| . A pete . Se aoklje, “Ye. van | STATE OF FLORIDA Heisev on DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION Mi CONSTRUCTION INDUSTRY LICENSING BOARD Ve DIVISION. DEPARTMENT OF BUSINESS AND Lente PROH SSIONAL REGULATION, ar A \HS Petitioner, Case No. 97-22100 EUGENE ANTHONY SAURINI, Respondent. / i ADMINISTRATIVE COMPLAINT | Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, CPethione files this Administrative Complaint before the Construction Industry Licensing | — Boar, against EUGENE ANTHONY SAURINI, ("Respondent"), and says: 1 ae Petitioner is the state agency charged with regulating the practice of contracting ~pursijant to Section 20.165, Florida Statutes, and Chapters 455 and 489, Florida Statutes. 2. Respondentlis, and has been at all times material hereto, a Certified Air - Conditioning Contractor, in the State of Florida, having been issued license number CA C048069. 3. Respondent's last known address is 5122 Gulf Drive, New Port Richey, Florida 4. At all times material hereto, Respondent was the licensed qualifier for Toce Air vette tinn Boilie Bes : 4 4 ed Su __ Conditioning and Heating, Inc. (hereinafter referred to as "Toce"). © | 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, Respondent has failed to obtain a qualified business license from the Board for Toce Air Conditioning and Heating, Inc, 7. Between March 1997 and June 1997, the Respondent performed one hundred and ‘ seven (107) air conditioning jobs in Citrus County without first obtaining permits. : 8. Onor about November 20, 1997, the Respondent received one hundred and seven ngeMeeer ts ates (107) citations from the Citrus County Building Department. 9. To date, the Respondent has not obtained permits for forty eight (48) of the one hundred seven a 07) jobs cited by the Citrus County Building Department. The following forty- eight (48) jobs still require permits: Address . Citation Number 12097 Magnolia Street, Dunellon 201 36 Benson Place, Dunellon ; 203 34 South Masters Drive, Homasassa 214 23 Rebecca Court, Citrus Hills 215 6170 West Star Court, Homasassa 217 17 West Balsam Court, Homasassa 220 8 Blair Court, Homasassa 222 Drive, Beverly Hills 223 ay Street, Beverly Hills : 224 29 Dogwood Drive, Homasassa 227 15 Byrsonima Circle, Homasassa 228 2311 North Page Avenue, Hernando “229 1173 South Palm Avenue, Crystal River 230 __ 2835 South Jean Avenue, Inverness 231 jas kab tka, ok aks a Y WU ew Address Citation Number 8240 West Bavarian Street, Homasassa 232 8972 West Forest View Drive, Crystal River 233 "1414 West Alex Lane, Citrus Springs 235 48 Hollyhock Court, Homasassa . 236 2830 West Beamwood Drive, Beverly Hills. 237 684 North Country Club Drive, Crystal River 239 5569 South Boulevard Drive 240 13 Lysiloma Court, Homasassa 241 10455 South Suncoast Boulevard, Homasassa 243 8705 North Torngat Point, Crystal River 244 66 South Lincoln Avenue, Beverly Hills 245 685 North Afterglow, Crystal River 246 4589 West Mesa Verde Drive, Beverly Hills 247 16 West Brysonimia Loop, Homasassa 248 4040 East Shorewood Drive, Hemando 251 7900 South Four Oaks Point, Floral City 252 9787 East Thomas Drive, Floral City 256 94 South J, Kellner Boulevard, Beverly Hills 257 29 Jamaica Court, Homasassa ; 265 7366 West Tall Pines Court, Crystal River 267 4947 East Stokes Ferry Road, Hernando 269 6506 East Mobile Street, Inverness 271 3895 West Catalpa Lane, Beverly Hills 272 976 South Candlenut Avenue, Homasassa 273 | 50 Pine Street, Homasassa 274 "5509 South Stoneridge Avenue, Inverness 275 8033 West Forestview Drive, Crystal River . 281 4 Esskay Street, Beverly Hills 289 5, 7 East Fig Court, Homasassa 290 . 7588 West Starburst Lane, Homasassa 291 1235 Blue Bonnett Terrace, Inverness 292 “°9440 North Milam Way, Citrus Springs 298 vo, TB West Ariane Street, Homasassa 299 “415 North Manor Way, Inverness 307 210. Citrus County, Florida, in case number LIL-99-17 suspending his pe’ On or about March 24, 1999, the Construction Licensing And Appeals Board for 3 6, entered a Final Order against Respondent it-pulling privileges in Citrus County iintil such time that each outstanding permit has been issued and penalties and fees have been paid, and all required final inspections and approved, COUNT I. 11. Petitioner realleges and incorporates the allegations set forth in paragraphs one ; toad ten as though fully set forth in this Count I. : 2, Based on the foregoing, the Respondent violated Section 489. 129(1)(i), Florida Siatutes, by being disciplined by z any municipality or county for an act or violation of this part. COUNT i ees, . “13. Petitioner realleges and incorporates the allegations set forth in paragraphs one through ten as though fully set forth in this Count I. ; : 14, ; ‘Based on the foregoing, the Responds violated Section 489. 129(1)(n), Florida : °Staiutes, by committing incompetency or misconduct in the practice of contracting. woes oe mo, - eoera 15. _ Petitioner realleges and | incorporates the allegations set forth i in paragraphs one through tena as .s though fully set forth j in this Count 10. ; 16. Based | on the foregoing, the Respondent violated Section 489. 129(1)(p), Florida Statutes, by proceeding on any jb wi without obtaining applicable local building department permits sand inspections. ces A i A all ele 3 | sabia arenrere Sarees ube tabi a idea di alles bil bel co si a lll Bd, al lal li, alll i AE ap. ble [IP _ : out + Kesler wo ND WU | ; U csi of authority through a qualifying agent. “19, Rule 64G4-15.0021(1)(b), Florida Administrative Code, provides that a certificate ij : issuedto a business organization shall bear the name of the business organization, the address of the bans organization, and the licensure number of the business organization. 20. Based on the foregoing, Respondent violated Section 489.129(1)(j), Florida Statutes, by failing i in any material respect to comply with the provisions of this part or violating a rule or - laf order of the board, including, as here, Section 489.1192), Florida Statutes and Rule 64G4- 15: 0021(1), Florida Administrative Code, by failing or refusing to obtain a qualified business ergarietion licensure number for Toce. | WHEREFORE, Petitioner respect request the Construction Industry Licensing Board enter an Order i imposing one or more of the following penalties: place on probation, reprimand the licensee, revoke, suspend, deny: the i issuance oF renewal of the certificate or . registfation, require nancial restitution to a consumer, impose an administrative fine not to exceet $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), Flo va Statutes, and/or any other relief that the Board is authorized to impose pursuant to promulgated thereunder. Chaplet 489, ‘455, Florida fatutes, and/or the mul ; - Signed this COZ _ day of of <_ \ ane 2, 1999. FILED _ Depart of Business and Professional Regulation Chief Attorney DEPUTY CLERK eines tes We Y “COUNSEL FOR DEPARTMENT: Ellen C. Marino Senior Attorney Department of Business and Professional Regulation ~ 3725 West Grace Street, Suite 500 Tampa, Florida 33607 ECM/nen Case 497-22100 Jo

Docket for Case No: 01-002148PL