DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, ; DBPR Case No. 2000-03142 v. RICHARD COBA, Ol-CY7T5 PL Respondent. ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, (“Petitioner”), files this Administrative Complaint before the Construction Industry Licensing Board against RICHARD COBA, (“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 CGC023823, 3. Respondent's last known address is 16155 SW 117 Avenue #10, Miami, Florida 33177. 4. At all times material hereto, Respondent was licensed to practice contracting as Coba Construction Inc., and is, therefore, responsible for all of its contracting and financial activities. 5, Section 489.1195(1)(a), Florida Statutes, provides that all primary qualifying 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 January 14, 1999, a Final Judgment, relating to the practice of contracting, was obtained against Coba Construction Inc. in Case Number 99-04123 in the Circuit Court of the Eleventh Judicial Circuit in and for Miami-Dade County, Florida in favor of Robert and Joan Birch in the principal amount of $16,309.21. 7. The foregoing judgment has not been satisfied in whole or in part, and there is no mutually agreed upon payment plan to satisfy the judgment. 8. Rule 61G4-17.001(23), Florida Administrative Code, states in part that for the purposes of Section 489.129(1)(r), Florida Statutes, [now Section 489.129(1)(q)] “reasonable time” means ninety (90) days following the entry of a civil judgment that is not appealed, 9, Based upon the foregoing, the Respondent violated Section 489, 129(1)(q), Florida 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 to enter an Order imposing one or more of the following penalties: place the license on probation, reprimand the licensee, revoke, suspend, deny the issuance or renewal of the certificate or registration, require financial restitution to the 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. th Signed this { "7 day of Sle , 2000. By: G. W. Harrell Interim Lead Construction Attorney COUNSEL FOR DEPARTMENT; G. W. Harrel vale 6° FILED Interim Lead Construction Attorhey Department of Business and Professional Regulation Department of Business and DEPUTY CLERK Professional Regulation Office of the General Counsel MN, Ncchels 7 CLERK ‘ 1940 N. Monroe Street, Ste. 60 Tallahassee, FL 32399-2202 DATE 7-24-2000 © GWH/dd Case # 2000-03142

Docket for Case No: 01-000475PL