STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION CONSTRUCTION INDUSTRY LICENSING BOARD DIVISION I OH 241 | EC DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, Case No. 2002-002350 vs. WILLIAM P. CARLTON, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Construction Industry Licensing Board, against WILLIAM P. CARLTON, ("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 C026013. 3. Respondent's last known address is 1000 Legion Place, Suite 1518, Orlando, Florida 32801, 4131 NE 6° Avenue, Oakland Park, Florida 33334, and 7711 Twin Pines Court, 4. At all times material hereto, Respondent was licensed as the qualifying agent for International Contracting Associates, Inc. (hereinafter referred to as "ICA"). 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 October 24, 2000, ICA entered into a written contract with Ronald and Rita Goldworm (hereinafter referred to as “Goldworms”) to re-roof a duplex owned by the Goldworms located at 3980 Coral Springs Drive, Coral Springs, Florida. 7. On or about January 11, 2002, the Goldworms filed a civil suit against ICA in the County Court, in and for Broward County, Florida, Case Number 02-245-CONO-71, In their lawsuit, the Goldworms alleged that from November 2000 to January 4, 2001, ICA performed work pursuant the contract but that after January 4, 2001 ICA failed to perform further work and never finished the project. 8. On or about November 1, 2002, a Final Judgment After Default was entered in favor of the Goldworms and against ICA in the sum of Eight Thousand Four Hundred dollars ($8,400.00) on principal, One Thousand Six Hundred Eighty Three dollars and Forty Five cents ($1,683 45) for interest, costs in the sum of Three Hundred Twenty Eight dollars and Thirty cents ($328.30), and attorney’s fees of Three Thousand Seven Hundred Fifty dollars ($3,750.00) for a total amount of Fourteen Thousand One Hundred Sixty One dollars and Seventy Five cents ($14,161.75). 9. The Final Judgment has not been satisfied. COUNT I 10. Petitioner realleges and incorporates the allegations set forth in paragraphs one through nine as though fully set forth in this Count L. ll. Section 455.227(1)(o), Florida Statues, provides: practicing or offering to practice beyond the scope permitted by law or accepting and performing professional responsibilities the licensee knows, or has reason to know, the licensee is not competent to perform is grounds for which disciplinary actions may be taken. 12. Based upon the foregoing, the Respondent violated Section 489.129(1)(c), Florida Statutes (1999), by violating any provision of part I of chapter 455, Florida Statutes. COUNT I 13. Petitioner realleges and incorporates the allegations set forth in paragraphs one through nine as though fully set forth in this Count II. 14. Based upon the foregoing, the Respondent violated Section 489.129(1)(q), Florida Statutes (2001), 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, reprimand 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 Su. day of Aprct , 2003. PaTRIGe CREEHAN CHIEF CONSTRUCTION ATTORNEY COUNSEL FOR DEPARTMENT: E " ulation Theodore R. Gay k snes « ant Professional Red! Assistant General Counsel Department of ae PUTY CLERK Department of Business and D : Professional Regulation ’ 2, 8685 NW 53" Terrace, #100 Pyar dn 10 Miami, FL 33166 CLERK 5- Q- (305) 470-6783 Ext, 2225 DATE TRG/sb Case #2002-002350 04/23/03 °C Baunc U.99-C3 Morcher/ thishand

Docket for Case No: 04-002377PL