Apr 3 200? 14:52 a@d/ag/2ae7 1d:4l 8589219186 DEPR PAGE @3/a9 ) ; ) STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION CONSTRUCTION INDUSTRY LICENSING BOARD DIVISION I DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, v. Case No. 2005-043416 LAURA LYNNE HILL, D/B/A HOMES BY LAURA, INC. Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Construction Industry Licensing Board, against LAURA LYNNE HILL, D/B/A HOMES BY LAURA, INC., ("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 Residential Contractor in the State of Florida, having been issued license number CR C1326886. Apr 3 200? 14:52 ad/ag a@d/ag/2ae7 1d:4l 8589219186 DEPR PAGE ) } 3. Respondent's last known address of record is 4924 Hidden Oaks Trail, Sarasota, Florida 34232. 4. The Respondent misrepresented her job experience and other information when she submitted her second application for a Certified Residential Contractor (“application”) on August 21, 2003, 3. The Respondent misrepresented her job duties with Cali Homes by Laura (“Cali Homes”) on her application by stating that she worked as a foreman. The Respondent did not work on the jobsites or act as a foreman, the only duties that the Subject held while working with Cali Homes consisted of design, customer service, and office work. 6. Thomas Schmidt (“Schmidt”) did not have direct knowledge of the Respondent’s work experience, as claimed on the Respondent’s application. Schmidt did not know the Respondent long enough to attest to the Respondent’s work experience. The only knowledge the Schmidt may have of the Subject’s work experience may be from intermittent visits with the Subject to her jobsites with Cali Homes. 7. In a deposition taken of the Respondent on October 11, 2004, the Respondent indicated her lack of work experience by stating that even though she did not hammer nails that she worked as a workman for four years with two different people. 8. On or about September 18, 2005, Joseph Pinto (“Pinto”) submitted a letter to the Department of Business and Professional Regulation (DBPR) stating that during the four years that he did business with the Respondent, he only knowledge of her picking up plans, reviewing quotes, marking plans, and ordering windows. Pinto stated that he did not feel comfortable corroborating her construction experience. Apr 3 200? 14:52 q a@d/ag/2ae7 1d:4l 8589219186 DEPR PAGE 85/8 } , } 9, On or about July 5, 1996, the Respondent submitted the first application to obiain her Certified Residential Contractor licenses. | 10. On or about August 14, 1996, the Construction Trades Board (“the Board”) declined to give the Respondent permission to take the Class B examination to obtain her Certified Residential Contractors license because the Respondent did not have the adequate amount of experience required, By doing this, the Board effectively denied the Respondent’s application for a Certified Residential Contractor. 11. The application completed by the Subject on August 21, 2003 that allowed her to get her current license indicates that she has never been denied an application for registration, certification, or licensure in the State of F lorida, COUNT I 12. Petitioner realleges and incorporates the allegations set forth in paragraphs | through 11 above as though fully set forth herein. 13. Based on the foregoing, Respondent violated Section 489,129(a), Florida Statutes, by obtaining a certificate, registration, or certificate of authority by fraud or muisrepresentation. COUNT II 14. Petitioner realleges and incorporates the allegations set forth in paragraphs | through 11 above as though fully set forth herein, 15. Based on the foregoing, Respondent violated ‘section 489.129(1)(m), Florida Statutes, by committing incompetency or misconduct in the practice of contracting. Apr 3 200? 14:53 PAGE 86/a9 a@d/ag/2ae7 1d:4l 8589219186 DEPR } : : 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 453.227(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 Go day of fi Re, , 2006, Brian Elzweig Assistant Gen if Counsel COUNSEL FOR DEPARTMENT: Brian Elzweig F | L. FE \ Assistant General Counsel sonal Regulation Department of Business and Department of Business and Professional Reg Professional Regulation AGENCY CLERK Office of the General Counsel 1340 N. Monroe Street, Ste. 42 Tallahassee, FL 32399-2202 CLERK “A wy Zt. WW | nm Case #: 2005-043416 DATE 2 =| A-Z OO BE/sh Po Found [ss lo Wh TTrorate + Roe

Docket for Case No: 07-001536PL