ROC notice of hearing packet.pdf

2024A-13179-NPC-ROC · Registrar of Contractors · 2025-03-20

REGISTRAR OF CONTRACTORS OF THE STATE OF ARIZONA

Ground Up Construction AZ LLC, Case No. 2024-13179

COMPLAINANT, Docket No. 2024A-13179-NPC-ROC

v. NOTICE OF HEARING ON CONTESTED CASE Jada Homes Properties LLC License No. ROC 304993,

RESPONDENT.

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

HEARING INFORMATION The hearing is set for:

March 27, 2025 1:00 PM Velva Moses-Thompson 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 January 27, 2025. 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 February 24, 2025.

By: /s/ Lollie Martinez Lollie Martinez Legal Secretary Legal Department Arizona Registrar of Contractors

Copy mailed via USPS First Class mail February 24, 2025 to:

Respondent Jada Homes Properties LLC 21071 W Mountain Cove Pl Buckeye, AZ 85396

Complainant Ground Up Construction AZ LLC 5275 N Ironwood Dr. Apache Junction, AZ 85120

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. 2024-13179 /

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

December 5, 2024

Via U.S. Mail and Email

Complainant Ground Up Construction AZ LLC 5275 N Ironwood Dr. Apache Junction, AZ 85120

Via U.S. Mail and Email

Respondent Jada Homes Properties LLC 21071 W Mountain Cove Pl Buckeye, AZ 85396-1501

Re: Complaint No. 2024-13179

Dear Complainant and Respondent:

The Registrar received a complaint filed against Jada Homes Properties 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 December 12, 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 December 12, 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/ Doug Ulmer ________________ Doug Ulmer Legal Assistant Legal Department Registrar of Contractors

1700 W. Washington Street, Suite 105 · Phoenix AZ 85007-2812 602.542.1525 · Toll Free 877.692.9762 · roc.az.gov Lg100 4/21 Received 2/10/25, 1:34 PM State of Arizona Mail - Response to case 2024-13179-No Pay Citation 2/07/2025 ROC Legal

Legal New Mail - AZROC <[email redacted]>

Response to case 2024-13179-No Pay Citation message

jarrett gorman <[email redacted]> Fri, Feb 7, 2025 at 4:06 PM To: [email redacted], Allison Gorman <[email redacted]>

Dear Douglas Ulmer,

In response to the complaint regarding non-payment, I am writing to present a detailed timeline and the supporting evidence explaining why Ground Up Construction has not been paid in full.

1. Timeline Delays: The project timeline extended two months beyond the initial expectations. The original proposed schedule provided by Ground Up Construction on July 29, 2024, was as follows:

Week 1 (July 29 - August 2): Build walls for the main house. Week 2 (August 5 - 9): Sheathing on the main house, Casita walls, 2nd floor floor joists, and hanging beams. Week 3 (August 12 - 16): Floor joists installed for the 2nd floor, framing, and sheathing for the 2nd floor. Week 4 (August 19 - 24): Set and sheath trusses. Week 5 (August 26 - 30): Additional framing and detailing. Week 6 (September 2 - 6): Final work and clean-up.

Actual Schedule: The project extended from July 26, 2024 (lumber drop) to November 1, 2024. During this period, Ground Up's team, including Keo and laborers, was onsite. However, due to discrepancies in the interior dimensions, doorways, and significant issues with the roof fascia, soffit, and tails, Jada Homes Properties was instructed to cease work until these concerns were addressed.

2. Truss Order Issue: Per the contract, Ground Up Construction was responsible for the truss order. However, Keo submitted an incomplete order, resulting in incorrect trusses being delivered without prior consultation with the engineer. In Buckeye, trusses must be stamped by the engineer of record and submitted for city permits. The delivered trusses lacked the required radius detail and were incomplete. These trusses were not approved by the engineer. Our site supervisor worked with Keo, the truss company, and the engineer to have the correct trusses designed and engineered. Eventually, our supervisor took over management of the truss order. Please refer to the attached documents, including the Truss Comments from Engineer and Truss Discrepancies. Supporting emails and texts on this matter can be provided if necessary.

3. Inspection Report: On October 8, 2024, AZSE Group conducted an inspection with the Architect and issued a report detailing several deficiencies, which Ground Up Construction has addressed, except for one. The issue was the glulam beam in Bed 2, which required additional posts for proper support. Please see the attached General Inspection report for further details.

4. Second Homeowner Inspection: On November 5, 2024, the homeowner conducted a second inspection with the Architect and Engineer, uncovering significant workmanship defects. As a result, they terminated their contract with Jada Homes. Jada Homes had offered to return to the job site to correct the defects, but the homeowner declined, insisting that Jada Homes and their subcontractors stay off the property. The homeowner demanded a return of all funds previously paid to Jada Homes. Please see the attached Schield Termination Notice for more information.

5. ROC Complaint: The homeowner submitted a complaint to the ROC. However, the complaint was dismissed due to the termination notice dated November 5, 2024. Jada Homes suggested that Ground Up Construction offer repairs, but Ground Up declined, stating that the contract was with Jada Homes, not the homeowner. Please see the attached Schield ROC List of Deficits for the details.

6. Invoices and Payment Status: Ground Up Construction has issued five invoices to Jada Homes as follows:

Invoice #1326 for $64,493.10, paid on August 2, 2024 Invoice #1328 for $64,493.10, paid on August 21, 2024 Invoice #1331 for $20,000.00, paid on October 7, 2024 Invoice #1333 for $10,000.00, paid on October 25, 2024 Invoice #1334 for $34,493.10, which remains unpaid and work not completed correctly per deficiency list attached. 21,497.70 not invoiced - it is the 10% retention for straight edge and crippling https://mail.google.com/mail/b/AEoRXRTopPr9aIRHsej913AkxX4gvkbRJuGWRS7S37ATyaNXNAgl/u/0/?ik=d3afebeda9&view=pt&search=all&permthi… 1/3 Received 2/10/25, 1:34 PM State of Arizona Mail - Response to case 2024-13179-No Pay Citation 2/07/2025 ROC Jada Homes proposed a settlement offer of $28,000, which was declined by Ground Up Construction. This amount Legal is deemed fair by Jada Homes, given that framing was not fully completed, and the ROC complaint list remained unresolved. Please refer to the attached invoices for verification.

7. Financial Losses and Settlement Offer: Jada Homes has experienced a $250,000 loss in income due to delays and issues caused by Ground Up Construction. While Jada Homes values the fair treatment of subcontractors, there are concerns about the funds, as they belong to the homeowner. We are uncertain about the homeowner’s additional repair costs and anticipate the possibility of a civil suit due to the defective framing performed by Ground Up Construction.

8. Conversation email from Ground Up Construction:

The following comments are in reference to the email sent by Keo Jones on January 31, 2024, summarizing her phone conversation with Jarrett Gorman:

The email mentions “losses by Ground Up on the project as well which are in excess of $300,000, not including the final $54,000 owed.” Jada Homes is only associated with the remaining $54,000 owed under the contract between Jada Homes and Ground Up Construction. The $300,000 loss mentioned likely refers to Ground Up’s incurred losses due to potential issues with estimating or labor management, but Jada Homes is not involved in these.

The email also references "$54,000 in his account to pay Ground Up for their contract but that the owners had demanded he not pay Ground Up anything further, and he was simply holding the funds until he was sure he could pay the subcontractors, including Ground Up, without legal ramifications from the owner." At the time of the homeowner's contract termination with Jada Homes, Jarrett was under the impression that all subcontractors would be paid. Jada Homes paid other subcontractors for work completed correctly, leaving the remaining $28,000 offered to Ground Up Construction.

Additionally, the email mentions, "We discussed the fact that the project took far longer than the original 5-6 week timeframe in the contract. We agreed that with a 1-week lead time, the truss company had given us a 3-week lead time on a rush job, but it actually took 5 weeks to deliver the trusses after construction started." Jada Homes believes that the truss order was mismanaged by Keo Jones and submitted incorrectly. Had the trusses been engineered properly and ordered correctly from the beginning, significant delays could have been avoided.

Please refer to the attached Notes on Phone Call for further details.

9. Contract and Timeline: Attached is the signed bid and contract, which included an estimated timeline of 4-5 weeks. However, the actual timeline extended to 12 weeks before Jada Homes was terminated from the contract. There were no specific payment terms outlined in the contract.

10. Contract: Please see attached Ground up Construction Bid signed. Contract provided to show the agreement between Jada Homes and Ground Up. Timeline quoted 4-5 weeks. Timeline to when Jada Homes was Terminated is 12 weeks. No payment terms.

Please review the attached documents for a comprehensive understanding of the situation. If you have any questions or require further clarification, do not hesitate to reach out.

Best regards,

Jarrett Gorman Owner, Jada Homes

A 21071 W Mountain Cove Pl. Buckeye, Arizona 85396 M 623-210-9825 E [email redacted] W www.jadahomes.com Office hours: 7:30am-4pm M-T 7:30am-3pm F

https://mail.google.com/mail/b/AEoRXRTopPr9aIRHsej913AkxX4gvkbRJuGWRS7S37ATyaNXNAgl/u/0/?ik=d3afebeda9&view=pt&search=all&permthi… 2/3 Received 2/10/25, 1:34 PM State of Arizona Mail - Response to case 2024-13179-No Pay Citation 2/07/2025 ROC Legal

attachments

Truss comments from engineer.png 360K

Schield schedule.pdf 101K Schield Termination Notice Nov 5.pdf 237K Schield ROC list of deficits Complaint Form.pdf (1) (1).pdf 165K $34493.10 - Invoice #1334.pdf 45K $10000 - Invoice#1333.pdf 44K $20000 - Invoice #1331.pdf 44K $64493.10 - Invoice #1328.pdf 45K $64493.10 - Invoice #1326.pdf 45K General Inspection (1).pdf 1215K Truss Discrepancies (1).pdf 1062K

https://mail.google.com/mail/b/AEoRXRTopPr9aIRHsej913AkxX4gvkbRJuGWRS7S37ATyaNXNAgl/u/0/?ik=d3afebeda9&view=pt&search=all&permthi… 3/3 Received 2/07/2025 ROC Legal Ground Up Construction AZ LLC 5275 Ironwood Dr Apache Junction, AZ 85120 USA +[number redacted] [email redacted]

INVOICE BILL TO INVOICE 1333 Jada Homes Properties LLC DATE 10/24/2024 TERMS Due on receipt DUE DATE 10/24/2024

SERVICE DESCRIPTION QTY RATE AMOUNT

Shield residence - 1 10,000.00 10,000.00 Framing

Wire Transfer to : Ground Up Construction AZ LLC BALANCE DUE $10,000.00 5275 N Ironwood Dr, Apache Junction, AZ 85120 Wells Fargo Bank NA Routin Accou Wire Transfer to : Ground Up Construction AZ LLC 5275 N Ironwood Dr, Apache Junction, AZ 85120 Wells Fargo Bank NA Routing Accoun

Received 2/07/2025 ROC Legal Ground Up Construction AZ LLC 5275 Ironwood Dr Apache Junction, AZ 85120 USA +[number redacted] [email redacted]

INVOICE BILL TO INVOICE 1331 Jada Homes Properties LLC DATE 10/04/2024 TERMS Due on receipt DUE DATE 10/04/2024

SERVICE DESCRIPTION QTY RATE AMOUNT

Shield residence - draw on completion payment 1 20,000.00 20,000.00 Framing

Wire Transfer to : Ground Up Construction AZ LLC BALANCE DUE $20,000.00 5275 N Ironwood Dr, Apache Junction, AZ 85120 Wells Fargo Bank NA Routin Accou

Received 2/07/2025 ROC Legal Ground Up Construction AZ LLC 5275 Ironwood Dr Apache Junction, AZ 85120 USA +[number redacted] [email redacted]

INVOICE BILL TO INVOICE 1334 Jada Homes Properties LLC DATE 11/04/2024 TERMS Net 30 DUE DATE 12/04/2024

SERVICE DESCRIPTION QTY RATE AMOUNT

Shield residence - As per our contract framing has been completed and partial 1 34,493.10 34,493.10 Framing pickup has been done. This is with a 10% holdback still for inspections and pickup.

Wire Transfer to : Ground Up Construction AZ LLC BALANCE DUE $34,493.10 5275 N Ironwood Dr, Apache Junction, AZ 85120 Wells Fargo Bank NA Routin Accou The 10 at will be left after this.

Received 2/07/2025 ROC Legal Ground Up Construction AZ LLC 5275 Ironwood Dr Apache Junction, AZ 85120 USA +[number redacted] [email redacted]

INVOICE BILL TO INVOICE 1326 Jada Homes Properties LLC DATE 08/02/2024 TERMS Net 30 DUE DATE 08/02/2024

SERVICE DESCRIPTION QTY RATE AMOUNT

Sales 1 64,493.10 64,493.10

This is for the 30% upon material drop as agreed. Additional 30% will be due in a BALANCE DUE $64,493.10 week; an additional 30% upon completion of job. 10% hold back depending on inspections for framing and paid once passed.

Received 2/07/2025 ROC Legal Ground Up Construction AZ LLC 5275 Ironwood Dr Apache Junction, AZ 85120 USA +[number redacted] [email redacted]

INVOICE BILL TO INVOICE 1328 Jada Homes Properties LLC DATE 08/19/2024 TERMS Due on receipt DUE DATE 08/19/2024

SERVICE DESCRIPTION QTY RATE AMOUNT

Shield residence - 2nd 30% payment on payment 1 64,493.10 64,493.10 Framing

invoicing for 30% for 60% total billed after paid for this job. BALANCE DUE $64,493.10

Received 2/07/2025 ROC Legal

October 8, 2024

Mary & Kevin Schield 4247 Bay Shore Dr. Sturgeon Bay, WI 54235 Email: [email redacted]

RE: Field Inspection for Schield Residence located at 21638 W Buckhorn Bend-lot 210, Buckeye, AZ 85396.

My office performed a field inspection, per your request, for the above-mentioned project on October 2, 2024. Tanner from my office met onsite with Greg Woods (designer) along with Jaylon and Jarrett with Jada Homes (builder). We observed the following items that need to be addressed:

1) A corner of the stair landing is being supported by a temporary post and does not have adequate permanent support. The existing stair landing is to have (2) straps added to provide support from the upper beam per the following detail.

Stair landing is being held up by a temporary support post. Landing will need straps installed up to beam prior to post removal. Received 2/07/2025 ROC Legal

2) The plan calls out for all glulam beams to have a minimum of (2)2x6 posts supporting each end. The glulam beam over the window in Bed 2 currently only has one 2x6 each end. An additional post is to be installed to provide (2) 2x6 posts beneath each end of the beam.

Glulam beam per plan with (1)2x6 post each end. Framer to add one more 2x6 each end.

3) There are several Simpson STHD14 holdowns that were installed in the wrong location. At each of these locations a Simpson HTT-5 may be installed as a 1 to 1 substitute using ½”x10” all thread rod and Simpson SET-3G epoxy (special inspection required). At the time of this inspection, we observed some, not all, of these alternative holdowns, see separate epoxy inspection report dated 10-8-24. Received 2/07/2025 ROC Legal

4) The APA Portal Frame Detail was called out on the shear walls for Guest Bed 2 in order to meet the required strength for wind pressure resistance. This detail required the window headers to be extended across the top of the walls. The headers were stopped at the edge of the wall and therefore unable to accommodate the required detail. The following shear wall can be added as an alternate along with Simpson HTT-5 holdowns, see item #3 above for installation requirements. Received 2/07/2025 ROC Legal

5) There are several places through out the project where the wood framed walls do not align with the concrete stem walls. Wood walls with exposed concrete stem need to be furred out to be flush with edge of stem to allow proper waterproofing installation. Wood framing that extends more than 3” past concrete stem must have additional stem added per detail shown below. Areas less than 3” may use dry pack with primer down to top of footing.

CONCRETE SUBCONTRACTOR INCORRECTLY POURED SLAB AND DID NOT POUR UNDER THE POPOUT AS SHOWN ON THE PLANS. WOOD FRAMING IS COMPLETELY EXPOSED ON THE BOTTOM. CONCRETE MUST BE ADDED PER DETAIL BELOW.

NOTE: SPECIAL INSPECTION REQUIRED FOR EPOXY Received 2/07/2025 ROC Legal

6) The TJI floor joists for the upper-level patio have been installed near the same height as the interior joists. This creates a waterproofing issue as there is no step to stop water from entering the interior. It is recommended that the TJI floor joists for the patio area be removed and lowered per plan to create the 3” drop at the door threshold to allow for drainage and flooring material thickness (Saltillo Tile). Alternative: If the homeowner agrees, an alternate would be to build up the raised floor on the interior hallway. This would result in a ceiling height reduction of 2.625” and increase the step heights from 6” to 7.3”. This could be achieved by installing 2x4 sleepers on the existing floor and 1 1/8” floor sheathing over the top.

7) The header in the master walk in closet was called out as (2) 2x12. A (2) 2x10 header was installed in its place. An analysis has been performed on the new header size and it has been determined that the (2) 2x10 header may remain. Received 2/07/2025 ROC Legal

8)

9) Received 2/07/2025 ROC Legal

10) The upper floor was framed with floor sheathing that was thinner than the plan called for. The plans specified the use of 1-1/8” T&G Advantech Subfloor, which can be found on Framing Sheet A5.1 noted as #18 in the Key Note Section. The existing sheathing is okay structurally but may cause more vibration and noise. It is recommended to have ½” min. sheathing installed over top of existing plywood to achieve the desired rigidity. The second layer is to be installed using recommendations provided by the Engineered Wood Association and the APA which recommends that adhesive NOT be used between plywood layers. Additional information can be found on apawood.org, Form R340. Advantech recommendations for the installation of the 2nd layer are as follows: a. First layer must be dry prior to laying the second layer. b. Place a layer of 15-lb felt on top of the subflooring prior to installing second layer. c. Adhesives should not be used to fasten the two layers together. d. Install second layer on top of the first layer inside of the wall studs. A minimum of ¼” gap is required between the second layer and the wall perimeter. e. All underlayment (second layer) joints should be offset from the subfloor (first layer) joints a minimum of 4-inches. f. Stagger end joints of adjacent panel runs by at least one joist space. g. Provide 1/8” expansion gap at 4-foot ends. T&G joint is self-spacing. h. Fasten top layer using wood screws of sufficient length to just penetrate the thickness of the subfloor. Do not screw second layer to floor joists. Received 2/07/2025 ROC Legal

11)

12) The wood framing in the mechanical closet does not allign with the concrete stem. It is recommended that the wood framing be moved to align with the concrete stem. Alternatively; concrete stem is to be added with rebar hooks drilled and epoxied into existing concrete stem with Simpson SET, see detail above on item #5. Received 2/07/2025 ROC Legal

If you should have any further questions concerning this matter, please do not hesitate to call.

Sincerely, ARIZONA STRUCTURAL ENGINEERING GROUP, LLC

ELECTRONICALLY SIGNED AND SEALED 10/8/2024

Jeremy Walterscheid, P.E. Received 2/07/2025 ROC Legal

Licensed Complaint Form Departmental Use Only For Current or Suspended Licensees

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

Mary Schield Mailing Address (Enter jobsite in Contract/Project section) City State Zip

21079 W Sage Hill Rd Buckeye Arizona 85396 Phone Number Email

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

Street Address of Attorney City State Zip

Phone Number of Attorney Email of Attorney

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

Jada Homes Properties LLC ROC 304993 Street Address City State Zip

21071 W Mountain Cove Pl Buckeye AZ 85396 Phone Number Email

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

Jarrett Gorman Contract/Project Information Contract Date Contract Amount Amount Paid

March 19, 2024 $2,836,491.24 $630,000.00 Date Work Started Date Work Stopped Date Work Was Completed

April 2, 2024 November 5, 2024 Close of Escrow (New Home) Move-In Date (New-Home)

Jobsite Street Address City State Zip

21638 W Buckhorn Bend Buckeye AZ 85396 Name of Construction Site Owner Construction Site Name (if applicable)

Mary C and Kevin L Schield Phone Number of Construction Site Owner Email of Construction Site Owner

[number redacted] [email redacted] This complaint is for Poor Work I have contacted the contractor by Have you filed a complaint in court? No

RCC099 12/05/18 Page 1 of 4 Received 2/07/2025 ROC Legal

Licensed Complaint Form Departmental Use Only For Current or Suspended Licensees

Has any work been corrected? No

The contract was Written All change orders were Written This project was Residential This project involved New Home

A building permit was obtained by Property Owner BLDR-23-2082 Buckeye List and briefly describe each complaint item (Please do not write "see attached" or use additional pages unless necessary to further describe issues or list more complaint items) (limited to 100 characters per line)

My husband and I arrived to Arizona from Wisconsin on 10/31/24. On 11/5/24 we met for several hours at the job site with our architect and structural engineer (still waiting for his field inspection report). Later that day we terminated our contract with Jada Homes. We would appreciate any guidance /help you can give. Thanks. Mary Allegations Listed on Complaint:

Per architect, 11/5/24 inspection shows not all overhanging concrete stem walls corrected from 10/2/24 inspection.

Per architect, concrete stem correction from 10/2/24 inspection done incorrectly resulting in frame/concrete gap.

Per architect, 10/2/24 instructions to correct misplaced windows/pot shelf not correctly followed.

Per architect, 10/2/24 instruction to remove wood blocks at gables & replace with planned outlookers was ignored.

Per architect, inspection revealed rough sawn wood gable end facias miters have open gaps etc.

Per architect, entry arch framing considerably hangs over stem wall.

Per architect, both sides of arched entry wall have no concrete below them.

Per architect, numerous areas have sheathing starting higher than the bottom of the plate.

Per architect, all framed walls have gaps at tops of wall between rafter tail framing.

Per architect, main entry door is framed as a rectangle when plan and door schedule show arched.

Per architect, due to failed correction, left side of main entry door has stem wall chipped away exposing hold down.

Per architect, right side of main entry door framing hangs over concrete by 3”.

RCC099 12/05/18 Page 2 of 4 Received 2/07/2025 ROC Legal

Licensed Complaint Form Departmental Use Only For Current or Suspended Licensees

Per architect, concrete stem across the entry door considerably out of plumb.

Per architect, guest house gable end trusses installed flush with wall sheathing below the top plate.

Per architect, guest house main living room sliding glass door opening not centered.

Per architect, roof gable framing/chimney framing for nook fireplace stopped short.

Per architect, on opposite side of above there is a gap where T&G boards were cut short of sheathing.

Per architect, guest house timber rafters tails & gable facia board are framed incorrectly.

Per architect, at several locations gable rake framing done incorrectly, roof sheathing not nailed to truss.

Per architect, added wood blocks not per plan, inconsistent spacing, do not meet structural integrity.

Per architect, guest house wall sheathing held back from mechanical closet door framing.

Per architect, vents have not been cut/framed in for high-low ventilation as specified by Jada Homes.

Per architect, guest house chimney left side roof sheathing gap between vertical wall sheathing.

Per architect, guest house right side of chimney, gable fascia timber installed incorrectly.

Per architect, hallway closet not centered as per plan.

Per architect, the two niches on either side of the great room fireplace are inconsistent.

Per architect, archways throughout the home have inconsistent heights.

Per architect, three niches at entry way have inconsistent heights.

Per architect, second floor sitting area header for arched opening too low thus circular ceiling cannot be achieved.

Per architect, missing cricket behind the chimney above the great room.

Per architect, roof framing behind smaller turret not completed.

RCC099 12/05/18 Page 3 of 4 Received 2/07/2025 ROC Legal

Licensed Complaint Form Departmental Use Only For Current or Suspended Licensees

Per architect, sizable gaps throughout between roof sheathing sheets and between sheets and T&G.

Per architect, roof gable ends not properly supported by outlooker framing members.

Per architect, numerous sheets of roof sheathing missing field nails and edges gave considerably when stepped on.

Per architect, roof cricket behind circular nook has not been installed per plan.

Per architect, small cricket required adjacent to upper balcony fireplace.

Per architect, door opening at second floor bedroom is missing entirely.

Per architect, cricket missing behind front courtyard chimney.

Per architect, circular roof at second floor sitting room blocked excessively.

Block perimeter wall was installed April/May 2024 and was not placed correctly on the lot.

Interior door company field inspection showed many, many door openings to be framed wrong.

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

Mary Schield \complainant1\ \complainantd1\

RCC099 12/05/18 Page 4 of 4 Received 2/07/2025 ROC Legal

21071 West Mountain Cove Place, Buckeye, AZ 85396 • 623-210-9825

Schedule - List - Schield Build

Show ID # Title Complete Phase Duration Start End Assignees Accepted Pending Declined Comments RFIs Predecessors client

Schield - lumber drop 100 % -- 1 day Jul 26, 2024 Jul 26, 2024 -- 0 0 0 0 0 Yes

Schield final frame layout 100 % -- 1 day Jul 26, 2024 Jul 26, 2024 -- 0 0 0 0 0 Yes Saturday

Schield - frame 100 % -- 1 day Jul 29, 2024 Jul 29, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Jul 30, 2024 Jul 30, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Jul 31, 2024 Jul 31, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Aug 1, 2024 Aug 1, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Aug 2, 2024 Aug 2, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Aug 5, 2024 Aug 5, 2024 -- 0 0 0 0 0 Yes

Schield figure out missing 100 % -- 1 day Aug 5, 2024 Aug 5, 2024 -- 0 0 0 0 0 Yes dims for framer

Schield - frame 100 % -- 1 day Aug 6, 2024 Aug 6, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Aug 7, 2024 Aug 7, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Aug 8, 2024 Aug 8, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Aug 9, 2024 Aug 9, 2024 -- 0 0 0 0 0 Yes

Schield - floor joists 100 % -- 1 day Aug 12, 2024 Aug 12, 2024 -- 0 0 0 0 0 Yes delivered

Schield - frame 100 % -- 1 day Aug 12, 2024 Aug 12, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Aug 13, 2024 Aug 13, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Aug 14, 2024 Aug 14, 2024 -- 0 0 0 0 0 Yes

Schield dumpster swap 100 % -- 1 day Aug 14, 2024 Aug 14, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Aug 15, 2024 Aug 15, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Aug 16, 2024 Aug 16, 2024 -- 0 0 0 0 0 Yes

Schield - truss delivery 100 % -- 1 day Aug 16, 2024 Aug 16, 2024 -- 0 0 0 0 0 Yes Received 2/07/2025 ROC Legal

Schield - frame 100 % -- 1 day Aug 19, 2024 Aug 19, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Aug 20, 2024 Aug 20, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Aug 21, 2024 Aug 21, 2024 -- 0 0 0 0 0 Yes

Schield. 8am. Frame 100 % -- 1 day Aug 21, 2024 Aug 21, 2024 -- 0 0 0 0 0 Yes meeting.

Schield - frame 100 % -- 1 day Aug 22, 2024 Aug 22, 2024 -- 0 0 0 0 0 Yes

Schield set trusses 100 % -- 1 day Aug 22, 2024 Aug 22, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Aug 23, 2024 Aug 23, 2024 -- 0 0 0 0 0 Yes

Schield - frame crew 100 % -- 1 day Aug 23, 2024 Aug 23, 2024 -- 0 0 0 0 0 Yes Saturday

Schield - frame 100 % -- 1 day Aug 26, 2024 Aug 26, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Aug 27, 2024 Aug 27, 2024 -- 0 0 0 0 0 Yes

Schield - second floor 100 % -- 1 day Aug 28, 2024 Aug 28, 2024 -- 0 0 0 0 0 Yes framing

Schield - second floor 100 % -- 1 day Aug 29, 2024 Aug 29, 2024 -- 0 0 0 0 0 Yes framing

Schield - frame 100 % -- 1 day Aug 30, 2024 Aug 30, 2024 -- 0 0 0 0 0 Yes

Schield - order roof tile 0% -- 1 day Aug 30, 2024 Aug 30, 2024 -- 0 0 0 0 0 Yes

Schield - schedule 0% -- 1 day Aug 30, 2024 Aug 30, 2024 -- 0 0 0 0 0 Yes penetrations and roughs

Schield - frame 100 % -- 1 day Sep 2, 2024 Sep 2, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Sep 3, 2024 Sep 3, 2024 -- 0 0 0 0 0 Yes

Schield - Yvonne check on 100 % -- 1 day Sep 3, 2024 Sep 3, 2024 -- 0 0 0 0 0 Yes truss approvals at city

Schield - frame 100 % -- 1 day Sep 4, 2024 Sep 4, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Sep 5, 2024 Sep 5, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Sep 6, 2024 Sep 6, 2024 -- 0 0 0 0 0 Yes

Schield crane on site 100 % -- 1 day Sep 9, 2024 Sep 9, 2024 -- 0 0 0 0 0 Yes

Schield - Dumpster swap 100 % -- 1 day Sep 11, 2024 Sep 11, 2024 -- 0 0 0 0 0 Yes

Schield framing 100 % -- 1 day Sep 11, 2024 Sep 11, 2024 -- 0 0 0 0 0 Yes

Schield frame 100 % -- 1 day Sep 12, 2024 Sep 12, 2024 -- 0 0 0 0 0 Yes

Schield frame 100 % -- 1 day Sep 13, 2024 Sep 13, 2024 -- 0 0 0 0 0 Yes Received 2/07/2025 ROC Legal

Schield Sat/Sun framing 100 % -- 1 day Sep 13, 2024 Sep 13, 2024 -- 0 0 0 0 0 Yes

Schield frame 100 % -- 1 day Sep 19, 2024 Sep 19, 2024 -- 0 0 0 0 0 Yes

Schield frame 100 % -- 1 day Sep 20, 2024 Sep 20, 2024 -- 0 0 0 0 0 Yes

Schield schedule Jeremy 100 % -- 1 day Sep 20, 2024 Sep 20, 2024 -- 0 0 0 0 0 Yes walkthrough

Schield- AZ Fireplaces Appt 100 % -- 1 day Sep 23, 2024 Sep 23, 2024 -- 0 0 0 0 0 Yes

Schield- frame 100 % -- 1 day Sep 23, 2024 Sep 23, 2024 -- 0 0 0 0 0 Yes

Schield - am - walk framing 100 % -- 1 day Sep 24, 2024 Sep 24, 2024 -- 0 0 0 0 0 Yes

Schield- frame 100 % -- 1 day Sep 24, 2024 Sep 24, 2024 -- 0 0 0 0 0 Yes

Schield - Dumpster swap 100 % -- 1 day Sep 25, 2024 Sep 25, 2024 -- 0 0 0 0 0 Yes

Schield am site meeting 100 % -- 1 day Sep 25, 2024 Sep 25, 2024 -- 0 0 0 0 0 Yes

Schield- frame 100 % -- 1 day Sep 25, 2024 Sep 25, 2024 -- 0 0 0 0 0 Yes

Schield- frame 100 % -- 1 day Sep 26, 2024 Sep 26, 2024 -- 0 0 0 0 0 Yes

Schield - schedule frame 0% -- 1 day Sep 27, 2024 Sep 27, 2024 -- 0 0 0 0 0 Yes inspection

Schield- frame 100 % -- 1 day Sep 27, 2024 Sep 27, 2024 -- 0 0 0 0 0 Yes

Schield. Frame. 100 % -- 1 day Sep 30, 2024 Sep 30, 2024 -- 0 0 0 0 0 Yes

Schield - check on air tub 100 % -- 1 day Oct 1, 2024 Oct 1, 2024 -- 0 0 0 0 0 Yes application

Schield - frame 100 % -- 1 day Oct 1, 2024 Oct 1, 2024 -- 0 0 0 0 0 Yes

Schield - 11:am structural 100 % -- 1 day Oct 2, 2024 Oct 2, 2024 -- 0 0 0 0 0 Yes engineering inspection

Schield - frame 100 % -- 1 day Oct 2, 2024 Oct 2, 2024 -- 0 0 0 0 0 Yes

Schield. 11:am Epoxy 100 % -- 1 day Oct 2, 2024 Oct 2, 2024 -- 0 0 0 0 0 Yes inspection

Schield. Take and load 100 % -- 1 day Oct 7, 2024 Oct 7, 2024 -- 0 0 0 0 0 Yes frame pics in BT

Schield. Frame 100 % -- 1 day Oct 7, 2024 Oct 7, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Oct 8, 2024 Oct 8, 2024 -- 0 0 0 0 0 Yes

Schield - frame 100 % -- 1 day Oct 9, 2024 Oct 9, 2024 -- 0 0 0 0 0 Yes

Schield - organize site - 100 % -- 1 day Oct 9, 2024 Oct 9, 2024 -- 0 0 0 0 0 Yes deliver color board

Schield- Rough-In delivery 100 % -- 1 day Oct 9, 2024 Oct 9, 2024 -- 0 0 0 0 0 Yes Received 2/07/2025 ROC Legal Schield - schedule stain for 100 % -- 1 day Oct 10, 2024 Oct 10, 2024 -- 0 0 0 0 0 Yes rough sawn wood

Schield- 10:00 HOA 100 % -- 1 day Oct 10, 2024 Oct 10, 2024 -- 0 0 0 0 0 Yes Meeting

Schield - detail frame work 100 % -- 1 day Oct 11, 2024 Oct 11, 2024 -- 0 0 0 0 0 Yes

Schield - check all corbel 100 % -- 1 day Oct 14, 2024 Oct 14, 2024 -- 0 0 0 0 0 Yes spacing

Schield - detail frame work 100 % -- 1 day Oct 14, 2024 Oct 14, 2024 -- 0 0 0 0 0 Yes

Schield - schedule roof 100 % -- 1 day Oct 14, 2024 Oct 14, 2024 -- 0 0 0 0 0 Yes penetrations

Schield - schedule rough 100 % -- 1 day Oct 14, 2024 Oct 14, 2024 -- 0 0 0 0 0 Yes ins

Schield - detail frame work 100 % -- 1 day Oct 15, 2024 Oct 15, 2024 -- 0 0 0 0 0 Yes

Schield - detail frame work 100 % -- 1 day Oct 16, 2024 Oct 16, 2024 -- 0 0 0 0 0 Yes

Schield 8 cabinet meeting 100 % -- 1 day Oct 16, 2024 Oct 16, 2024 -- 0 0 0 0 0 Yes for layout

Schield - detail frame work 100 % -- 1 day Oct 17, 2024 Oct 17, 2024 -- 0 0 0 0 0 Yes

Schield - schedule roof 100 % -- 1 day Oct 17, 2024 Oct 17, 2024 -- 0 0 0 0 0 Yes sheathing inspection

Schield - detail frame work 100 % -- 1 day Oct 18, 2024 Oct 18, 2024 -- 0 0 0 0 0 Yes

Schield - roof sheething 100 % -- 1 day Oct 18, 2024 Oct 18, 2024 -- 0 0 0 0 0 Yes inspection

Schield - plumbing rough 100 % -- 1 day Oct 21, 2024 Oct 21, 2024 -- 0 0 0 0 0 Yes

Schield - walk site - check 100 % -- 1 day Oct 21, 2024 Oct 21, 2024 -- 0 0 0 0 0 Yes measurements

Schield frame detail 100 % -- 1 day Oct 21, 2024 Oct 21, 2024 -- 0 0 0 0 0 Yes

Schield - clean and 100 % -- 1 day Oct 22, 2024 Oct 22, 2024 -- 0 0 0 0 0 Yes organize site

Schield - plumbing rough 100 % -- 1 day Oct 22, 2024 Oct 22, 2024 -- 0 0 0 0 0 Yes

Schield. Fireplace instal 100 % -- 1 day Oct 22, 2024 Oct 22, 2024 -- 0 0 0 0 0 Yes

Schield - plumbing rough 100 % -- 1 day Oct 23, 2024 Oct 23, 2024 -- 0 0 0 0 0 Yes

Schield. Clean site. 100 % -- 1 day Oct 23, 2024 Oct 23, 2024 -- 0 0 0 0 0 Yes

Schield. Fireplace instal 100 % -- 1 day Oct 23, 2024 Oct 23, 2024 -- 0 0 0 0 0 Yes

Shield - Dumpster swap 100 % -- 1 day Oct 23, 2024 Oct 23, 2024 -- 0 0 0 0 0 Yes

Schield. Schedule Truss and 100 % -- 1 day Oct 24, 2024 Oct 24, 2024 -- 0 0 0 0 0 Yes nail inspection Received 2/07/2025 ROC Legal Schield - schedule epoxy 100 % -- 1 day Oct 25, 2024 Oct 25, 2024 -- 0 0 0 0 0 Yes inspection

Schield. Truss and nailing 100 100 % -- 1 day Oct 25, 2024 Oct 25, 2024 -- 0 0 0 0 0 Yes inspection

Schield - 10am - epoxy 101 100 % -- 1 day Oct 28, 2024 Oct 28, 2024 -- 0 0 0 0 0 Yes inspection

Schield. Take and load 102 100 % -- 1 day Nov 1, 2024 Nov 1, 2024 -- 0 0 0 0 0 Yes frame pics in BT

103 Schields in town 100 % -- 1 day Nov 1, 2024 Nov 1, 2024 -- 0 0 0 0 0 Yes Received 2/5/25, 1:55 PM Gmail - Termination Notice 2/07/2025 ROC Legal

jarrett gorman <[email redacted]>

Termination Notice messages

Mary Schield <[email redacted]> Tue, Nov 5, 2024 at 6:13 PM To: jarrett gorman <[email redacted]>, allison gorman <[email redacted]>

Jarrett and Allison -

We spent several hours today with Greg Woods and Jeremy Walterscheid while they performed a second thorough inspection at our Buckhorn Bend property. Not surprisingly, today’s inspection resulted in the discovery of major defects in workmanship performed by Jada Homes subcontractors while under the supervision of Jada Homes employees.

Aside from Greg’s and Jeremy’s inspection, two employees from Door Works arrived on the property for a scheduled meeting with Jaylon who was a no show. The Door Works employees came up with an unusually long list of framing mistakes while they performed an onsite measurement of door openings.

We have a sizable investment in our lot as well as in architectural and design fees. It has been very stressful seeing this project continually mismanaged by Jada Homes.

Given the unresolved issues going back as far as April, we have concluded that you, your employees and subcontractors are unwilling or incapable, or both, of resolving the costly serious flaws your inattention, poor management and lack of professionalism has caused. Therefore, effective immediately, we are terminating our contract with Jada Homes.

We are demanding that our $56,910.57 checking account balance be returned to us immediately. This is to be sent to 21079 W Sage Hill Road, Buckeye, AZ 85396.

Kevin L. Schield Mary C. Schield

https://mail.google.com/mail/u/1/?ik=ebfea721a0&view=pt&search=all&permthid=thread-f:[number redacted]&simpl=msg-f:[number redacted]&simpl=msg-a:r1521421653694399488&simpl=msg-a:r75214409… 1/3 Received 2/5/25, 1:55 PM Gmail - Termination Notice 2/07/2025 ROC Legal jarrett gorman <[email redacted]> Thu, Nov 7, 2024 at 4:04 PM To: Rina Rai <[email redacted]>

Jarrett Gorman Owner, Jada Homes

A 21071 W Mountain Cove Pl. Buckeye, Arizona 85396 M 623-210-9825 E [email redacted] W www.jadahomes.com Office hours: 7:30am-4pm M-T 7:30am-3pm F

[Quoted text hidden]

jarrett gorman <[email redacted]> Fri, Nov 8, 2024 at 5:00 PM To: Mary Schield <[email redacted]>

Dear Mary and Kevin, Thank you for your message and for sharing your concerns. I want to acknowledge the frustration and stress you are experiencing with the project, and I sincerely regret that it has reached this point. It is always our intention to provide quality workmanship and effective project management, and I deeply regret that we have fallen short in your opinion. Regarding the issues identified during the recent inspections by Greg Woods and Jeremy Walterscheid, as well as the concerns raised by Door Works, I would appreciate the opportunity to discuss these in detail. While we understand your decision to https://mail.google.com/mail/u/1/?ik=ebfea721a0&view=pt&search=all&permthid=thread-f:[number redacted]&simpl=msg-f:[number redacted]&simpl=msg-a:r1521421653694399488&simpl=msg-a:r75214409… 2/3 Received 2/5/25, 1:55 PM Gmail - Termination Notice 2/07/2025 ROC Legal terminate the contract, we want to ensure that we have a clear understanding of the defects you’ve referenced and review the findings with you, if possible, to avoid any further misunderstandings. In regard to your request for the return of the $56,910.57, we are taking this matter seriously. We will initiate the process for a review of the account balance and return of the funds. Please allow us some time to ensure the proper steps are taken. We will send the refund to the address you’ve provided at 21079 W Sage Hill Road, Buckeye, AZ 85396, and notify you once it has been processed. I truly regret that the project did not meet your expectations, and I wish you the best moving forward. Should you have any further questions or concerns, please feel free to reach out. Best regards,

Jarrett Gorman Owner, Jada Homes

A 21071 W Mountain Cove Pl. Buckeye, Arizona 85396 M 623-210-9825 E [email redacted] W www.jadahomes.com Office hours: 7:30am-4pm M-T 7:30am-3pm F

[Quoted text hidden]

https://mail.google.com/mail/u/1/?ik=ebfea721a0&view=pt&search=all&permthid=thread-f:[number redacted]&simpl=msg-f:[number redacted]&simpl=msg-a:r1521421653694399488&simpl=msg-a:r75214409… 3/3 Received 2/07/2025 ROC Legal Received 2/07/2025 I inserted an inside and ROC Legal outside circle that represents the bearing wall of the turret Trusses shown projecting into the volume of the turret. The ceiling in the turret is higher than the lower trusses so they would be visible if they projected into the turret - NOT acceptable.

I inserted an inside and I attempted to do an overlay with the outside circle that truss manufacturer drawing but it is represents the bearing not to scale and seems to be off in wall of the turret several areas. The bold black outline is from our CAD file outline of the building

I attempted to do an overlay with the truss manufacturer drawing but it is not to scale and seems to be off in several areas. The bold black outline is from our CAD file outline of the building Received 2/07/2025 ROC Legal

Trusses shown projecting into the volume of the turret. The ceiling in the turret is higher than the lower trusses so they would be visible if they projected into the turret - NOT Trusses shown Trusses shown acceptable. with overhang on with overhang on this side this side

It is common to see trusses end at the wall (no overhang) when we have the scabbed on wood truss tail detail like our detail shows, but this truss layout drawing is inconsistent

I attempted to do an overlay with the truss manufacturer drawing but it is not to scale and seems to be off in several areas. The bold I inserted an inside and black outline is from outside circle that our CAD file outline represents the bearing of the building wall of the turret

Trusses shown with no overhang on this side I inserted an inside and Trusses shown outside circle that represents with no overhang the bearing wall of the turret on this side

The upper turret trusses for this area are totally missing from this layout drawing 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. 2024A-13179-NPV-ROC

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 Keo Jones 480-226-7220 [email redacted]

4. Subject Matter of Expected Testimony Contracts, Payments, Work completed, Invoices, Unpaid contract balance

Witness 1. Name 2. Telephone Number 3. Email Address Erin Rosenau 714-717-3230 [email redacted] 4. Subject Matter of Expected Testimony Contracts, Payments, Work completed, invoices, unpaid contract balance

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. 2024A-13179-NPC-ROC

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 1. Bid for framing job between Jada Homes and Ground Up Construction AZ LLC Contract for framing job between Jada Homes and Ground Up Construction AZ LLC

invoice 1332 invoice 1333 invoice 1334 invoice 1331 invoice 1326 invoice 1328 change order Arizona Structural Engineering Group inspection report 10/08/2024 License Complaint Form Mary Schield 10/22/2024 email from Sarah Connor-kerr@jadahomes to keo Jones Groound Up Construction

08/02/2024 from Keo jones Ground UP to Sarah Connor-kerr 08/02/2024 From Sarah Connor-kerr to ground up 08/02/2024 email from erin rosenau ground up to sarah connor-kerr at Jada homes 11/25/2025 email from Jarrett Gorman Jada homes to keo Jones Ground Up 11/25/2024 email from keo jones ground up to jarrett gorman@jada homes 01/08/2024 email from Jarrett gorman Jada homes to Keo jones ground up 09/10/2024 email jaylon gorman to keo jones ground up

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. 2024A-13179-NPC-ROC

Digitally signed by keo jones

keo jones keo jones Date: 2025.03.19 18:51:37 -07'00'

Print Name Signature Date

Form RC-L-800A Prehearing Disclosure Statement Rev. 1/15/2019 Page 3 of 3