2024A-03468-CHC-ROC Notice of Hearing & Packet MAILED 2024-03468.pdf

2024A-03468-CHC-ROC · Registrar of Contractors · 2024-07-17

REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA

Lisa Cockrell , Case No. 2024-03468

COMPLAINANT, Docket No. 2024A-03468-CHC-ROC

v. NOTICE OF HEARING ON CONTESTED CASE HR Capital Contracting LLC License No. ROC 346260,

RESPONDENT.

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

HEARING INFORMATION The hearing is set for:

August 20, 2024 1:00 PM Jenna Clark 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 June 13, 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 15, 2024.

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

Copy mailed via USPS First Class mail July 15, 2024 to:

Respondent(s) HR Capital Contracting LLC 11214 W Sieno Pl Avondale, AZ 85392 Complainant(s) Lisa Cockrell 5214 S. 53rd Lane Laveen, AZ 85339

Copy sent electronically this same date to:

Respondent at email address on record with the Registrar Complainant at email address on record with the Registrar

Case No. 2024-03468 /

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

Jobsite Inspection Notes

Case No.: 2024-03468 Investigator: Jack Grimm Inspection Date: Monday, April 22, 2024 Inspection Time: 10:00 AM

Complainant: Lisa Cockrell Respondent: HR Capital Not Present: Contracting LLC Not Present:

Jobsite General Notes: Present representing HR Capital Contracting LLC was Hugo Reyna – Owner. This project was a mostly labor only as the complainant/homeowner provided most of the materials and components. HR states he provided some small needed materials and billed for those materials.

Complaint Item #1: Incomplete bathroom #1, incomplete vanity, exposed wiring, sharp edges at shower tile trim and not ADA compliant Investigators Observation: Bathroom # 1 is incomplete. Most of the components are in place. The incomplete work includes but not limited to, incomplete electrical, drywall repairs and paint, incomplete vanity installation, poor tile trim work with sharp edges, incomplete casing on door, incomplete toilet installation, incomplete plumbing and generally not completed and cleaned. Electrical work is provided and paid for by the homeowner and should be completed prior to the completion of drywall and paint. *Complete bathroom as outlined above. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #2: Demolished master bathroom. Investigators Observation: Demo in master bathroom appears to be mostly completed and invoiced and paid for. Some minor framing work was completed at the doorway. Unable to determine if the walls are in the correct locations as no plans exist. Walls were built over carpet. Parties’ state there was talk about adding a pocket door. Generally unable to determine what was agreed upon or not regarding the master bathroom. *Correct locations where walls were built over carpet. 1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C011 12/23

Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #3: Facilitated unlicensed subcontractors. Investigators Observation: No evidence was presented regarding this allegation. Governing Rule: N/A

Complaint Item #4: Poor framing and lack of green board. Investigators Observation: Framing will be addressed in #7. Green board is generally not used anymore. There are certain requirements for moisture resistance drywall in various locations. Code compliance would address this item if needed. However no permits were obtained. This issue will be addressed in #7. Governing Rule: N/A

Complaint Item #5: Incomplete door casing and paint. Investigators Observation: New doors and with jams were installed throughout the home. New door install should and generally do include the installation of casing and there was an agreement to paint the home that is incomplete. *Complete all door installation including the installation of casing as needed and paint. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #6: Wall painted with black paint damaged. Investigators Observation: Homeowner states she had this location painted black and the respondent’s workers damaged it. *Correct locations of damaged paint. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #7: Lack of permit for framing, electrical and plumbing. Investigators Observation: Extensive framing and electrical work is being performed in the home. Framing and plumbing is being performed by the respondent. Homeowner states she has hired and paid for the electrical work. Framing and any plumbing work that took place below the floor line and behind the wall line would require a permit. Homeowner has hired an electrician and that work was performed with no permit as well. I encouraged the homeowner to have her or her electrician obtain a permit. This is a health and safety issue. *Obtain the required permits and obtain all required inspections and approvals from the local code jurisdiction governing authority. Governing Rule: 32-1154(A)(2) Departure from or disregard of building codes.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C011 12/23

Complaint Item #8: Incorrect laundry room recessed tool and coat areas. Investigators Observation: Unable to determine if the work performed is correct or not as there is no documentation regarding this installation. Work appears complete. Governing Rule: N/A

Complaint Item #9: Incomplete floor base and paint. Investigators Observation: Installation of flooring appears complete. The base installation is incomplete in several locations throughout the home. Several locations of drywall work was performed and the painting of those locations is incomplete. *Complete the installation of the base and paint walls and base as needed. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #10: Plaster/white substance dumped in yard. Investigators Observation: Observed locations of residual debris in yard. Clean as needed. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #11: Continuous excess work performed – extra day rates charged. Investigators Observation: Work was being charged at a labor rate. The ROC does not regulate costs. Unable to address financial issues. Governing Rule: N/A

Complaint Item #12: Closets and shelving incomplete. Investigators Observation: Owner provided modular closet shelves and drawers. This work is started but incomplete. Homeowner states there was an agreement to raise the boxes off of the floor. Some have been raised and others not. If some are done it appears there was an agreement. *Lift boxes off of floor and complete installation including but not limited to installation, trim as needed, perform any drywall repairs and paint as needed and complete for functionality. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #13: Requesting remediation and financial reimbursement. Investigators Observation: The ROC has no financial jurisdiction to direct any payments, restitution or reimbursements. That is what civil court does. Governing Rule: N/A

Complaint Item #14: Lack of Contract. Investigators Observation: No contract or agreement was in place. A warning letter for minimum elements of a contract will be issued. Governing Rule: 32-1158(A) Minimum Elements of a contract over $1,000.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C011 12/23

Complaint Item #15: Paneling and trim in two (2) bedrooms poorly installed and incomplete. Investigators Observation: Work regarding trim around the windows and walls was performed in two bedrooms. This work is poorly done. Paneling was installed on top of base, has poor fit and finish. Trim around windows is not installed the same. *Correct trim around windows, base should be installed in top of paneling and correct for fit and finish. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #16: Paint on vehicle stored in garage. Investigators Observation: Unable to determine who got paint/drywall compound on car as homeowner had others at the home and at some point performing drywall and/or paint work in garage. Governing Rule: N/A

Jack Grimm Jack Grimm, Investigator #172 602 7716741 [email redacted] 1700 W Washington St. Suite 105 Phoenix, Arizona 85007-2812

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C011 12/23

REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA

Lisa Cockrell, Case No. 2024-03468 COMPLAINANT, v. HR Capital Contracting LLC, CITATION License No. ROC 346260, RESPONDENT.

The Registrar issues this Citation to HR Capital Contracting LLC, (“Respondent”) under A.R.S. § 32-1155(A). If Respondent fails to answer this Citation by June 28, 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 March 24, 2024, Lisa Cockrell, (“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. 2024-03468. 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 28, 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 party demands the attendance at the hearing of any other person, that party must obtain and

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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 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 the Citation and Complaint, showing cause, if any, why Respondent’s license(s) should not be

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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 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 June 13, 2024. By: /s/ Gail Mathews Gail Mathews Legal Assistant II Legal Department Arizona Registrar of Contractors

COPY of the foregoing mailed by Certified Mail, Return Receipt Requested, June 13, 2024 to: Respondent Certified Mail No: [number redacted] HR Capital Contracting LLC 11214 W Sieno Pl Avondale, AZ 85392

Copy mailed by USPS First Class mail this same date to: HR Capital Contracting LLC 11214 W Sieno Pl Avondale, AZ 85392

Complainant Lisa Cockrell 5214 S. 53rd Lane Laveen, AZ 85339

Copy sent electronically this same date to:

Respondent at email address on record with the Registrar Complainant at email address on record with the Registrar

Case No. 2024-03468 of 5

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg101 8/21 Licensed Complaint Form Departmental Use Only For Current or Suspended Licensees

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

Lisa Yvette Cockrell Mailing Address (Enter jobsite in Contract/Project section) City State Zip

5214 S. 53rd Lane Laveen Arizona 85339 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)

HR Capital Contracting LLC ROC 346260 Street Address City State Zip

Phone Number Email

480-606-8613 [email redacted] Name of Person(s) Representing License

Hugo Ruben Reyna Contract/Project Information Contract Date Contract Amount Amount Paid

January 1, 1994 $0.00 $22,871.87 Date Work Started Date Work Stopped Date Work Was Completed

December 27, 2023 March 20, 2024 Close of Escrow (New Home) Move-In Date (New-Home)

Jobsite Street Address City State Zip

5214 S. 53rd Lane Laveen AZ 85339 Name of Construction Site Owner Construction Site Name (if applicable)

Lisa Yvette Cockrell Phone Number of Construction Site Owner Email of Construction Site Owner

[number redacted] This complaint is for Abandonment;Poor Work;Other I have contacted the contractor by Have you filed a complaint in court? No Has any work been corrected? No

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

The contract was Oral All change orders were N/A This project was Residential This project involved Remodel

A building permit was obtained by Contractor 00000 Phoenix 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)

I have requested on several occasions, a contract including a Summary Plan or itemized list of the total project cost. It was refused and denied by Mr. Reyna. Allegations Listed on Complaint:

Incomplete bathroom, demolish master bath, facilitated unlicensed subcontractors, poor framing and lack of green board.

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

Lisa Yvette Cockrell \complainant1\ \complainantd1\

RCC099 12/05/18 Page 2 of 2 To: AZ Registrar of Contractors (ROC)

Yvette Cockrell 5214 S. 53rd Lane Laveen, AZ 85339

vs.

HR Capital Contracting, LLC Hugo Ruben Reyna License Number: ROC 346260

Initially I’d filed a complaint against Hugo Reyna, the qualifying party for HR Capital Contracting, LLC but contacted the ROC and spoke with a representative who recommended I allow Mr. Reyna an opportunity to complete any services. I already was aware of this recommendation which is why I’d kept Mr. Reyna onboard for over 90 days although I was unsatisfied with several services. But I’d informed Mr. Reyna of the complaint and my immediate withdrawal. I asked about his performing plumbing services and he said he was allowed to perform several services if it’s under $1,000. I once again asked for a contract for uncompleted work and a receipt(s). It was promised but never received. Prior to beginning to work with Hugo Reyna, the qualifying party for HR Capital Contracting, LLC, I have requested on several occasions, a contract including a Summary or itemized and detailed list of the cost of the project. Mr. Reyna was always about to text/send it but no documentation authorizing Mr. Reyna and his unlicensed subcontractors were allowed to perform certain services within my home. According to the requirements for licensed contractors in Arizona, a list of necessary elements for a valid and binding contract each time a contractor performs work under his license for over $1,000 was disregarded. I believe Mr. Reyna failed to provide one or several contracts were due to my vision issues. Several framing services were performed without installing greenboard, performed plumbing, drywall services, and demolished several areas of my home including the second and only remaining bathroom without my authorization, permission, or agreed upon contract, and facilitated unlicensed subcontractor (no license or bond) to performing services. I was planning to use Floor & Décor for floor replacement throughout the house and my bathroom development. According to Mr. Reyna, “Floor & Décor does not install tile correctly that he’s had to demolished and rebuilt a bathroom completed by Floor & Décor.” I told him, Floor & Décor will have my areas demolished and completed within 3 days, he said he and his team will too. As of today, it is over 2.5 months and the project is still not completed.

BATHROOM1 As of today, I still do not have a fully functioning bathroom (Bathroom1 and Master Bathroom) due to Mr. Reyna lack of experience and incompetence, utilizing underqualified and unlicensed sub- contractors and awareness of the severity of leaving exposed wiring, nails and sharp jagged edges for over 45 days, it was brought to his attention and never repaired.

During all times of the day, Bathroom1 is a dangerous room to utilize and lacks any privacy for me who is partially blind and my adult son who suffers from Epilepsy and blackout seizure. Although the shower was initially used by the both of us on two occasions, when I’d scraped my arm against the sharp edges, I’d felt around for all the sharp edges and there were many. Instead, we use a neighbor’s bathroom for fear of being electrocuted, exposed nails through our hands, slipping in the non-ADA friendly shower or tripping and falling on the shower lip against several very sharp edges surrounding the shower. Although Mr. Reyna performed all the plumbing services including lining the shower with something, I cannot confirm if any of the prep shower and sink services were performed correctly. In addition, Bathroom1 is not private and exposed to anyone at any time due to remove the door frame exposing any private moments to anyone in the home. He installed an ADA toilet but we have never used this product because he is not a licensed plumber and it sits across from an open wire, exposed facing up nails, etc. This is the third extended time; Mr. Reyna left me and my son in uncompromising situations including private and intimate exposure to each other while waiting for Mr. Reyna and his team to complete work that will never be completed. In the last 30 days, I have fallen down and broken my arm in two places due to his negligence, my son had unwarranted seizures due to very loud noises and sounds causing my son to have a Grand Mal seizure while Mr. Reyna and his team were demolishing my bathroom. If I’d approved demolishing the bathroom, I would have removed my daily personal and intimate items, securely packed the items and placed in a secure location and removed my son from the home. When my son has seizures, he had no control of his limbs and will suddenly and unknowingly fall down without supporting his fall. If a slip or fall happened in Bathroom1, theirs is no ADA bar or any secured item to grab hold except a wall fill of exposed upward facing nails, electrical utilized last by Mr. Reyna in an attempt to install a towel warner, sharp edges on the bench and pony wall would definitely leave me and my son greatly wounded or death may occur. In addition, the shower extended lip prevent free movement when falling down due to seizures or movement disability such as my limited sight and arthritis. I’d questioned Mr. Reyna about his contractor license. It states, the contractor is not allowed to perform any electrical or plumbing among an outlined list. Mr. Reyna said he is allowed to perform any work including plumbing as long as it does not exceed $1,000. Mr. Reyna has performed a lot of services in my home, perhaps keeping it all under $1,000, hence no contract or need to provide proof of funds received. I’d also asked on several occasions, the license number of the plumber and tilers brought to perform services who’d misaligned my vanity plumbing, pushed open two clean out covers on the exterior of the home and left these openings opened and exposed to the elements for over two weeks until I’d investigated how were scorpions and spiders suddenly inside the rear of the home, coming from the master bathroom area. These openings left my home exposed to the exterior elements including 3 days of heavy rain for over two weeks. I could see into my master bathroom! At this time, I do not know if I will have an insect infestation. Before hiring Mr. Reyna, I asked him on several occasions do I need a permit or will he assist with a permit to perform framing services such as demolish the bathroom wall and build a new wall frame in my master bathroom. Mr. Reyna response was, “No, a permit is not required”.

LAUNDRY ROOM

I’d asked Mr. Reyna about a recessed tool and coat area in the laundry room. He’d confirmed he could complete this task but I’d informed him I was not ready for this service until after Phase One or after March. Although the area is nice, it was not a service I’d needed at that time. Currently, I cannot use this area because it is not finished and cannot be used.

KITCHEN AND ALL LIVING ROOMS (10 ROOMS TOTAL) Mr. Reyna demolished the flooring in my living room, kitchen, family room, four bedrooms, laundry room, hallway and Bathroom1, my kitchen walls and cabinets. Mr. Reyna extended an existing kitchen wall and I again asked if a permit was needed. Mr. Reyna said, “No”. Mr. Reyna and his team removed the drywall and electrical, extended the back end of the wall, did not use greenboard, drywalled it back up and textured for painting. Mr. Reyna left a soffit opened that is an anchor for upper and lower kitchen cabinets. Mr. Reyna said he knew someone who can build kitchen cabinets but after 33 days of requesting and waiting for him to document anything to begin the process, I’d decided to go with a professional and experience cabinet making company. For over 6 weeks, I have asked Mr. Reyna repeatedly to drywall the open soffit which exposed plumbing and wiring and other open walls so the cabinets can be measured and ordered. He refused until after I’d filed the initial complaint. On 3/14-15/2024, Mr. Reyna finally drywalled and textured the soffit and other holes after over 90 days from when he’d demolished and removed my kitchen cabinets, I could finally order cabinets on the main wall. Please Note: The cabinet company sent their salesman to my home each week to confirm measurements and confirm if the soffit and wall was repaired.

MASTER BATHROOM Mr. Reyna, moved the entrance to the master bathroom and installed a wall and door opening and reframed the closet entrance. At the time, I did not provide authorization and did not have plans to perform services in the master bathroom while the rest of the home was under construction. He’d showed up and started then brought me back to the area to ask a question is when I’d noticed he’d already moved forward. I needed one safe area in the home free of drywall, dust and nails. This doorway was never provided a temporary door when my adult son and I had to reside in the master bedroom exclusively for over three weeks waiting for Mr. Reyna and his team to put down, grout, and tile the main house floors and bathroom. Mr. Reyna never told us we could vacate the master bathroom but after three weeks including one week with no reply from Mr. Reyna, I was upset and began to move our belongings back into the main areas. I am still upset we had to endure that type of living 24/7 for 22 days. The master bathroom wall was constructed and framed on top of carpet, and greenboard was not used. I was not aware Mr. Reyna had plans to demolish the master bathroom because I’d had several communications, I needed a fully working and functional bathroom at all times. And, the way Mr. Reyna was neglecting services discussed including no intention of completing Bathroom1. Mr. Reyna assured me he would not demolish my bathroom without my authorization and permission. Because he agreed I “needed a fulling working bathroom”. When he demolished the other 10 rooms prior, I was still using my vanity and had personal items used daily in the bathroom.

When the extremely loud noise started, I was working and noticed my son who was in the beginning stages of a seizure with slurred speech, forgetfulness, etc. I didn’t immediately notice the noise until I couldn’t conduct a business call. I’d went to the bedroom to investigate. Immediately, I’d noticed my shower was completely dismantled and my tub was ½ way cut with a chainsaw. No one stopped but kept demolishing. I yelled I have my personal bathroom items in my vanity and Mr. Reyna said, he’ll remove my items from inside my vanity drawers and cabinets for me which I felt would be an invasion of privacy. I immediately grabbed anything and began to fill boxes and tubs with items but it became too heavy to move. My son came back and said he was ok and helped moved the boxes up front but I knew his exposure to the really, really loud noise and cloudy room would cause a full seizure. Within 10 minutes after returning to the front room, my son had a Grand Mal seizure in a chair and fell over his desk and hit the floor. My master bathroom was not demolished by a licensed plumber so the shower, vanity, and tub plumbing were not properly assessed and on two occasions, water leaked from the vanity throughout the bathroom and overflowed into the master bedroom on the newly laid tile floors. Due to the weekend and working other projects, Mr. Reyna did not come over until several days later. I used towels and sheets on an unfinished dusty floor to keep the water soaked up. Mr. Reyna brought and used a fan to dry the wood frames. When the bathroom filled with water twice, the carpet under the frame was soaked. I asked for the wall to be redone and the carpet removed. Mr. Reyna refused. He said the tilers will use a tool to “pull out the carpet”. Since, Mr. Reyna has attempted to pull out some of the carpet from under the framed wall but carpet remains. Mr. Reyna lack the experience to know when carpet is wet, it remains soggy, grow mold then rot. He informed me he offers a warranty but on a non-existent contract? A few hours later, the boxes I was forced to bring up front was not in a secure area before night time and my vision is very low at night. In my attempt to move the heavy boxes myself (my son was recovering and could no longer assist), I’d fallen and broke my arm in two places. Combined with the open wound from the sharp edges in Bathroom1, I immediately informed Mr. Reyna of the displacement caused by several incomplete services including now two bathrooms.

GARAGE Mr. Reyna utilizes my garage as a work area allowing machinery and other items to remain plugged for over 60 days and covered the plug with large items to hide from my view. When I’d asked him if his machinery plugged into my garage outlets, he would respond, “No”, although the cord that leads to the plug was clearly in the air leading to wall outlet. Mr. Reyna and/or his team utilized items in my garage including a push-broom he would unscrew the handle and use it as extender for paining. I’d approached him and requested it is put back. He complied but when I’d left the garage, he unscrewed it and continue to use it for his work. The item has my last name is identified on the product. When I informed Mr. Reyna, I have a video camera with a doorbell in the garage and on the front porch, where the doorbell could be rung to let me know he had arrived. Mr. Reyna responded he was not aware, covered the camera with a newspaper and tape and left it for me to discover. When I’d asked him why he’d covered the camera, he said he didn’t do it and blamed my son who cannot freely access the garage.

Although his tools and work items were stored in the garage, I do not believe these items needed to be in the garage for over 90 consecutive days. Every single day, Mr. Reyna had the opportunity to remove his items and take them with him without fail. I believe these items were part of staging or a con to mislead me to believe work should be anticipated and will be completed soon but this was not the case. In addition, Mr. Reyna use of my garage for his construction site, displaced my vehicle where I have not been able to park in my garage for over 90 consecutive days.

EXTERIOR There are several droppings of plaster with buckets of white substance on my bricks surround the front of the home, the same white substance poured in a front joining area with a neighbor. Mr. Reyna assured me the white substance is water based and will immediately be dissolved with the first rainfall or with a hose. But for three days it rained heavily and the heavy white substance still remains on the new rocks purchased. My HOA has cited me to have the substance removed and this area restored. This area must be replaced. In addition, there is at least one patch of wood shavings left on the front of the home cited by my HOA to remove. When I’d brought it to his attention, he said it would dissolve into the rocks. After 4 weeks it has not resolved and is still there.

Continuous Excess Work Performed – Extra Day Rates Charged? Mr. Reyna and his team would purchase Sherwin Williams Super Paint around $70 a gallon and paint walls 2-3 times without caulking holes. When I’d asked why were the holes filled prior to painting, the response was “of course there will be a few tweaks”, and proceed to paint another 2-3 times again. The issue since I never received a contract, statement, or detailed summary prior to any work being performed, I guarantee, he was passing off daily rate charges to me to paint 3-4 walls an excess of 6-8 times including after the walls were already painted twice with white paint by his team. I’d asked Mr. Reyna several times to pre-paint the floor board prior to installing within the home because I did not was paint on the tile just installed. Mr. Reyna and his team said that is not the way floorboard are installed although I have talked to several crown molding Arizona companies informed me (prior to Mr. Reyna) not to allow anyone to install floorboards without painting first or you may be doubled or triple charged to perform the service several times: Mr. Reyna cut and installed floorboards and crown molding on one day, caulk another day, then paint on another day or maybe add more floorboards, then move onto another project then come back to the same floorboards, never completing. I would be billed for the same task several time although installation has never been completed. There’s paint on nearly all new items purchased prior to Mr. Reyna starting in December such as ceiling fans, new entry door and locks, a feature wall painted by someone I’d hired in February 2024, paint on my son’s car, etc. He has yet to remove any of the paint.

CLOSETS I’d purchased several thousand dollars’ worth of closet systems from IKEA for 8 closets (6 existing). To this day, if these closets were properly installed, we would be able to eliminate 20-30 boxes

of packed clothes and items. Mr. Reyna did not believe they should be placed on 2x4s for floorboards to adhere to but if there’s water damage, the closet systems will not be damaged with minimal water overflow. Against my wishes, a few of the closet systems were anchored to the wall without being placed on 2x4s. I was not happy and expressed this to Mr. Reyna. He’d attempted to put the closet systems on the 2x4 but several were not placed as instructed so I have not been able to unpack as expected. I’d asked if his brother can assemble the closet systems. If not, I will hire an outside service to assist me but due to his delays, I needed services escalated. There was an irregular pattern when his brother worked on the closets causing me stress because I could not eliminate the overflow of boxes and tubs for fear of harm if me or my son fell again. Mr. Reyna informed me his brother gets bored often and when there’s nothing for his brother to do, then he’ll send him over from other projects to assembly the closet systems. Which meant, it was not a priority and I had to wait and see what happens at “other” projects. This was probably the most honest statement Mr. Reyna has ever communicated to me.

PURCHASED PRODUCT – BATHROOM1 Mr. Reyna informed me to order the toilet (which was ADA), vanity with countertop, sink and faucets, towel warmer, mirrored vanity, he was ready to install. Mr. Reyna never attempted to remove the 72” vanity from the garage, blocking my car for over 30 days, and place into Bathroom1. I hired movers to move the vanity, inspect the countertop, sink and toilet for damages since Mr. Reyna never completed this task. Fortunately, I’d order through Amazon but only had 30 days from receipt to utilize the product for issues and defects then return for a full refund or exchange for a new product. All of these expensive items sat in my garage until the expiration of the 30-day warranty then I had to send back expensive and very heavy items then repurchase again for another 30-day warranty because Mr. Reyna failed to install any of the items because of his lack of knowledge to install and/or he didn’t care I would be out of pocket double the cost until the same items have been received, inspected and undamaged. That was $4,500 worth of product - twice! As of today, the towel warmer which was purchased twice, at his instructions, still have not been installed and time ran out on the 30-day warranty from Amazon. One of the Seller requested both the vanity and mirror medicine cabinet be installed within 5 days and they would extend their 30-day warranty for 60 days. These items were never installed within the time allotted and I’d lost the extra 60- day warranty on the vanity and mirror medicine cabinet.

ASSISTANCE A friend and I reviewed and discussed the red flags through financial and performance fraud conducted by Mr. Reyna. On several occasions, Mr. Reyna has eluded and manipulated legal requirements for his personal benefit. He would type random amounts on his calculator (unseen and unspoken), show me the amount I needed to pay and expected payment since he was leaving for the day. Although none of the projects were completed, I was expected to pay immediately. Each time, I’d asked for a Summary or itemized list and a receipt for my payment but he never provided any documentation or paperwork before services were rendered. Never!

I’m in training to sit for my Certified Fraud Examiners certification and I have told him several times. I’m trained to notice red flags in financial statements, contracts, etc. I’d misunderstood although Mr. Reyna had knowledge of projects yet started, I was informed to stop engaging with him via text with pictures and ideas of these future or incomplete projects. His lack of experience is displayed throughout my home. A friend read the ROC website and several Arizona laws to helped me understand, without a contract, I do not need to engage with Mr. Reyna for new projects or tasks. I’d ceased immediately. Then on March 20th, Mr. Reyna refused to provide any documentation or engage with an authorized third-party assessor or inspector, he abruptly abandoned the project and informed me I will be paying more undisclosed and uncontracted amount because he will be sending a bill, although I’ve never received previous statements or invoices outside of two bills from his unlicensed subcontractors (tilers). That was the beginning of his intimidation tactics.

WEDNESDAY, MARCH 20, 2024 When I’d asked for a contract or detailed summary for more than 12 times, Mr. Reyna sent me a current bill dated 3/20/2024, not 2/21/2024 as he’d previously showed me during a walkthrough. This bill had general amounts and without itemized details of whatever he’s working on. I’d once again asked for a contract or Summary Plan so I can understand the charges I have paid for. Mr. Reyna communication for payments have solely been by typing amounts on his phone’s calculator then turning to me to view and send a payment to his personal account. As a final attempt, I’d offered for us to locate a neutral third-party to assess or inspect the work he has completed (regardless if it was illegally installed) and the cost I’ve paid so I can develop the Project Summary since he’d refused on over 12 occasions to provide even a receipt when requested. He’d refused the third-party assessor or inspector option and informed me via text, he abandoned any unfinished projects and will be sending me a bill for additional monies never discussed or approved with an expectation for immediate payment. I made every attempt to resolve several outstanding issues but Mr. Reyna refused to work with me and abandoned all uncompleted services. To assist Mr. Reyna and avoid future discrepancies, I even recommended via text, Mr. Reyna consider utilizing DocuSign or hire someone to manage his finances. He refused, demanded his items and called the police without waiting the weekend or until Monday, March 25, 2024 for me to contact the ROC.

MARCH 24, 2024 – POLICE INTIMIDATION I have been in constant communications with Mr. Reyna since he’d abandoned the job via text on Wednesday, March 20, 2024, including specifically his tools left inside my garage for more than 90 days. Mr. Reyna has full and complete access to my garage since December 2023 via a code to enter. I informed Mr. Reyna, I will wait until I talk with the ROC on Monday, March 25th before allowing for him to return to my home. I also told him he was not allowed to use the code any longer and enter my home without my permission. His response was to call the police, not to mediate. Mr. Reyna called the police and both the police and Mr. Reyna came to my home on the morning of 3/24/2024 to collect his items on a civil matter, and the police informed me he had rights to enter my

home/garage to retrieve his item. I informed the police all of the items in the garage were included with my claim against Mr. Reyna with the ROC but the police said he had a legal claim to his items: Incident 24-431113. This is a civil complaint, not a criminal complaint. I thought the police enforce criminal codes not civil codes. I will have an attorney review this complaint and the complaint with the police. As far as I know, Mr. Reyna knew these police officers and encouraged them to accompany him to my home as part of his ongoing intimidation tactic, three men approaching an older female alone to cite the law and inform me it was against the law to without his items willingly left in my garage for more than 90 days. The police refused me to have a valid opportunity for the ROC to investigate and view home without interference. The only communications from Mr. Reyna in front of the police is that he left the current mess in the garage for the ROC to view, not the complaint of dangerous tools and unauthorized use of my SRP. In addition, Mr. Reyna informed me in front of the police, he will be sending a bill for more unauthorized and uncontracted items never discussed including charges for all the “product” or garbage he’d left on the floor of the garage. He’d failed to clean up the mess he scattered around the garage. This is now twice in 45 days I’ve been forced to hire someone to pay out of pocket to clean his mess.

ADDITIONAL COSTS - DAMAGES Additional costs as outlined below: 1) $3,500+ for take-out meals and grocery meals (24/7 breakfast, lunch, dinner); 2) $550+ additional unknown costs to clean the garage on two separate occasions; 3) $700 to purchase, deliver and distribute new rocks required by my HOA; 4) Time lost and additional time for another remodel, ongoing interference with new employment including background noise, lack of privacy until and no available time off for new licensed contractor (Value: $5,000) 5) There is white paint on the side of the car stored in the garage Mr. Reyna was working on, must be removed (Value to Repair: Unknown); 6) Similar to white paint on my new ceiling fans in two rooms (Valued to Replace: $100 each); 7) New fire door (Valued to Repair: $1,400/$500); 8) New keyed door locks (Valued to Replace: $125); 9) Several areas from painting the newly installed porcelain floor (Value to Replace: Unknown); 10) A newly textured black wall (Valued Replace: $750); 11) Purchase, deliver, and distribute new rocks required by my HOA for an area he’d poured a white non-dissolvable substance that has now stained the area in an adjoining area (Value to Replace: $700 include delivery); 12) 90-day storage fee for his tools and equipment (Valued: $300); 13) Cost to repair water line for refrigerator (Value: Unknown to Repair);

I refused to purchase a new bed and bed frame for fear of it being damaged with paint by Mr. Reyna and his team. After several discussions with Mr. Reyna to remove the paint on the above items, no attempts have been made. My friend pointed out it appears any new item that was not installed or not serviced by Mr. Reyna has paint on it. It appears malicious.

I’d initially filed a claim with the ROC but after I’d talked to the ROC, I was told it is recommended to allow for a contractor to fix the work. Although I didn’t agree because he was using unlicensed subcontractors, demolishing and building without a contract and permit, requesting payments totaling over $22,000 via Zelle and have not completed one single project in my home. I believe any monies paid was used for other project at other locations. Mr. Reyna proudly showed how Mr. Reyna and his team installed windows, oversized patio wall doors, remodeled bathrooms, and kitchens, completed since he’d started working over at my home.

REMEDIATION I’m requesting financial reimbursement of: 1) All payments totaling over $22,000 paid directly to Mr. Reyna via Chase Bank, Zelle. My tasks were on a project basis and not one project has been completed. I’ve brought this to his attention on several occasions. Please Note: Previously, I’ve reimbursed Mr. Reyna any out-of- pocket costs for products. 2) $50,000 for pain and suffering. 3) $2,000+ additional unknown costs in damages outlined under the Additional Costs section. 4) Lawyer and court costs (If needed)

Mr. Reyna left my home in an egregious manner for two ADA occupants to unskillfully maneuver. We have tripped, stumbled, and fallen several times throughout the day. All services were unpermitted and general work performed by Mr. Reyna and his unlicensed subcontractors were not experienced with large remodeling, contract management, or experienced handling large sums of monies.

1) I’m requesting a full walkthrough from the ROC as soon as possible. It is uncomfortable to navigate around a construction site within my home and garage. My home has been left untouched and waiting for a walkthrough investigation. Mr. Reyna texted to notify me he was abandoning the work and will compile a list of unknown costs for unknown services and unknown material. Another retaliatory attempt from Mr. Reyna to extort unjustified costs. 2) I informed Mr. Reyna on several occasions that I was looking for a full-time license contractor that will finish my home with projects in stages with the first stage ending 2/1/2024 because my son suffers seizures and has blackouts, I needed to ensure periods of stability before continuing to complete the remodeling. He disregarded my request. 3) I’d informed Mr. Reyna on several occasions, I’m partially blind and have trouble with my vision at night so his tools and cords lying around for days or weeks was scary and overwhelming. There were times, boxes or items were moved and left in a pathway where we could suffer injuries due to falls. 4) I never provided authorization to demolish of my bathroom, caused me to fall and break my primary arm in two places and smash my right breast. I’d showed him the bruise on my arm but his lack of empathy has left my home in its current state. 5) I’ve been displaced without a bed and sleeping on the couch for over 5 weeks. The carelessness of painting newly purchased or items not installed by Mr. Reyna appeared to be malicious. 6) We do not have a bathroom to wash up in or bedroom I can dress in before work. We use the toilet in one room, can’t shower in either of the bathrooms, and wash our bodies, face and

hands, brush our teeth in the kitchen sink that is sitting on (4) 2x4s. Unfortunately, visitors and contractors use the same one toilet (which smells after various uses) and wash their hands in the kitchen sink. 7) Mr. Reyna refused on several occasions to provide any contract, Summary Plan or a Plan with detailed services that will be performed, has been performed, a statement and receipts of any monies paid to his personal account via Zelle. The only two general statements provided included services from his subcontractor tilers for tile services and plumbing services Mr. Reyna performed under $1,000 and flooring installed. 8) According to Mr. Reyna, his KB-2 license allows for him to perform ongoing $1,000 jobs without a contract for framing, drywall, plumbing and partial electrical services. I believe this is a Handyman or similar License. 9) Mr. Reyna never provided a Plot Plan from an architect or obtain any permits from the City of Phoenix before demolition and framing walls and other items. 10) Mr. Reyna led me to believe the subcontractors he was providing was licensed and bonded. 11) Bathroom1 is not ADA compliant and does not have a slope or grab bar to use for assistance. The shower does not provide a 30” clearance between the pony wall and the shower bench, nor is there a beachfront slope entry. Upward facing nails, wires, sharp and jaggered edges are exposed and dangerous. For the last 42 days, we’ve shower at a neighbor or friend house. 12) If in use, Bathroom1 currently is exposed and does not offer any privacy from the hallway and surrounding rooms. 13) My home is left as an ongoing dangerous construction site – items left for a partially blind person to continuously fall and cause more bodily harm. 14) I am seeking reimbursement for the cost of take-out meals via Door dash, Uber Eats or Pick up, and groceries for meals in lieu of cooked meals due to Mr. Reyna refusal to install a temporary range fan or reinstall the previous range fan so I can use the stove top and oven to cook meals. I was told on several occasions the grease would stain the walls and paint job, so I could not use the new range recently purchased from Lowe’s. 15) Mr. Reyna installed a water line for my new refrigerator that has never worked. It is too late for Lowe’s to install the water line because Mr. Reyna stated he will “fix it”. There will be a cost for a licensed plumber to fix his error.

I request the ROC take a look at Mr. Reyna other jobs currently working or recently completed. He’d showed me windows, large panel sliding doors, bathrooms and kitchens being installed at another location(s). Were permits pulled on those projects as well? Did his customer receive a contract, Summary Detail or receipts for services rendered? Those jobs are not my concern, just the pattern Mr. Reyna will go to defraud customers and not adhere to the guidelines outlined by the ROC. I’m physical sore caused by his negligence, and we’re emotionally and physically damaged from this experience. Although Mr. Reyna and his team appeared to be professional, cordial and never stole personal items, his willingness to take on project outside of his scope of his license with not research Arizona law or provide an apology for falsely representing he could do it all, fell short on completing absolutely nothing and wasted my time, took my money, and now acting as if he’s the victim.

Mr. Reyna has since acted malicious towards me because I’d simply requested a Summary Plan, offered a neutral third-party to assess his work and my payments paid, recommended DocuSign for use within his business, and I have not to this day, called the police nor provided a negative comment for online reviews of his business regarding this horrific experience working with Mr. Reyna and his team. I do not know Mr. Reyna personally and Mr. Reyna, his subcontractors and family members had full access to my home including a code to enter the garage whenever it was convenient. Since March 20, 2024, Mr. Reyna has never communicated, apologized, or assured me via text or in person, Mr. Reyna, his subcontractors, associates, family, and friends will not physically retaliate or bring physical harm against me, Yvette Cockrell, my son, Princeton Cockrell, family members, pets, home structure, personal property, employment, neighbors and future licensed contractors because I, Yvette Cockrell, who reside at 5214 S. 53rd Lane, Laveen, AZ 85339, filed a complaint with the AZ Registrar of Contractors (ROC) or other legal entities due to his business actions only. This document serves as validation if Mr. Reyna, his subcontractors, associates, family, and friends physically retaliate or bring physical harm, I have the right to immediately contact the police and file a criminal lawsuit against these parties. From my understanding, each violation by Mr. Reyna has facilitated several possible felonies that carries imprisonment including financial restitution. Mr. Reyna swiftly and without fail, abandoned the work site then called the police all within 4 calendar days which included Saturday and Sunday. Please find in my favor I am due a full reimbursement of all monies paid, reimbursement of damages, and additional costs outlined above, including pain and suffering. Thank you.

Yvette Cockrell 480-322-1618

Additional documentation – Available Upon Request

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<=ÿ ÿ 6/26/24, 8:04 AM State of Arizona Mail - Written Answer to Citation and Complaint Case No. 2024-03468.

Answers - AZROC <[email redacted]>

Written Answer to Citation and Complaint Case No. 2024-03468. message

hugo reyna <[email redacted]> Tue, Jun 25, 2024 at 10:53 PM To: [email redacted]

Good evening,

I have tried to two separate attempts to complete written directive given by ROC Investigator, homeowner has failed to allow access to complete work. Homeowner continues to send a separate list via email and usps demanding all work conducted by my complete be completely redone. The corrective directive required us to fix a couple items and finish items in which before ROC complaint began I tried scheduling with Mrs. Yvette. Not once did we abandoned work as she claims, when this allege abandonment was filed. I advised homeowner when she cancelled the day before for the 3rd time. To let me know when we can reschedule to come back to work but we would be completing last items and no new work would take place. I’ am still willing to comeback and complete work as per ROC.

thank you,

https://mail.google.com/mail/b/AEoRXRRXSmi9Lzg70f0hcMCgzg0L2sQxsnDIqJeLwN39AROdZrYl/u/0/?ik=581c53cf5c&view=pt&search=all&permthid… 1/1 01232ÿ567892ÿ1 ÿÿ5ÿ56ÿÿ56ÿÿ5ÿ6ÿÿ !"#$%&'#($)ÿ+,-&-./'(,%ÿÿ 1223245ÿ ÿ 6ÿ)-ÿ7-&ÿ,'8$ÿ'ÿ)'&$ÿ&,$ÿ('"7&ÿ9'%ÿ-7ÿ&,$ÿ8$,":;$ÿ)<$ÿ&-ÿ7-&ÿ,'8"7.ÿ'::$%%ÿ&-ÿ&,$ÿ.'/'.$ÿ=-/ÿ%$8$/';ÿ 9$>%ÿ'7)ÿ&,$ÿ?#$ÿ6@)ÿ$7&$/$)ÿ&,$ÿ.'/'.$ÿ9,$7ÿA/BÿC$D7'ÿ9'%ÿ(/$%$7&Eÿ&,$/$ÿ9$/$ÿ';9'D%ÿF-G$%ÿ-/ÿ,"%ÿ "&$#%ÿ;

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Case No.: 2024-03468 Investigator: Jack Grimm Inspection Date: Monday, April 22, 2024 Inspection Time: 10:00 AM

Complainant: Lisa Cockrell Respondent: HR Capital Not Present: Contracting LLC Not Present:

Jobsite General Notes: Present representing HR Capital Contracting LLC was Hugo Reyna – Owner. This project was a mostly labor only as the complainant/homeowner provided most of the materials and components. HR states he provided some small needed materials and billed for those materials.

Complaint Item #1: Incomplete bathroom #1, incomplete vanity, exposed wiring, sharp edges at shower tile trim and not ADA compliant Investigators Observation: Bathroom # 1 is incomplete. Most of the components are in place. The incomplete work includes but not limited to, incomplete electrical, drywall repairs and paint, incomplete vanity installation, poor tile trim work with sharp edges, incomplete casing on door, incomplete toilet installation, incomplete plumbing and generally not completed and cleaned. Electrical work is provided and paid for by the homeowner and should be completed prior to the completion of drywall and paint. *Complete bathroom as outlined above. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #2: Demolished master bathroom. Investigators Observation: Demo in master bathroom appears to be mostly completed and invoiced and paid for. Some minor framing work was completed at the doorway. Unable to determine if the walls are in the correct locations as no plans exist. Walls were built over carpet. Parties’ state there was talk about adding a pocket door. Generally unable to determine what was agreed upon or not regarding the master bathroom. *Correct locations where walls were built over carpet. 1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C011 12/23

Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #3: Facilitated unlicensed subcontractors. Investigators Observation: No evidence was presented regarding this allegation. Governing Rule: N/A

Complaint Item #4: Poor framing and lack of green board. Investigators Observation: Framing will be addressed in #7. Green board is generally not used anymore. There are certain requirements for moisture resistance drywall in various locations. Code compliance would address this item if needed. However no permits were obtained. This issue will be addressed in #7. Governing Rule: N/A

Complaint Item #5: Incomplete door casing and paint. Investigators Observation: New doors and with jams were installed throughout the home. New door install should and generally do include the installation of casing and there was an agreement to paint the home that is incomplete. *Complete all door installation including the installation of casing as needed and paint. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #6: Wall painted with black paint damaged. Investigators Observation: Homeowner states she had this location painted black and the respondent’s workers damaged it. *Correct locations of damaged paint. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #7: Lack of permit for framing, electrical and plumbing. Investigators Observation: Extensive framing and electrical work is being performed in the home. Framing and plumbing is being performed by the respondent. Homeowner states she has hired and paid for the electrical work. Framing and any plumbing work that took place below the floor line and behind the wall line would require a permit. Homeowner has hired an electrician and that work was performed with no permit as well. I encouraged the homeowner to have her or her electrician obtain a permit. This is a health and safety issue. *Obtain the required permits and obtain all required inspections and approvals from the local code jurisdiction governing authority. Governing Rule: 32-1154(A)(2) Departure from or disregard of building codes.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C011 12/23

Complaint Item #8: Incorrect laundry room recessed tool and coat areas. Investigators Observation: Unable to determine if the work performed is correct or not as there is no documentation regarding this installation. Work appears complete. Governing Rule: N/A

Complaint Item #9: Incomplete floor base and paint. Investigators Observation: Installation of flooring appears complete. The base installation is incomplete in several locations throughout the home. Several locations of drywall work was performed and the painting of those locations is incomplete. *Complete the installation of the base and paint walls and base as needed. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #10: Plaster/white substance dumped in yard. Investigators Observation: Observed locations of residual debris in yard. Clean as needed. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #11: Continuous excess work performed – extra day rates charged. Investigators Observation: Work was being charged at a labor rate. The ROC does not regulate costs. Unable to address financial issues. Governing Rule: N/A

Complaint Item #12: Closets and shelving incomplete. Investigators Observation: Owner provided modular closet shelves and drawers. This work is started but incomplete. Homeowner states there was an agreement to raise the boxes off of the floor. Some have been raised and others not. If some are done it appears there was an agreement. *Lift boxes off of floor and complete installation including but not limited to installation, trim as needed, perform any drywall repairs and paint as needed and complete for functionality. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #13: Requesting remediation and financial reimbursement. Investigators Observation: The ROC has no financial jurisdiction to direct any payments, restitution or reimbursements. That is what civil court does. Governing Rule: N/A

Complaint Item #14: Lack of Contract. Investigators Observation: No contract or agreement was in place. A warning letter for minimum elements of a contract will be issued. Governing Rule: 32-1158(A) Minimum Elements of a contract over $1,000.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C011 12/23

Complaint Item #15: Paneling and trim in two (2) bedrooms poorly installed and incomplete. Investigators Observation: Work regarding trim around the windows and walls was performed in two bedrooms. This work is poorly done. Paneling was installed on top of base, has poor fit and finish. Trim around windows is not installed the same. *Correct trim around windows, base should be installed in top of paneling and correct for fit and finish. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #16: Paint on vehicle stored in garage. Investigators Observation: Unable to determine who got paint/drywall compound on car as homeowner had others at the home and at some point performing drywall and/or paint work in garage. Governing Rule: N/A

Jack Grimm Jack Grimm, Investigator #172 602 7716741 [email redacted] 1700 W Washington St. Suite 105 Phoenix, Arizona 85007-2812

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C011 12/23

Complainant: Lisa Cockrell 5214 S. 53rd Lane Laveen, AZ 85339

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C008 12/23 Respondent: HR Capital Contracting LLC 11214 W Sieno Pl Avondale, AZ 85392

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C008 12/23 March 29, 2024

Re: Complaint No. 2024-03468

Dear Complainant and Respondent:

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

A jobsite inspection is scheduled for Monday, April 22, 2024 at 10:00 AM. The Complainant is required to be present. The Respondent’s attendance is requested and encouraged. The Registrar encourages both parties to make a good faith effort to resolve this complaint prior to the jobsite inspection.

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

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

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C008 12/23 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,

Jack Grimm Jack Grimm, Investigator #172 602 7716741 [email redacted] 1700 W Washington St. Suite 105 Phoenix, Arizona 85007-2812

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C008 12/23 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 1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C008 12/23 make any determination at the time of the jobsite inspection regarding whether the allegations listed in the complaint are supported. ● If the allegations are confirmed, the Registrar’s Investigator may issue a Written Directive telling the contractor to correct the poor or incomplete work. ● If the allegations are not confirmed, the Registrar’s Investigator will close the complaint.

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

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C008 12/23 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 1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C008 12/23 professionalism to complete the work. Moreover, the complainant may not dictate the manner of repair. If the contractor fails to appropriately correct the work according to the contract, the Registrar will issue a citation.

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

Work performed after the directive ends: After the Directive period ends, a property owner may choose to allow the contractor to continue its work. The Registrar encourages parties to work cooperatively, but cannot 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 12/23 Complainant: Lisa Cockrell 5214 S. 53rd Lane Laveen, AZ 85339

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 12/23 Respondent: HR Capital Contracting LLC 11214 W Sieno Pl Avondale, AZ 85392

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 12/23 May 7, 2024

License No. ROC 346260

Re:Complaint No. 2024-03468

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 Thursday, May 30, 2024.

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

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

Complaint Item #1: Incomplete bathroom #1, incomplete vanity, exposed wiring, sharp edges at shower tile trim and not ADA compliant Investigators Observation: Bathroom # 1 is incomplete. Most of the components are in place. The incomplete work includes but not limited to, incomplete electrical, drywall repairs and paint, incomplete vanity installation, poor tile trim work with sharp edges, incomplete casing on door, incomplete toilet installation, incomplete plumbing and generally not completed and cleaned. Electrical work is provided and paid for by the homeowner and should be completed prior to the completion of drywall and paint. *Complete bathroom as outlined above. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall 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 12/23 perform all work in a professional and workmanlike manner.

Complaint Item #2: Demolished master bathroom. Investigators Observation: Demo in master bathroom appears to be mostly completed and invoiced and paid for. Some minor framing work was completed at the doorway. Unable to determine if the walls are in the correct locations as no plans exist. Walls were built over carpet. Parties’ state there was talk about adding a pocket door. Generally unable to determine what was agreed upon or not regarding the master bathroom. *Correct locations where walls were built over carpet. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #5: Incomplete door casing and paint. Investigators Observation: New doors and with jams were installed throughout the home. New door install should and generally do include the installation of casing and there was an agreement to paint the home that is incomplete. *Complete all door installation including the installation of casing as needed and paint. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #6: Wall painted with black paint damaged. Investigators Observation: Homeowner states she had this location painted black and the respondent’s workers damaged it. *Correct locations of damaged paint. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #7: Lack of permit for framing, electrical and plumbing. Investigators Observation: Extensive framing and electrical work is being performed in the home. Framing and plumbing is being performed by the respondent. Homeowner states she has hired and paid for the electrical work. Framing and any plumbing work that took place below the floor line and behind the wall line would require a permit. Homeowner has hired an electrician and that work was performed with no permit as well. I encouraged the homeowner to have her or her electrician obtain a permit. This is a health and safety issue. *Obtain the required permits and obtain all required inspections and approvals from the local code jurisdiction governing authority. Governing Rule: 32-1154(A)(2) Departure from or disregard of building codes.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 12/23 Complaint Item #9: Incomplete floor base and paint. Investigators Observation: Installation of flooring appears complete. The base installation is incomplete in several locations throughout the home. Several locations of drywall work was performed and the painting of those locations is incomplete. *Complete the installation of the base and paint walls and base as needed. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #10: Plaster/white substance dumped in yard. Investigators Observation: Observed locations of residual debris in yard. Clean as needed. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #12: Closets and shelving incomplete. Investigators Observation: Owner provided modular closet shelves and drawers. This work is started but incomplete. Homeowner states there was an agreement to raise the boxes off of the floor. Some have been raised and others not. If some are done it appears there was an agreement. *Lift boxes off of floor and complete installation including but not limited to installation, trim as needed, perform any drywall repairs and paint as needed and complete for functionality. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – A contractor shall perform all work in a professional and workmanlike manner.

Complaint Item #14: Lack of Contract. Investigators Observation: No contract or agreement was in place. A warning letter for minimum elements of a contract will be issued. Governing Rule: 32-1158(A) Minimum Elements of a contract over $1,000.

Complaint Item #15: Paneling and trim in two (2) bedrooms poorly installed and incomplete. Investigators Observation: Work regarding trim around the windows and walls was performed in two bedrooms. This work is poorly done. Paneling was installed on top of base, has poor fit and finish. Trim around windows is not installed the same. *Correct trim around windows, base should be installed in top of paneling and correct for fit and finish. Governing Rule: 32-1154 (A)(3) Poor or incomplete work – 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 C009 12/23 ITEMS NOT REQUIRING CORRECTION The following complaint items require no action by the Respondent:

Complaint Item #3: Facilitated unlicensed subcontractors. Investigators Observation: No evidence was presented regarding this allegation. Governing Rule: N/A

Complaint Item #4: Poor framing and lack of green board. Investigators Observation: Framing will be addressed in #7. Green board is generally not used anymore. There are certain requirements for moisture resistance drywall in various locations. Code compliance would address this item if needed. However no permits were obtained. This issue will be addressed in #7. Governing Rule: N/A

Complaint Item #8: Incorrect laundry room recessed tool and coat areas. Investigators Observation: Unable to determine if the work performed is correct or not as there is no documentation regarding this installation. Work appears complete. Governing Rule: N/A

Complaint Item #11: Continuous excess work performed – extra day rates charged. Investigators Observation: Work was being charged at a labor rate. The ROC does not regulate costs. Unable to address financial issues. Governing Rule: N/A

Complaint Item #13: Requesting remediation and financial reimbursement. Investigators Observation: The ROC has no financial jurisdiction to direct any payments, restitution or reimbursements. That is what civil court does. Governing Rule: N/A

Complaint Item #16: Paint on vehicle stored in garage. Investigators Observation: Unable to determine who got paint/drywall compound on car as homeowner had others at the home and at some point performing drywall and/or paint work in garage. Governing Rule: N/A

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 12/23 Please direct all questions regarding this Directive to the undersigned Investigator.

Sincerely,

Jack Grimm Jack Grimm, Investigator #172 602 7716741 [email redacted] 1700 W Washington St. Suite 105 Phoenix, Arizona 85007-2812

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 12/23 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