2024A-09799-NPC-ROC Notice of Hearing & Packet MAILED 2024-09799

2024A-09799-NPC-ROC · Registrar of Contractors · 2024-10-11

REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA

Innovative Plumbing LLC, Case No. 2024-09799

COMPLAINANT, Docket No. 2024A-09799-NPC-ROC

v. NOTICE OF HEARING ON CONTESTED CASE REIcon LLC License No. ROC 340420,

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

HEARING INFORMATION The hearing is set for:

December 2, 2024 10:30 AM Tammy Eigenheer 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)(10)

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

be a party to the hearing.

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

argument to the administrative law judge.

RIGHT TO BE REPRESENTED The parties to the administrative hearing may choose to be represented by an attorney. A.R.S. § 41-1092.07(B). If one of the parties is a company, the company may be represented

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

1156(B).

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

HEARING PROCEDURES AND RULES

The administrative hearing will be conducted in accordance with A.R.S. §§ 41-1092 to -1092.12, and A.A.C. R2-19-101 to -122. The parties should review the statutes, rules, and

processes governing the administrative hearing. Copies of the statutes, rules, and articles regarding the administrative hearing process can be found at https://www.azoah.com/.

REGISTRAR’S APPEARANCE BY VIDEO CONFERENCE OR TELEPHONE

The Registrar’s investigators, employees, and attorneys will appear at the hearing via

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

HEARING PACKET

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

certain documents to the parties and the Office of Administrative Hearings. These documents

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

SUBPOENAS FOR TESTIMONY FROM A WITNESS OR DOCUMENTS

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

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

possession, the party must prepare and file a written subpoena for the Administrative Law

Judge to review and sign, if approved. A.R.S. § 41-1092.07(C). Forms for requesting a subpoena can be found on the Office of Administrative Hearings’ website at www.azoah.com.

The party seeking a subpoena must serve notice on all the parties to the hearing, and on the Registrar. A.R.S. § 41-1092.04.

DISCLOSURE STATEMENT

At least seven calendar days before the hearing, each party must prepare and serve a

disclosure statement on all other parties, and file it with the Office of Administrative Hearings. A.A.C. R4-9-118; A.A.C. R2-19-108. The disclosure statement must include any exhibit the party will use at the hearing. A party’s failure to timely disclose any witness or exhibit, without good cause, may result in the administrative law judge excluding those witnesses or exhibits from being used at the hearing. A.A.C. R4-9-118(C). A sample disclosure form is available on the Registrar’s website at https://roc.az.gov/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 11, 2024.

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

Copy mailed via USPS First Class mail October 11, 2024 to:

Respondent(s) REIcon LLC 4233 E Villa Theresa Drive Phoenix, AZ 85032

Complainant(s) Innovative Plumbing LLC 8802 W Lane Ave Glendale, AZ 85305

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. 2024-09799 /

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

August 27, 2024

Via U.S. Mail and Email

Complainant Innovative Plumbing LLC 8802 W Lane Ave Glendale, AZ 85305

Via U.S. Mail and Email

Respondent REIcon LLC 4233 E Villa Theresa Dr Phoenix, AZ 85032

Re: Complaint No. 2024-09799

Dear Complainant and Respondent:

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

Respondent is free to raise any issue or affirmative defense to this complaint by filing a response with the Registrar by September 3, 2024. Please reference the complaint number listed above if you file a response. Respondent may file a response by:

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

The Registrar will not issue a citation before September 3, 2024 and will review Respondent’s response, if one is submitted.

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

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

/s/Madelyn Hayes Madelyn Hayes Legal Assistant II Legal Department 1700 W Washington St. Ste 105 Phoenix, AZ 85007

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg100 4/21 Received by Investigations 08/23/2024 2024-09799 RECEIVED AUG 2 3 202{Departmental Use only Non-Payment ComPlaint Form Numret: I NVE sfl GATI gfgqrdaint

Mail to: U.iat\( in Registrar of Contractors P.O. Box 18243 Phoenix, AZ 85005-8243

PeIson ROC License Numbc(s) (if any) ll Name irst Middle Last) Busincss Name State Zi Code

E rl Ad Phone Number

I consent to receive communications electronically in connection with this case Yes[ Notr

Name Attomey (if any) State Zip Code 's Strect Address City

Attorney's Email Adtuess Attorlrey's Phone Number

ROC License Number(s) is shown on contracts, invoic€s, etc') State Zi Code

t il Address Phorle Number

Na of Person(s) n ti t Licensc ?* Co m I aint In rma tion if P P licab1 ,s D din and fees) Con D

Yes ! (tf yes, provide a coPy of the civll judgment No H you fi cd .I No P

b id ttach ad di ti al es if necessa l.ist all s ific hic h have t. + oa a OO I s oc) .t

of It 1l 11 Ll red fifrv d o /5 tth n a f1 d be ref, tha tllc t1 booe- )t d 5 hns f, le d to Pt1 v tno ES tl ces ,fu ll P o nt'o co t tctor. I t', f t1 certify, upotl nfor tl t1 ti IL a d (l ll dc ed c tl l a o tl ?{r It Iicensee's op 10t a t1 Llut t'. tl teri t1 1',1 pattiallar coflstrucl u i? oTe- /l d the L.nPa c ty p av o lns recc oecl rt'f' ct t1 t|10nles ds^ Payn n f, t1

ltt cf, a th lL ) Ax wl i.h t1 efp aEs of tl a ltr d 5 32 1 1 t k t't, c ar tl 1011 rtcd Name Da D e clar ati on & Si pt: I d c t] n pc hJ of p efl IL ry tha c d lt ly 0 lr orL z ed feP resc la Coruplcinant n fltis C tltp tl tft F a) r t1 p n 11 t1 I alll rrec to f1 1( best l v knot d8 Ilt fr ae hn rtli n do etL btr ted nt'ort tl ii tl CO ttt tl a d 11 th 75 F on is truc tl d c "f kn le d 7Al a ,s 1l h PP OI ,f this c 1t1p lLt ll art tln Ll correcl co?ics hc ar ,f 5 and a re acc u rn te io I he best 111 v 0?l) .q "f to ct 5 fr f n tl a {l he ll r1 ll {ln d o l1 o h ao n lrfi t)r a l1 85 a 1t 41, 5 tl in Ir 0se a Di Si Received by Investigations 08/23/2024 2024-09799

Written Statement Regarding Contract with Reicon LLC:

On November 15,2023 Reicon LLC posted an lnvitation to Bid on the Hummus Repubtic project 128000.

On February 20, 2024 we were emaited a copy of the contract atong with a request for a Certificate of lnsurance and ourW9 of which both were sentto Reicon LLC on March 4,2024.

On March 7,2024wewerc emaited a Change Order for this contract in the amount of $6880.00

severat attempts were made to emait the signed contract to no avaitwith the finat attempt made on March 14,2024

On AWil22,2024lnvoices 7452 and 7453 were sent to Reicon LLC atong with the Conditionat Waiver and Retease on Progress Payment. These funds have never been received.

On May 2 an emall was sent to the project manager, John Zimmerman, requesting payment status. He forwarded the emaiI to the owner requesting status. Noresponse.

On May 29, 2024 an emailwas sent requesting payment status. Chris Reiget responded saying that payment has been hetd up. Saidhewasmakingaphonecattthenextdayandwoutdupdateup after. No response was forthcoming.

on Jun 18, 2024we sent a firmer request for payment status and were totd they had a wire coming in that day and the next day with a promise of payment on 06118/204 and another one the next week. No payments were received.

On Juty 16, 2024 a request for payment was sent to ch ris Reiget with no response.

On July 24,2024 a phone catlwas made with no response. Amessagewas teft requestingto settte this maiter. lf no response then fiting with ROC for non payment.

These are the facts and documentation I have cottected in this matter to best of my knowtedge.

Thank you

Date Eagy

President

lnnovative Ptumbing LLC Received by Investigations none Lilail - FW: lnvitation to Bid from Reicon LLC 08/23/2024 124124 , 3:10 Pl4 2024-09799

Cheryl Eagy <cheryl@mcdowell tax>

l$t Gmail FW: lnvitation to Bid from ReiCon LLC l message Wed, Jul 24, 2024 at 1i33 Pl/ Dalo <[email redacted]> To: Cheryl Eagy <cheryl@mcdowell tax>

com> From' Reicon LLc <OneTearn3033448@bbbid thebluebook sent: Wednesday, November 15,2023 1:30 PM subject: lnvitation to 8id from Reicon LLc

i!ilE*tr lnvitation to Bid

Bid is due by 12:15A14 (Mouniain) on Novemhet 22' 2023

ReiCon LLC has invited You to bid on Hummus RePublic.

We are lookilg for Plumbing Contractors.

view Full Prolect Deta,ls & Files

Do you intend to bid on this Project?

Yes No Maybe

Project Summary

113

httpsJ/mait.google.com lmaillt)lzl?lk=7 afa]635f'1&view=pt&search=all&permthid=thread-f:[number redacted]&simpl=msg-f:1805493S64084279486 Received by Investigations 124124 . 3:10 PM none lrail - FW: lnvitation to Bid from Reicon LLC 08/23/2024 2024-09799

Hummus Republic I Surprise, AZ 85374 (SurPrise)

View Full Project Details View Project Files

11122123 12:15 AM (Mounlain\ Bid Due Date subcontractor o Negotiating Project Status

Tenant improved proiect Hummus Republic Project quick serve restaurant. Phone: (602) 290- Description 6973 Email: [email redacted]

Submil Bid

John Zimmerman

P: (602) 290-6973

Click He.e for Email

ReiCon LLC

Don't FALI behind, Get the mo6t ol Your leads with the tf EueBook Blue Book Constructon Networl Call 888-720-Ir'1{ -

Book Network You are receiving this omai! because you aae registered in The Blue www.lhebluebook.com

Blue Book N€Nvork's Reioon LLC is sharing this proiect opportlnit) / wilh you lhrough The ONffenU. fo, n"tp i t aining on how lo viewand respond to this ITB call88&303-2243

To unsubscrbe from Bid lnvitalions click hele

View Pnvacy-Pqley

213 1180549396408427s486&simpl=msoJ:1805493s64o84279486 httpsl/mait.googte.com tmailut2l?tk=1 af8i635f1&view=pt&search=all&pernrthld=thread-f Received by Investigations 08/23/2024 2024-09799

REI a Reicon, LLC Powered by RedTeam SUBCONTRACT

Number: 1280010-011 Oalei 0U2012024

Proiect: 1280010 - Hummus Republic Suprise

Location: Hummus Repbulic Suprise 3864 West Bell Road Unit 100, Suprise, AZ 85374

Cost Code: 220000

Scope: Original

subject: Plumbing

Subcontractor: lnnovative Plumbing LLC Billto: Reicon, LLc 8802 W Lane Ave 4233 E Villa Theresa Dr Glendale, AZ 85305 Phoenix, AZ 85032

Contact: Dale Eagy Manager: John Zimmerman 602-228-9094 (602) 290-6973 [email redacted] [email redacted]

Terms: When Paid % Retainage: 10 Start Date: [number redacted]

THIS SUBCONTRACT AGREE[/ENT ('Agreement") by and between Contractor and Subcontractor shall be performed in strict accordance with these terms and conditions, the Contract Documents incorporated by reference, including the Plans and Speciflcations plus any Additional Documents attached hereto,

Contractor agrees to pay and Subcontractor agrees lo receive and accept as full compensation for performing the scope of work described herein, in accordance with the following Schedule of Values:

Schedule of Values

Item Oescription Quantity Price Per Unit ($) Amounr (S)

Plumbing 1 36,800.00/l/s 36,800.00

Plumbing per plans and specs

Cut concrele and lrench, backfill and concrete to grade per plans and specs

Total (S) 36,800.00 Thirty six Thousand Eight Hundred Dollars and Zero cents

NOW THEREFORE, Contractor and Subcontraclor agree as follows: Received by Investigations 08/23/2024 2024-09799 Section 1. The Subcontractor warrants and represents lhal it is and was prior to submitting its proposal to Contractor, duly licensed by all governmental licensing authorities having jurisdiction over ihe Wori or the proiect location. Subcontractor further warrants that at all times throughout the performance of this Agreement it shall comply with all government regulations and contractual obligations affecting the Work or the project location.

Section 2. The Subcontractor agrees to begin working as soon as it is notified by the Contractor that the project is far enough advanced for it to start the Work and to carry forward and complete its Work as rapidly as the contractor may judge necessary. Time is of the essence of this Agreement. The Subcontractor is to execute this Agreement with sufficient speed and diligence to enablelhe Contractor and other subcontractors to comply wilh the Construction Schedule.

Section 3. The Subcontractor shall provide its employees with a safe place to work, to perform the Work in a safe manner with high regard for the safety and health of all and to comply with health and safety requirements of the contractor, including contractor's policies regarding a drug-free workplace, local, state and federal agencies, and to hold the Contractor harmless for any cosl of defrciencies, fines or damages incurred because of its negligence or failure to take reasonable safety precautions or lo comply with safety regulations.

section 4. The subcontractor shall employ a full time supervisor, equipped with a radio or mobile phone, on site with full authority to act as agent for subcontractor. The Subcontractor's supervisor must check in with Contractor's Site Operations Manager or designee prior to starting Work and at least 30 minutes prior to finishing Work each work day.

Section 5. The Subcontractor shall not employ any material supplier, subcontractor, architect, consultant, worker or supervisor whose employment on the building or project is reasonably objected to by the Contractor.

Section 6. The Subconlractor shall attend periodic progress meetings as required by the Contractor. Subcontractor shall regularly advise Contractor of i1s progress and ongoing ability to fully perform the Work and to maintain the Construclion Schedule. Subcontractor agrees to pay Contractor the amount of 5500 for its failure to attend any scheduled progress meeting.

Section 7. The Subcontractor shall examine the work of the Contractor and any other subcontraclor and report to the Contractor in writing any defects that would adversely affect Subcontractor's Work. lf the Subcontractor does not so advise the Contractor in writing then it will be assumed it has fully accepted the work of others as being satisfactory for the inslallation or application of the Subcontractor's Work and is fully responsible for the satisfactory performance of the Work covered by this Agreement. The Subcontractor shall not interfe,e with the work being performed by the Contractor and other subcontractors and shall further perform its subcontract in such a manner that protects the work and/or materials being used by others. Any and all such damages or injuries sustained by the Contractor or others shall be charged back to the Subcontraclor.

Section 8. The Subcontractor agrees that its shop drawings and submittals represent that all measurements and fteld conslruction criteria have been determined and regularly verified right up to the time of installation of its Work, and that it has checked and coordinated each shop drawing and submittal wilh the requirements of the Work and of the Contract Documents. Approval of drawings or other submittals by the Contractor or owner shall not relieve Subcontractor of its obligations to perform the Work in strict accordance with the Contract Documents or ils responsibility for proper matching of its Work to contiguous work.

Section 9. The Subcontractor shall be responsible for keeping its part of the job clean and orderly subject to the approval of the Contractor and owner. Should it become necessary for the Contractor to perform cleanup work for the Subcontractor, the Contractor will deduct such expenses from any funds due to Subcontractor at the rate of $50 per hour for a minimum of at least eight hours plus expenses.

Section 10. The Subcontractor shall upon request furnish Contractor with a list of major services, materials and equipment required for the Work, listing the service providers or suppliers and the dates of performance of or deliveries to the project location, as well as copies of purchase orders or sub- Received by Investigations 08/23/2024 2024-09799 subcontracts to the Contractot Subcontractor further warranls that it shall make full and proper payments for any and all of Subcontractor's obligations arising from Subcontractor's Work including but not limited to labor, services, materials, taxes (including sales or use taxes), insurance cor"i.g", equipment, and permits.

section 11. The subcontractor shall prepare an Application for payment, form AIA G7o1/G702 or equivalent, indicating the value of its Work properly installed through the end of each calendar month, unless otherwise specified, and shall submit such Application for payment at least five (5) business days prior to the end of the period. To the extent that such Application for payment is ipproved by Contractor, payment shall be made to the Subcontractor on Friday after t:00 pm within five (ij business days following receipt of payment from Owner for the Contractor's monthly Application for iayment in which the Subcontlactor's Application for Payment was incorporated. lt is a condition pr""ed"nt to Contractor's obligation to pay Subcontractor that Contractor shall have first received payment from the Owner. Subcontractor acknowledges that it relies on the credit of the Owner, not tie Contracror, for Payment of the Subcontractor's work. Should the Subcontractor's portion of the Contractor's application be withheld or reduced for any reason, payment to lhe Subcontractor will be reduced accordingly. Relainage shall be withheld from each progress payment at the rate of '10%, unless otherwise specifled, and released upon final payment. Approval and payment of subcontractor's Application for payment does not constitute or imply final acceptance of Subcontractor's Work by the Contractor or Owner. The Subcontractor is to use all monies received or to which it may be entitled to be paid by the Contractor as payment for labor, materials, or other expenses incurred in the performance of this Agreement. Contractor may offset against any sums due Subcontractor hereunder the amount of any obligations of the subcontractor to the contractor whether or not such obligation arises from this Agreement.

Section 12. Final payment to Subcontractor shall be made after the last of the following to occur: a) completion of the work by subcontractor; b) acceptance thereof by the contractor and owner; c) issuance of a Certificate of occupancy by the governmental authority having jurisdiction over the project; d) flnal payment by Owner to Contractor; e) furnishing of evidence satisfactory to the contractor that there are no claims obligations or liens outstanding or unsatisfied for labor or materials or other items contributing to the Work; f) submission of subcontract deliverables such as warranties or "as built" drawings; g) a general release by the Subcontractor in a form satisfactory to the Contractor and in favor of the conlractor and owner; and h) authorizalion by subcontractor's surety or other performance guarantor, for Contractor to release final payment to Subcontraclor.

Section 13. The Subcontractor shall furnish upon request affidavits that its obligations pursuant to any part of the Work have been satisfled. Prior to any partial or flnal payment to the Subcontractor, a release of lien in conformance with F.S. 713.20 shall be furnished to the Contractor. Subcontractor shall indemnify and hold harmless Contractor from any and all claims, liens, or encumbrances on or against the project or the real property on which same is situated arising out of the failure of the Subcontractor to make payments of any kind. Without limiting the foregoing, Subcontractor shall cause any such liens or claims to be satisfied, removed or discharged by bond, payment or otherwise within frve (5) business days from the date of flling or receipt as the case may be. The existence of any lien or claim shall preclude Subcontractor's right to receive future payment until such lien or claim has been removed. ln the event it shall become necessary for the Contractor to employ an attorney to defend against any such claims, liens or encumbrances in any court, slate or federal, the Subcontractor shall pay the cost and expenses incurred by the Contractor in the defense of such, whether or not such claims are.iust or unjust, including but not limited to a reasonable attorney's fee. At its discretion, the Contractor reserves the right to Pay any obligalions of the Subcontractor arising on this job. Such payments shall be applied and fully credited as payment of this Agreement.

Section 14. The Subcontractor may be directed to perform Extra Work by the Contractor for which Subcontractor may or may not be due additional compensation. ln the event that the amount of such additional compensation, if due, is not agreed upon in advance, Subcontractor must submit a claim foa additional compensation within five (5) business days fol:owing completion of any work it asserts is Extra Work. Subcontractor shall support its claim for additional compensation by providing Contractor wilh proof of its actual direct costs plus 10% for overhead and 57" for Profit, provided such amounts are approved by the Contractor and the owner. No claim for additional compensation will be considered unless written authorization was given by Contractor prior to execution of the Extra Work. For as long as the additional compensation is undetermined, it must be listed as a Potential Change Order on the Received by Investigations 08/23/2024 2024-09799 Subcontractoas Application for Payment. Failure to advise Contractor prior to execution of Extra Work or failure to submit a full and proper claim within frve (5) business days following completion of Extra Work or failure to lisl extra work as a Potential Change Order on Subcontractor's Application for Payment, shall constitute a waiver of Subcontractor's claim for additional compensation for such Extra Work.

Section 15. No payment or additional compensation of any kind shall be due to the Subcontractor for damages arising from hindrance or delay from any cause in the progress of the work, whether such delays were avoidable or unavoidable.

Section 16. ln lhe event the Subcontractor shall fail to perform in accordance with this Agreement or if the interest of the Contraclor becomes endangered by reason of the Subcontractor's failure to perform or if the Subcontractor shall become insolvent or if at any time the Subcontractor admits its inability to promptly satisfy any obligation arising from or affecting its ability to perform any requirement of this Agreement or if the Subcontractor should fail to carry forward and complete its Work as rapidly as the Contractor may judge necessary or its personnel refuse to work after having been requested by the Contractor to proceed with the Work or changes thereto or should fail to comply with instructions of the Contractor or with applicable portions of laws, or should olherwise be guilty of a breach of contract, then the Contractor without prejudice 10 any other right of remedy and after giving the Subcontractor forty- eight (48) hours writlen notice of the Contractor's intention to do so may, at the Contractor's option either a) terminate the employment of the Subcontractor or b) take control of the Subcontractor's Work in whole or in part including taking possession of all materials and instruments thereon and complete the work as the Contractor may think best. The Subcontraclor shall not be entitled to receive any further payments until the Work is completed and accepted. The Contractor shall be entitled to proceed and complete the Work as was required of the Subcontractor on the Contractor's own account or through another Subcontractor. lf the unpaid balance under this subcontracl shall exceed the expense of ftnishing the Work, including compensation for additional managerial and administrative services and all other expenses that may be necessary to complete this Agreement, the excess shall be paid to the Subcontractor. lf such expense is greater than such unpaid balance, the Subcontractor shall pay the difference to the Contractor.

Section 17. The Subcontractor shall warrant its Work and materials as free of defects in accordance with the Contract Documents and for at leasl twelve (12) months from the date of acceptance of the Work by the Contractor and Owner

Section 18. The Subcontractor is bound to the Contractor by the same terms as the Contractor is 10 the owner, with the exception of all payment provisions of this Agreement. ln case of conflicl between the provjsions between the owner and the Conlraclor and the provisions of this Agreement, the provision imposing the greater duty, obligation and responsibility on the Subcontractor shall govern in all respects.

Section 19. lf Owner, with or without cause, shall terminate or suspend the Work, or fail to pay Contractor any sum due and payable, Contractor may order Subcontractor to stop or suspend work hereunder and Contractor shall be liable to Subcontractor for any such stoppage or suspension only if and to the extent that owner shall be liable to Contractor therefore. Contractor will pay to Subcontractor the value of work that Subcontractor has completed before the work was stopped or suspended but only if and to the extent that Owner shall have paid Contractor for such work of Subcontractor. Contractor shall never under any circumstances or conditions are liable to Subcontractor to any greater extent that owner is liable to Contractor.

Section 20. This Agreement supersedes all previous representations or agreements, either written or oral. Modifications to this Agreement must be in writing and executed by both Contractor and Subcontractor and Subcontractor may not transfer or assign this agreement, in part or whole, without the written consent of the Contractor. The failure by Contractor at any time to enforce or to require strict compliance or performance by Subcontraclor of any of the provisions of this Agreement shall not constitute a waiver of such provisions, and shall not affect or impair in any way Contractofs rights at any time to enforce said provisions or to avail itself of such remedies as it may have for any breach thereof. lf any provision of this subcontract shall be invalid or uneniorceable to any extent, the remainder of this Agreement shall not be affected thereby, and shall be enforceable. Received by Investigations 08/23/2024 2024-09799 Section 21. The Subcontractor shall pay any and all costs and expenses incurred for the performance and enforcement of lhis Agreement by the Contractor. Any and all sums due the Subcontractor under this Agreement may be used by the Contractor in completing the performance of or enforcing the terms of this conlract, including all cost and expenses incurred in the performance thereof including construction costs, attorneys' fees and expenses.

Section 22. ln good faith, the parties shall endeavor to fully perform their respective contractual obligations and shall provide other reasonable notice and opportunity to cure any suspected or apparent lack of performance that might be considered a breach of the Agreement. ln the event of controversy, the Subcontract shall be considered made in the state in which the Work is located and shall be construed in accordance with and governed by the laws of that state. Prior to litigation of any claims or disputes arising out of or in any manner related to this Agreement or the performance or lack of performance hereunder by Contractor or Subcontractor shall be preceded by mediation. ln any event, Subcontractor hereby waives its rights to lrial by jury.

Section 23. The Subcontractor shall fully defend, protect, indemnify and hold harmless Contractor, its officers, employees, agents, representatives or successors and assigns (the lndemnified Parties) from and against any and all claims, demands, actions or causes of action, and any and all liabilities, costs and expenses (including but not limited to attorneys' fees and expenses, incurred of defense of any lndemnifred Party), damage or loss in connection therewith, which may be made or assened by SUbcontraclor, lls officers, employees, agents, representatives, sUccessors or assigns or any other third parly on account ol or sustained or alleged to have been sustained by, or arising out of or growing out of bodily injury including death, or loss of use or damage to or destruction of property, caused by, arising out ol sustained or alleged to have been sustained by, or in any way incidental to oI in connection with the Subcontractor's performance of the Work under this Contract or any change order, regardless of whether such claims, demands, actions, causes of action or liability are or alleged to have been caused or contributed to by the negligence, fault or strict liability of any lndemnified Party. lnsurance providing coverage for this lndemnity provision shall be provided by the Subcontractor. The Subcontractor's liability shall not be limited to the insurance coverage required of the Subcontractor.

Section 24. The Subcontractor will maintain for the duration of thas Agreement such insurance as will protect Subcontractor, the Contractor and the Owner at the limits and coverage required by Contractor or at greater limits and coverage as may be required by Owner. This insurance shall be from companies and in form and substance acceptable to Contractor. This insurance coverage shall be provided before commencing any Work and shall be for the life of this Agreement, which shall include all warranty periods.

Section 25. The Subcontractor agrees not to reveal any Confidential Information to any third party whatsoever except with the specific written prior authorization of Contractor and agrees to return upon request of Contractor any Confidential lnformation including documents, memoranda, notes and olher writings in hardcopy or electronic format identified by Contractor as Confidential lnformation. The Subcontractor further agrees and guarantees that il shall not directly or indirectly interfere with, circumvent, or attempt to circumvent, avoid, by-pass, or obviate Contractor's inlerest with any of Contractor's business relationships.

Seclion 26. By acceptance and execution of this Agreement, Subcontractor warrants and represents that it has and shall maintain for the duration of the Agreement all necessary Credentials to fully perform in accordance with the Scope of Work and as itemized as follows.

This subcontract Agreement has been executed by the parties to be effective on the date above.

vendor Credentials Required

- General Liabi:ity

Subcontractor shall provide Commercial General Liability insurance. Contractor, Owner and Engineer Received by Investigations 08/23/2024 2024-09799

(if necessary) shall be named each as an additional insured (utilizing endorsement CG20101 185) for all acts or omissions or any other liability of additional insured arising out of Subcontractor's work performed for additional insureds or subcontractor's use of premises, equipment and facililies of additional insureds. Policy shall be primary and non-contributory with resPect to other insurance coverages carried by contractor, owner and other indemnities, as required by contract, including waiver of subrogation. Policy includes premises & operations, independent contractors and products & completed operations in the amount of $1,000,000 per occurrence, S1,000,000 personal and advertising injury S2,000,000 products and completed operations aggregate;$2,000,000 aggregate and $5,000 medical expense.

- Aulomobile Liability

- Occupational License

- w-9

Conlractor: Subcontractori

Reicon, LLC lnnovative Plumbing LLC

)ate Date Received by Investigations 08/23/2024 2024-09799

REI a Reicon, LLC Powered by RedTeam PLANS AND SPECIFICATIONS

Project: 128OO1O - Hummus Republlc Suprise Dale:0A2U2024 Document: 1280010-011

The following contract documents are hereby incorporated by reference. These documents may be viewed online and downloaded in their entirety at: https://reiconus.flex.,edteam.com/planroom *Entet Prcject Number 1280010 when accessing the online planroom.

Name Date Author Scope

AO.O'COVER SHEET vBid Set 09129/2023 RElcon, LLC ungrnal

01.0 ' DEi\,{OLlTloN PLAN v31d Set 09t29/2023 RElcon, LLC Original

A1 O. FLOOR PLAN AND NOTESVBid SEt 09/29t2023 RElcon, LLC O.iginal

A],1 ' R€FLECTED CEILING PLAN SCHEDULES AND NOTES 09/2912023 RElcon, Original vBid Set

A1 ? . FINISH SCHEDIJLE AND vBid SCt 09/29/2023 RElcon, LLC Original 'ETAILS A2.0 EQUIPMENT PLAN AND SCH:,ULE vBid Set 09t29/2023 RElcon, LLC Original

A3.0 - LIFE SAFE fY PrAN AND FLoOR FINISH PLAN vBid 09/29t2023 RElcon, LLC Original Set

A3.0 RESIROOM ELARGED PLAN AND ELEVATIONS vBid 09129/2023 RElcon, LLC Original Set

,A4.0 INTERIOR ELEVATIONS vBid Set 09129/2023 RElcon, LLc Original

09t29/2023 RElcon, LLC Original A5.0 - COUNTER SECTTONS vBid Sel

A6.0 'ARCHifECTURE SPECIFICATIoNS vBid Set 09/29t2023 RElcon, LLC Original

0 ' ARCHITECTURE SPECIFICATIONS vBid Set 09/29/2023 RElcon, LLC 0riginal

09t29/2023 RElcon, LLC Original El,O ' ELECI POWER LIGHTING PLANS NOIES ANO DETAILS vBid SeI

:? O, PANEL SCHEDULES, RISEN AND DElAILS [number redacted] RE,con, LLC Original vBid Set 'IAGRAM

E3.0 - ELECIRiCAL SP:C FICATIONS vBid Set 09/2912023 RElcon, LLC 0riginal

l\,11.0 ' MECIIANlCAL PLAN AND NOTES vBid Set 09t29/2023 RElcon, LLC Original

09/29t2023 RElcon, LLC Original M2.0 - MECHANICAL RooF PIAN vBid Set

09/29/2023 RElcon, LLC Original SHEIT NO. ! - EXHAUST HOOD DRAWINGS vBid Sel

09/29/2023 RElcon, LLC Orjgina, SHEET NO. 2 - EXHAUST HOOD DRAW!N0SvBid Set

Original SH:aT NO. 3 EXHAUST HOOD DRAWINGS vBid Set 09t29/2023 RElcon, LLC

09t2912023 RElcon, LLC Original SHEET NO. 4 - EXHAUST HOOD tRAWINGS vBid Sel

Reicon, LLC: Subcontractor:

- - Received by Investigations 08/23/2024 2024-09799

;T Reicon, LLC Powered by RedTeam PLANS AND SPECI FICATIONS REl,:.,' .,r ,

Project 1280010 - Hummus Republic Suprise Dale: [number redacted]

Document: 1280010-011

Name Date Author Scope

P1.0 - plU[nBlNG WAIER AND WASTE PLANS vBid Set 09/2912023 RElcon, LLC Original

P2.0 - WATaR AND WASTE ISOMETRlCS vBid Set 09/29t2023 RElcon, LLC Orlginal

P3.0 - GAS PLAN AND ISOMETRIC vBid Set 09/29 /2023 RElcon, LLC Orig:nal

Rei con, LLC: Subcontra

- Received by Investigations 08/23/2024 2024-09799

REI a Reicon, LLC Powered by RedTeam CHANGE ORDER

Number: 1280010-011 Change: 01 Date: 03107 12024

Proiect: 1280010 - Hummus RePUblic SuPrise

Location: Hummus Repbulic SuPrise 13864 West Bell Road Unit 1 00, Suprise, AZ 85374

Cost Code: 220000 Scope: Original

Subiect: Plumbing

Billto: Reicon, LLC Subcontractor: lnnovative Plumbing LLC 8802 W Lane Ave 4233 E Villa Theresa Dr Glendale, Az 85305 Phoenix, Az 85032

Contact: Dale Eagy Manager: John Zimmerman 602-2?8-9094 (602) 290-6973 [email redacted] [email redacted]

Terms: When Paid % Relainage: 10

Schedule of Values

It€m Oescription Quanlity Price Per unit (S) mount (S)

6,800.00 GreaseTrap 1 6,800.00/l/s Original plans did not call for supply and install of 125 gallon grease trap. we will cut additional concr€te and excavate then set trap and install newly configured grease system pe. Plan. Walls have been installed prior 10 plumbing and Pit will need to be hand dug. Do to over sizing ol glease system we will need to supply and install extension riser as trap wili need to be set at over deplh oftlap itself. lncluded we will haul awaY excess spoils created by install of trap.

Total (S) 6,800.00

Original Value: 36,800.00

Previous Approved changes: 0.00

Value of This Change: 6,800.00

Revised Value: 43,600.00

"SUBCONTRACTOR" "CONTRACTOR' lnnovative Plumbing LLC Reicon, ILC BY BY John Zimmerman Received by Investigations 08/23/2024 2024-09799

TITLE TITL F. DATE:-= --_-- DATE Received by Investigations 08/23/2024 2024-09799

Ril a Reicon, LLC Powered by Redleam PLANS AND SPECIFICATIONS

Pro.iect 1280010 - Hummus Republic Suprise Date:[number redacted]

Document: 1280010-011

The following contract documents are hereby incorporated by reference. These documents may be viewed online and downloaded in their entirety at: hltps://reiconus.flex.redteam.com/planroom *Entet Project Numbet 1280010 when accessing the online plavoom.

Name Date Author Scope

AO.O - COVER SHEET vBid Sel 09/29/2023 RElcon, LLC Original

D'l.0 ' DEMOLITION PLAN vBid Set 09/29/2023 RElcon, LLC Original

A1.0 - FLOOR PLAN AND NOTES vBid Set 09/29/2023 RElcon, LLC 0r:ginal

A'I,1 - REFLECTED CEILING PLAN SCHEDULES AND NOTES 09/29/2023 RElcon, LLC Original v3id Set

A1.2 . FINISH SCHLDULT AND Dt IAILS vBid Set 09t29/2023 RElcon, LLC Original

42.0 - EQUIPMENT PLAN AND SCHEDUaE vBid Set 09/29/2023 REtcon, LLC Original

A3.0 LIFE SAFETY PLAN AND FLOOR FINISH PLAN vBid 09/29/2023 RElcon, LLC Origlna S€t

A3,O . RLS I ROOM LLARGLD PLAN AND ELEVATIONS vBid 09/2912023 RElcon, LLC Original Set

44.O - INTERIOR ELEVATIONS vBid S€t 09/29t2023 RElcon, LLC Original

As 0 - COUNTER SECTIONSvBid Set 09/29/2023 RElcon, LLC Original

A6.0 - ARCHITECTUR: SPECIFICATIoNS v8,d Sel 09t29/2023 RElcon, LLC Original

A7.0 - ARCH'TaCTLIRE SPECIFICATI0NS vBid Set 09/29/2023 RElcon, LLC Original

El,O - ELECI POWER LIGHTING PLANS NOIES ANO 09/29/2023 RElcon, LLC Original DETAILS v8id Set

E2,0. PANEL SCHEDULES, RISER DIAGRAM AND DEIAILS 09129/2023 RElcon, LLC Original vBid Set

E3.0 EIECTRICAL SPECIFICATIONS vBid Set 09/2912023 RElcon, LLC Original

M1.0 - IVECHANICAL PLAN AND NOfES vBid Set 09/29/2023 RElcon, LLC Original

[r2.0 - MECHANICAL ROOF PLAN vBid Set 09/29t2023 RElcon, LLC Original

SHEEI NO. 1 - iXt-IAUST HOOD DRAWINGS vBid Sei 09/29/2023 RElcon, LLC Original

SHEET NO, 2. IXHAUST HOOD ORAWINGS vBid SEl 09/29t2023 RElcon, LLC O.iginal

SHEET NO. 3 - EXHAUSf HOOD oRAWINGS vBid Sel 09/29/2023 RElcon, LLC O.iginal

SHTET NO 4 t X*AUS f HOOD DRAWINGS v8rd Ser 09/2912023 RElcon, LLC Original

Reicon, LLC: Subcontractor:

- - Received by Investigations 08/23/2024 2024-09799

aEt a Reicon, LLC Powered by RedTeam PLANS AND SPECI FICATIONS

Project: 1280010 - Hummus Republlc Suprise Datei [number redacted] Document 1280010-011

Name Date Author Scope

PI.0 - PLUMSING WATER AND WASIE PLANS vBid Set 09/29/2023 RElcon, LLC Original

P2.0 - WATER AND WASTE ISOMETRICS vB:d Set 09/2912023 RElcon, LLC Original

P3.0 GAS PLAN AND ISOMETR,C vBid Set 09/29/2023 RElcon, LLC Original

Reicon, LLC: Subcontractor:

- - Received by Investigations 08/23/2024 7124124. 1236 pM 2024-09799 none Mail - FW: Subcontract l2gOOlO-011 plumbing (1280010 _ Hummus Republic Supns€)

r*t Gmail Chery, Eagy <cheryt@mcdowelt_tax>

FW: Subcontract r2gOOl O -011 Plumbing (12SOOlO messaqe - Hummus Repubtic Suprise)

Dalo <[email redacted]> To: cheryt Eagy <cheryt@mcooiett tax> Wed, Jul24, 2024 at i2t36 pM

F.om: John Zimmerman <[email redacted]> Sent: Thursday, March 14, 2024 8:08 AM To: Dale <[email redacted]> Subject Re: Subcontiact 128OO1O,Oi1 plumbing (1280010, Hummus Repubtic Suprise)

Ihanks Dale

On Wed, Mar 13, 2024 at Sj3O pM Date <[email redacted]> wrote John

I have tried sending the @ntract several times and it keeps coming back.

I willtry again.

Fromi John 2tmmerman <[email redacted]> Sem: Wednesda, M ar ch 13,2024 2t1] pM To: hnovative ptumbing <[email redacted]> cc: Dale <[email redacted]>; Gabriella Copeland <[email redacted]> subje.t Re: Subcontract 128001G011 ptumbing (r2s00ro _ x;mus ilprUfi. irpiir"f

Hello,

I hope you're having a great dayt

I am following up as we have not received the signed contract orthe COI as of yet.

Can you pleas€ provide these items before th€ end ofthe week?

Thank you,

On Tue, Mar 5, 2024 at 7:11 AM tnnovative plumbing <[email redacted]> wmte:

cabby Please send them a COltoday.

Thank you

https://mail google cody'm6illul2l?ik=7ata163511&view=pt&search=a &permthid=thread-r:[number redacted]&simpt=msg-f:1E05490360147428839 1/5 Received by Investigations 08/23/2024 2024-09799

hrovdive Hrmbirg LL,iC ,t 8802 West Lane Ave Glendale, AZ 85305 (602)228-9094 Xk;r*irrlr {-lrrer: Tmn t Plumbing [email redacted]

t.rli.ai ai!ible Pltlit6aa

BILL TIO NVOICD7452 Humus Republic 13864 West Bell #100 Suprise, Az DAIE03/18/2024 IERIf,S Net 30

DUIDNTT, 04/1712021

PLI'MBM. Dale

DATE ACIIVIIY DfSiCTIPIION qTY NAIE AMOUNT Change (Her Original plans did not call for supply r 6,800.00 6,800.00 and install ofgrease trap. We will cut additional concrete and excavate then set trap and install newly configured grease system per p1an. Walls have been installed prior to plumbing and pit will need to bc hand dug. Do to over sizing ofgrease system we will need to supply and install extension riscr as tmp will need to be set at oyer dcpth oftlap itself. Included we will haul away excess spoils created by install oftrap

ACCEPTANCE OF WORK PERFORMED: Customer acknowledges satisfactory completion of the above described work and that the premises have been lcft in a satisfactory condition. I agree that the amount set fofih in the space marked "Total" is thc total price i have agrccd to. Services purchascd on this invoice are sold with a 30 day warranty unless otherwise stated by the Plumber on above invoice in wananty section and is only for workmanship. Equipment/pafts waranty are only manufacturer wa[anty. Innovative Plumbing LLC is not responsible for down time, Iabor shipping or damages existing or proglessive as a rcsult of parts/cquipment failure. Payment is due at timc of seryices rendercd unless stated otherwise in customer account.

TOTAL DUI $6,8oo.oo

We appreciate your business F.OC#327570 Received by Investigations 08/23/2024 2024-09799

Innovdive llmbirg LI-C 8802 West Lane Ave Glendale, AZ 85305 (602)228-9094 I Ilt n nlrre*irrn lnfo(@innovative.plumbing

t Plumbing i-lilrl a:aai .atarla airallirf a

BILLfi) nworcE7453 Humus Republic 13864 West Bell #100 Suprise, Az DATE 0l/18/2021 IERMS Net l5

DVEDATE,04t02t2024

PI,I'MBER. Dalc

DATE ACTIWIT DES(NPIION ATY RAIE AMOT'NT

nurbing Demo cxisting fixtures as outlined in 0.30 36,800.00 11,040.00 plans Cut concretc and trench to install underground waste sysrem per plan in plastic pipe, back frll and concrete to grade. Install waste and vent system with hot and cold water system including water hcatm ( not including insulation also install filter water lines ( Filtcr system supplied by others). Install gas system using steel pipe. Ansul supplied by others.

ACCEPTANCE OF WORK PERFORMED: Customer acknowledges satisfactory completion of the above described work and that the premises have been left in a satisfactory condition. I agree that the amount sct forth in the spacc marked "Total" is the total price i have agreed to. Services purchased on this invoice are sold with a 30 day warranty unless othendise stated by the Plumber on above invoice in waraanty section and is only for workmanship. Equipmenvpafts warranty are only manufacturer waranty. Innovative Plumbing LLC is not rcsponsible for down timc, labor shipping or damages existing or progressivc as a result of parts/equipment failure. Payment is due at time ofservices rendered unlcss stated otherwisc in customer account.

TOTAL DUE $11,040.00

We appreciate your business PIOC#327570 Received by Investigations 08/23/2024 2024-09799

CONDI TIONAL WAIVERAND RELEASE ON PROG RESS PAY ENT ST OF ARI NA (P ursuant to Arizona Revised Statutes S33-1009)

Project Hummus Republ i c Surprise Job No T2 0010

On receipt by the undersigned of a check from RE I CON, LLC (Maker of check) in the sum of$ 11,040 ' 00 pay able to Inn ovative P Iumbing (Amount of Check) (Payee or Payees of Check ) and when the check has been prop erly endorsed and has been paid by the bank on which it is drawn, this document becomes effective to rel ease any mechanic's lien, any state or fede ral statutory bond right, any private b ond right, any claim for payment and any rights under any similar ordinance, rule or statute related to claim or payment rlghts .fqr. perso ns in th e undersigned's position that the undersigned has o n the job of [ummus Hepu.Ol f c Su rprase (Owner) 16ga1.6 61 13864 tri Surprise Rd Uni I 100 Surpr.ise AZ 853'1 4 (Job Description) to the following extent. Th is release covers a proqress payment for all labor, services, equipment or materials furnished to the.J ob site or to REICOI'], "Ll,C ' (Person with whom undersigned contracted) throug 6 04/22/2a24 only and does not cover any retentton, pending modifications (Date) and changes or items furnished after that date. Before any recipient of thjs document relies on it, that person should verify evidence of payment to the undersigned.

The undersigned warrants that he either has already paid or will use the monies he receives from this progress payment to promptly pay in full all of his iaborers, subcontractors, materialmen and suppliers for all work, materials, equipment or services provided for or to the above referenced pro.lect up to the date of this waiver.

DATED on APril 22 ,20 lnnovative Plumbing LLC (Claimant name)

By: Cheryl L Eagy

Its: Accountant Address: 8802 W La ne Avenue Glendale M 85305 Phone: 602-4 -1604 Fax: Received by Investigations 08/23/2024 2024-09799 hnovdive HunHng LLC 8802 West Lane Ave Glendale, AZ 85305 (602)228-9094 Info(@innovative.plumbing

BIII IO Humus Republic nworcE7612 13864 West Bell #100 Suprise, Az DATE04/ll/2024 TERI|{S Ner lO

DUEDATS,0S/ t 1/2024

PLUMBM, Dale

DATE ASIIVIIY DDSCRIMON ory NAID AMOTJNT ntmDitrg Demo existing fixtures as outlined in 0.30 36,800.00 I 1,040.00 plans Cut concrete and tench to install underground waste sysiem per plan in plastic pipe, back fill ard concrete ro grade. Install waste and vent systcm with hot and cold water system including water heater ( not including insulation also install filter water lines ( Filter systern supplied by others). Install gas system using steel pipe. Ansul by others. Note 2nd invoice completion of in wall 1 0.00 0.00 plumbing

ACCEPTANCE OF WORK PERFORMED: Customer acknowledges satisfactory completion of the above described work and that the premises have been left in a satisfactory condition. I agree that the amount set forth in the space marked "Total" is the total price i have agreed to. Services furchased on this invoice are sold with a 30 day warranty unlcss otherwise statcd bv the Plumber on abor e invtrice in warranry seclion and is only lor workmanship. Equipment/parts warranty are only manufacturer warranty. Innovative Plumbing LLC is not responsible for down time, Iabor shipping or damages existilg or progressive as a result of parts/equipment failure. Payment is duc at time ofservices rendered unless stated otherwise in customer account,

TOTAL DUE $11,040.00

We appreciate your business ROC #327570 Received by Investigations 08/23/2024 7124124,2:57 PM non6 Mail - FW: Payments past due 2024-09799

ivt Gmait Cheryl Eagy <[email redacted]>

FW: Payments past due messages

lnnovative Plumbing <[email redacted]> wed, Jul 24 , 2024 al 12143 PM To: Cheryl Eagy <[email redacted]>

From: lohn Zimmerman <[email redacted]> Sent: Thursday, May 2,202412:29 PM To: chris Reigel <[email redacted]> cc: lnnovative Plumbing <[email redacted]> Subject: Payments past due

Hey Chris,

I just spoke to Dale and he was following up on the h^/o invoices dated 03-18-2024 for $11,400.00 and $6,800.00 that have not been paid.

Please advise when paymentwill be made

Thank you,

REICON, LLC

John Zimmerman Proiect Manager

602-2S0-6973

lnnovative Plumbing <[email redacted]> Wed Jul24, 2024 al2 55 PM To: Cheryl Eagy <[email redacted]>

From: lnnovative Plumbing Sent: Thursdav, MaV 9, 2024 11:13 PM To: John Zimmerman < [email redacted]>; Chris Reigel <[email redacted]> Subjecti RE: Payments past due

lnvoices 7453 and 7452 Were originally sent on l\,4arch 18 at your request we have signed and sent-waiverfor 7453 Could Ipleaseget ,pJit" on pry."nt as currentiy yori have been billed $28,880.00 with $17,840.00 past due and $11 ,040.00 soon to be past due. ""

Dale

https://mait.qoogte.com tmaitlul2t? k=7 at81635f'1&view=pt&search=all&permlh d=thread-i:fiD5490791224962991&simpl=msgJil [number redacted] 112 Received by Investigations 7124124,4102 PM 08/23/2024 none Mail- FW: Payments past due 2024-09799 lrrnovative Plumbing

{OL,olcd texl hidd-anl

lnnovativo Plumbing <[email redacted]> Wed , Jul 24 , 2024 at 2 50 PM To: Cheryl Eagy <[email redacted]>

lQ!.r.rd r.i llddcll

lnnovative Plumbing <[email redacted]> Wed, Jul 24 , 2024 at 3.32 PM Tor Cheryl Eagy <[email redacted]>

Fromr lnnovative Plumbing Sent: Wednesday, June 5, 2024 11:29 AM To: Chris Reigel <ch sr@reiconus_com> Subiect: RE: Payments past due

Can you please provide an update on this as soon as possible?

From: Chris Rei8el <[email redacted]> Sent: Wednesday, May 29,2024 7176 PM To: lnnovative Plumbing <[email redacted]> Subiect: Re: Payments past due

We had a change order go in for a bunch of items that changed on the permit set of drawings and this bank has made it miserable and it has held up payment. I have a call tomorrow moming to try and get it released and l'll update you afler

On Wed, May 29,2024 at 1:12 PM lnnovative Plumbing <[email redacted]> wrote:

Chris

Any update on paymenls the pre-lien from my vendor on this account is about to mature to lien. Could you please let me know

Get Outlook for iOS

lnnovative Plumbing <info@rnnovat ve.plumb ng> Wed, Ju|24,2024 at 3134 PIV To: Cheryl Eagy <[email redacted]>

From: lnnovafve Plumbing Sent: Tuesday, July 16,2024 10145 PM Toi [email redacted] Subject: RE: Payments past due

Chris https://mail.google.comlmaillul2l?ik=7a$1635f1&view=pt&search=all&permthid=thread-f1180U9O791224962991&simpl=msg-t180549079'[number redacted] 213 Received by Investigations 7124124, 4:02 pM 08/23/2024 Ittas now bgen a month since we ras:^:qor:e; r 2024-09799 b:e" ,ffi pavment bv Fridav the 19 dav of !.:ye August'zoza r *irr o" rii""il ""#ffil;T,"ll:j::'#;;""", i!!li'"o,"" flte a case with the Roc. r can no ronser.r r do not receive

"nd

Respecttully

Oale Eagy

lnnovative Plumbing LLC

From: [email redacted] <[email redacted]> Sent: Tuesday, June 18, 2024 8:08 AM To: lnnovative plumbinB <[email redacted]> Subject: RE: payments past due

Dale,

y: |3il",""#i:"t""[,[Xlf"l,,ll3.1l"** Mondav, l'll have a pavment out today and then another earry next week. rhese thinss "ne

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From: lnnovative plumbing <[email redacted]> Sent: Tuesday, June 18,2O24 8:06 AM To: Chris Reigel <[email redacted]> Subiect: Re: Payments past due

Chris

come Fdday the preen will mature to a full lean could you please provide me with a response to when we would receive payment thank you dale

G6t Outlook Jor iOS

Fromlnnovative plumbing <[email redacted]> Sent: Tuesday, June 18,2024 8tOS.47 AM To: Chris Reigel <[email redacted]> Subjed: Re: Payments past due

Chris

lnnorativg Plumbing <[email redacted]> To: Cheryl Eagy <[email redacted]> Wed, Jul24,2024 al 3:42 pM

iou.L.a ierr rdc..'

https://mail google com lmaillut2/?ik=7aru635f1&view=pt&search=all&permthid=thread-f 1ao54go7g122496299.,&stmpl=msg-f:1805 4go79122496299 3/3 7124124, 4:Og pM Received by Investigations none Mail - FW: payments past due 08/23/2024 lnnovative plumblng 2024-09799

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.[email redacted]> f11X11ur"ltuInling ro: uneryt Eagy <[email redacted]> Wed, Jul24, 2024 at ZSO pM

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,lgl"^r1r.,"j,1lhol"n:[email redacted]> ro: uheryt Eagy <cheryt@mcdowe .tax> Wed, Jul24,2024 at3.32 pM

F.om: lnnovative plumbing Sent: Wednesda, Jun e E,2OZ4l7:2g AM To: Chris Reigel <[email redacted]> Subiect: RE: payments past due

Can you please provide an update on this as soon as possible?

From: Chrls Reigel <[email redacted]> Sent: Wednesday, May 29,2024I:t6 pM To: lnnovative plumbing <[email redacted]> Subiecti Re: payments past due

H;,i:lf ii?i'""""9i1ffi;:T",:'.1,""3?:;ilxff:i1?:,"",H1*:fi,il::i:;::.:#?* *d thjs bankhas made it miserab,eand ithas he,d up

On Wed, May 29,2024 at 1:i 2 pM lnnovative plumbing <[email redacted]> wrote Chris

Any update on payments the pre-lien from my vendor on this account is about to mature to lien. could you please let me know

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lnnovative_Plumbing <[email redacted]> ro: uneryt Eagy <[email redacted]> Wed, Jul 24, 2024 at 3:34 pM

From: lnnovative plumbing Senti Tuesday, July 16,202410.45 pM Tor [email redacted] Subiect: RE: payments past due

Chris https://mail google com lmaillul2l?ik=7a181635f1&view=pt&search:all&permthid=thread-t 1Bos4go791224962991&simpr=msg-f:18054 go7g122496299 7124124,4:09 pM Received by Investigations 08/23/2024 rtra5 ns\'!r' rsgn 3 rnonth since we,rast sryre; 2024-09799 payment by Friday the 19 dav bjen ve#I,Iiyr,il.:Jllil::n;;""", r can no ronser if r do not receive of Augusi zoza ,r r *liil"'r.i*i'" i"I:'iE'gi, u"no, ,nd fire a case wirh the Roc. r,?v.e

Respecttu y

Dale Eagy

lnnovative Plumbing LLC

From: [email redacted] <[email redacted]> Sent: Tuesday, June 18,2024 8..Oa AM To: innovative plumbing <[email redacted]> Subject: RE: payments past due

Dale,

y: 13il","U.:;"#[Xl?orlrll3 j-** Mondav, l'rl have a pavment out today and then another earry next week. rhese thinss "ne

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FromJnnovative plumbing <[email redacted]> Sent: Tu esday, J u n e 18 , 2024 BiO6 AM To; Chris Reigel <[email redacted]> Subiect: Re: Payments past due

Chris

come Friday the preen will matu'e to a full lean. could you please provide me with a response to when we wourd receive payment thank you dale

Get Outlook for iOS

From: lnnovative plumbinS <[email redacted]> Sent: Tuesday, June 18,2024 8:OS:47 AM To; Chris Reigei <[email redacted]> Subjed; Re: Payments past due

Chris

lnnorativo Plumbing <[email redacted]> To: Cheryl Eagy <cheryt@mcdowe .tax> Wed, Jul 24, 2024 at 3:42 pM

;lru.i.l l-rr. r.lie.'

https://mail google com lmail/ul2l?ik=7 a181635f1&view=pt&search=a &permthid=thread-f :ft054907g1224962991&simpt=msg-f:1805 4go7g122496299 3t3 9/10/24, 8:06 AM State of Arizona Mail - No Pay Notice 2024-09799

Legal New Mail - AZROC <[email redacted]>

No Pay Notice 2024-09799 messages

Legal New Mail - AZROC <[email redacted]> Tue, Aug 27, 2024 at 1:00 PM Bcc: [email redacted], [email redacted]

Hello,

Attached please find an electronic courtesy copy of the letter issued in this case. This document was also sent to your attention via US Mail. Please include [email redacted] with all further correspondence regarding this matter.

Thank you,

Arizona Registrar of Contractors Legal Department 602-542-1525

Fill out AZ ROC’s survey to let us know how we’re doing and how we can better serve you!

20240827 Notice of No-Pay Complaint MAILED 2024-09799.pdf 8735K

Chris Reigel <[email redacted]> Tue, Sep 10, 2024 at 12:09 AM To: Legal New Mail - AZROC <[email redacted]>

Good morning,

We missed this notice, it came in while I was away for the long holiday weekend. Can we please have an extension to file a complete response? [Quoted text hidden]

Legal New Mail - AZROC <[email redacted]> Tue, Sep 10, 2024 at 8:04 AM To: Chris Reigel <[email redacted]>

Hello,

An extension can be granted until 9/13.

Thank you,

Arizona Registrar of Contractors Legal Department

Fill out AZ ROC’s survey to let us know how we’re doing and how we can better serve you!

https://mail.google.com/mail/b/AEoRXRQtT2hqic7-gAEAjHZgN29o56cd7KNag2Uhq71Qm6ccjXHY/u/0/?ik=d3afebeda9&view=pt&search=all&permthi… 1/2 9/10/24, 8:06 AM State of Arizona Mail - No Pay Notice 2024-09799

[Quoted text hidden]

https://mail.google.com/mail/b/AEoRXRQtT2hqic7-gAEAjHZgN29o56cd7KNag2Uhq71Qm6ccjXHY/u/0/?ik=d3afebeda9&view=pt&search=all&permthi… 2/2 LEGAL RECEIVED 09/13/2024

9/13/2024

Arizona Registrar of Contractors 1700 W Washington Street Suite 105 Phoenix, AZ 85007

RE: Complaint No. 2024-09799

To whom it may concern,

In response to the above referenced complaint, Innovative Plumbing LLC is requesting payments for change orders that the owner has not approved nor paid for. REIcon, LLC is in the process of building a case against the owner of the project to recoup not only Innovative Plumbing’s money but other subcontractors and our own. The owner terminated us from this project without following the contract and has left us with a balance of $127,443 unpaid. REIcon is a small family owned business and this client has destroyed our business and left us with little options. I am more than willing to work out a payment plan with the subcontractor on any billing that was base contract work while we try and solve the bigger problem.

Sincerely,

Chris Reigel (602) 909-2897 REIcon, LLC 9/13/24, 11:53 AM State of Arizona Mail - No Pay Notice 2024-09799 LEGAL RECEIVED 09/13/2024

Legal New Mail - AZROC <[email redacted]>

No Pay Notice 2024-09799 messages

Legal New Mail - AZROC <[email redacted]> Tue, Aug 27, 2024 at 1:00 PM Bcc: [email redacted], [email redacted]

Hello,

Attached please find an electronic courtesy copy of the letter issued in this case. This document was also sent to your attention via US Mail. Please include [email redacted] with all further correspondence regarding this matter.

Thank you,

Arizona Registrar of Contractors Legal Department 602-542-1525

Fill out AZ ROC’s survey to let us know how we’re doing and how we can better serve you!

20240827 Notice of No-Pay Complaint MAILED 2024-09799.pdf 8735K

Chris Reigel <[email redacted]> Tue, Sep 10, 2024 at 12:09 AM To: Legal New Mail - AZROC <[email redacted]>

Good morning,

We missed this notice, it came in while I was away for the long holiday weekend. Can we please have an extension to file a complete response? [Quoted text hidden]

Legal New Mail - AZROC <[email redacted]> Tue, Sep 10, 2024 at 8:04 AM To: Chris Reigel <[email redacted]>

Hello,

An extension can be granted until 9/13.

Thank you,

Arizona Registrar of Contractors Legal Department

Fill out AZ ROC’s survey to let us know how we’re doing and how we can better serve you!

https://mail.google.com/mail/b/AEoRXRRdY0tYYhCRCm7ExT_jMoeaQbcXhf6c7gmerwa389oddKmj/u/0/?ik=d3afebeda9&view=pt&search=all&permth… 1/3 9/13/24, 11:53 AM State of Arizona Mail - No Pay Notice 2024-09799 LEGAL RECEIVED 09/13/2024

[Quoted text hidden]

[email redacted] <[email redacted]> Fri, Sep 13, 2024 at 9:03 AM To: Legal New Mail - AZROC <[email redacted]>

Please see attached response.

Christopher M. Reigel

From: [email redacted] <[email redacted]> On Behalf Of Legal New Mail - AZROC Sent: Tuesday, August 27, 2024 1:00 PM To: undisclosed-recipients: Subject: No Pay Notice 2024-09799

Hello,

Attached please find an electronic courtesy copy of the letter issued in this case. This document was also sent to your attention via US Mail. Please include [email redacted] with all further correspondence regarding this matter.

Thank you,

Arizona Registrar of Contractors

Legal Department

602-542-1525

Fill out AZ ROC’s survey to let us know how we’re doing and how we can better serve you!

https://mail.google.com/mail/b/AEoRXRRdY0tYYhCRCm7ExT_jMoeaQbcXhf6c7gmerwa389oddKmj/u/0/?ik=d3afebeda9&view=pt&search=all&permth… 2/3 9/13/24, 11:53 AM State of Arizona Mail - No Pay Notice 2024-09799 LEGAL RECEIVED 09/13/2024

AZ ROC Response Innovative Plumbing.pdf 87K

https://mail.google.com/mail/b/AEoRXRRdY0tYYhCRCm7ExT_jMoeaQbcXhf6c7gmerwa389oddKmj/u/0/?ik=d3afebeda9&view=pt&search=all&permth… 3/3 REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA

Case No. 2024-09799 Innovative Plumbing LLC,

COMPLAINANT, v. CITATION REIcon LLC License No. ROC 340420,

RESPONDENT.

The Registrar issues this Citation to REIcon 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 August 23, 2024, Innovative Plumbing LLC (“Complainant”) filed a written complaint with the Registrar. A copy of that Complaint is attached to this Citation. A FORMAL STATEMENT OF THE CHARGES AGAINST RESPONDENT

Charge :1 A.R.S. § 32-1154(A)(10) — Failure by a licensee or agent or official of a licensee to pay monies in excess of $750 when due for materials or services rendered in connection with the licensee's operations as a contractor

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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 unless the licensee proves that the licensee lacks the capacity to pay and has not received sufficient monies as payment for the particular construction work project or operation for which the services or materials were rendered or purchased. 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:

If the matter proceeds to a hearing and the administrative law judge determines that any of the charges listed above are supported by a preponderance of the evidence, then Respondent’s license(s) may be subject to suspension or revocation, and Respondent may be subject to other penalties provided by law, including civil penalties under A.R.S. §§ 32-1154(E) and (F). FILING A WRITTEN ANSWER Respondent must appear by filing with the Registrar a written answer to the citation and complaint showing cause, if any, why Respondent’s license(s) should not be suspended or revoked. A.R.S. § 32-1155(A). Respondent’s written answer should contain the heading “Written Answer to Citation and Complaint” and should include the case number, which is Case No. 2024-09799. 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

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 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). 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

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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 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 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/ Robert Stirling Robert Stirling Assistant General Counsel Legal Department Arizona Registrar of Contractors

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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 COPY of the foregoing mailed by Certified Mail, Return Receipt Requested, September 18, 2024 to:

Respondent Certified Mail No: [number redacted]

REIcon LLC 4233 E Villa Theresa Drive Phoenix, AZ 85032 Copy mailed by USPS First Class mail this same date to: REIcon LLC 4233 E Villa Theresa Drive Phoenix, AZ 85032

Complainant Innovative Plumbing LLC 8802 W Lane Ave Glendale, AZ 85305

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. 2024-09799 / MTH

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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 Received by Investigations 08/23/2024 2024-09799 RECEIVED AUG 2 3 202{Departmental Use only Non-Payment ComPlaint Form Numret: I NVE sfl GATI gfgqrdaint

Mail to: U.iat\( in Registrar of Contractors P.O. Box 18243 Phoenix, AZ 85005-8243

PeIson ROC License Numbc(s) (if any) ll Name irst Middle Last) Busincss Name State Zi Code

E rl Ad Phone Number

I consent to receive communications electronically in connection with this case Yes[ Notr

Name Attomey (if any) State Zip Code 's Strect Address City

Attorney's Email Adtuess Attorlrey's Phone Number

ROC License Number(s) is shown on contracts, invoic€s, etc') State Zi Code

t il Address Phorle Number

Na of Person(s) n ti t Licensc ?* Co m I aint In rma tion if P P licab1 ,s D din and fees) Con D

Yes ! (tf yes, provide a coPy of the civll judgment No H you fi cd .I No P

b id ttach ad di ti al es if necessa l.ist all s ific hic h have t. + oa a OO I s oc) .t

of It 1l 11 Ll red fifrv d o /5 tth n a f1 d be ref, tha tllc t1 booe- )t d 5 hns f, le d to Pt1 v tno ES tl ces ,fu ll P o nt'o co t tctor. I t', f t1 certify, upotl nfor tl t1 ti IL a d (l ll dc ed c tl l a o tl ?{r It Iicensee's op 10t a t1 Llut t'. tl teri t1 1',1 pattiallar coflstrucl u i? oTe- /l d the L.nPa c ty p av o lns recc oecl rt'f' ct t1 t|10nles ds^ Payn n f, t1

ltt cf, a th lL ) Ax wl i.h t1 efp aEs of tl a ltr d 5 32 1 1 t k t't, c ar tl 1011 rtcd Name Da D e clar ati on & Si pt: I d c t] n pc hJ of p efl IL ry tha c d lt ly 0 lr orL z ed feP resc la Coruplcinant n fltis C tltp tl tft F a) r t1 p n 11 t1 I alll rrec to f1 1( best l v knot d8 Ilt fr ae hn rtli n do etL btr ted nt'ort tl ii tl CO ttt tl a d 11 th 75 F on is truc tl d c "f kn le d 7Al a ,s 1l h PP OI ,f this c 1t1p lLt ll art tln Ll correcl co?ics hc ar ,f 5 and a re acc u rn te io I he best 111 v 0?l) .q "f to ct 5 fr f n tl a {l he ll r1 ll {ln d o l1 o h ao n lrfi t)r a l1 85 a 1t 41, 5 tl in Ir 0se a Di Si August 27, 2024

Via U.S. Mail and Email

Complainant Innovative Plumbing LLC 8802 W Lane Ave Glendale, AZ 85305

Via U.S. Mail and Email

Respondent REIcon LLC 4233 E Villa Theresa Dr Phoenix, AZ 85032

Re: Complaint No. 2024-09799

Dear Complainant and Respondent:

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

Respondent is free to raise any issue or affirmative defense to this complaint by filing a response with the Registrar by September 3, 2024. Please reference the complaint number listed above if you file a response. Respondent may file a response by:

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

The Registrar will not issue a citation before September 3, 2024 and will review Respondent’s response, if one is submitted.

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

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

/s/Madelyn Hayes Madelyn Hayes Legal Assistant II Legal Department 1700 W Washington St. Ste 105 Phoenix, AZ 85007

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg100 4/21 Received by Investigations 08/23/2024 2024-09799

Written Statement Regarding Contract with Reicon LLC:

On November 15,2023 Reicon LLC posted an lnvitation to Bid on the Hummus Repubtic project 128000.

On February 20, 2024 we were emaited a copy of the contract atong with a request for a Certificate of lnsurance and ourW9 of which both were sentto Reicon LLC on March 4,2024.

On March 7,2024wewerc emaited a Change Order for this contract in the amount of $6880.00

severat attempts were made to emait the signed contract to no avaitwith the finat attempt made on March 14,2024

On AWil22,2024lnvoices 7452 and 7453 were sent to Reicon LLC atong with the Conditionat Waiver and Retease on Progress Payment. These funds have never been received.

On May 2 an emall was sent to the project manager, John Zimmerman, requesting payment status. He forwarded the emaiI to the owner requesting status. Noresponse.

On May 29, 2024 an emailwas sent requesting payment status. Chris Reiget responded saying that payment has been hetd up. Saidhewasmakingaphonecattthenextdayandwoutdupdateup after. No response was forthcoming.

on Jun 18, 2024we sent a firmer request for payment status and were totd they had a wire coming in that day and the next day with a promise of payment on 06118/204 and another one the next week. No payments were received.

On Juty 16, 2024 a request for payment was sent to ch ris Reiget with no response.

On July 24,2024 a phone catlwas made with no response. Amessagewas teft requestingto settte this maiter. lf no response then fiting with ROC for non payment.

These are the facts and documentation I have cottected in this matter to best of my knowtedge.

Thank you

Date Eagy

President

lnnovative Ptumbing LLC Received by Investigations none Lilail - FW: lnvitation to Bid from Reicon LLC 08/23/2024 124124 , 3:10 Pl4 2024-09799

Cheryl Eagy <cheryl@mcdowell tax>

l$t Gmail FW: lnvitation to Bid from ReiCon LLC l message Wed, Jul 24, 2024 at 1i33 Pl/ Dalo <[email redacted]> To: Cheryl Eagy <cheryl@mcdowell tax>

com> From' Reicon LLc <OneTearn3033448@bbbid thebluebook sent: Wednesday, November 15,2023 1:30 PM subject: lnvitation to 8id from Reicon LLc

i!ilE*tr lnvitation to Bid

Bid is due by 12:15A14 (Mouniain) on Novemhet 22' 2023

ReiCon LLC has invited You to bid on Hummus RePublic.

We are lookilg for Plumbing Contractors.

view Full Prolect Deta,ls & Files

Do you intend to bid on this Project?

Yes No Maybe

Project Summary

113

httpsJ/mait.google.com lmaillt)lzl?lk=7 afa]635f'1&view=pt&search=all&permthid=thread-f:[number redacted]&simpl=msg-f:1805493S64084279486 Received by Investigations 124124 . 3:10 PM none lrail - FW: lnvitation to Bid from Reicon LLC 08/23/2024 2024-09799

Hummus Republic I Surprise, AZ 85374 (SurPrise)

View Full Project Details View Project Files

11122123 12:15 AM (Mounlain\ Bid Due Date subcontractor o Negotiating Project Status

Tenant improved proiect Hummus Republic Project quick serve restaurant. Phone: (602) 290- Description 6973 Email: [email redacted]

Submil Bid

John Zimmerman

P: (602) 290-6973

Click He.e for Email

ReiCon LLC

Don't FALI behind, Get the mo6t ol Your leads with the tf EueBook Blue Book Constructon Networl Call 888-720-Ir'1{ -

Book Network You are receiving this omai! because you aae registered in The Blue www.lhebluebook.com

Blue Book N€Nvork's Reioon LLC is sharing this proiect opportlnit) / wilh you lhrough The ONffenU. fo, n"tp i t aining on how lo viewand respond to this ITB call88&303-2243

To unsubscrbe from Bid lnvitalions click hele

View Pnvacy-Pqley

213 1180549396408427s486&simpl=msoJ:1805493s64o84279486 httpsl/mait.googte.com tmailut2l?tk=1 af8i635f1&view=pt&search=all&pernrthld=thread-f Received by Investigations 08/23/2024 2024-09799

REI a Reicon, LLC Powered by RedTeam SUBCONTRACT

Number: 1280010-011 Oalei 0U2012024

Proiect: 1280010 - Hummus Republic Suprise

Location: Hummus Repbulic Suprise 3864 West Bell Road Unit 100, Suprise, AZ 85374

Cost Code: 220000

Scope: Original

subject: Plumbing

Subcontractor: lnnovative Plumbing LLC Billto: Reicon, LLc 8802 W Lane Ave 4233 E Villa Theresa Dr Glendale, AZ 85305 Phoenix, AZ 85032

Contact: Dale Eagy Manager: John Zimmerman 602-228-9094 (602) 290-6973 [email redacted] [email redacted]

Terms: When Paid % Retainage: 10 Start Date: [number redacted]

THIS SUBCONTRACT AGREE[/ENT ('Agreement") by and between Contractor and Subcontractor shall be performed in strict accordance with these terms and conditions, the Contract Documents incorporated by reference, including the Plans and Speciflcations plus any Additional Documents attached hereto,

Contractor agrees to pay and Subcontractor agrees lo receive and accept as full compensation for performing the scope of work described herein, in accordance with the following Schedule of Values:

Schedule of Values

Item Oescription Quantity Price Per Unit ($) Amounr (S)

Plumbing 1 36,800.00/l/s 36,800.00

Plumbing per plans and specs

Cut concrele and lrench, backfill and concrete to grade per plans and specs

Total (S) 36,800.00 Thirty six Thousand Eight Hundred Dollars and Zero cents

NOW THEREFORE, Contractor and Subcontraclor agree as follows: Received by Investigations 08/23/2024 2024-09799 Section 1. The Subcontractor warrants and represents lhal it is and was prior to submitting its proposal to Contractor, duly licensed by all governmental licensing authorities having jurisdiction over ihe Wori or the proiect location. Subcontractor further warrants that at all times throughout the performance of this Agreement it shall comply with all government regulations and contractual obligations affecting the Work or the project location.

Section 2. The Subcontractor agrees to begin working as soon as it is notified by the Contractor that the project is far enough advanced for it to start the Work and to carry forward and complete its Work as rapidly as the contractor may judge necessary. Time is of the essence of this Agreement. The Subcontractor is to execute this Agreement with sufficient speed and diligence to enablelhe Contractor and other subcontractors to comply wilh the Construction Schedule.

Section 3. The Subcontractor shall provide its employees with a safe place to work, to perform the Work in a safe manner with high regard for the safety and health of all and to comply with health and safety requirements of the contractor, including contractor's policies regarding a drug-free workplace, local, state and federal agencies, and to hold the Contractor harmless for any cosl of defrciencies, fines or damages incurred because of its negligence or failure to take reasonable safety precautions or lo comply with safety regulations.

section 4. The subcontractor shall employ a full time supervisor, equipped with a radio or mobile phone, on site with full authority to act as agent for subcontractor. The Subcontractor's supervisor must check in with Contractor's Site Operations Manager or designee prior to starting Work and at least 30 minutes prior to finishing Work each work day.

Section 5. The Subcontractor shall not employ any material supplier, subcontractor, architect, consultant, worker or supervisor whose employment on the building or project is reasonably objected to by the Contractor.

Section 6. The Subconlractor shall attend periodic progress meetings as required by the Contractor. Subcontractor shall regularly advise Contractor of i1s progress and ongoing ability to fully perform the Work and to maintain the Construclion Schedule. Subcontractor agrees to pay Contractor the amount of 5500 for its failure to attend any scheduled progress meeting.

Section 7. The Subcontractor shall examine the work of the Contractor and any other subcontraclor and report to the Contractor in writing any defects that would adversely affect Subcontractor's Work. lf the Subcontractor does not so advise the Contractor in writing then it will be assumed it has fully accepted the work of others as being satisfactory for the inslallation or application of the Subcontractor's Work and is fully responsible for the satisfactory performance of the Work covered by this Agreement. The Subcontractor shall not interfe,e with the work being performed by the Contractor and other subcontractors and shall further perform its subcontract in such a manner that protects the work and/or materials being used by others. Any and all such damages or injuries sustained by the Contractor or others shall be charged back to the Subcontraclor.

Section 8. The Subcontractor agrees that its shop drawings and submittals represent that all measurements and fteld conslruction criteria have been determined and regularly verified right up to the time of installation of its Work, and that it has checked and coordinated each shop drawing and submittal wilh the requirements of the Work and of the Contract Documents. Approval of drawings or other submittals by the Contractor or owner shall not relieve Subcontractor of its obligations to perform the Work in strict accordance with the Contract Documents or ils responsibility for proper matching of its Work to contiguous work.

Section 9. The Subcontractor shall be responsible for keeping its part of the job clean and orderly subject to the approval of the Contractor and owner. Should it become necessary for the Contractor to perform cleanup work for the Subcontractor, the Contractor will deduct such expenses from any funds due to Subcontractor at the rate of $50 per hour for a minimum of at least eight hours plus expenses.

Section 10. The Subcontractor shall upon request furnish Contractor with a list of major services, materials and equipment required for the Work, listing the service providers or suppliers and the dates of performance of or deliveries to the project location, as well as copies of purchase orders or sub- Received by Investigations 08/23/2024 2024-09799 subcontracts to the Contractot Subcontractor further warranls that it shall make full and proper payments for any and all of Subcontractor's obligations arising from Subcontractor's Work including but not limited to labor, services, materials, taxes (including sales or use taxes), insurance cor"i.g", equipment, and permits.

section 11. The subcontractor shall prepare an Application for payment, form AIA G7o1/G702 or equivalent, indicating the value of its Work properly installed through the end of each calendar month, unless otherwise specified, and shall submit such Application for payment at least five (5) business days prior to the end of the period. To the extent that such Application for payment is ipproved by Contractor, payment shall be made to the Subcontractor on Friday after t:00 pm within five (ij business days following receipt of payment from Owner for the Contractor's monthly Application for iayment in which the Subcontlactor's Application for Payment was incorporated. lt is a condition pr""ed"nt to Contractor's obligation to pay Subcontractor that Contractor shall have first received payment from the Owner. Subcontractor acknowledges that it relies on the credit of the Owner, not tie Contracror, for Payment of the Subcontractor's work. Should the Subcontractor's portion of the Contractor's application be withheld or reduced for any reason, payment to lhe Subcontractor will be reduced accordingly. Relainage shall be withheld from each progress payment at the rate of '10%, unless otherwise specifled, and released upon final payment. Approval and payment of subcontractor's Application for payment does not constitute or imply final acceptance of Subcontractor's Work by the Contractor or Owner. The Subcontractor is to use all monies received or to which it may be entitled to be paid by the Contractor as payment for labor, materials, or other expenses incurred in the performance of this Agreement. Contractor may offset against any sums due Subcontractor hereunder the amount of any obligations of the subcontractor to the contractor whether or not such obligation arises from this Agreement.

Section 12. Final payment to Subcontractor shall be made after the last of the following to occur: a) completion of the work by subcontractor; b) acceptance thereof by the contractor and owner; c) issuance of a Certificate of occupancy by the governmental authority having jurisdiction over the project; d) flnal payment by Owner to Contractor; e) furnishing of evidence satisfactory to the contractor that there are no claims obligations or liens outstanding or unsatisfied for labor or materials or other items contributing to the Work; f) submission of subcontract deliverables such as warranties or "as built" drawings; g) a general release by the Subcontractor in a form satisfactory to the Contractor and in favor of the conlractor and owner; and h) authorizalion by subcontractor's surety or other performance guarantor, for Contractor to release final payment to Subcontraclor.

Section 13. The Subcontractor shall furnish upon request affidavits that its obligations pursuant to any part of the Work have been satisfled. Prior to any partial or flnal payment to the Subcontractor, a release of lien in conformance with F.S. 713.20 shall be furnished to the Contractor. Subcontractor shall indemnify and hold harmless Contractor from any and all claims, liens, or encumbrances on or against the project or the real property on which same is situated arising out of the failure of the Subcontractor to make payments of any kind. Without limiting the foregoing, Subcontractor shall cause any such liens or claims to be satisfied, removed or discharged by bond, payment or otherwise within frve (5) business days from the date of flling or receipt as the case may be. The existence of any lien or claim shall preclude Subcontractor's right to receive future payment until such lien or claim has been removed. ln the event it shall become necessary for the Contractor to employ an attorney to defend against any such claims, liens or encumbrances in any court, slate or federal, the Subcontractor shall pay the cost and expenses incurred by the Contractor in the defense of such, whether or not such claims are.iust or unjust, including but not limited to a reasonable attorney's fee. At its discretion, the Contractor reserves the right to Pay any obligalions of the Subcontractor arising on this job. Such payments shall be applied and fully credited as payment of this Agreement.

Section 14. The Subcontractor may be directed to perform Extra Work by the Contractor for which Subcontractor may or may not be due additional compensation. ln the event that the amount of such additional compensation, if due, is not agreed upon in advance, Subcontractor must submit a claim foa additional compensation within five (5) business days fol:owing completion of any work it asserts is Extra Work. Subcontractor shall support its claim for additional compensation by providing Contractor wilh proof of its actual direct costs plus 10% for overhead and 57" for Profit, provided such amounts are approved by the Contractor and the owner. No claim for additional compensation will be considered unless written authorization was given by Contractor prior to execution of the Extra Work. For as long as the additional compensation is undetermined, it must be listed as a Potential Change Order on the Received by Investigations 08/23/2024 2024-09799 Subcontractoas Application for Payment. Failure to advise Contractor prior to execution of Extra Work or failure to submit a full and proper claim within frve (5) business days following completion of Extra Work or failure to lisl extra work as a Potential Change Order on Subcontractor's Application for Payment, shall constitute a waiver of Subcontractor's claim for additional compensation for such Extra Work.

Section 15. No payment or additional compensation of any kind shall be due to the Subcontractor for damages arising from hindrance or delay from any cause in the progress of the work, whether such delays were avoidable or unavoidable.

Section 16. ln lhe event the Subcontractor shall fail to perform in accordance with this Agreement or if the interest of the Contraclor becomes endangered by reason of the Subcontractor's failure to perform or if the Subcontractor shall become insolvent or if at any time the Subcontractor admits its inability to promptly satisfy any obligation arising from or affecting its ability to perform any requirement of this Agreement or if the Subcontractor should fail to carry forward and complete its Work as rapidly as the Contractor may judge necessary or its personnel refuse to work after having been requested by the Contractor to proceed with the Work or changes thereto or should fail to comply with instructions of the Contractor or with applicable portions of laws, or should olherwise be guilty of a breach of contract, then the Contractor without prejudice 10 any other right of remedy and after giving the Subcontractor forty- eight (48) hours writlen notice of the Contractor's intention to do so may, at the Contractor's option either a) terminate the employment of the Subcontractor or b) take control of the Subcontractor's Work in whole or in part including taking possession of all materials and instruments thereon and complete the work as the Contractor may think best. The Subcontraclor shall not be entitled to receive any further payments until the Work is completed and accepted. The Contractor shall be entitled to proceed and complete the Work as was required of the Subcontractor on the Contractor's own account or through another Subcontractor. lf the unpaid balance under this subcontracl shall exceed the expense of ftnishing the Work, including compensation for additional managerial and administrative services and all other expenses that may be necessary to complete this Agreement, the excess shall be paid to the Subcontractor. lf such expense is greater than such unpaid balance, the Subcontractor shall pay the difference to the Contractor.

Section 17. The Subcontractor shall warrant its Work and materials as free of defects in accordance with the Contract Documents and for at leasl twelve (12) months from the date of acceptance of the Work by the Contractor and Owner

Section 18. The Subcontractor is bound to the Contractor by the same terms as the Contractor is 10 the owner, with the exception of all payment provisions of this Agreement. ln case of conflicl between the provjsions between the owner and the Conlraclor and the provisions of this Agreement, the provision imposing the greater duty, obligation and responsibility on the Subcontractor shall govern in all respects.

Section 19. lf Owner, with or without cause, shall terminate or suspend the Work, or fail to pay Contractor any sum due and payable, Contractor may order Subcontractor to stop or suspend work hereunder and Contractor shall be liable to Subcontractor for any such stoppage or suspension only if and to the extent that owner shall be liable to Contractor therefore. Contractor will pay to Subcontractor the value of work that Subcontractor has completed before the work was stopped or suspended but only if and to the extent that Owner shall have paid Contractor for such work of Subcontractor. Contractor shall never under any circumstances or conditions are liable to Subcontractor to any greater extent that owner is liable to Contractor.

Section 20. This Agreement supersedes all previous representations or agreements, either written or oral. Modifications to this Agreement must be in writing and executed by both Contractor and Subcontractor and Subcontractor may not transfer or assign this agreement, in part or whole, without the written consent of the Contractor. The failure by Contractor at any time to enforce or to require strict compliance or performance by Subcontraclor of any of the provisions of this Agreement shall not constitute a waiver of such provisions, and shall not affect or impair in any way Contractofs rights at any time to enforce said provisions or to avail itself of such remedies as it may have for any breach thereof. lf any provision of this subcontract shall be invalid or uneniorceable to any extent, the remainder of this Agreement shall not be affected thereby, and shall be enforceable. Received by Investigations 08/23/2024 2024-09799 Section 21. The Subcontractor shall pay any and all costs and expenses incurred for the performance and enforcement of lhis Agreement by the Contractor. Any and all sums due the Subcontractor under this Agreement may be used by the Contractor in completing the performance of or enforcing the terms of this conlract, including all cost and expenses incurred in the performance thereof including construction costs, attorneys' fees and expenses.

Section 22. ln good faith, the parties shall endeavor to fully perform their respective contractual obligations and shall provide other reasonable notice and opportunity to cure any suspected or apparent lack of performance that might be considered a breach of the Agreement. ln the event of controversy, the Subcontract shall be considered made in the state in which the Work is located and shall be construed in accordance with and governed by the laws of that state. Prior to litigation of any claims or disputes arising out of or in any manner related to this Agreement or the performance or lack of performance hereunder by Contractor or Subcontractor shall be preceded by mediation. ln any event, Subcontractor hereby waives its rights to lrial by jury.

Section 23. The Subcontractor shall fully defend, protect, indemnify and hold harmless Contractor, its officers, employees, agents, representatives or successors and assigns (the lndemnified Parties) from and against any and all claims, demands, actions or causes of action, and any and all liabilities, costs and expenses (including but not limited to attorneys' fees and expenses, incurred of defense of any lndemnifred Party), damage or loss in connection therewith, which may be made or assened by SUbcontraclor, lls officers, employees, agents, representatives, sUccessors or assigns or any other third parly on account ol or sustained or alleged to have been sustained by, or arising out of or growing out of bodily injury including death, or loss of use or damage to or destruction of property, caused by, arising out ol sustained or alleged to have been sustained by, or in any way incidental to oI in connection with the Subcontractor's performance of the Work under this Contract or any change order, regardless of whether such claims, demands, actions, causes of action or liability are or alleged to have been caused or contributed to by the negligence, fault or strict liability of any lndemnified Party. lnsurance providing coverage for this lndemnity provision shall be provided by the Subcontractor. The Subcontractor's liability shall not be limited to the insurance coverage required of the Subcontractor.

Section 24. The Subcontractor will maintain for the duration of thas Agreement such insurance as will protect Subcontractor, the Contractor and the Owner at the limits and coverage required by Contractor or at greater limits and coverage as may be required by Owner. This insurance shall be from companies and in form and substance acceptable to Contractor. This insurance coverage shall be provided before commencing any Work and shall be for the life of this Agreement, which shall include all warranty periods.

Section 25. The Subcontractor agrees not to reveal any Confidential Information to any third party whatsoever except with the specific written prior authorization of Contractor and agrees to return upon request of Contractor any Confidential lnformation including documents, memoranda, notes and olher writings in hardcopy or electronic format identified by Contractor as Confidential lnformation. The Subcontractor further agrees and guarantees that il shall not directly or indirectly interfere with, circumvent, or attempt to circumvent, avoid, by-pass, or obviate Contractor's inlerest with any of Contractor's business relationships.

Seclion 26. By acceptance and execution of this Agreement, Subcontractor warrants and represents that it has and shall maintain for the duration of the Agreement all necessary Credentials to fully perform in accordance with the Scope of Work and as itemized as follows.

This subcontract Agreement has been executed by the parties to be effective on the date above.

vendor Credentials Required

- General Liabi:ity

Subcontractor shall provide Commercial General Liability insurance. Contractor, Owner and Engineer Received by Investigations 08/23/2024 2024-09799

(if necessary) shall be named each as an additional insured (utilizing endorsement CG20101 185) for all acts or omissions or any other liability of additional insured arising out of Subcontractor's work performed for additional insureds or subcontractor's use of premises, equipment and facililies of additional insureds. Policy shall be primary and non-contributory with resPect to other insurance coverages carried by contractor, owner and other indemnities, as required by contract, including waiver of subrogation. Policy includes premises & operations, independent contractors and products & completed operations in the amount of $1,000,000 per occurrence, S1,000,000 personal and advertising injury S2,000,000 products and completed operations aggregate;$2,000,000 aggregate and $5,000 medical expense.

- Aulomobile Liability

- Occupational License

- w-9

Conlractor: Subcontractori

Reicon, LLC lnnovative Plumbing LLC

)ate Date Received by Investigations 08/23/2024 2024-09799

REI a Reicon, LLC Powered by RedTeam PLANS AND SPECIFICATIONS

Project: 128OO1O - Hummus Republlc Suprise Dale:0A2U2024 Document: 1280010-011

The following contract documents are hereby incorporated by reference. These documents may be viewed online and downloaded in their entirety at: https://reiconus.flex.,edteam.com/planroom *Entet Prcject Number 1280010 when accessing the online planroom.

Name Date Author Scope

AO.O'COVER SHEET vBid Set 09129/2023 RElcon, LLC ungrnal

01.0 ' DEi\,{OLlTloN PLAN v31d Set 09t29/2023 RElcon, LLC Original

A1 O. FLOOR PLAN AND NOTESVBid SEt 09/29t2023 RElcon, LLC O.iginal

A],1 ' R€FLECTED CEILING PLAN SCHEDULES AND NOTES 09/2912023 RElcon, Original vBid Set

A1 ? . FINISH SCHEDIJLE AND vBid SCt 09/29/2023 RElcon, LLC Original 'ETAILS A2.0 EQUIPMENT PLAN AND SCH:,ULE vBid Set 09t29/2023 RElcon, LLC Original

A3.0 - LIFE SAFE fY PrAN AND FLoOR FINISH PLAN vBid 09/29t2023 RElcon, LLC Original Set

A3.0 RESIROOM ELARGED PLAN AND ELEVATIONS vBid 09129/2023 RElcon, LLC Original Set

,A4.0 INTERIOR ELEVATIONS vBid Set 09129/2023 RElcon, LLc Original

09t29/2023 RElcon, LLC Original A5.0 - COUNTER SECTTONS vBid Sel

A6.0 'ARCHifECTURE SPECIFICATIoNS vBid Set 09/29t2023 RElcon, LLC Original

0 ' ARCHITECTURE SPECIFICATIONS vBid Set 09/29/2023 RElcon, LLC 0riginal

09t29/2023 RElcon, LLC Original El,O ' ELECI POWER LIGHTING PLANS NOIES ANO DETAILS vBid SeI

:? O, PANEL SCHEDULES, RISEN AND DElAILS [number redacted] RE,con, LLC Original vBid Set 'IAGRAM

E3.0 - ELECIRiCAL SP:C FICATIONS vBid Set 09/2912023 RElcon, LLC 0riginal

l\,11.0 ' MECIIANlCAL PLAN AND NOTES vBid Set 09t29/2023 RElcon, LLC Original

09/29t2023 RElcon, LLC Original M2.0 - MECHANICAL RooF PIAN vBid Set

09/29/2023 RElcon, LLC Original SHEIT NO. ! - EXHAUST HOOD DRAWINGS vBid Sel

09/29/2023 RElcon, LLC Orjgina, SHEET NO. 2 - EXHAUST HOOD DRAW!N0SvBid Set

Original SH:aT NO. 3 EXHAUST HOOD DRAWINGS vBid Set 09t29/2023 RElcon, LLC

09t2912023 RElcon, LLC Original SHEET NO. 4 - EXHAUST HOOD tRAWINGS vBid Sel

Reicon, LLC: Subcontractor:

- - Received by Investigations 08/23/2024 2024-09799

;T Reicon, LLC Powered by RedTeam PLANS AND SPECI FICATIONS REl,:.,' .,r ,

Project 1280010 - Hummus Republic Suprise Dale: [number redacted]

Document: 1280010-011

Name Date Author Scope

P1.0 - plU[nBlNG WAIER AND WASTE PLANS vBid Set 09/2912023 RElcon, LLC Original

P2.0 - WATaR AND WASTE ISOMETRlCS vBid Set 09/29t2023 RElcon, LLC Orlginal

P3.0 - GAS PLAN AND ISOMETRIC vBid Set 09/29 /2023 RElcon, LLC Orig:nal

Rei con, LLC: Subcontra

- Received by Investigations 08/23/2024 2024-09799

REI a Reicon, LLC Powered by RedTeam CHANGE ORDER

Number: 1280010-011 Change: 01 Date: 03107 12024

Proiect: 1280010 - Hummus RePUblic SuPrise

Location: Hummus Repbulic SuPrise 13864 West Bell Road Unit 1 00, Suprise, AZ 85374

Cost Code: 220000 Scope: Original

Subiect: Plumbing

Billto: Reicon, LLC Subcontractor: lnnovative Plumbing LLC 8802 W Lane Ave 4233 E Villa Theresa Dr Glendale, Az 85305 Phoenix, Az 85032

Contact: Dale Eagy Manager: John Zimmerman 602-2?8-9094 (602) 290-6973 [email redacted] [email redacted]

Terms: When Paid % Relainage: 10

Schedule of Values

It€m Oescription Quanlity Price Per unit (S) mount (S)

6,800.00 GreaseTrap 1 6,800.00/l/s Original plans did not call for supply and install of 125 gallon grease trap. we will cut additional concr€te and excavate then set trap and install newly configured grease system pe. Plan. Walls have been installed prior 10 plumbing and Pit will need to be hand dug. Do to over sizing ol glease system we will need to supply and install extension riser as trap wili need to be set at over deplh oftlap itself. lncluded we will haul awaY excess spoils created by install of trap.

Total (S) 6,800.00

Original Value: 36,800.00

Previous Approved changes: 0.00

Value of This Change: 6,800.00

Revised Value: 43,600.00

"SUBCONTRACTOR" "CONTRACTOR' lnnovative Plumbing LLC Reicon, ILC BY BY John Zimmerman Received by Investigations 08/23/2024 2024-09799

TITLE TITL F. DATE:-= --_-- DATE Received by Investigations 08/23/2024 2024-09799

Ril a Reicon, LLC Powered by Redleam PLANS AND SPECIFICATIONS

Pro.iect 1280010 - Hummus Republic Suprise Date:[number redacted]

Document: 1280010-011

The following contract documents are hereby incorporated by reference. These documents may be viewed online and downloaded in their entirety at: hltps://reiconus.flex.redteam.com/planroom *Entet Project Numbet 1280010 when accessing the online plavoom.

Name Date Author Scope

AO.O - COVER SHEET vBid Sel 09/29/2023 RElcon, LLC Original

D'l.0 ' DEMOLITION PLAN vBid Set 09/29/2023 RElcon, LLC Original

A1.0 - FLOOR PLAN AND NOTES vBid Set 09/29/2023 RElcon, LLC 0r:ginal

A'I,1 - REFLECTED CEILING PLAN SCHEDULES AND NOTES 09/29/2023 RElcon, LLC Original v3id Set

A1.2 . FINISH SCHLDULT AND Dt IAILS vBid Set 09t29/2023 RElcon, LLC Original

42.0 - EQUIPMENT PLAN AND SCHEDUaE vBid Set 09/29/2023 REtcon, LLC Original

A3.0 LIFE SAFETY PLAN AND FLOOR FINISH PLAN vBid 09/29/2023 RElcon, LLC Origlna S€t

A3,O . RLS I ROOM LLARGLD PLAN AND ELEVATIONS vBid 09/2912023 RElcon, LLC Original Set

44.O - INTERIOR ELEVATIONS vBid S€t 09/29t2023 RElcon, LLC Original

As 0 - COUNTER SECTIONSvBid Set 09/29/2023 RElcon, LLC Original

A6.0 - ARCHITECTUR: SPECIFICATIoNS v8,d Sel 09t29/2023 RElcon, LLC Original

A7.0 - ARCH'TaCTLIRE SPECIFICATI0NS vBid Set 09/29/2023 RElcon, LLC Original

El,O - ELECI POWER LIGHTING PLANS NOIES ANO 09/29/2023 RElcon, LLC Original DETAILS v8id Set

E2,0. PANEL SCHEDULES, RISER DIAGRAM AND DEIAILS 09129/2023 RElcon, LLC Original vBid Set

E3.0 EIECTRICAL SPECIFICATIONS vBid Set 09/2912023 RElcon, LLC Original

M1.0 - IVECHANICAL PLAN AND NOfES vBid Set 09/29/2023 RElcon, LLC Original

[r2.0 - MECHANICAL ROOF PLAN vBid Set 09/29t2023 RElcon, LLC Original

SHEEI NO. 1 - iXt-IAUST HOOD DRAWINGS vBid Sei 09/29/2023 RElcon, LLC Original

SHEET NO, 2. IXHAUST HOOD ORAWINGS vBid SEl 09/29t2023 RElcon, LLC O.iginal

SHEET NO. 3 - EXHAUSf HOOD oRAWINGS vBid Sel 09/29/2023 RElcon, LLC O.iginal

SHTET NO 4 t X*AUS f HOOD DRAWINGS v8rd Ser 09/2912023 RElcon, LLC Original

Reicon, LLC: Subcontractor:

- - Received by Investigations 08/23/2024 2024-09799

aEt a Reicon, LLC Powered by RedTeam PLANS AND SPECI FICATIONS

Project: 1280010 - Hummus Republlc Suprise Datei [number redacted] Document 1280010-011

Name Date Author Scope

PI.0 - PLUMSING WATER AND WASIE PLANS vBid Set 09/29/2023 RElcon, LLC Original

P2.0 - WATER AND WASTE ISOMETRICS vB:d Set 09/2912023 RElcon, LLC Original

P3.0 GAS PLAN AND ISOMETR,C vBid Set 09/29/2023 RElcon, LLC Original

Reicon, LLC: Subcontractor:

- - Received by Investigations 08/23/2024 7124124. 1236 pM 2024-09799 none Mail - FW: Subcontract l2gOOlO-011 plumbing (1280010 _ Hummus Republic Supns€)

r*t Gmail Chery, Eagy <cheryt@mcdowelt_tax>

FW: Subcontract r2gOOl O -011 Plumbing (12SOOlO messaqe - Hummus Repubtic Suprise)

Dalo <[email redacted]> To: cheryt Eagy <cheryt@mcooiett tax> Wed, Jul24, 2024 at i2t36 pM

F.om: John Zimmerman <[email redacted]> Sent: Thursday, March 14, 2024 8:08 AM To: Dale <[email redacted]> Subject Re: Subcontiact 128OO1O,Oi1 plumbing (1280010, Hummus Repubtic Suprise)

Ihanks Dale

On Wed, Mar 13, 2024 at Sj3O pM Date <[email redacted]> wrote John

I have tried sending the @ntract several times and it keeps coming back.

I willtry again.

Fromi John 2tmmerman <[email redacted]> Sem: Wednesda, M ar ch 13,2024 2t1] pM To: hnovative ptumbing <[email redacted]> cc: Dale <[email redacted]>; Gabriella Copeland <[email redacted]> subje.t Re: Subcontract 128001G011 ptumbing (r2s00ro _ x;mus ilprUfi. irpiir"f

Hello,

I hope you're having a great dayt

I am following up as we have not received the signed contract orthe COI as of yet.

Can you pleas€ provide these items before th€ end ofthe week?

Thank you,

On Tue, Mar 5, 2024 at 7:11 AM tnnovative plumbing <[email redacted]> wmte:

cabby Please send them a COltoday.

Thank you

https://mail google cody'm6illul2l?ik=7ata163511&view=pt&search=a &permthid=thread-r:[number redacted]&simpt=msg-f:1E05490360147428839 1/5 Received by Investigations 08/23/2024 2024-09799

hrovdive Hrmbirg LL,iC ,t 8802 West Lane Ave Glendale, AZ 85305 (602)228-9094 Xk;r*irrlr {-lrrer: Tmn t Plumbing [email redacted]

t.rli.ai ai!ible Pltlit6aa

BILL TIO NVOICD7452 Humus Republic 13864 West Bell #100 Suprise, Az DAIE03/18/2024 IERIf,S Net 30

DUIDNTT, 04/1712021

PLI'MBM. Dale

DATE ACIIVIIY DfSiCTIPIION qTY NAIE AMOUNT Change (Her Original plans did not call for supply r 6,800.00 6,800.00 and install ofgrease trap. We will cut additional concrete and excavate then set trap and install newly configured grease system per p1an. Walls have been installed prior to plumbing and pit will need to bc hand dug. Do to over sizing ofgrease system we will need to supply and install extension riscr as tmp will need to be set at oyer dcpth oftlap itself. Included we will haul away excess spoils created by install oftrap

ACCEPTANCE OF WORK PERFORMED: Customer acknowledges satisfactory completion of the above described work and that the premises have been lcft in a satisfactory condition. I agree that the amount set fofih in the space marked "Total" is thc total price i have agrccd to. Services purchascd on this invoice are sold with a 30 day warranty unless otherwise stated by the Plumber on above invoice in wananty section and is only for workmanship. Equipment/pafts waranty are only manufacturer wa[anty. Innovative Plumbing LLC is not responsible for down time, Iabor shipping or damages existing or proglessive as a rcsult of parts/cquipment failure. Payment is due at timc of seryices rendercd unless stated otherwise in customer account.

TOTAL DUI $6,8oo.oo

We appreciate your business F.OC#327570 Received by Investigations 08/23/2024 2024-09799

Innovdive llmbirg LI-C 8802 West Lane Ave Glendale, AZ 85305 (602)228-9094 I Ilt n nlrre*irrn lnfo(@innovative.plumbing

t Plumbing i-lilrl a:aai .atarla airallirf a

BILLfi) nworcE7453 Humus Republic 13864 West Bell #100 Suprise, Az DATE 0l/18/2021 IERMS Net l5

DVEDATE,04t02t2024

PI,I'MBER. Dalc

DATE ACTIWIT DES(NPIION ATY RAIE AMOT'NT

nurbing Demo cxisting fixtures as outlined in 0.30 36,800.00 11,040.00 plans Cut concretc and trench to install underground waste sysrem per plan in plastic pipe, back frll and concrete to grade. Install waste and vent system with hot and cold water system including water hcatm ( not including insulation also install filter water lines ( Filtcr system supplied by others). Install gas system using steel pipe. Ansul supplied by others.

ACCEPTANCE OF WORK PERFORMED: Customer acknowledges satisfactory completion of the above described work and that the premises have been left in a satisfactory condition. I agree that the amount sct forth in the spacc marked "Total" is the total price i have agreed to. Services purchased on this invoice are sold with a 30 day warranty unless othendise stated by the Plumber on above invoice in waraanty section and is only for workmanship. Equipmenvpafts warranty are only manufacturer waranty. Innovative Plumbing LLC is not rcsponsible for down timc, labor shipping or damages existing or progressivc as a result of parts/equipment failure. Payment is due at time ofservices rendered unlcss stated otherwisc in customer account.

TOTAL DUE $11,040.00

We appreciate your business PIOC#327570 Received by Investigations 08/23/2024 2024-09799

CONDI TIONAL WAIVERAND RELEASE ON PROG RESS PAY ENT ST OF ARI NA (P ursuant to Arizona Revised Statutes S33-1009)

Project Hummus Republ i c Surprise Job No T2 0010

On receipt by the undersigned of a check from RE I CON, LLC (Maker of check) in the sum of$ 11,040 ' 00 pay able to Inn ovative P Iumbing (Amount of Check) (Payee or Payees of Check ) and when the check has been prop erly endorsed and has been paid by the bank on which it is drawn, this document becomes effective to rel ease any mechanic's lien, any state or fede ral statutory bond right, any private b ond right, any claim for payment and any rights under any similar ordinance, rule or statute related to claim or payment rlghts .fqr. perso ns in th e undersigned's position that the undersigned has o n the job of [ummus Hepu.Ol f c Su rprase (Owner) 16ga1.6 61 13864 tri Surprise Rd Uni I 100 Surpr.ise AZ 853'1 4 (Job Description) to the following extent. Th is release covers a proqress payment for all labor, services, equipment or materials furnished to the.J ob site or to REICOI'], "Ll,C ' (Person with whom undersigned contracted) throug 6 04/22/2a24 only and does not cover any retentton, pending modifications (Date) and changes or items furnished after that date. Before any recipient of thjs document relies on it, that person should verify evidence of payment to the undersigned.

The undersigned warrants that he either has already paid or will use the monies he receives from this progress payment to promptly pay in full all of his iaborers, subcontractors, materialmen and suppliers for all work, materials, equipment or services provided for or to the above referenced pro.lect up to the date of this waiver.

DATED on APril 22 ,20 lnnovative Plumbing LLC (Claimant name)

By: Cheryl L Eagy

Its: Accountant Address: 8802 W La ne Avenue Glendale M 85305 Phone: 602-4 -1604 Fax: Received by Investigations 08/23/2024 2024-09799 hnovdive HunHng LLC 8802 West Lane Ave Glendale, AZ 85305 (602)228-9094 Info(@innovative.plumbing

BIII IO Humus Republic nworcE7612 13864 West Bell #100 Suprise, Az DATE04/ll/2024 TERI|{S Ner lO

DUEDATS,0S/ t 1/2024

PLUMBM, Dale

DATE ASIIVIIY DDSCRIMON ory NAID AMOTJNT ntmDitrg Demo existing fixtures as outlined in 0.30 36,800.00 I 1,040.00 plans Cut concrete and tench to install underground waste sysiem per plan in plastic pipe, back fill ard concrete ro grade. Install waste and vent systcm with hot and cold water system including water heater ( not including insulation also install filter water lines ( Filter systern supplied by others). Install gas system using steel pipe. Ansul by others. Note 2nd invoice completion of in wall 1 0.00 0.00 plumbing

ACCEPTANCE OF WORK PERFORMED: Customer acknowledges satisfactory completion of the above described work and that the premises have been left in a satisfactory condition. I agree that the amount set forth in the space marked "Total" is the total price i have agreed to. Services furchased on this invoice are sold with a 30 day warranty unlcss otherwise statcd bv the Plumber on abor e invtrice in warranry seclion and is only lor workmanship. Equipment/parts warranty are only manufacturer warranty. Innovative Plumbing LLC is not responsible for down time, Iabor shipping or damages existilg or progressive as a result of parts/equipment failure. Payment is duc at time ofservices rendered unless stated otherwise in customer account,

TOTAL DUE $11,040.00

We appreciate your business ROC #327570 Received by Investigations 08/23/2024 7124124,2:57 PM non6 Mail - FW: Payments past due 2024-09799

ivt Gmait Cheryl Eagy <[email redacted]>

FW: Payments past due messages

lnnovative Plumbing <[email redacted]> wed, Jul 24 , 2024 al 12143 PM To: Cheryl Eagy <[email redacted]>

From: lohn Zimmerman <[email redacted]> Sent: Thursday, May 2,202412:29 PM To: chris Reigel <[email redacted]> cc: lnnovative Plumbing <[email redacted]> Subject: Payments past due

Hey Chris,

I just spoke to Dale and he was following up on the h^/o invoices dated 03-18-2024 for $11,400.00 and $6,800.00 that have not been paid.

Please advise when paymentwill be made

Thank you,

REICON, LLC

John Zimmerman Proiect Manager

602-2S0-6973

lnnovative Plumbing <[email redacted]> Wed Jul24, 2024 al2 55 PM To: Cheryl Eagy <[email redacted]>

From: lnnovative Plumbing Sent: Thursdav, MaV 9, 2024 11:13 PM To: John Zimmerman < [email redacted]>; Chris Reigel <[email redacted]> Subjecti RE: Payments past due

lnvoices 7453 and 7452 Were originally sent on l\,4arch 18 at your request we have signed and sent-waiverfor 7453 Could Ipleaseget ,pJit" on pry."nt as currentiy yori have been billed $28,880.00 with $17,840.00 past due and $11 ,040.00 soon to be past due. ""

Dale

https://mait.qoogte.com tmaitlul2t? k=7 at81635f'1&view=pt&search=all&permlh d=thread-i:fiD5490791224962991&simpl=msgJil [number redacted] 112 Received by Investigations 7124124,4102 PM 08/23/2024 none Mail- FW: Payments past due 2024-09799 lrrnovative Plumbing

{OL,olcd texl hidd-anl

lnnovativo Plumbing <[email redacted]> Wed , Jul 24 , 2024 at 2 50 PM To: Cheryl Eagy <[email redacted]>

lQ!.r.rd r.i llddcll

lnnovative Plumbing <[email redacted]> Wed, Jul 24 , 2024 at 3.32 PM Tor Cheryl Eagy <[email redacted]>

Fromr lnnovative Plumbing Sent: Wednesday, June 5, 2024 11:29 AM To: Chris Reigel <ch sr@reiconus_com> Subiect: RE: Payments past due

Can you please provide an update on this as soon as possible?

From: Chris Rei8el <[email redacted]> Sent: Wednesday, May 29,2024 7176 PM To: lnnovative Plumbing <[email redacted]> Subiect: Re: Payments past due

We had a change order go in for a bunch of items that changed on the permit set of drawings and this bank has made it miserable and it has held up payment. I have a call tomorrow moming to try and get it released and l'll update you afler

On Wed, May 29,2024 at 1:12 PM lnnovative Plumbing <[email redacted]> wrote:

Chris

Any update on paymenls the pre-lien from my vendor on this account is about to mature to lien. Could you please let me know

Get Outlook for iOS

lnnovative Plumbing <info@rnnovat ve.plumb ng> Wed, Ju|24,2024 at 3134 PIV To: Cheryl Eagy <[email redacted]>

From: lnnovafve Plumbing Sent: Tuesday, July 16,2024 10145 PM Toi [email redacted] Subject: RE: Payments past due

Chris https://mail.google.comlmaillul2l?ik=7a$1635f1&view=pt&search=all&permthid=thread-f1180U9O791224962991&simpl=msg-t180549079'[number redacted] 213 Received by Investigations 7124124, 4:02 pM 08/23/2024 Ittas now bgen a month since we ras:^:qor:e; r 2024-09799 b:e" ,ffi pavment bv Fridav the 19 dav of !.:ye August'zoza r *irr o" rii""il ""#ffil;T,"ll:j::'#;;""", i!!li'"o,"" flte a case with the Roc. r can no ronser.r r do not receive

"nd

Respecttully

Oale Eagy

lnnovative Plumbing LLC

From: [email redacted] <[email redacted]> Sent: Tuesday, June 18, 2024 8:08 AM To: lnnovative plumbinB <[email redacted]> Subject: RE: payments past due

Dale,

y: |3il",""#i:"t""[,[Xlf"l,,ll3.1l"** Mondav, l'll have a pavment out today and then another earry next week. rhese thinss "ne

(l,aalor%. "aa REIOON tlllt!ut i ttiirr

From: lnnovative plumbing <[email redacted]> Sent: Tuesday, June 18,2O24 8:06 AM To: Chris Reigel <[email redacted]> Subiect: Re: Payments past due

Chris

come Fdday the preen will mature to a full lean could you please provide me with a response to when we would receive payment thank you dale

G6t Outlook Jor iOS

Fromlnnovative plumbing <[email redacted]> Sent: Tuesday, June 18,2024 8tOS.47 AM To: Chris Reigel <[email redacted]> Subjed: Re: Payments past due

Chris

lnnorativg Plumbing <[email redacted]> To: Cheryl Eagy <[email redacted]> Wed, Jul24,2024 al 3:42 pM

iou.L.a ierr rdc..'

https://mail google com lmaillut2/?ik=7aru635f1&view=pt&search=all&permthid=thread-f 1ao54go7g122496299.,&stmpl=msg-f:1805 4go79122496299 3/3 7124124, 4:Og pM Received by Investigations none Mail - FW: payments past due 08/23/2024 lnnovative plumblng 2024-09799

lor otea rext nidrte.l

.[email redacted]> f11X11ur"ltuInling ro: uneryt Eagy <[email redacted]> Wed, Jul24, 2024 at ZSO pM

iot,or.i lerLnidd''4.

,lgl"^r1r.,"j,1lhol"n:[email redacted]> ro: uheryt Eagy <cheryt@mcdowe .tax> Wed, Jul24,2024 at3.32 pM

F.om: lnnovative plumbing Sent: Wednesda, Jun e E,2OZ4l7:2g AM To: Chris Reigel <[email redacted]> Subiect: RE: payments past due

Can you please provide an update on this as soon as possible?

From: Chrls Reigel <[email redacted]> Sent: Wednesday, May 29,2024I:t6 pM To: lnnovative plumbing <[email redacted]> Subiecti Re: payments past due

H;,i:lf ii?i'""""9i1ffi;:T",:'.1,""3?:;ilxff:i1?:,"",H1*:fi,il::i:;::.:#?* *d thjs bankhas made it miserab,eand ithas he,d up

On Wed, May 29,2024 at 1:i 2 pM lnnovative plumbing <[email redacted]> wrote Chris

Any update on payments the pre-lien from my vendor on this account is about to mature to lien. could you please let me know

Get Oullook for iOS

lnnovative_Plumbing <[email redacted]> ro: uneryt Eagy <[email redacted]> Wed, Jul 24, 2024 at 3:34 pM

From: lnnovative plumbing Senti Tuesday, July 16,202410.45 pM Tor [email redacted] Subiect: RE: payments past due

Chris https://mail google com lmaillul2l?ik=7a181635f1&view=pt&search:all&permthid=thread-t 1Bos4go791224962991&simpr=msg-f:18054 go7g122496299 7124124,4:09 pM Received by Investigations 08/23/2024 rtra5 ns\'!r' rsgn 3 rnonth since we,rast sryre; 2024-09799 payment by Friday the 19 dav bjen ve#I,Iiyr,il.:Jllil::n;;""", r can no ronser if r do not receive of Augusi zoza ,r r *liil"'r.i*i'" i"I:'iE'gi, u"no, ,nd fire a case wirh the Roc. r,?v.e

Respecttu y

Dale Eagy

lnnovative Plumbing LLC

From: [email redacted] <[email redacted]> Sent: Tuesday, June 18,2024 8..Oa AM To: innovative plumbing <[email redacted]> Subject: RE: payments past due

Dale,

y: 13il","U.:;"#[Xl?orlrll3 j-** Mondav, l'rl have a pavment out today and then another earry next week. rhese thinss "ne

(laalot%. Raa

REICON tI,t!0lli I lIStCI

FromJnnovative plumbing <[email redacted]> Sent: Tu esday, J u n e 18 , 2024 BiO6 AM To; Chris Reigel <[email redacted]> Subiect: Re: Payments past due

Chris

come Friday the preen will matu'e to a full lean. could you please provide me with a response to when we wourd receive payment thank you dale

Get Outlook for iOS

From: lnnovative plumbinS <[email redacted]> Sent: Tuesday, June 18,2024 8:OS:47 AM To; Chris Reigei <[email redacted]> Subjed; Re: Payments past due

Chris

lnnorativo Plumbing <[email redacted]> To: Cheryl Eagy <cheryt@mcdowe .tax> Wed, Jul 24, 2024 at 3:42 pM

;lru.i.l l-rr. r.lie.'

https://mail google com lmail/ul2l?ik=7 a181635f1&view=pt&search=a &permthid=thread-f :ft054907g1224962991&simpt=msg-f:1805 4go7g122496299 3t3 LEGAL RECEIVED 10/02/2024

10/2/2024

Arizona Registrar of Contractors 1700 W Washington Street Suite 105 Phoenix, AZ 85007

RE: Complaint No. 2024-09799

To whom it may concern,

The above referenced complaint is a part of an ongoing pursuit to recoup money from Hummus Republic and REIcon, LLC will be escalating our efforts of collection within the next 10 days. Innovative Plumbing’s complaint has some validity, but they should be putting their efforts into holding the right person(s) accountable.

Hummus Republic has paid REIcon for a small portion of plumbing which went to purchasing plumbing fixtures that Innovative plumbing did not have in their proposal, and was purchased before Innovative Plumbing presented their invoice. In addition, the change order that was billed was never executed because Hummus Republic never authorized the change order. Lastly, Innovative Plumbing did not complete the amount of work that they billed for. As of their last day onsite, no plumbing fixtures were installed, gas piping was left incomplete, the water heater was not onsite, the filters were not installed, and none of the equipment was hooked up. This is a significant amount of work that needed to be completed with no response when our superintendent called Innovative Plumbing repeatedly.

We did expect our billing to get approved and paid for as we stated to Innovative Plumbing via email, and we would have paid the $11,040.00 had that happened. While REIcon, LLC stands behind the fact that Innovative Plumbing at some level abandoned the project, we do feel that Hummus Republic owes money for work completed by Innovative Plumbing. Unfortunately, Hummus Republic terminated REIcon, LLC from 3 projects in a week, and it is our belief that they did this, so they did not have to pay REIcon, LLC and our subcontractors. REIcon, LLC is currently owed in excess of $400,000 on these projects and cannot afford to pay subcontractors monies we have not received.

The best solution for all parties is for Innovative Plumbing to work with REIcon, LLC making sure Hummus Republic is held accountable for their actions. Several of the subcontractors on this project have filed liens and have provided REIcon, LLC with the needed backup to strengthen our case. We hope that the ROC can help compel Innovative Plumbing to work with us in this matter.

Sincerely,

Chris Reigel (602) 909-2897 REIcon, LLC 10/11/24, 10:49 AM State of Arizona Mail - No Pay Citation 2024-09799 LEGAL RECEIVED 10/02/2024

Legal New Mail - AZROC <[email redacted]>

No Pay Citation 2024-09799 messages

Legal New Mail - AZROC <[email redacted]> Wed, Sep 18, 2024 at 1:00 PM Bcc: Chris Reigel <[email redacted]>, [email redacted]

Hello,

Attached please find an electronic courtesy copy of the No Pay Citation issued in this case. This document was also sent to your attention via US Mail. Please include [email redacted]. gov with all further correspondence regarding this matter.

Thank you,

Arizona Registrar of Contractors Legal Department 602-542-1525

Fill out AZ ROC’s survey to let us know how we’re doing and how we can better serve you!

20240918 No Pay Citation MAILED 2024-09799.pdf 8879K

[email redacted] <[email redacted]> Wed, Oct 2, 2024 at 10:00 PM To: Legal New Mail - AZROC <[email redacted]>

Please see attached.

Christopher M. Reigel

From: [email redacted] <[email redacted]> On Behalf Of Legal New Mail - AZROC Sent: Wednesday, September 18, 2024 1:00 PM

https://mail.google.com/mail/b/AEoRXRTQVYqmlXX-sYFcxt-Oa4MXPnU8LpdlxQpwLgSeD3dYLdx5/u/0/?ik=d3afebeda9&view=pt&search=all&permthi… 1/2 10/11/24, 10:49 AM State of Arizona Mail - No Pay Citation 2024-09799 LEGAL RECEIVED 10/02/2024 To: undisclosed-recipients: Subject: No Pay Citation 2024-09799

Hello,

Attached please find an electronic courtesy copy of the No Pay Citation issued in this case. This document was also sent to your attention via US Mail. Please include [email redacted] with all further correspondence regarding this matter.

Thank you,

Arizona Registrar of Contractors

Legal Department

602-542-1525

Fill out AZ ROC’s survey to let us know how we’re doing and how we can better serve you!

AZ ROC Case No 2024 09799.pdf 90K

https://mail.google.com/mail/b/AEoRXRTQVYqmlXX-sYFcxt-Oa4MXPnU8LpdlxQpwLgSeD3dYLdx5/u/0/?ik=d3afebeda9&view=pt&search=all&permthi… 2/2 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