CO; Yo, LP STATE OF FLORIDA CO ., 6 & DEPARTMENT OF BUSINESS & PROFESSIONAL REGULATION %y <3, “? ro) FLORIDA REAL ESTATE APPRAISAL BOARD BS, ty Se ee FLORIDA DEPARTMENT OF BUSINESS & Uifig Dn Fy PROFESSIONAL REGULATION, ONAL. DIVISION OF REAL ESTATE, p ¢ a -(R2 Petitioner, C4 ‘ 3 L v. CASE NO. 2009016617 GWENDOLYN BARKER, Respondent. / ADMINISTRATIVE COMPLAINT The Florida Department of Business & Professional Regulation, Division of Real Estate ("Petitioner") files this Administrative Complaint against Gwendolyn Barker (“Respondent”), and alleges: ESSENTIAL ALLEGATIONS OF MATERIAL FACT 1. Petitioner is a state government licensing and regulatory agency charged with the responsibility and duty to prosecute Administrative Complaints pursuant to the laws of the State of Florida, including Section 20.165 and Chapters 120, 455 and 475 of the Florida Statutes, and the rules promulgated thereunder. 2. Respondent is currently a ‘Florida stated certified residential real estate appraiser having been issued license 4672 in accordance with Chapter 475 Part II of the Florida Statutes. 3. The last license the State issued to Respondent was as a state certified residential real estate appraiser at 2005 Cardiff Lane, Middleburg, Florida 32068. H:\FREAB\FREABa\FREAB\barker.doc 1 FDBPR v. Gwendolyn Barker Case No. 2009016617 Administrative Complaint 4, On or about September 16, 2004, Gwendolyn Barker (Respondent) and Fred Catchpole developed and communicated an appraisal report (Report) for property commonly known as 209 Ponderosa Pine Court, Georgetown, Florida 32139 (Subject Property), and estimated its value at $77,000.00. A copy of the Report is attached hereto and incorporated herein as Administrative Complaint Exhibit 1. 5. At the time the Report was developed and communicated, Respondent was a State Certified Residential real estate appraiser and Fred Catchpole was a Licensed real estate appraiser. -6. Respondent made the following errors and omissions in the Report: A) Incorrect borrower’s name in the Subject section of the B) Incorrect census track data for the Subject Property in the Subject section of the Report; C) Incorrect zoning description for the Subject Property in the Site section of the Report; D) Incorrect FEMA data for the Subject Property in the Site section of the Report; E) Incorrect Site data for the Subject Property, based on workfile documentation, in the Sales Comparison Approach section of H:\FREAB\FREABa\FREAB\barker.doc 2 FDBPR v. Gwendolyn Barker . Case No. 2009016617 Administrative Complaint the Report; F) Failure to note, in the Sales Comparison Approach section of the Report, a prior sale of comparable sale 1 in December 2002 for $69,000; G) Incorrect address, based on workfile documentation, for comparable sale 1 in the Sales Comparison Approach section of the Report; H) Incorrect Site data for comparable sale 1, based on workfile documentation, in the Sales Comparison Approach section of the Report; I) Incorrect Age data for comparable sale 1, based on workfile documentation, in the Sales Comparison Approach section of the Report; J) Failure to note, in the Sales Comparison Approach section of the Report, that comparable sale 1 had a fence, as outlined in workfile documentation; K) Failure to make an adjustment or provide an explanation for no adjustment on comparable sale 1 for its fence; L) Incorrect proximity to Subject data for comparable sale 1 in the Sales Comparison Approach section of the Report; M) Incorrect address, based on workfile documentation, for comparable sale 2 in the Sales Comparison Approach section of the H:\FREAB\FREABa\FREAB\barker.doc 3 FDBPR v. Gwendolyn Barker Case No. 2009016617 Administrative Complaint Report; N) Incorrect Age data for comparable sale 2, based on workfile documentation, in the Sales Comparison Approach section of the Report; ©) Incorrect prior sale data, in the Sales Comparison Approach section of the Report, for comparable sale 2; P) Incorrect proximity to Subject data for comparable sale 2 in the sales Comparison Approach section of the Report; Q) Failure to verify the correct Site size for comparable sale 2, when there is a discrepancy between data sources; .R) Failure to note that comparable sale 2 had a hot tub, as evidenced by workfile documentation; S) Failure to note the renovated status of comparable sale 2, as outlined in workfile documentation; T) Failure to make an adjustment or provide an explanation for no adjustment on comparable sale 2 for its renovated status; U) Failure to note, in the Sales Comparison Approach section of the Report, that comparable sale 2 had a fence, as outlined in workfile documentation; V) Failure to make an adjustment or provide an explanation for no adjustment on comparable sale 2 for its fence; W) Incorrect proximity to Subject data for comparable sale 3 H:\FREAB\FREABa\FREAB\barker.doc 4 FDBPR v. Gwendolyn Barker Case No. 2009016617 Administrative Complaint in the sales Comparison Approach section of the Report; X) Failure to make an adjustment or provide an explanation for no adjustment on comparable sale 3 for its Site difference; Y) Failure to make an adjustment or provide an explanation for no adjustment on comparable sale 3 for its Date of Sale/Time; Z) Failure to explain the Basement & Finished adjustment notation for comparable sale 3 in the Sales Comparison Approach section of the Report; AA) Incorrect gross living area, based on workfile documentation, for comparable sale 4 in the Sales Comparison Approach section of the Report; BB) Failure to note, in the Sales Comparison Approach section of the Report, that comparable sale 4 had a fireplace, as outlined in workfile documentation; CC) Failure to make an adjustment or provide an explanation for no adjustment on comparable sale 4 for its fireplace; DD) Failure to note, in the Sales Comparison Approach section of the Report, that comparable sale 4 had a pole barn, as outlined in workfile documentation; EE) Failure to note, in the Sales Comparison Approach section of the Report, that comparable sale 4 had a partial fence, as outlined in workfile documentation; H:A\FREAB\FREABa\FREAB \barker.doc 5 FDBPR v. Gwendolyn Barker Case No. 2009016617 Administrative Complaint FF) Failure to make an adjustment or provide an explanation for no adjustment on comparable sale 4 for its partial fence; GG) Incorrect proximity to Subject data for comparable sale 4 in the Sales Comparison Approach section of the Report; HH) Incorrect proximity to Subject data for comparable sale 6 in the Sales Comparison Approach section of the Report; II) Failure to make an adjustment or provide an explanation for no adjustment on comparable sale 6 for its Date of Sale/Time; and JJ) Inconsistent Cost Approach data in the Report (the URAR Cost Approach data located on Exhibit 1, pg. 8 of the Investigative Report, does not agree with the Form 1004 Fannie Mae Cost Approach data on Exhibit 1, pg. 11 of the Investigative Report). 7. The workfile lacks documentation to support the FEMA data in the Site section of the Report. 8. There is no documentation in the workfile to support the Growth Rate, Property Values, Demand/Supply or Marketing Time data in the Neighborhood section of the Report. 9. There is no documentation in the workfile to support the Single Family Housing data in the Neighborhood section of the Report. 10. There is no documentation in the workfile to support the H:AFREAB\FREABa\FREAB\barker.doc 6 FDBPR v. Gwendolyn Barker Case No. 2009016617 Administrative Complaint 25 sales of manufactured homes ranging in price from $10,000 to $200,000 in the Fannie Mae Manufactured Home Appraisal Report Addendum. 11. There is no documentation in the workfile to support the 10 listings of manufactured homes ranging in price from $20,000 to $180,000 in the Fannie Mae Manufactured Home Appraisal Report Addendum. 12. There is no information in the workfile to support the Manufactured Housing Property Values, Manufactured Housing Supply/Demand, Manufactured Housing Marketing Time, Manufactured Housing Price Range, or Manufactured Housing Age Range data in the Supplemental Neighborhood Information section of the Fannie Mae Manufactured Home Appraisal Report Addendum. 13. There is no documentation in the workfile to support the $5,000 Site adjustment to comparable sale 2 in the Sales Comparison Approach section of the Report. 14. There is no documentation in the workfile to support the $11,000 Site adjustment to comparable sale 4 in the Sales Comparison Approach section of the Report. 15. There is no documentation in the workfile to support the $20,000 Site adjustment to comparable sale 6 in the Sales Comparison Approach section of the Report. H:\FREAB\FREABa\FREAB \barker.doc 7 FDBPR v. Gwendolyn Barker Case No. 2009016617 Administrative Complaint 16. There is no documentation in the workfile to support the $4,500 Age adjustment to comparable sale 1 in the Sales Comparison Approach section of the Report. 17. There is no documentation in the workfile to support the $4,500 Age adjustment to comparable sale 3 in the Sales Comparison Approach section of the Report. 18. There is no documentation in the workfile to support the $4,500 Age adjustment to comparable sale 4 in the Sales Comparison Approach section of the Report. 19. There is no documentation in the workfile to support the $4,000. Age adjustment to comparable sale 5 in the Sales Comparison Approach section of the Report. 20. There is no documentation. in the workfile $7,150 Gross Living Area adjustment to comparable Sales Comparison Approach section of the Report. 21. There is no documentation ‘in the workfile $4,880 Gross Living Area adjustment to comparable Sales Comparison Approach section of the Report. 22. There is no documentation in the workfile $9,400 Gross Living Area adjustment to comparable Sales Comparison Approach section of the Report. 23. There is no documentation in the workfile H:\FREAB\FREABa\FREAB \barker.doc to support sale 1 in to support sale 3 in to support sale 4 in to support the the the the the the FDBPR v. Gwendolyn Barker Case No. 2009016617 Administrative Complaint $12,480 Gross Living Area adjustment to comparable sale 5 in the Sales Comparison Approach section of the Report. 24. There is no documentation in the workfile to support the $1,000 Basement & Finished/WORKSHOP adjustment to comparable sale 1 in the Sales Comparison Approach section of the Report. 25. There is no documentation in the workfile to support the $1,000 Basement & Finished/WORKSHOP adjustment to comparable sale 5 in the Sales Comparison Approach section of the Report. 26. There is no documentation in the workfile to support the $1,000 Garage/Carport adjustment to comparable sale 1 in the Sales Comparison Approach section of the Report. 27. There is no documentation in the workfile to support the $1,000 Garage/Carport adjustment to comparable sale 2 in the Sales Comparison Approach section of the Report. 28. There is no documentation in the workfile to support the $1,000 Garage/Carport adjustment to comparable sale 3 in the Sales Comparison Approach section of the Report. 29. There is no documentation in the workfile to support the $1,000 Garage/Carport adjustment to comparable sale 4 in the Sales Comparison Approach section of the Report. 30. There is no documentation in the workfile to support the $1,500 Porch, Patio, Deck adjustment to comparable sale 2 in the H:AFREAB\FREABa\FREAB \barker.doc 9 FDBPR vy. Gwendolyn Barker Case No. 2009016617 Administrative Complaint Sales Comparison Approach section of the Report. 31. There is no documentation in the workfile to support the $1,500 Porch, Patio, Deck adjustment to comparable sale 4 in the Sales Comparison Approach section of the Report. 32. There is no documentation in the workfile to support the $1,000 Porch, Patio, Deck adjustment to comparable sale 5 in the Sales Comparison Approach section of the Report. 33. Respondent’s Report contains two different Cost Approach sections with differing data. 34. The Cost Approach data on the URAR form, found on Exhibit 1, pg. 8 in the Investigative Report has the following errors or omissions: A) Incorrect Depreciation dollar amount; B) Incorrect Depreciated Value of Improvements amount; and C) Incorrect Indicated Value of Site Improvements. 35. The Cost Approach data on ‘the Fannie Mae 1004 form form, found on Exhibit 1, pg. 11 in the Investigative Report has the following errors or omissions: A) Incorrect Depreciation dollar amount; B) Incorrect Depreciated Value of Improvements amount; and C) Incorrect Indicated Value of Site Improvements. 36. The workfile lacks MLS data for comparable sale 3, when H:\FREAB\FREABa\FREAB \barker.doc 10 FDBPR v. Gwendolyn Barker Case No. 2009016617 Administrative Complaint this is listed as a data source in the Report. 37. The workfile lacks documentation to support the Room Count for comparable sale 3 in the Sales Comparison Approach section of the Report. 38. Some of the documentation for comparable sale 5 located in the workfile is not contemporaneous to the effective date of the Report. 39. The workfile lacks MLS data for comparable sale 5, when this is listed as a data source in the Report. 40. The workfile lacks documentation to support the Room Count data for comparable sale 6 in the Sales Comparison Approach section of the Report. 41. The workfile lacks documentation to support the Gross Living Area data for comparable sale 6 in the Sales Comparison Approach section of the Report. 42. There is no documentation in the work file to support the $15,000 Estimated Site Value in the Cost Approach section of the Report, found on the URAR form (Exhibit 1, pg. 8). 43. There is no documentation in the work file to support the $8,000 LUMP SUM adjustment in the Cost Approach section of the Report, found on the URAR form (Exhibit 1, pg. 8). 44. There is no documentation in the work file to support the H:AFREAB\FREABa\FREAB \barker.doc 11 FDBPR v. Gwendolyn Barker Case No. 2009016617 Administrative Complaint $15,000 As-Is Value of Site Improvements adjustment in the Cost Approach section of the Report, found on the URAR form (Exhibit 1, pg. 8). 45. There is no documentation in the work file to support the $10,000 Market Value of Subject Site in the Cost Approach section of the Report, found on the Fannie Mae 1004 form (Exhibit 1, pg. 11). 46. There is no documentation in the work file to support the $10,000 Other Depreciated Site Improvements adjustment in the Cost Approach section of the Report, found on the Fannie Mae 1004 form (Exhibit 1, pg. 11). Al. There is no documentation in the work file to support the $5,000 LUMP SUM adjustment in the Cost Approach section of the Report, found on the Fannie Mae 1004 form (Exhibit 1, pg. 11). 48. The work file lacks dated local builder’s costs data for the time frame that the Report was completed to justify the dwelling square footage price in both the URAR and Fannie Mae Cost Approach sections of the Report. 49. The work file lacks dated Marshall and Swift pages for the time frame that the Report was completed to justify the dwelling square footage price in both the URAR and Fannie Mae Cost Approach sections of the Report. A copy of the Workfile is attached hereto and incorporated herein as Administrative Complaint Exhibit 2. H:\FREAB\FREABa\FREAB \barker.doc 12 FDBPR v. Gwendolyn Barker Case No. 2009016617 Administrative Complaint 50. Respondent’s primary business address is located in excess of 80 miles from the Subject Property, and Respondent provided no information pertaining to knowledge or experience in the Subject property area. COUNT ONE Based upon the foregoing, Respondent is guilty of having failed to exercise reasonable diligence in developing an appraisal report in violation of Section 475.624(15), Florida Statutes. COUNT TWO Based upon the foregoing, Respondent has violated a standard for the development or communication of a real estate appraisal, specifically the Conduct Section of the Ethics Rule, or other provision of the Uniform Standards of Professional Appraisal Practice (2004) in violation of Section 475.624(14), Florida Statutes. COUNT THREE Based upon the foregoing, Respondent has violated a standard for the development or communication of a real estate appraisal, specifically the Recordkeeping Section of the Ethics Rule, or other provision of the Uniform Standards of Professional Appraisal Practice (2004) in violation of Section 475.624(14), Florida Statutes. H:\FREAB\FREABa\FREAB\barker.doc 13 FDBPR v. Gwendolyn Barker Case No. 2009016617 Administrative Complaint COUNT FOUR Based upon the foregoing, Respondent has violated a standard for the development or communication of a real estate appraisal, specifically the Competency Rule, or other provision of the Uniform Standards of Professional Appraisal Practice (2004) in violation of Section 475.624(14), Florida Statutes. COUNT FIVE Based upon the foregoing, Respondent has violated a standard for the development or communication of a real estate appraisal, specifically the Supplemental Standards Rule, or other provision of the Uniform Standards of Professional Appraisal Practice (2004) in violation of Section 475.624(14), Florida Statutes. COUNT SIX Based upon the foregoing, Respondent has violated a standard for the development or communication of a real estate appraisal, specifically Standards Rule 1-l(a), (b), and (c), or other provision of the Uniform Standards of Professional Appraisal Practice (2004) in violation of Section 475.624(14), Florida Statutes. COUNT SEVEN Based upon the foregoing, Respondent has violated a standard for the development or communication of a real estate appraisal, H:AFREAB\FREABa\FREAB\barker.doc 14 FDBPR v. Gwendolyn Barker Case No. 2009016617 Administrative Complaint specifically Standards Rule 1-2(f), or other provision of the Uniform Standards of Professional Appraisal Practice (2004) in violation of Section 475.624(14), Florida Statutes. COUNT EIGHT Based upon the foregoing, Respondent has violated a standard for the development or communication of a real estate appraisal, specifically Standards Rule 1-4(a) and (b), or other provision of the Uniform Standards of Professional Appraisal Practice (2004) in violation of Section 475.624(14), Florida Statutes. COUNT NINE -Based upon the foregoing, Respondent has violated a standard for the development or communication of a real estate appraisal, specifically Standards Rule 1-6(a), or other provision of the Uniform Standards of Professional Appraisal Practice (2004) in violation of Section 475.624(14), Florida Statutes. COUNT TEN Based upon the foregoing, Respondent has violated a standard for the development or communication of a real estate appraisal, specifically Standards Rule 2-1(a) and (b), or other provision of the Uniform Standards of Professional Appraisal Practice (2004) in violation of Section 475.624(14), Florida Statutes. H:AFREAB\FREABa\FREAB\barker.doc 15 FDBPR v. Gwendolyn Barker Case No. 2009016617 Administrative Complaint COUNT ELEVEN Based upon the foregoing, Respondent has violated a standard for the development or communication of a real estate appraisal, specifically Standards Rule 2-2(b) (ix), or other provision of the Uniform Standards of Professional Appraisal Practice (2004) in violation of Section 475.624(14), Florida Statutes. COUNT TWELVE Based upon the foregoing, Respondent has violated a standard for the development or communication of a real estate appraisal, specifically Standards Rule 2-3, or other provision of the Uniform Standards of Professional Appraisal Practice (2004) in violation of Section 475.624(14), Florida Statutes. WHEREFORE, Petitioner respectfully requests the Florida Real Estate Appraisal Board, or the Department of Business and Professional Regulation, as may be appropriate, to issue a Final Order as final agency action finding the Respondent(s) guilty as charged. The penalties which may be imposed for violation(s) of Chapter 475 of the Florida Statutes, depending upon the severity of the offense(s), include: revocation of the license, registration, or certificate; suspension of the license, registration or certificate for a period not to exceed ten (10) years; imposition of an administrative fine of up to $5,000 for each count or H:AFREAB\FREABa\FREAB \barker.doc 16 FDBPR v. Gwendolyn Barker Case No. 2009016617 Administrative Complaint offense; imposition of investigative costs; issuance of a reprimand; imposition of probation subject to terms including, but not limited to, requiring the licensee, registrant, or certificate holder to complete and pass additional appraisal education courses; publication, or any combination of the foregoing which may apply. See Section 475.624, Florida Statutes and Rule 61J1-8.002, Florida Administrative Code. The penalties which may be imposed for violation(s) of Chapter 455 of the Florida Statutes, depending upon the severity of the offense(s), include: revocation of the license, registration, or certificate; suspension of the license, registration, or certificate for a period not to exceed ten (10) years; imposition of an administrative fine of up to $5,000 for each count or offense; imposition of investigative costs; issuance of a reprimand; imposition of probation subject to terms including, but not limited to, requiring the licensee, registrant, or certificate holder to complete and pass additional appraisal education courses; publication; restriction of practice; injunctive or mandamus relief; imposition of a cease and desist notice; or any combination of the foregoing which may apply. See Section 455.227, Fla. Statutes and Florida Administrative Code Rule 61J1-8.002. H:\FREAB\FREABa\FREAB \barker.doc 17 FDBPR v. Gwendolyn Barker Administrative Complaint SIGNED this \S PCP: JH/JS 10/09 vo, H:AFREAB\FREABa\FREAB \barker.doc Case No. 2009016617 day of Ach ber , 2009. ATTORNEY FOR PETITIONER 2. Robert Minarcin Senior Attorney Fla. Bar No. 163147 Division of Real Estate Legal Section 400 W. Robinson Street, N801 Orlando, Florida 32801-1757 (407) 481-5632 (407) 317-7260 - FAX FDBPR v. Gwendolyn Barker Case No. 2009016617 Administrative Complaint NOTICE TO RESPONDENTS PLEASE BE ADVISED that mediation under Section 120.573 of the Florida Statutes, is not available for administrative disputes involving this type of agency action. PLEASE BE FURTHER ADVISED that pursuant to this Administrative Complaint you may request, within the time allowed by law, a hearing to be conducted in this matter in accordance with Sections 120.569 and 120.57 of the Florida Statutes; that you have the right, at your option and expense, to be represented by counsel or other qualified representative in this matter; and that you have the right, at your option and expense, to take testimony, to call and cross-examine witnesses, and to have subpoena and subpoena duces tecum issued on your behalf if a formal hearing is requested. PLEASE BE FURTHER ADVISED that if you do not file an Election of Rights form or some other responsive pleading with the Petitioner within twenty-one (21) days of receipt of this Administrative Complaint, the Petitioner will file with the Florida Real Estate Appraisal Board a motion requesting an informal hearing and entry of an appropriate Final Order which may result in the suspension or revocation of your real estate license or registration. Please see the enclosed Explanation of Rights and Election of Rights form. H:\FREAB\FREABa\FREAB\barker.doc 19 we SUMMARY REPORT operty Description UNIFORM RESIDENTIAL APPRAISAL REPORT __ritewo. 041850cb Address 209 PONDEROSA PINE CT City GEORGETOWN D ogal Description PLANTATION PINES Il WHISPERING PINES SEC MBS P 80 LOT 61 ‘Assessor's Parcel No. O5-13-27-7225-0000-0610 Tax Year 2003 RE, Taxes 952.58 Special Assessments § N/A RNARDO Occupant: (x) Owner CJ Tenant _ CT vacant Cl condominium (HUDIVAcniy) HORS N/A. Ma. | Census Tract 954400 LenderCiient_ PASS AND ASSOCIATES ‘Aadress SAN MATEO, FL MM Appraiser GWENDOLYN C BARKER CCl CREA. ‘Address 5449 MARCIA CIRCLE, JACKSONVILLE, FL Location Urban Suburban Rural Predominant Single famity housing Present land use % | Land use change. Bull up Over 75% 25-75% Under 25% | Sesupancy PRICE AGE | One family _75% (X) Not tkety — () Likey HBB Growin rate Rapid __(X) Stable Stow & owner 40 Low _NEW | 2-4 tamity OO inprocess TB Propery values (J increasing OX) stabie C2) desing | [) Tenant 200 High 100] suritamiy To: Demandisupply C) Shortage OX) Inbatence () Oversspny Vacant (25%) i Predo EE Commercial Marketing time {_] Under3 mos. (X) 3-6 mos. (1) Over mos} (1) vecan [7 [20 |vaca 25% Note: Race and the racial composition of the neighborhood are not appraisal factors. Neighborhood boundaries and characteristics: S€@ Attached Addendum. OD [>] Factors that affect the marketability of the properties in the neighborhood (proximity to ‘employment and amenities, employment stability, appeal to market, etc.): F3 MSA 3600 THE AREA LOCATED IN SOUTH PUTNAM COUNTY, IS CONVENIENT TO MAJOR TRANSPORTATION ROUTES, EJ WHICH OFFER EASY ACCESS TO EMPLOYMENT OPPORTUNITIES, SCHOOLS. AND MOST RESIDENTIAL SERVICES. THE 3 HOMES IN THE AREA EXHIBIT AVERAGE TO GOOD QUALITY AND. APPEAL AND ARE TYPICALLY FRAME, MANUFACTURED 2 ‘OR MASONRY CONSTRUCTION AND ARE GENERALLY WELL MAINTAINED. Merkel conditions in the subject neighborhood (Including support for the above conclusions related to the trend of property values. demand/supply, and marketing time «such as data on competitive properties for sale in the neighborhood, description af the prevalence of sales and financing concessions, etc.): f THE MARKET 1$ CURRENTLY STABLE WITH MORTGAGE FUNDS AVAILABLE TO QUALIFIED BUYERS AT COMPETITIVE. RATES. THERE IS NO EVIDENCE OF CONCESSIONS. BUYDOWNS, OR DISCOUNTS WHICH WOULD AFFECT MARKET. VALUE. PROPERTY VALUES ARE RELATIVELY STABLE WITH NO CHANGES EXPECTED IN THE MARKET IN THE NEAR TERM. RECENT FLUCTUATIONS IN MORTGAGE LENDING RATES DO NOT APPEAR TO HAVE AFFECTED MARKET. VALUES IN. THE SUBJECT MARKET AREA ~ js the developeribullder in control of the Home Owners’ Association (HOA)? CT ves Lino Approximate total number of units for sale in the subject project Tomoapy ——~