STATE OF FLORIDA Uoehs DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION CONSTRUCTION INDUSTRY LICENSING BOARDL 27 Pil 19 DIVISION Il . DEPARTMENT OF BUSINESS AND _ PROFESSIONAL REGULATION, Petitioner, | O | 7 BObAP U_ vs Case Nos. 2000-07714, 2000-07715, 2000-007716, 2000-07834, & 2000-07836 ANTHONY F. AGRUSA, Respondent. ee ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFES SIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Construction Industry Licensing Board, against ANT: HONY F. AGRUSA, ("Respondent"), and says: 7 ‘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 Plumbing Contractor in the State of Florida, having been issued license number CF C026530. > 3. Respondent's last known address is 444] Northlake Boulevard, Palm Beach ~ Gardens, Florida, 3341 0. 4. At all times material hereto, Ri espondent ‘was licensed to qualify North County Plumbing. 5. Section 489.1195(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. Respondent failed to obtain a certificate of authority for North County Plumbing. COUNT I . “7. Petitioner realleges and incorporates the allegations set forth in Paragraphs One through Six as though fully set forth herein. 8. Section 489.119(2), Florida Statutes, requires that if an applicant proposes to engage in contracting as a business organization, including any partnership, corporation, business trust, or other legal entity, or in any name other than the applicant’s legal name or a fictitious name where the applicant is doing business as a sole proprietorship, the business organization. must apply for a certificate of authority through a qualifying agent and under a fictitious name, if any. 9, Based on the foregoing, the Respondent violated Section 489.129(1)@), Florida Statutes, by failing in any material respect to comply with the provisions of this part or violating a rule or lawful order of the board. FACTS PERTAINING TO CASE NO. 2000-077 14 10. Respondent installed a hot water heater at a residence located at 5794 South 37” Street without obtaining a permit. | . 11. Respondent applied for a permit after being discovered as not having one, however, it was allowed to expire. . “ft, . 12. Respondent renewed the permit, and the permit was available for pick-up on September 13, 2000, however Respondent did not pick up the permit until November 28, 2000. 2 13. Respondent has failed to obtain a final inspection for the heater. COUNT I 14. Petitioner realleges and incorporates the allegations set forth in Paragraphs One through Six and Paragraphs Ten through Thirteen as though fully set forth herein. 15. _ Based on the foregoing, the Respondent violated Section 489. 129(1)(0), Florida Statutes, by proceeding on any job without obtaining applicable local building department permits and inspections. FACTS PERTAINING TO CASE NO. 2000-077 15 16. | Respondent installed a hot water heater at a residence located at 4 Ashby Court, Greenacres, Florida without obtaining a permit. . | 17. Respondent applied for a permit after being discovered as not having one, however, it was allowed to expire. . 18. Respondent renewed the permit, and the permit was available for pick-up on September 13, 2000, however Respondent did not pick up the permit until November 28, 2000. | 19.. Respondent has failed to obtain a final inspection for the heater. ~ COUNT 20. Petitioner realleges and incorporates the allegations set forth in Paragraphs One through Six and Paragraphs Sixteen through Nineteen as though fully set forth herein. 21. Based on the foregoing, the Respondent violated Section 489. 129(1)(0), Florida Statutes, by proceeding on any job without obtaining applicable local building department permits and inspections. , “a, FACTS PERTAINING TO CASE NO. 2000-0771 6 22. Respondent installed a hot water heater at a residence located at 213 , Foxtall: 3 Drive, West Palm Beach, Florida, without obtaining a permit, 23. Respondent applied for a permit after being discovered as not having one, however, it was allowed to expire. 24. Respondent renewed the permit, and the permit was available for pick-up on September 13, 2000, however Respondent did not pick up the permit until November 28, 2000. 25. Respondent has failed to obtain a final inspection for the heater. COUNT IV 26. ~ Petitioner realleges and incorporates the allegations set forth in Paragraphs One | through Six and Paragraphs Twenty-Two through Twenty-Five as though fully set forth herein. 27. Based on the foregoing, the Respondent violated Section 489.129(1)(0), Florida Statutes, by proceeding on any 9 ob without obtaining applicable local building department permits and inspections. FACTS PERTAINING TO CASE NO. 2000-07834 28. Respondent installed a hot water heater at a residence located at 722 Sunny Pine Way 4G1, Greenacres, Florida, without obtaining a permit, 29, Respondent applied for a permit after being discovered as not having one, however, it was allowed to expire. _ . 30. - Respondent renewed the permit, and the permit was available for pick-up on ‘September 33, 2000, ‘however Respondent did not >t pick up the e permit until November 28, 2000. “31, - ondent has failed to obtain a ‘final inspection for the heater COUNT V