STATE OF FLORIDA ; DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION CONSTRUCTION INDUSTRY LICENSING BOARD DIVISION I DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, vs. , Case No. 2000-02964 | | 01-3990 PL ROBERT ALBERT LEVESQUE, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Construction Industry Licensing Board, _ against ROBERT ALBERT LEVESQUE, ("Respondent"), and says: 1. Petitioner i is s the state agency charged with regulating the practice of contracting “pursuant to Section 20. 165, Florida Statutes, and Chapters 455 and 489, Florida Statutes. “Respondent i is, and ‘has been at all times ‘material hereto, a a certified residential ; ; ‘contractor in in icense number cR 024267. 3. Respondent's last known address is P.O. Box 8505, St. Petersburg, Florida 33738. Ea id RARER aE bs GRR Le (1997), throug Aa an ne nena = 4. At all times material hereto, Respondent was the qualifying agent for Suncoast Designer Homes, Inc., QB 0001812. 5. Section 489.1 19S(Iy@), Florida Statutes (1999), 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 Jun une 17, 1998, Respondent entered into an agreement with Lana Wagner (hereinafter "Wagner"), whereby Respondent was to construct a commercial building at 601 93 Avenue, St. Petersburg, Florida. . 7. The contract price was $123,600.00, of which amount Wagner paid Respondent ' $118,092.00. | 8. Respondent subcontracted the job to a general contractor, David Reed, CG C055240. 9. Respondent handled the financial aspects of the contract and allowed his crew to participate in the construction. 10. Atno time material hereto was Respondent licensed or certified to contract for the construction of a commercial building. “Tie ‘Based 0 on nthe foregoing, Respondent violated Section 489. 1290). FB florida Statutes a violation of Section “488. 2271)(0), F lorida Statutes, by practicing 0 or offering to the licensee knows, or has reason to know, the’ licensee is is 5 not st competent t to 5 perform. WHEREFORE, Petitioner respectfully requests the Construction Industry Licensing Board enter an Order imposing one or more of the following penalties: place on probation, reprimand the SmI RE os ‘ge AR He Tallahassee, FL 32399-2202 Case # 2000-02964 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 _// r Hh day of E 2001. ; b Tohn I pC | Assistant General Counsel COUNSEL FOR DEPARTMENT: Ellen C. Marino F | L E [). . Assistant General Counsel Department of Business and Professional Regulation’ Department of Business and AGENCY CLERK Professional Regulation Office of the General Counsel 1940 N. Monroe Street, Ste. 60 cuRK Sonus £. Wowhun am ‘vate_e= 19 + ECM/bjb PCP: January 31, 2001 Alford & Borgemeister ec npgeene reer nee on pees Ee ee

Docket for Case No: 01-002990PL