Y 7) 28 STATIC OF PEURIDA” ~ ‘ re; DEPARTMENT OF BUSINESS AND PROFESSIONAL necurangy, Oy CONSTRUCTION INDUSTRY LICENSING BOARD We ‘, 1). 2 DIVISION I ys ip boa e Ags Pn DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, vs. Case No. 2000-00790 04) ov 2d BEHZAD KHAZRAEE, Respondent. 7 / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Construction Industry Licensing Board, against BEHZAD KHAZRAEE, ("Respondent"), and says: 1. Petitioner is the state agency charged with regulating the practice of contracting pursuant to Section 20.165, Florida Statutes, and Chapters 455 and 489, Florida Statutes. 2. Respondent is, and has been at all times material hereto, a Certified General Contractor, in the State of Florida, having been issued license number CG C057726. 3. Respondent's last known address is 732 Summerbrooke Drive, Tallahassee, Florida 32312. 4. At all times material hereto, Respondent was the licensed qualifier for Classy Homes, Inc. ("Classy Homes"). U v - 5. Sisottbn 489.1 195(N@), Floride:Stamtes, provides thet allprimary quakifving, 7” agents for a business organization are jointly and equally responsible for supervision of all operations of the business organization; for all field work at all sites; and for financial matters, both for the organization in general and for each specific job. 6. On or about June 15, 1998, the Respondent, doing business as Classy Homes, entered into a contract with Diop Kamau for the sale and purchase of a new home located at 9217 Hampton Glenn Court, Tallahassee, Florida. 7. The total contract price was $369,900.00. 8. On or about August 20, 1998, the Respondent completed the project. 9. Kamau alleged numerous problems with the completed home. 10. On or about August 17, 1999, a Final Judgment, related to the practice of contracting, in the amount of $6,212.65 was obtained against the Respondent and awarded to t Diop Kamau in the Circuit Court of the Second Judicial Circuit in and for Leon County, Florida, under Case Number 99-0448 SC. | ) ll. On or about March 10, 2000, a notice of appeal of the aforementioned final judgment was dismissed in the Circuit Court of the Second Judicial Circuit in and for Leon County, Florida. 12. As of May 19, 2000, the Respondent has not satisfied the aforementioned final judgment, nor is there a mutually agreed upon payment plan to satisfy the judgment. 13. Rule 61G4-17.001(23), Florida Administrative Code, states in part that for the purposes of Section 489.129(1)(r), Florida Statutes, “reasonable time” means ninety (90) days following the entry of civil judgment that is not appealed. 2 U WY ~ "1d. Seised o@ the fansvoings the Respendest violated Section 489.1 2909@)y Florida. ve Statutes, by failing to satisfy within a reasonable time, the terms of a civil judgment obtained against the licensee, or the business organization qualified by the licensee, relating to the practice of the licensee's profession. WHEREFORE, Petitioner respectfully requests the Construction Industry Licensing Board enter an Order imposing one or more of the following penalties: place on probation, Teprimand the licensee, revoke, suspend, deny the issuance or renewal of the certificate or registration, require financial restitution to a consumer, impose an administrative fine not to exceed $5,000 per violation, require continuing education, assess costs associated with investigation and prosecution, impose any or all penalties delineated within Section 455.227(2), Florida Statutes, and/or any other relief that the Board is authorized to impose pursuant to Chapters 489, 455, Florida Statutes, and/or the rules promulgated thereunder. Signed this, Ju” ___ day of STey , 2000. La hhe & D'daud By: Cathleen E. O’Dowd Lead Construction Attorney COUNSEL FOR DEPARTMENT: Cathleen E. O'Dowd F | L E D , Lead Construction Attorney Department of Business and Professional Regulation Department of Business and DEPUTY CLERK Professional Regulation Office of the General Counsel ccm nardent Michele 1940 N. Monroe Street, Ste. 60 6-2 -2AOCO Tallahassee, FL 32399-2202 DATE __(O * CEO/jkm Case # 2000-00790 Lop: °Sas]m °

Docket for Case No: 00-003047PL