I just wanted to respond with Brian’s information as well. Please see below.

Brian Snow 520-229-4827 [email redacted]

Regards, Laura

Sent from my iPhone

On May 22, 2024, at 5:01 PM, James Carter <[email redacted]> wrote:

Evan Who have you spoken to at the Tow of Oro Valley? If you can provide that information I will confirm. The people I have spoken to have not advised that Mr Norris was delaying anything

James Carter Investigator #229 Arizona Registrar Of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007 Phone(602) 771-6770 E-mail [email redacted]

On Wed, May 22, 2024 at 4:10 PM Evan Thompson <[email redacted]> wrote:

Inspector Carter

My client forwarded me your email below. Please in the future include me on any correspondence with Ms. Strangio. Your statements below are incorrect. Oro Valley held its inspections yesterday morning and 9:00 am. All of the inspections failed. The inspector stated that there is no way to approve any of what was requested without the removal of a great deal of drywall and other materials to determine what was completed and if any of it meets code. The Respondent knows this and did not make arrangements to provide the required access. The inspector also stated that the plans were incomplete and as well as the engineering provided. I was present for the inspections and spoke directly with the inspector.

This complaint has been open since November of last year which is now six months. In my discussions with Oro Valley it is clear the holdup is not the town of Oro Valley it is the Respondent’s continued failure https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-f:[number redacted]… 1/3 5/24/24, 10:21 AM State of Arizona Mail - Re: Inspections to submit what is required and to follow through.

We would appreciate it if the Registrar would issue the necessary citation and if Respondent feels it is not his fault or wishes to refute the order he can bring that before the administrative law judge and provide proof of the same.

Evan Thompson Admitted in Arizona, Colorado & Texas

Thompson•Krone, P.L.C. 3430 East Sunrise Drive. Suite 110

Tucson, Arizona 85718 p: (520) 884-9694 f: (520) 323-4613

Tucson | Phoenix ThompsonKrone.com

---------- Forwarded message --------- From: James Carter <[email redacted]> Date: Wed, May 22, 2024 at 2:06 PM Subject: Re: Inspections To: JERAMY NORRIS <[email redacted]> Cc: Laura Strangio <[email redacted]>

Good afternoon Laura

I understand the frustration in the delay in getting this completed, however the time frame in which the permits are approved and scheduling of the Town of Oro Valley is out of the control of the ROC. I have been in contact with them at the beginning of this process and they made every indication to me they were in no hurry to address this.

That being said, now that they have approved this and are willing to go out and inspect it is imperative that we get a schedule confirmation. Please let Jeramy know when you are available to schedule these

https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-f:[number redacted]… 2/3 5/24/24, 10:21 AM State of Arizona Mail - Re: Inspections inspections. If there is no access for them to inspect I will have to close the complaint.

James Carter Investigator #229 Arizona Registrar Of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007 Phone(602) 771-6770 E-mail [email redacted]

https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-f:[number redacted]… 3/3 REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA

Laura Strangio, Case No. 2023-11453 COMPLAINANT, v. North Construction LLC CITATION License No. ROC 305312,

RESPONDENT.

The Registrar issues this Citation to North Construction LLC (“Respondent”) under A.R.S. § 32-1155(A). If Respondent fails to answer this Citation by June 12, 2024, 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 October 3, 2023, Laura Strangio (“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)(2)(b) Departure from or disregard of: (b) A building code of this state or any political subdivision of this state in any material respect that is prejudicial to another

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1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg101 8/21 Charge :2 A.R.S. § 32-1154(A)(3) - R4-9-108(c) Violation of any rule adopted by the Registrar; Namely A.A.C. R4-9-108(c): All work performed by a contractor in a county, city, or town that has not adopted building codes or where any adopted building codes do not contain specific provisions applicable to that aspect of construction work shall be performed in accordance with professional industry standards. Charge :3 A.R.S. § 32-1154(A)(22) Failure to take appropriate corrective action to comply with this chapter or with rules adopted pursuant to this chapter without valid justification within a reasonable period of time after receiving a written directive from the Registrar. The written directive shall set forth the time within which the contractor is to complete the remedial action. The time permitted for compliance shall not be less than fifteen days from the date of issuance of the directive. A license shall not be revoked or suspended nor shall any other penalty be imposed for a violation of this paragraph until after a hearing has been held.

If the matter proceeds to a hearing and the administrative law judge determines that any of the charges listed above are supported by a preponderance of the evidence, then Respondent’s license(s) may be subject to suspension or revocation, and Respondent may be subject to other penalties provided by law, including civil penalties under A.R.S. §§ 32-1154(E) and (F). FILING A WRITTEN ANSWER Respondent must appear by filing with the Registrar a written answer to the citation and complaint showing cause, if any, why Respondent’s license(s) should not be suspended or revoked. A.R.S. § 32-1155(A). Respondent’s written answer should contain the heading “Written Answer to Citation and Complaint” and should include the case number, which is

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1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg101 8/21 Case No. 2023-11453. How to File a Written Answer: Respondent’s written answer may be submitted in the following ways: In-Person: 1700 W. Washington St., Ste. 105, Phoenix, Arizona, 85007-2812 Mail: P.O. Box 18244, Phoenix, Arizona, 85005-8244 Email: [email redacted] 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 June 12, 2024. This deadline is calculated under A.R.S. §§ 32-1155(A) and (B), which provides a deadline ten days after service of the Citation. Service of the Citation and Complaint is complete five days after the Registrar mails a copy of the Citation and Complaint to Respondent’s latest address of record in the Registrar’s office. Consequences for Failing to File a Written Answer: If Respondent fails to answer, Respondent’s failure may be deemed an admission of the act or acts charged in the written complaint. A.R.S. § 32-1155(C). The Registrar may then suspend or revoke Respondent’s license(s). THE ADMINISTRATIVE HEARING If Respondent files a timely written answer contesting any charges in the Complaint, then the Registrar will request the Office of Administrative Hearings set a date for an administrative hearing and will notify all the parties at least 30 days before that hearing. A.R.S. § 41-1092.05(D). INVESTIGATOR’S APPEARANCE AS A WITNESS The Registrar’s assigned investigator will appear as a witness at the hearing. If either

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1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg101 8/21 party demands the attendance at the hearing of any other person, that party must obtain and serve a subpoena in compliance with the rules and processes established by the Office of Administrative Hearings. RESPONDENT’S RIGHT TO REQUEST AN INFORMAL SETTLEMENT CONFERENCE Under A.R.S. § 41-1092.06, if Respondent submits a request to the Registrar for an informal settlement conference, the Registrar must hold a conference within 15 days after receiving the request. Respondent’s request for an informal settlement conference must be in writing and must be filed no later than 20 days before the administrative hearing. A.R.S. § 41- 1092.06(A). The Registrar will not close or settle any case without both parties’ appearance at the Settlement Conference. The parties participating in the settlement conference must have the authority to settle the case and must waive their right to object to the participation of the Registrar’s settlement conference representative in the final administrative decision. A.R.S. § 41-1092.06(B). Any statements, either written or oral, made by the parties at the conference, including a written document, created or expressed solely for the purpose of settlement negotiations, are inadmissible in the administrative hearing. A.R.S. § 41-1092.06(B). RESPONDENT’S PRIOR RECORD Under A.A.C. R4-9-117, in determining the appropriate discipline, the administrative law judge and the Registrar may consider not only facts in the current case, but also facts in prior cases and any documents regarding Respondent on file with the Registrar. Respondent’s prior disciplinary record and current license(s) status may be considered as a mitigating or aggravating factor in determining the appropriate discipline. EVIDENTIARY DISCLAIMER By issuing this Citation, the Registrar is directing Respondent to file a written answer to

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1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg101 8/21 the 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 May 28, 2024. By: /s/ Tedi Quezada Tedi Quezada Legal Assistant Legal Department Arizona Registrar of Contractors COPY of the foregoing mailed by Certified Mail, Return Receipt Requested, May 28, 2024 to:

Respondent Certified Mail No: [number redacted]

North Construction LLC 4826 W Country Sky Dr. Tucson, AZ 85742 Copy mailed by USPS First Class mail this same date to: Respondent North Construction LLC 4826 W Country Sky Dr. Tucson, AZ 85742

Complainant Laura Strangio 445 E Glenhurst Dr. Oro Valley, AZ 85704

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1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg101 8/21 Complainant’s Attorney Evan L. Thompson, Esq. Thompson Krone PLC 3430 E Sunrise Dr. Ste. 110 Tucson, AZ 85718

Copy sent electronically this same date to:

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

Case No. 2023-11453

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1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg101 8/21 5/24/24, 10:21 AM State of Arizona Mail - Re: Inspections

James Carter <[email redacted]>

Re: Inspections message

Laura Strangio <[email redacted]> Wed, May 22, 2024 at 6:20 PM To: James Carter <[email redacted]>, [email redacted] Cc: "Attorney at Law Evan L. Thompson (House)" <[email redacted]>

Good evening James,

I’ve cc’d Brian and Evan. I just wanted to respond with Brian’s information as well. Please see below.

Brian Snow 520-229-4827 [email redacted]

Regards, Laura

Sent from my iPhone

On May 22, 2024, at 5:01 PM, James Carter <[email redacted]> wrote:

Evan Who have you spoken to at the Tow of Oro Valley? If you can provide that information I will confirm. The people I have spoken to have not advised that Mr Norris was delaying anything

James Carter Investigator #229 Arizona Registrar Of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007 Phone(602) 771-6770 E-mail [email redacted]

On Wed, May 22, 2024 at 4:10 PM Evan Thompson <[email redacted]> wrote:

Inspector Carter

Evan Thompson Admitted in Arizona, Colorado & Texas

Thompson•Krone, P.L.C. 3430 East Sunrise Drive. Suite 110

Tucson, Arizona 85718 p: (520) 884-9694 f: (520) 323-4613

Tucson | Phoenix ThompsonKrone.com

Good afternoon Laura

James Carter Investigator #229 Arizona Registrar Of Contractors 1700 W Washington St Ste 105 Phoenix, AZ 85007 Phone(602) 771-6770 E-mail [email redacted]

https://mail.google.com/mail/u/0/?ik=8b703c773b&view=pt&search=all&permthid=thread-f:[number redacted]%7Cmsg-f:[number redacted]… 3/3 Licensed Complaint Form Departmental Use Only For Current or Suspended Licensees

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

Laura Strangio Mailing Address (Enter jobsite in Contract/Project section) City State Zip

445 E Glenhurst Dr Oro Valley Arizona 85704 Phone Number Email

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

Street Address of Attorney City State Zip

Phone Number of Attorney Email of Attorney

Contractor Information Name (as shown on contract/invoice) ROC License Number(s)

North Construction LLC ROC 305312 Street Address City State Zip

4826 W Country Sky Dr Tucson AZ 85742 Phone Number Email

[number redacted] [email redacted] Name of Person(s) Representing License

Jeramy Norris Contract/Project Information Contract Date Contract Amount Amount Paid

June 21, 2022 $56,415.00 $155,000.00 Date Work Started Date Work Stopped Date Work Was Completed

June 21, 2022 October 2, 2023 Close of Escrow (New Home) Move-In Date (New-Home)

Jobsite Street Address City State Zip

445 E Glenhurst Dr Oro Valley AZ 85704 Name of Construction Site Owner Construction Site Name (if applicable)

Phone Number of Construction Site Owner Email of Construction Site Owner

This complaint is for Abandonment;Poor Work I have contacted the contractor by Phone/Text;Email Have you filed a complaint in court? No Has any work been corrected? Yes

RCC099 12/05/18 Page 1 of 3 Licensed Complaint Form Departmental Use Only For Current or Suspended Licensees

Attempts were made by subcontractor of Jeramy Norris. The contract was Both All change orders were Both This project was Residential This project involved Remodel

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

Items listed below need verification that permits were obtained, as necessary, and that all work was completed to code by licensed professionals : * Install of new beam and beam support posts * A/C ductwork - HVAC not cooling sq footage, diminished out-put of cool air, incorrect parts used and installed, ductwork damaged. * All electrical throughout remodel. * Gas redirected. * Plumbing - toilet and sink pipes not installed to contract measurement, install of outside shower plumbing/electrical, existing outside water lines/connections are not working, * Install of 4 trapezoid fixed glass windows - mismeasured, framing warped during install, incomplete stucco/sheetrock/drywall/paint repair. * Install of a 4-pane 4-panel patio door - mismeasured, misaligned, framing warped during install, track installed incorrectly, small pieces/parts not installed, incomplete stucco/sheetrock/drywall/paint repair. * Concrete floors - cracks, not level, mis-stamped, un-uniform color stain. * Complete re-roof * 4 book-matched prefabricated stone slabs were purchased; however, mismatched stone slabs were installed.

* Stucco/sheetrock/drywall/tape/texture/primer/paint of ceiling and all walls - visible seams throughout ceiling, gaps noted surrounding recessed can lighting/outlets/switches, texture/paint of walls showed varing degrees of visual/physical imperfections (waves, rough spots, powdery to touch, translucent paint spots) not per contracted "smooth finish" *Install of wall base to all walls - showed varing degrees of visual/physical imperfections (open seams, angles not at 45- degrees, messy caulking, rough to touch) * Install of recessed can lighting not per North Construction blueprint/contract. * Install of light pendants/ceiling fans not per North Construction blueprint/contract. * Install of new data box in ceiling - open, unsecured wires * Install of new R30 insulation to all ceiling areas - unsure if installed * Install of central vac floor sweep pan not completed

Signature

RCC099 12/05/18 Page 2 of 3 Licensed Complaint Form Departmental Use Only For Current or Suspended Licensees

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

Laura Strangio \complainant1\ \complainantd1\

RCC099 12/05/18 Page 3 of 3 Received 6/11/2024 ROC Legal

BREI CASTILLO 4574 N. First Ave., Suite 150 Tucson, AZ 85718 Phone: 520-297-4411 Fax: 520-297-8811 E-mail: [email redacted] Justin D. Castillo PCC No. 65892; AZ State Bar: 024086 Attorneys for Respondent REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA LAURA STRANGIO, Case No. 2023-11453 COMPLAINANT, DOCKET NO. v. WRITTEN ANSWER TO CITATION AND COMPLAINT NORTH CONSTRUCTION, LLC, License No. ROC 305312 RESPONDENT. In response to Complainant Laura Strangio’s (“Complainant”) Citation and Complaint, Respondent North Construction, LLC (“Respondent”) hereby admits, denies and otherwise responds to the allegations in the Citation and Complaint as follows: GENERAL ALLEGATIONS 1. Respondent denies the allegations that it is in violation of A.R.S. § 32- 1154(A)(2)(b) as alleged in Charge 1. 2. Respondent denies the allegations that it is in violation of A.R.S. § 32- 1154(A)(3) – R4-9-108(a) as alleged in Charge 2. 3. Respondent denies the allegations that it is in violation of A.R.S. § 32- 1154(A)(22) as alleged in Charge 3. Received 6/11/2024 ROC Legal

4. Respondent affirmatively alleges that it should not have its license suspended or revoked and it should not be subject to other penalties provided by law, including civil penalties under A.R.S. §§ 32-1154(E) and (F) because Respondent has not done a wrongful or fraudulent act resulting in Complainant being substantially injured. 5. Respondent specifically denies each and every allegation in Complainant’s Complaint not specifically addressed herein. AFFIRMATIVE DEFENSES 6. Additional facts may be revealed by future discovery, which support affirmative defenses presently available to Respondent, but which are presently unknown to Respondent. Accordingly, Respondent hereby alleges all of the affirmative defenses indicated in Rule 8, Arizona Rules of Civil Procedure, and the following affirmative defenses that may or may not be contained in Rule 8, Arizona Rules of Civil Procedure: Accord and satisfaction, arbitration and award; assumption of risk; contributory negligence; comparative fault; discharge in bankruptcy; duress; estoppel; failure of consideration; fraud; illegality; laches; license; merger of contract; non-party at fault; payment; release; res judicata; statute of frauds; statute of limitations; waiver; lack of jurisdiction over the subject matter; lack of jurisdiction over the person; improper venue; insufficiency of process and service of process; failure to join persons needed for adjudication under Rule 19, Arizona Rules of Civil Procedure; multiplicity of suits and pendency of other actions; abatement, setoff; failure to mitigate damages; collateral estoppel; privilege; immunity; novation; statutory exemption; condition precedent; indemnification; standing; fraud in the inducement, and failure to state a claim upon which relief may be granted. 7. Respondent expressly reserves its right to amend this Answer to plead such affirmative defenses with more specificity once those affirmative defenses are discovered.

Received 6/11/2024 ROC Legal

WHEREFORE, Respondent prays as follows: A. For the Citation and Complaint to be dismissed with prejudice and that Complainant take nothing thereby; B. For no action of any kind be taken against Respondent’s license; and C. For such other and further relief that the Registrar of Contractors deems just and proper in the circumstance. REPECTFULLY SUBMITTED this 11th day of June 2024. BREI CASTILLO /s/Justin D. Castillo Justin D. Castillo Attorneys for Respondent

Received 6/11/2024 ROC Legal

Original of the foregoing emailed this 11th day of June 2024 to: Registrar of Contractors 1700 W. Washington St., Ste. 105 Phoenix, AZ 85007-2812 Email: [email redacted] James Carter, Investigator #229 [email redacted] THOMPSON KRONE, PLC Evan Thompson 3430 East Sunrise Drive, Suite 110 Tucson, Arizona 85718 [email redacted] Attorneys for Complainant By:/s/ CharlotteAnn Ortega CharlotteAnn Ortega

Received 6/11/24, 1:25 PM State of Arizona Mail - Case No. 2023-11453; North Construction, LLC adv. Strangio: Answer to Citation6/11/2024 and Complaint ROC Legal

Answers - AZROC <[email redacted]>

Case No. 2023-11453; North Construction, LLC adv. Strangio: Answer to Citation and Complaint message

CharlotteAnn Ortega <[email redacted]> Tue, Jun 11, 2024 at 11:51 AM To: "[email redacted]" <[email redacted]>, "[email redacted]" <[email redacted]>, "[email redacted]" <[email redacted]> Cc: Justin Castillo <[email redacted]>, CharlotteAnn Ortega <[email redacted]>

Good afternoon,

Attached is Respondent’s Answer to the Citation and Complaint. A hard copy will not be placed in the US Mail unless requested.

Thank you.

Respectfully, CharlotteAnn Ortega Paralegal to Justin D. Castillo, Esq., Suzanne L. Brei, Esq., and Jeffrey T. Brei, Esq.

4574 N. First Ave., Suite 150

Tucson, Arizona 85718

Phone: 520.297.4411

Fax: 520.297.8811

For more information about our firm, see our website at www.breilaw.com

https://mail.google.com/mail/b/AEoRXRQf1f_TyJh7MKy297J6hmYMe2418S0GfdDuM7UNx3nAUyhw/u/0/?ik=581c53cf5c&view=pt&search=all&permt… 1/2 Received 6/11/24, 1:25 PM State of Arizona Mail - Case No. 2023-11453; North Construction, LLC adv. Strangio: Answer to Citation6/11/2024 and Complaint ROC Legal Written Answer to Citation and Complaint - ROC.pdf 148K

https://mail.google.com/mail/b/AEoRXRQf1f_TyJh7MKy297J6hmYMe2418S0GfdDuM7UNx3nAUyhw/u/0/?ik=581c53cf5c&view=pt&search=all&permt… 2/2 LEGAL RECEIVED 06/11/2024

BREI CASTILLO 4574 N. First Ave., Suite 150 Tucson, AZ 85718 Phone: 520-297-4411 Fax: 520-297-8811 E-mail: [email redacted] Justin D. Castillo PCC No. 65892; AZ State Bar: 024086 Attorneys for Respondent REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA LAURA STRANGIO, Case No. 2023-11453 COMPLAINANT, DOCKET NO. v. NOTICE OF APPEARANCE NORTH CONSTRUCTION, LLC, License No. ROC 305312 RESPONDENT. NOTICE IS HEREBY GIVEN that Justin D. Castillo, of Brei Castillo, makes his appearance as counsel of record for Respondent, North Construction, LLC in these proceedings. Counsel requests that all pleadings, notices, and communications of any sort be sent to the address listed above. RESPECTFULLY SUBMITTED this 11th day of June 2024. BREI CASTILLO /s/Justin D. Castillo Justin D. Castillo Attorneys for Respondent LEGAL RECEIVED 06/11/2024

Original of the foregoing e-mailed this 11th day of June, 2024 to: Arizona Registrar of Contractors P.O. Box 18244 Phoenix, Arizona 85005-8244 E-mail: [email redacted] James Carter, Investigator #229 [email redacted] THOMPSON KRONE, PLC Evan Thompson 3430 East Sunrise Drive, Suite 110 Tucson, Arizona 85718 [email redacted] Attorneys for Complainant By: /s/ CharlotteAnn Ortega CharlotteAnn Ortega

6/11/24, 2:06 PM State of Arizona Mail - Case No. 2023-11453; North Construction, LLC adv. LEGAL Strangio: Notice of Appearance RECEIVED 06/11/2024

Legal New Mail - AZROC <[email redacted]>

Case No. 2023-11453; North Construction, LLC adv. Strangio: Notice of Appearance message

CharlotteAnn Ortega <[email redacted]> Tue, Jun 11, 2024 at 11:48 AM To: "[email redacted]" <[email redacted]>, "[email redacted]" <[email redacted]>, "[email redacted]" <[email redacted]> Cc: Justin Castillo <[email redacted]>, CharlotteAnn Ortega <[email redacted]>

Good afternoon,

Attached is our Notice of Appearance for Respondent, North Construction, LLC. A hard copy will not be placed in the US Mail unless requested.

Thank you.

Respectfully, CharlotteAnn Ortega Paralegal to Justin D. Castillo, Esq., Suzanne L. Brei, Esq., and Jeffrey T. Brei, Esq.

4574 N. First Ave., Suite 150

Tucson, Arizona 85718

Phone: 520.297.4411

Fax: 520.297.8811

For more information about our firm, see our website at www.breilaw.com

https://mail.google.com/mail/b/AEoRXRSi7d-m1PmxABLCjh8fdPWNsY56Ul1IFcOsLuCAaOklCQeX/u/0/?ik=d3afebeda9&view=pt&search=all&permth… 1/2 6/11/24, 2:06 PM State of Arizona Mail - Case No. 2023-11453; North Construction, LLC adv. LEGAL Strangio: Notice of Appearance RECEIVED 06/11/2024 Notice of Appearance - ROC.pdf 136K

https://mail.google.com/mail/b/AEoRXRSi7d-m1PmxABLCjh8fdPWNsY56Ul1IFcOsLuCAaOklCQeX/u/0/?ik=d3afebeda9&view=pt&search=all&permth… 2/2 REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA

Laura Strangio, Case No. 2023-11453 COMPLAINANT,

North Construction LLC, ORDER DENYING REQUEST TO License No. ROC 305312, DISMISS

RESPONDENT.

BACKGROUND On May 28, 2024, the Registrar issued a Citation against Respondent’s License No. 305312, charging Respondent with violations of A.R.S. § 32-1154(A)(2)(b), (3), and (22). On June 11, 2024, Respondent filed an Answer. The Answer included a request to dismiss the Citation and Complaint. ORDER IT IS ORDERED that Respondent’s request to dismiss is DENIED. The issues underlying the Citation and Complaint are best suited for presentation before the Office of Administrative Hearings. Respondent is free to raise the arguments and defenses presented in its request to dismiss before the administrative law judge. A Notice of Hearing will be issued in due course. Dated July 17, 2024. By: /s/ Robert Stirling Robert Stirling Assistant General Counsel Legal Department Arizona Registrar of Contractors of 2 REGISTRAR OF CONTRACTORS 1700 W. Washington St. – Ste. 105 – Phoenix, AZ 85007-2812 Telephone (602) 542-1525 Toll Free (877) 692-9762 Lg127 5/21 Copy mailed via USPS First Class Mail July 17, 2024 to:

Respondent North Construction LLC 4826 W Country Sky Dr Tucson, AZ 85742

Respondent’s Attorney Justin D. Castillo, Esq. Brei Law Firm 4574 N 1st Ave Ste 150 Tucson, AZ 85718

Complainant Laura Strangio 445 E Glenhurst Dr Oro Valley, AZ 85704

Complainant’s Attorney Evan L. Thompson, Esq. Thompson Krone PLC 3430 E Sunrise Dr Ste 110 Tucson, AZ 85718 Copy sent electronically this same date to:

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

Case No. 2023-11453 / KR

of 2 REGISTRAR OF CONTRACTORS 1700 W. Washington St. – Ste. 105 – Phoenix, AZ 85007-2812 Telephone (602) 542-1525 Toll Free (877) 692-9762 Lg127 5/21 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 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