2024A-05725-CHC-ROC Notice of Hearing & Packet MAILED.pdf

2024A-05725-CHC-ROC · Registrar of Contractors · 2024-10-09

REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA

Stephen Barton , Case No. 2024-05725

COMPLAINANT, Docket No. 2024A-05725-CHC-ROC

v. NOTICE OF HEARING ON CONTESTED CASE Solar Electric Freedom LLC License No. ROC 315008,

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

HEARING INFORMATION The hearing is set for:

November 25, 2024 1:00 PM Kay Abramsohn Google Meet. A link will be provided directly from The Office of Administrative Hearings. Go to www.azoah.com to request to appear in-person.

If you have requested to appear in-person at the hearing, the hearing will be held at 1740 W Adams Street, Phoenix, AZ 85007.

You must attend this hearing. This is an adversarial hearing before an administrative law judge, and is conducted in a similar manner as judicial proceedings. Thus, you must be

prepared to present evidence, including witness testimony and documents, in support of your case.

STATEMENT OF LEGAL AUTHORITY AND JURISDICTION

The State of Arizona has determined that the licensing and regulation of construction contractors is a proper state function, and has vested authority in the Registrar of Contractors to administer Title 32, Chapter 10 of the Arizona Revised Statutes. A.R.S. §§ 32-1101 et seq. All hearings for alleged violations of Title 32, Chapter 10 are conducted under Title 41,

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

The statutes and rules governing the hearing can be found at: Arizona Revised

Statutes §§ 41-1092 to -1092.12, and Arizona Administrative Code R2-19-101 to -122.

PARTICULAR ARIZONA STATUTES AND RULES INVOLVED

The statutes and rules the Respondent is alleged to have violated are cited in the

complaint and citation, which were served on the Respondent on September 18, 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 October 9, 2024.

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

Copy mailed via USPS First Class mail October 9, 2024 to:

Respondent(s) Solar Electric Freedom LLC PO Box 22157 Mesa, AZ 85277

Respondent's Attorney Paul K Frame, Esq. 2901 N Central Ave., Ste. 1600 Phoenix, AZ 85012 Complainant(s) Stephen Barton 19895 E Sonoqui Blvd Queen creek, AZ 85142

Copy sent electronically this same date to: Respondent at email address on record with the Registrar Respondent’s Attorney at email address of record with Registrar Complainant at email address on record with the Registrar

Case No. 2024-05725 /

Hearing Packet FAQ What is the The Hearing Packet is a packet of certain documents collected or Hearing Packet? issued by the Registrar over the course of its investigation. Who gets the The Hearing Packet is assembled and distributed to all parties and Hearing Packet? to the Office of Administrative Hearings (“OAH”) prior to an administrative hearing. What types of The Registrar prepares a Hearing Packet for Complainant-Handled cases does the Cases and No-Pay Cases. Note: If the Docket Number on the Registrar prepare a Notice of Hearing contains a “CHC” or “NPC”, your case is a Hearing Packet for? Complainant-Handled Case or a No-Pay Case. What is in the The Hearing Packet contains essential case-specific documents and Hearing Packet? at a minimum will include the following documents: ● Original complaint; ● 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 If there is any evidence you submitted to the Registrar that are not documents missing included in the Hearing Packet it is your responsibility to introduce from the Hearing that evidence at the administrative hearing. Note: The Packet? 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

How do I disclose You must properly disclose any and all documents and witnesses evidence I intend to you intend to use at your hearing according to the Registrar’s use at a Hearing? 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 If you previously submitted documents to the Registrar and need a documents I copy of these documents, please contact the Registrar’s Legal previously submitted Department or submit a public records request at to the Registrar? https://roc.force.com/AZRoc/s/roc-public-request.

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

Complainant: Stephen Barton 19895 e Sonoqui Blvd Queen creek, AZ 85142

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: Solar Electric Freedom LLC DBA: PO Box 22157 Mesa, AZ 85277

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C008 12/23 May 22, 2024

Re: Complaint No. 2024-05725

Dear Complainant and Respondent:

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

A jobsite inspection is scheduled for Friday, June 7, 2024 at 08:00 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,

Patricia Schuette, Investigator (602) 771-6744 [email redacted] 1700 W Washington St, Ste 105 Phoenix, AZ 85007

Cc: File Respondent Complainant

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

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

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · 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.

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

Case No.: 2024-05725 Investigator: Patricia Schuette Inspection Date: Friday, June 7, 2024 Inspection Time: 08:00 AM

Jobsite Address: 19895 E Sonoqui Blvd Queen Creek, AZ 85142

Complainant: Stephen Barton Respondent: Solar Electric Not Present: Freedom LLC Not Present:

Jobsite General Notes: Both parties were present including Keith Rowley with Solar Electric.

Complaint Item: 1- Blown out walls in attic with debris left everywhere. Attempts to repair are not industry standard or to ROC guidelines Investigator’s Observation: Verified. There are some remnants of foam insulation left on attic drywall from installation. Respondent to correct within appropriate means. Governing Rule: ARS §32-1154 (A) (3) namely R4-108, Poor work not performed in accordance with professional industry standards.

Complaint Item: 2- Drywall repair at Garage not to code or guidelines. Investigator’s Observation: Verified. There are drywall repairs needed where panel work was performed. Respondent to correct within appropriate means. Governing Rule: ARS §32-1154 (A) (3) namely R4-108, Poor work not performed in accordance with professional industry standards.

Complaint Item: 3- Insulation behind drywall repair at garage not to R value and guidelines Investigator’s Observation: Verified. Spray foam insulation was used in an attempt to insulate the area above all 3 panels but did not fill the cavity properly. Respondent to correct within appropriate means. Governing Rule: ARS §32-1154 (A) (3) namely R4-108, Poor work not performed in accordance with professional industry standards. 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: 4- Panels not labeled and other panel installed incorrectly Investigator’s Observation: Corrected prior to inspection. Governing Rule: N/A

Complaint Item: 5- Sub Panel at garage exposed and blanks in spaces not installed Investigator’s Observation: Verified. There are blanks without covers as well as knock outs that were not used nor sealed properly in multiple panels. E3404.6 Unused openings. Unused openings, other than those intended for the operation of equipment, those for mounting purposes, and those permitted as part of the design for listed equipment shall be closed to afford protection substantially equivalent to the wall of the equipment. Where metallic plugs or plates are used with nonmetallic enclosures they shall be recessed at least ¼” (6.4 mm) from the outer surface of the enclosure. [110.12(A)] Respondent to identify areas and correct within appropriate means. Governing Rule: ARS §32-1154 (A)(2)(b) Departure from or disregard of: A building code of this state or any political subdivision of this state in any material respect that is prejudicial to another.

Complaint Item: 6- abandoned wiring in attic not properly capped off or ended. Investigator’s Observation: Corrected prior to inspection Governing Rule: N/A

Complaint Item: 7- Conduit for elec items not plumb or level multiple places Investigator’s Observation: Unverified. The issue brought to attention at the time of inspection is that there were electrical conduits that were running over the top of two separate plat forms, which is against code. This is on another complaint filed. Governing Rule: N/A

Complaint Item: 8- over cut holes in exterior walls of home not properly sealed or weatherproofed. Investigator’s Observation: Partially verified. Some repairs had been made prior to the inspection but paint still needed. Respondent to correct within appropriate means. Governing Rule: ARS §32-1154 (A) (3) namely R4-108, Poor work not performed in accordance with professional industry standards.

Complaint Item: 9- unsure/unlikley back up sub panel is permitted for. Was never inspected, installed after elec final was passed. Investigator’s Observation: Verified. Sub panel was installed after final 1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C011 12/23

and close out of permit was done. Respondent to obtain applicable permit for corrections and submit new renderings to Queen Creek building department for approval on any and all changes from original submission. Governing Rule: ARS §32-1154 (A)(2)(b) Departure from or disregard of: A building code of this state or any political subdivision of this state in any material respect that is prejudicial to another.

Complaint Item: 10- Holes, drill bit left in ceiling of garage Investigator’s Observation: Unverified. Corrected prior to inspection. Governing Rule: N/A

Complaint Item: 11- excessive cracking and drywall staining from dirty hands etc in garage Investigator’s Observation: Partially verified. Some drywall repairs were completed by the complainant. Unable to confirm that any new drywall issues at the ceiling are at the result of the respondent. Respondent to address the dirt staining on the attic access within appropriate means. Governing Rule: ARS §32-1154 (A) (3) namely R4-108, Poor work not performed in accordance with professional industry standards.

Complaint Item: 12- R value at conduits at scuttled in garage non existent due to removed insulation Investigator’s Observation: Unverified. Corrected prior to inspection. Governing Rule: N/A

Complaint Item: 13- Insulation pulled out of walls left scattered in attic space. Investigator’s Observation: Verified. This is duplication to item 1. Respondent to correct within appropriate means. Governing Rule: ARS §32-1154 (A) (3) namely R4-108, Poor work not performed in accordance with professional industry standards.

Complaint Item: 14- 8sqft of insulation removed leaving huge hole in attic compartment, No R value Investigator’s Observation: Unverified. Corrected prior to inspection. Governing Rule: N/A

Complaint Item: 15- Attempted repair above sons bedroom not to code or standard. No R value Investigator’s Observation: Unverified. Corrected prior to inspection. Governing Rule: N/A

Complaint Item: 16- Debris and material left on site in garage Investigator’s Observation: Partially verified. There was some debris under the 3 panels in the garage. Some definitely from Respondent. Some may be from complainant. Respondent to clean up after work. 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: ARS §32-1154 (A) (3) namely R4-108, Poor work not performed in accordance with professional industry standards.

Complaint Item: 18- Debris and drywall mud left on floor and walls of garage Investigator’s Observation: Partially verified. Duplication to item 16. Respondent to correct within appropriate means. Governing Rule: ARS §32-1154 (A) (3) namely R4-108, Poor work not performed in accordance with professional industry standards.

Complaint Item: 19- excessive spray foam hanging out of exterior of home at conduits Investigator’s Observation: Unverified. Corrected prior to inspection. Governing Rule: N/A

Complaint Item: 20- Poor repair between garage and house for removed insulation, no R value Investigator’s Observation: Unverified. Corrected prior to inspection. Governing Rule: N/A

Complaint Item: 21- Drywall repair at Garage not to code or guidelines. Investigator’s Observation: Unverified. Corrected prior to inspection. Governing Rule: N/A

Patricia Schuette, Investigator (602) 771-6744 [email redacted] 1700 W Washington St, Ste 105 Phoenix, AZ 85007

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

Complainant: Stephen Barton 19895 e Sonoqui Blvd Queen creek, AZ 85142

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: Solar Electric Freedom LLC DBA: PO Box 22157 Mesa, AZ 85277

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 12/23 June 25, 2024

License No. ROC 315008

Re:Complaint No. 2024-05725

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 July 20, 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: 2- Drywall repair at Garage not to code or guidelines. Investigator’s Observation: Verified. There are drywall repairs needed 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 where panel work was performed. Respondent to correct within appropriate means. Governing Rule: ARS §32-1154 (A) (3) namely R4-108, Poor work not performed in accordance with professional industry standards.

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- unsure/unlikley back up sub panel is permitted for. Was never inspected, installed after elec final was passed. Investigator’s Observation: Verified. Sub panel was installed after final and close out of permit was done. Respondent to obtain applicable permit for corrections and submit new renderings to Queen Creek building department for approval on any and all changes from original submission. Governing Rule: ARS §32-1154 (A)(2)(b) Departure from or disregard of: A building code of this state or any political subdivision of this state in any material respect that is prejudicial to another.

Complaint Item: 16- Debris and material left on site in garage Investigator’s Observation: Partially verified. There was some debris under the 3 panels in the garage. Some definitely from Respondent. Some may be from complainant. Respondent to clean up after work. Governing Rule: ARS §32-1154 (A) (3) namely R4-108, Poor work not performed in accordance with professional industry standards.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 12/23 not performed in accordance with professional industry standards.

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

Complaint Item: 4- Panels not labeled and other panel installed incorrectly Investigator’s Observation: Unverified. Corrected prior to inspection. Governing Rule: N/A

Complaint Item: 6- abandoned wiring in attic not properly capped off or ended. Investigator’s Observation: Unverified. Corrected prior to inspection Governing Rule: N/A

Complaint Item: 10- Holes, drill bit left in ceiling of garage Investigator’s Observation: Unverified. Corrected prior to inspection. Governing Rule: N/A

Complaint Item: 12- R value at conduits at scuttled in garage non existent due to removed insulation Investigator’s Observation: Unverified. Corrected prior to inspection. 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 Complaint Item: 14- 8sqft of insulation removed leaving huge hole in attic compartment, No R value Investigator’s Observation: Unverified. Corrected prior to inspection. Governing Rule: N/A

Complaint Item: 15- Attempted repair above sons bedroom not to code or standard. No R value Investigator’s Observation: Unverified. Corrected prior to inspection. Governing Rule: N/A

Complaint Item: 19- excessive spray foam hanging out of exterior of home at conduits Investigator’s Observation: Unverified. Corrected prior to inspection. Governing Rule: N/A

Complaint Item: 20- Poor repair between garage and house for removed insulation, no R value Investigator’s Observation: Unverified. Corrected prior to inspection. Governing Rule: N/A

Complaint Item: 21- Drywall repair at Garage not to code or guidelines. Investigator’s Observation: Unverified. Corrected prior to inspection. Governing Rule: N/A

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

Sincerely,

Patricia Schuette, Investigator (602) 771-6744 [email redacted] 1700 W Washington St, Ste 105 Phoenix, AZ 85007

CC: Respondent Complainant

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 12/23 Complainant: Stephen Barton 19895 e Sonoqui Blvd Queen creek, AZ 85142

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

C012 12/23 Respondent: Solar Electric Freedom LLC DBA: PO Box 22157 Mesa, AZ 85277

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

C012 12/23 July 24, 2024

Compliance Jobsite Inspection Notice Re: Complaint No. 2024-05725

Dear Complainant and Respondent:

A Compliance Inspection has been scheduled for Tuesday, July 30, 2024 at 09:30 AM to determine the current status of the items listed on the issued Directive.

The Complainant is required to be present for this inspection. The Respondent is encouraged to be present but is not required to attend.

Complainant: SAFE ACCESS IS REQUIRED TO ANY AREA TO BE INSPECTED.

Sincerely,

Patricia Schuette, Investigator (602) 771-6744 [email redacted] 1700 W Washington St, Ste 105 Phoenix, AZ 85007

CC: Respondent Complainant

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

C012 12/23 Complainant: Stephen Barton 19895 e Sonoqui Blvd Queen creek, AZ 85142

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: Solar Electric Freedom LLC DBA: PO Box 22157 Mesa, AZ 85277

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 12/23 July 30, 2024

License No. ROC 315008

Re:Complaint No. 2024-05725

AMENDED WRITTEN DIRECTIVE FROM THE REGISTRAR

Dear Respondent:

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

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

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: 8- over cut holes in exterior walls of home not properly sealed or weatherproofed. Investigator’s Observation: Partially verified. Some repairs had been made prior to the inspection but paint still needed. Respondent to correct within appropriate means. Governing Rule: ARS §32-1154 (A) (3) namely R4-108, Poor work not performed in accordance with professional industry standards. Compliance Findings: Corrected

Complaint Item: 9- unsure/unlikley back up sub panel is permitted for. Was never inspected, installed after elec final was passed. Investigator’s Observation: Verified. Sub panel was installed after final and close out of permit was done. Respondent to obtain applicable permit for corrections and submit new renderings to Queen Creek building department for approval on any and all changes from original submission. Governing Rule: ARS §32-1154 (A)(2)(b) Departure from or disregard of: A building code of this state or any political subdivision of this state in any material respect that is prejudicial to another. Compliance Findings: Permit was applied for but not granted. There are pending documents needed per Queen Creek. Respondent to submit all required documents to secure permit.

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

Complaint Item: 16- Debris and material left on site in garage Investigator’s Observation: Partially verified. There was some debris under the 3 panels in the garage. Some definitely from Respondent. Some may be from complainant. Respondent to clean up after work. Governing Rule: ARS §32-1154 (A) (3) namely R4-108, Poor work not performed in accordance with professional industry standards. Compliance Findings: Additional cleanup is needed. Respondent to correct within appropriate means.

Complaint Item: 17- Wrong screws in Electric panel Investigator’s Observation: Verified. Manufacturer of panel has specification on screws as well as open penetrations. Respondent to correct within appropriate means. Governing Rule: ARS §32-1154 (A) (3) namely R4-108, Poor work not performed in accordance with professional industry standards. Compliance Findings: Not corrected. Respondent to contact manufacturer for acceptable correction method and provide letter from manufacturer for documentation.

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

Sincerely,

Patricia Schuette, Investigator (602) 771-6744 [email redacted]

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

CC: Respondent Complainant

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C009 12/23 Complainant: Stephen Barton 19895 e Sonoqui Blvd Queen creek, AZ 85142

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 12/23 Respondent: Solar Electric Freedom LLC DBA: PO Box 22157 Mesa, AZ 85277

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 12/23 Case No.: 2024-05725 Investigator: Patricia Schuette Inspection Date: Tuesday, July 30, 2024 Inspection Time: 09:30 AM

Compliance Jobsite General Notes:

Compliance Findings:

Complaint Item: 5- Sub Panel at garage exposed and blanks in spaces not installed Investigator’s Observation: Verified. There are blanks without covers as well as knock outs that were not used nor sealed properly in multiple panels. E3404.6 Unused openings. Unused openings, other than those intended for the operation of equipment, those for mounting 1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 12/23 purposes, and those permitted as part of the design for listed equipment shall be closed to afford protection substantially equivalent to the wall of the equipment. Where metallic plugs or plates are used with nonmetallic enclosures they shall be recessed at least ¼” (6.4 mm) from the outer surface of the enclosure. [110.12(A)] Respondent to identify areas and correct within appropriate means. Governing Rule: ARS §32-1154 (A)(2)(b) Departure from or disregard of: A building code of this state or any political subdivision of this state in any material respect that is prejudicial to another. Compliance Findings: Corrected

Complaint Item: 9- unsure/unlikley back up sub panel is permitted for. Was never inspected, installed after elec final was passed. Investigator’s Observation: Verified. Sub panel was installed after final and close out of permit was done. Respondent to obtain applicable permit for corrections and submit new renderings to Queen Creek building department for approval on any and all changes from original submission. Governing Rule: ARS §32-1154 (A)(2)(b) Departure from or disregard of: A building code of this state or any political subdivision of this state in any material respect that is prejudicial to another. Compliance Findings: Permit was applied for but not granted. There are pending documents needed per Queen Creek. Respondent to submit all required documents to secure permit.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 12/23 Governing Rule: ARS §32-1154 (A) (3) namely R4-108, Poor work not performed in accordance with professional industry standards. Compliance Findings: Attic access was not corrected. Respondent to correct within appropriate means.

Complaint Item: 16- Debris and material left on site in garage Investigator’s Observation: Partially verified. There was some debris under the 3 panels in the garage. Some definitely from Respondent. Some may be from complainant. Respondent to clean up after work. Governing Rule: ARS §32-1154 (A) (3) namely R4-108, Poor work not performed in accordance with professional industry standards. Compliance Findings: Additional cleanup is needed. Respondent to correct within appropriate means.

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 12/23 Note:

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

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

Patricia Schuette, Investigator (602) 771-6744 [email redacted] 1700 W Washington St, Ste 105 Phoenix, AZ 85007

CC: Respondent Complainant

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov C013 12/23 REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA

Stephen Barton, Case No. 2024-05725 COMPLAINANT, v. Solar Electric Freedom LLC CITATION License No. ROC 315008,

RESPONDENT.

The Registrar issues this Citation to Solar Electric Freedom LLC (“Respondent”) under A.R.S. § 32-1155(A). If Respondent fails to answer this Citation by October 3, 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 May 17, 2024, Stephen Barton (“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. 2024-05725. 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 October 3, 2024. This deadline is calculated under A.R.S. §§ 32-1155(A) and (B), which provides a deadline ten days after service of the Citation. Service of the Citation and Complaint is complete five days after the Registrar mails a copy of the Citation and Complaint to Respondent’s latest address of record in the Registrar’s office. Consequences for Failing to File a Written Answer: If Respondent fails to answer, Respondent’s failure may be deemed an admission of the act or acts charged in the written complaint. A.R.S. § 32-1155(C). The Registrar may then suspend or revoke Respondent’s license(s). THE ADMINISTRATIVE HEARING If Respondent files a timely written answer contesting any charges in the Complaint, then the Registrar will request the Office of Administrative Hearings set a date for an administrative hearing and will notify all the parties at least 30 days before that hearing. A.R.S. § 41-1092.05(D). INVESTIGATOR’S APPEARANCE AS A WITNESS The Registrar’s assigned investigator will appear as a witness at the hearing. If either

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

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1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg101 8/21 the Citation and Complaint, showing cause, if any, why Respondent’s license(s) should not be suspended or revoked. A.R.S. § 32-1155(A). This Citation does not constitute proof that any charge or allegation in Complainant’s written complaint is in fact true. This Citation does not constitute proof that Respondent violated any statutory provision or rule adopted by the Registrar. Dated September 18, 2024. By: /s/ Tedi Quezada Tedi Quezada Legal Assistant Legal Department Arizona Registrar of Contractors COPY of the foregoing mailed by Certified Mail, Return Receipt Requested, September 18, 2024 to:

Respondent Certified Mail No: [number redacted]

Solar Electric Freedom LLC PO Box 22157 Mesa, AZ 85277 Copy mailed by USPS First Class mail this same date to: Respondent Solar Electric Freedom LLC PO Box 22157 Mesa, AZ 85277

Solar Electric Freedom LLC 2118 E Oasis St. Mesa, AZ 85213 Complainant Stephen Barton 19895 E Sonoqui Blvd Queen creek, AZ 85142 of 6

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg101 8/21 Copy 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. 2024-05725

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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 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)

Stephen Barton Mailing Address (Enter jobsite in Contract/Project section) City State Zip

19895 e Sonoqui Blvd Queen creek Arizona 85142 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)

Solar Electric Freedom LLC ROC 315008 Street Address City State Zip

Phone Number Email

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

Kieth Rowley Contract/Project Information Contract Date Contract Amount Amount Paid

January 19, 2023 $70,575.00 $43,000.00 Date Work Started Date Work Stopped Date Work Was Completed

December 14, 2023 May 1, 2024 Close of Escrow (New Home) Move-In Date (New-Home)

Jobsite Street Address City State Zip

19895 E Sonoqui Blvd Queen Creek AZ 85142 Name of Construction Site Owner Construction Site Name (if applicable)

Phone Number of Construction Site Owner Email of Construction Site Owner

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

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

Some independent contractor for original contractor The contract was Both All change orders were Both This project was Residential This project involved Other Solar Panels A building permit was obtained by Contractor unknown Queen Creek 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)

This is a 3rd or 4th attempt to let contractor fix items. Contractor got belligerent and claimed the house is to standard and all items are complete and is demanding payment. Contractor not capable of performing the work to code or industry standards. Fear of retaliation against home. Allegations Listed on Complaint:

Blown out walls in attic with debris left everywhere. Attempts to repair are not industry standard or to ROC guidelines

Drywall repair at Garage not to code or guidelines.

Insulation behind drywall repair at garage not to R value and guidelines

Panels not labeled and other panel installed incorrectly

Sub Panel at garage exposed and blanks in spaces not installed

abandoned wiring in attic not properly capped off or ended.

Conduit for elec items not plumb or level multiple places

over cut holes in exterior walls of home not properly sealed or weatherproofed.

unsure/unlikley back up sub panel is permitted for. Was never inspected, installed after elec final was passed.

Holes, drill bit left in ceiling of garage

excessive cracking and drywall staining from dirty hands etc in garage

R value at conduits at scuttled in garage non existent due to removed insulation

Insulation pulled out of walls left scattered in attic space.

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

8sqft of insulation removed leaving huge hole in attic compartment, No R value

Attempted repair above sons bedroom not to code or standard. No R value

Debris and material left on site in garage

Wrong screws in Electric panel

Debris and drywall mud left on floor and walls of garage

excessive spray foam hanging out of exterior of home at conduits

Poor repair between garage and house for removed insulation, no R value

No access APP or software to monitor panel performance

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

Stephen Barton \complainant1\ \complainantd1\

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337,,8#77#1$78,8,,,89:)!5;1&:73;16$:;71683):361)15444 ! 4;87:8#15444 ! < 4,4 Received Legal 10/01/2024

FRAME LAW, PLLC Paul K. Frame, Esq., SBN 026937 Kristy M. Frame, Esq., SBN 027491 3120 W. Carefree Hwy. Suite One PMB #336 Phoenix, Arizona 85086 (p) 480-508-7282 (f) 480-658-2936 [email redacted] [email redacted] Attorneys for Solar Electric Freedom, LLC REGISTRAR OF CONTRACTORS OF STATE OF ARIZONA STEPHEN BARTON, COMPLAINANT, CASE NO. 2024-05725 v. SOLAR ELECTRIC FREEDOM, LLC’S WRITTEN ANSWER TO SOLAR ELECTRIC FREEDOM, LLC CITATION AND COMPLAINT License No. 315008 RESPONDENT. Respondent SOLAR ELECTRIC FREEDOM, LLC (“SEF”) by and through counsel Frame Law, PLLC, hereby provides its response to the CITATION dated September 18, 2024 as follows: 1. In response to Charge 1, purported violation of A.R.S. §32-1154(A)(2)(b), SEF denies that it has materially departed from applicable building code in any material respect that is prejudicial to another. 2. In response to Charge 2, purported violation of A.R.S. §32-1154(A)(3) – R4- 9-108(c), SEF denies that it has failed to perform its work in accordance with applicable professional industry standards. 3. In response to Charge 3, purported violation of A.R.S. §32-1154(A)(22), SEF denies that it failed to take timely corrective action without justification. Despite its attempts, SEF was denied access to address various items in the corrective work order(s) issued related to this Complaint on numerous occasions. See Exhibit A. SEF has acted in good faith and under reasonable diligence in responding to / addressing the items in the Received Legal 10/01/2024

corrective work order. SEF made substantial efforts to comply with the directive as indicated in the July 30, 2024 Amended Written Directive From the Registrar. However, Complainant has taken inordinate steps to keep SEF from addressing the issues identified. For example, SEF has been precluded from continuing/completing work that is ready such as painting drywall repairs because Complainant does not believe that same is ready for paint despite the fact that SEF engaged an appropriately qualified contractor who states same is ready for paint (Complaint Items 2, 16 and18) or installing a special ordered circuit breaker box trim cover and screws that Complainant specifically asked SEF (Complaint Item 17) to order but now says it is too late to complete that item of the directive. For the reasons set forth above, SEF asks that its license not be disciplined and no civil penalty be imposed. DATED this October 1, 2024. FRAME LAW, PLLC By: /s/ Paul K. Frame, Esq. Paul K. Frame, Esq. Attorney for Solar Electric Freedom, LLC ORIGINAL of the foregoing was e-filed and COPIES of the foregoing were served via Email only on this October 1, 2024 to: By: /s/ Paul K. Frame For Frame Law, PLLC Received Legal 10/01/2024

EXHIBIT A SOLAR ELECTRIC FREEDOM, LLC's ANSWER TO CITATION CASE# 2024-05725 Received Legal 10/01/2024

Date Description Work Performed?

18-May-24 No keys supplied to inverters Key supplied to customer. Work completed before inspection on 31Jul72024 25-Jun-24 Insulation pulled out of walls left scattered in attic space. Y Attic cleaned of all debris and foam.

25-Jun-24 Debris and materials left on site in garage Y Debris and materials removed. Walls will be painted upon next visit to house upon owners approval and permit issuance. 25-Jun-24 Wrong screws in electric panel N Front panel (Trim) of Customer's existing subpanel to be replaced upon next visit to house. 26-Jun-24 I am only available to provide access to my home until N Access was denied on 29Aug24 and 30Aug24. Thrusday at noon. 27-Jun-24 Labels missing Y Labels installed 27-Jun-24 Conduit upon platform Cover built over condits over platforms 27-Jun-24 Added Customer back-up subpanel not permitted N Customer back-up subpanel on original drawings. Waiting for Customer to sign SIC before contract can be approved and panel can be installed. SEF has stamped drawings already. 27-Jun-24 Added panel wasn't on original permit submittal, need to N Customer back-up subpanel on original drawings. Waiting for request for a new permit and show all equipment Customer to sign SIC before contract can be approved and panel can be installed. SEF has stamped drawings already. 27-Jun-24 Circuit wire needs to run through same conduit to Y Wire corrected with Emergency repair permit that was issued, prevent "induction heater" . inspecte and closed on 1Jul2024 27-Jun-24 Replace wirenut that has wire installed. Y Replaced 27-Jun-24 Spray Foam is messy Y Spray foam has been replaced. 27-Jun-24 Com cables not plugged in Y Not to be plugged in per Manufacturer's instruction. Will re-configure when allowed to go to house again. 27-Jun-24 Ground wire not tight Y Tightened 27-Jun-24 Stranded conductors not all in Lugs Y Wires in lugs corrected and NOALOX put on all connectors. 27-Jun-24 Remove the foam from inside the electrical panels Y Foam removed 27-Jun-24 The electrical system on this proroperty was altered. Y SEF is allowed to change system design. See contract paragraph #8 27-Jun-24 Knockouts not secured or filled Y Knockouts have been filled or corrected. Received Legal 10/01/2024

27-Jun-24 Mr. Barton wants a bypass switch N Bypass switch is not part of the origianal contract and is an add on. It is not required by the manufacturer. Letter is attached. If he still wants a bypass switch, an ECO will be prepared. 27-Jun-24 Customer back-up loads panel needs to be permitted N Will be completed upon customer signing SIC and permit issued by 27-Jun-24 Foam insulatin behind drywall repair at garage not to R- Y Foam above panels have been sprayed with commercial grade foam. Value. Additional Sheetrock needs to be removed upon next permit. 27-Jun-24 Blanks in customer sub-panel missing. Y 1. All blanks have been filled. 2. New cover will be installed upon next allowed visit by SEF. 1-Jul-24 200 amp sub panel feed not to code and changed Y Emergency repair permit issued, inspected and closed 1July2024. without permit or H/O aware Homeowner acknowleged that Sub panel feed now to code. Homeowner was aware of 200 Amp subpanel situation. He wrote 10-Jul-24 Five attic wiring access holes are not closed. Y Completed by foam contractor 10-Jul-24 Electric runs strung under and over plumbing, HVAC and Y Platforms installed over conduit. other electric. 12-Jul-24 Attic wiring is not secure. N Not needed. Abandonded wire left in attic 13-Jul-24 Debris and insulation were left in the attic. Y All debris and insulation cleaned up. 14-Jul-24 Romex disappears into conduit? Y Romex changed to individual wires 15-Jul-24 Siding over-cut and removed. Y Replaced siding 16-Jul-24 Battery and inverter area poor workmanship. Y Secured flex conduits 17-Jul-24 Drywall holes in places. Y Repaired and closed holes 18-Jul-24 Poor drywall patch attempts Y Replaced by licensed drywall contractor 19-Jul-24 Vertical conduits are not plumb. Y Conduit straightened. Now very vertical 20-Jul-24 Flex conduits are not secured or neat. Y Secured flex conduits 21-Jul-24 Conduit in attic not to code. Conduit run over HVAC Y Platforms installed over conduit. walkway/platform. 22-Jul-24 Romex wiring disappears into metal conduit. Y Romex changed to individual wires 23-Jul-24 Daylight can be seen in attic over drilled holes for the 2 Y Holes sealed and painted ½” conduit. Received Legal 10/01/2024

23-Jul-24 Sheetrock and painting contractor denied access to Yes/No Sheetrock replaced and initial coat put on. PAINT delivered to house. house Waiting for changes for final coat and painting. Customer wouldn't allow painters back into the garage. "Hi there Keith, homeowner basically told us we weren't allowed to be there today so I'm not sure what going on but I left the paint there. We drove out from Phx so not really sure what we're supposed to do as of right now" 23-Jul-24 Alex boxes not labeled correctly We do not know what a "Alex Box" is. Labels have been added per direction. 23-Jul-24 Install current sensors per plan in the 400 amp panel with Waiting for permit from TOQC to complete CT re-location comms. 23-Jul-24 Tigo Rapid Shutdown box on slave inverter not grounded Y Ground was correctly installed and is now correctly installed per code 23-Jul-24 Rapid shutdown test failed. PV inputs maintain voltage. Y Test was performed incorrectly. Breaker for Tigo boxes in back-up loads panel. When breaker is turned off, panels shut down. 23-Jul-24 Primary inverter damaged at top. Large dent at cooling Y Dent removed fan 23-Jul-24 Romex into conduit at Tigo boxes against code. Y Romex changed to individual wires. 23-Jul-24 Clean up Romex and wiring at all sub panel. Y Romex removed except where entering subpanels per code 23-Jul-24 Caulk and drywall damage on sub panel covers from N Waiting for permit from TOQC to complete permit to replace cover-up. customers subpanel cover 23-Jul-24 Sub panels modified and drilled to secure covers … N Waiting for permit from TOQC to complete permit to replace damaged customers subpanel cover 23-Jul-24 Knock outs in sub panels not secures, sealed when N Waiting for permit from TOQC to complete permit to replace unused customers subpanel cover 23-Jul-24 Tigo rapid shutdown power must be supplied from Y Breaker placed in Customer's back-up loads panel backup panel in case of power failure. It isn't. 23-Jul-24 Manual back up switch needed to get energy in grid N Note in scope of contract. We will install with paid change order. failure Received Legal 10/01/2024

23-Jul-24 Keith, antonio (sheet rock contractor) didn't come by N No access was granted. today. Last week someone was supposted to come by and didn't show also. At this point th edirective time period has passed. I don't want any more work on directive items performed until ROC can check things for compliance. Tell Antonio I have his drill and he can contact me so I can get it back to him". 23-Jul-24 "Antonio is coming back tomorrow. I was mistaken. He N No access was granted. meant Wednesday. Between 10 and 12 am". 24-Jul-24 Solar modules have dirt and grime. N/A Panels will clean themselves when we get rain. 25-Jul-24 The sheetrock above master bedroom and main garage N Cracks in garage ceiling and customer's bedroom not our making has excessive cracking. 26-Jul-24 Ceiling above the master bathroom has “loud humming N Service entrance does not cause noise. Openings in attic closed and sound non-stop at same wall as disconnects and electric stopped noise. panel.” 27-Jul-24 Side Fence panel cracking due to equipment hung on N Natrual cracks. Customer agreed. wall. 15-Aug-24 "I did ask him not to start work on the comber panel N Access was denied. The flush mounted combiner panel was not listed replacement because a surfacre mount is outside of the in the contracted design. Siemens subpanel was not listed in the contracted design. quote or the stamped drawings. 15-Aug-24 "The "CT's" are required by manufacturer to be installed N CT's are not required to be mounted at the service entry panel. See at the service entry panel. LuxPower manufacturer's signed letter.

15-Aug-24 My batteries havce not perfomed since day 1. N Customer has been living on system and batteries since March 2024. Batteries were set to unapprove settings per manufactruer settings at the request of Mr. Barton. New SOC settings will be incorporated when Mr. Barton allows us to access the garage and the inverters. Permit and SIC required before we can access the inverters. 15-Aug-24 All of my equipment is supposed to be Siemens an that's N Customer back-up loads panel is not identified as Siemens in the what the plans call for and in our contract. contract or the drawings. This request is not contractual. 27-Aug-24 Subcontractors failed to show up at Barton's house on N Asked to come to house to paint sheetrock on 28 or 29Aug24 and was 27Aug24 denied by Mr. Barton 28-Aug-24 Can we come over tomorrow to finish the painting. N Access was denied on 29Aug24 and 30Aug24. Received Legal 10/01/2024

30-Aug-24 I will not allow any access to my home on any expired N Access was denied 30Aug24. directive items, You're welcome to ask ROC for another extension, but I can't image thay will consider they alreaded extednded for you once before when you refused to do the directed work. 3-Sep-24 "Can we come over on Thursday morning, 5Sep2024, to N No answer. paint your sheet rock that we installed. 3-Sep-24 Mr. Barton said "I will not allow any access to my home N Access denied on 3Sep24.(I don't understand. If I can't work on the on any expired directive items. (anything after 30Aug24) expired items of the previous directives, why would I want to work on Your welcime to ask the ROC for another extension, but I anything else that isn't on the "directive"?) can't imagine they will considerthey already extended for you once before when you refused to do the directed work. 3-Sep-24 email: Steve, Can we come over on Thursday morning, N Not authorized. 5Sep2024, to paint your sheet rock that we installed? Respectfully, Keith Rowley 4-Sep-24 David Tallman TOQC, "At this point the Town of Queen N After 3Sep24 text, we immediately received an email from David Creek has NOT received the completed Special Tollman of TOQC stating "Solar Electric Freedom may NOT perform inspection Certificate which is required in order for us to any work on the solar system". approve any further work on your Solar system. Without the Special Inspection form completed, submitted, approved and the plan we have in house approved, the solar contractor, Solar Electric Freedom may NOT perform any work on your solar system". 4-Sep-24 "I am authorized to do the non-electrical work. We will N paint the sheet rock. We will paint the attic access door. We will hookup the batteries to the inverters for closed loop communication. We will put new trim cover on your existing subpanel. Do you authorize the above items to be done?". 4-Sep-24 "I would also like to put in the Cat-5 cable from the N After 4Sep24 text, we immediately received an email from David inverter to the service in preparation for moving the CT's". Tollman of TOQC stating "Solar Electric Freedom may NOT perform any work on the solar system". Received Legal 10/01/2024

21-Sep-24 "The install manual is available onsite anytime" N Mr. Barton is using an outdated version of the manual. There is a newer version of the installation manual. He should not be using the old version. 21-Sep-24 My sprinkler timer was secured to my home bbefore this N Will re-attach sprinkler timer on next allowed visit to home. project. Steve Barton Punch-list: 8Mar24 "=¶<¶<>9ÿ·@<<ÿ̧B K;';%ÿ5.ÿ̧/ME5D'ÿB'M1ÿ¹ÿGM;';M5D¶G5$-1'MD;ÿºÿ<=<>¹=?»<? Received Legal 10/01/2024

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337,,8#77#1$78,8,,,89:)!5;1&:73;16$:;71683):361)15444 ! 4;87:8#15444 ! < 4,4 Complaint #2024-05725 P 1 JSI date 06/7/2024 at 8:00AM JSI PHOTOS Complaint #2024-05725 P 2 JSI date 06/7/2024 at 8:00AM JSI PHOTOS Complaint #2024-05725 P 3 JSI date 06/7/2024 at 8:00AM JSI PHOTOS Complaint #2024-05725 P 4 JSI date 06/7/2024 at 8:00AM JSI PHOTOS Complaint #2024-05725 P 5 JSI date 06/7/2024 at 8:00AM JSI PHOTOS Complaint #2024-05725 P 6 JSI date 06/7/2024 at 8:00AM JSI PHOTOS Complaint #2024-05725 P 7 JSI date 06/7/2024 at 8:00AM JSI PHOTOS Complaint #2024-05725 P 8 JSI date 06/7/2024 at 8:00AM JSI PHOTOS Complaint #2024-05725 P 9 JSI date 06/7/2024 at 8:00AM JSI PHOTOS Complaint #2024-05725 P 10 JSI date 06/7/2024 at 8:00AM JSI PHOTOS Complaint #2024-05725 P 11 JSI date 06/7/2024 at 8:00AM JSI PHOTOS Complaint #2024-05725 P 12 JSI date 06/7/2024 at 8:00AM JSI PHOTOS Complaint #2024-05725 P 13 JSI date 06/7/2024 at 8:00AM JSI PHOTOS Complaint #2024-05725 P 14 JSI date 06/7/2024 at 8:00AM JSI PHOTOS Complaint #2024-05725 P 15 JSI date 06/7/2024 at 8:00AM JSI PHOTOS Complaint #2024-05725 P 16 JSI date 06/7/2024 at 8:00AM JSI PHOTOS 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