Hannah Robertson Disclosure Packet.pdf

2025A-02092-CHC-ROC · Registrar of Contractors · 2025-07-17

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 EXHIBIT 1: Arizona Registrar of Contractors Workmanship Standards for Licensed Contractors. Page 22 - Resilient Floor Covering EXHIBIT 2: Elite Flooring Installation, Care and Warranty EXHIBIT 2: Elite Flooring Installation, Care and Warranty EXHIBIT 2: Elite Flooring Installation, Care and Warranty EXHIBIT 3: Communication Timeline and Screenshots

Date Communication Type Reason for Communication Outcome

09/07/2024 Outgoing text from Hannah to Schuyler Initial complaint No response

09/09/2024 Outgoing text from Hannah to Schuyler Follow up No response

09/10/2024 Outgoing call from Hannah to Schuyler Follow up No response

09/11/2024 Outgoing call from Hannah to Schuyler Follow up Schuyler said he will see when Chris can come and look at the floors

09/12/2024 Outgoing text from Hannah to Schuyler Follow up No response

09/13/2024 Outgoing text from Hannah to Schuyler Follow up No response

09/13/2024 Incoming text from Schuyler to Hannah Scheduled Chris to inspect floors on Chris did not come on 09/14/2024 as he 09/14/2024 was sick

09/23/2024 Outgoing text from Hannah to Schuyler Follow up to see if someone can No response inspect our floors since Chris is sick

09/25/2024 Incoming text from Schuyler to Hannah Scheduled Chris to come on Chris replaced several pieces of flooring 09/27/2024 in one area that was lifting

11/25/2024 Outgoing text from Hannah to Schuyler New complaint - Flooring lifting No response again

12/02/2024 Outgoing text from Hannah to Schuyler Follow up No response

12/13/2024 Outgoing text from Hannah to Schuyler Follow up No response

12/16/2024 Outgoing call from Hannah to Schuyler Follow up No response

12/28/2024 Outgoing text from Hannah to Schuyler Follow up No response

12/28/2024 Outgoing email from Hannah to Schuyler Follow up No response

01/09/2025 Outgoing text from Hannah to Schuyler Follow up - Let Schuyler know I will No response be filing complaint with AZ ROC

01/09/2025 Outgoing email from Hannah to Schuyler Follow up - Let Schuyler know I will No response be filing complaint with AZ ROC EXHIBIT 3: Communication Timeline and Screenshots

01/10/2025 Incoming call from Schuyler to Hannah Schuyler asking for contact Schuyler called flooring store, says “He information for flooring supplier was being a jerk so I need to talk to the rep”

01/11/2025 Outgoing text from Hannah to Schuyler Sent picture of flooring installation No response instructions

01/20/2025 Outgoing text from Hannah to Schuyler Sent contact information of flooring Schuyler gave the message a “thumbs representative up”, then no further communication received

02/03/2024 Outgoing text from Hannah to Schuyler Follow up to see if he can contact Schuyler says he will contact them the representative tomorrow. Says he will install flooring for free but they will need to pay for materials or he will take them to ROC

02/07/2025 Outgoing text from Hannah to Schuyler Follow up again to see if he Schuylar says representative is out of contacted representative oﬃce till 2/10/2025

02/13/2025 Outgoing text from Hannah to Schuyler Follow up again to see if he No response contacted representative

02/17/2025 Outgoing text from Hannah to Schuyler Follow up again to see if he Schuyler has not heard back from flooring contacted representative representative. I contacted rep and he is not allowed to communicate with the contractor.

02/21/2025 Outgoing text from Hannah to Schuyler Follow up - let Schuyler know No response warranty voided

03/01/2025 Complaint filed with AZ ROC EXHIBIT 3: Communication Timeline and Screenshots

2 EXHIBIT 3: Communication Timeline and Screenshots

EXHIBIT 3: Communication Timeline and Screenshots

8 EXHIBIT 3: Communication Timeline and Screenshots

EXHIBIT 3: Communication Timeline and Screenshots

12 EXHIBIT 3: Communication Timeline and Screenshots

EXHIBIT 4: New Modern LLC Receipt EXHIBIT 5: Carpet Closeout Receipt