Prehearing Disclosure Statement_Case# 2025-11380_TABOR_UPDATED.pdf

2025A-11380-CHC-ROC · Registrar of Contractors · 2026-05-19

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. 2025A-11380 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 Georgia Tabor 951.218.5540 [email redacted]

4. Subject Matter of Expected Testimony Will testify regarding the initial engagement and negotiations with Respondent; the terms of the project agreement and the Respondent’s failure to provide a written contract under A.R.S. § 32-1158; the history, timeline, and sequencing of the renovation project; the discovery of workmanship deficiencies; communications with the Respondent; the timeline, scheduling, and failure of the Respondent's corrective work window; and the authentication of Complainant's photographic, video, and written exhibits.

Witness 1. Name 2. Telephone Number 3. Email Address Michael Tabor 619.318.7241 [email redacted] 4. Subject Matter of Expected Testimony Will testify regarding the execution of the renovation work; firsthand observations of project delays and workmanship deficiencies; communications with the Respondent and subcontractors; the allocation of time and execution of the failed corrective work; and the authentication of Complainant's photographic, video, and written exhibits.

Witness 1. Name 2. Telephone Number 3. Email Address Joey Chester (ROC Investigator) 602.771.6737 [email redacted]

4. Subject Matter of Expected Testimony May testify to the authentication of the official Arizona Registrar of Contractors Investigation Report, the issuance of the Directive for Corrective Work, the findings of the Compliance Reinspection, and the Respondent's failure to satisfy the Directive under A.R.S. § 32-1154(A)(22). Witness 1. Name 2. Telephone Number 3. Email Address Adam Bailey 909.771.8320 [email redacted]

4. Subject Matter of Expected Testimony Will testify regarding his role as the licensed contractor and qualifying party for the project; the formation, terms, and execution of the renovation agreement; the failure to provide a written contract under A.R.S. § 32-1158; the scheduling, coordination, and execution of the corrective work; communications with the Complainants and subcontractors; and his failure to comply with the official ROC Directive for Corrective Work under A.R.S. § 32-1154(A)(22).

Form RC-L-800A Prehearing Disclosure Statement Rev. 1/15/2019 Page 1 of 3 PART 2: EXHIBIT LIST DOCKET NO. 2025A-11380 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 1 Contract for new garage door. 2 Invoice #10001 – Cost for garage door replacement.

Exhibit Exhibit Name A Kitchen Island - evidence showing failed corrective work B Kitchen Cabinetry/Trim - evidence showing failed corrective work C Entertainment Wall/Shelves - evidence showing failed corrective work D Baseboards - evidence showing failed corrective work E Interior Doors - evidence showing failed corrective work F Corrective Timeline - as supplied by Respondent G Settlement Attempts by Complainant H Corrective Work - Estimates from other contractors I Vandalism Accusations - evidence to prove unsubstantiated J Extortion Accusations - evidence to prove unsubstantiated K Painting Coordination - evidence to show thoughtful coordination L Open Gas Line Incident - evidence to show disregard for safety M No Contract/Orig Estimate/Final Payment/Cancelled Checks N Mr. Bailey's Subcontractor Coordination - text messages to support

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. 2025A-11380

Georgia Tabor Georgia Tabor Digitally signed by Georgia Tabor Date: 2026.05.19 08:37:42 -07'00' 05/19/26 Print Name Signature Date

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