STATE OF FLORIDA . DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES <"7 ,, DIVISION OF MOTOR VEHICLES . OTSS3I PL DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES, DIVISION OF MOTOR VEHICLES, Petitioner, Case No.: DMV-07-1590 License No.: [H-0000097 v. LAURIE CREWS, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, the Department of Highway Safety and Motor Vehicles, Division of Motor _... Vehicles, files this Administrative Complaint against Laurie Crews, Respondent, and alleges: 1. Petitioner is the state agency charged with regulating the business of mobile home installation pursuant to section 20.24 and chapter 320, Florida Statutes and Rules 15-2.001, 15C- 1, 15C-2, and 28-107.004, Florida Administrative Code. 2. Respondent is, and has been at all times material hereto, a licensed mobile home installer in the State of Florida, having been issued license number IH-0000097. The address of record is 10560 Southeast Terrace Road, Candler, Florida 32111. COUNT ONE 3. Petitioner realleges and incorporates as if fully stated herein the allegations contained in the paragraphs above. 4. On or about August 29, 2007, John Priester, Division of Motor Vehicles Community Assistance Consultant, inspected a mobile home Respondent installed for Bonnie Green, 12675 Southeast 102 Avenue, Belleview, Florida 34420. 5. At the time of his inspection, Mr. Priester noted the following violations: a. One centerline pier was missing, in violation of Rule 15C-1.0102(1), Florida Administrative Code; Two or more centerline piers were not repacked with soil every six inches, in violation of Rule 15C-1.0102(4), Florida Administrative Code; Two blocks were cracked, in violation of Rule 15C-1.0102(6), Florida Administrative Code; One stabilizer plate was defective/broken, in violation of Rule 15C-1.0102(2), Florida Administrative Code; Five or more straps have seals with improper number of crimps, in violation ~~of Rule 15C-1.0104(5)(g), Florida Administrative Code;-——--—- Electrical wires and plumbing crossovers were not properly sealed, in violation of Rule 15C-1.010212), Florida Administrative Code, and Bottom board holes were not sealed, in violation of Rule 15C-2.0073(6), Florida Administrative Code. 6. Based on the foregoing, Respondent violated section 320.8249(9)(c), Florida Statutes, by violating the installation standards contained in Rules 15C-1.0102 to 15C-1.0104, Florida Administrative Code. COUNT TWO 7. Petitioner realleges and incorporates as if fully stated herein the allegations contained in one and two, above. 8. On or about September 10, 2007, the Department received a fax letter from Gilchrist County stating that Respondent had moved a home on to the property located at 1220 Southeast 100" Place, Trenton, Florida 32111, without first obtaining a building permit. 9. At the time of their inspection, Gilchrist County noted the following violations: a. Home had been located on the property without first obtaining a building permit, in violation of Rule 15C-2.0073(8), Florida Administrative Code. 10. Based on the foregoing, Respondent violated section 320.8249(9)(c), Florida Statutes, by violating the installation standards contained in Rule 15C-1.0102 to 15C-1.0104, Florida Administrative Code. EXPLANATION OF RIGHTS You have the right to request a hearing to be conducted in accordance with sections 120.569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to p present evidence and argument, to ‘call and ¢ cross-examine witnesses, and ito have subpoena and subpoena duces tecum issued on your behalf if a hearing is requested. In | response to the allegations set forth above, you must make one of the following elections and file your response within twenty-one (21) days from the date of your receipt of this Administrative Complaint. Please make your election on the enclosed Election of Rights form and ensure the Department receives it within 21 days. 1. If you admit the material fact(s) alleged in this Administrative Complaint, you may request a hearing, pursuant to section 120.57(2), Florida Statutes, before the Division of Motor Vehicles Hearing Officer. At this hearing, you would be given an opportunity to challenge the conclusions of law and/or present either written and/or oral evidence in mitigation of any proposed penalty. A request for this type of hearing, in which no material facts are in dispute, should be directed to the Office of the Hearing Officer, 2900 Apalachee Parkway, MD-61, Tallahassee, Florida 32399, by checking the appropriate space, marked as “1” on the Election of Rights form and ensuring the Office of the Hearing Officer, 2900 Apalachee Parkway, MS-61, Tallahassee, Florida 32399, receives it within 21 days from the date of your receipt of this Administrative Complaint. 2. If you dispute any material fact alleged in this Administrative Complaint, you must present sufficient evidence of your dispute and you may request a hearing, pursuant to section 120.57(1), Florida Statutes, at the Division of Administrative Hearings before an Administrative Law Judge. A request for this type of evidentiary hearing, in which material facts are in dispute, should be directed to the Office of the Hearing Officer, 2900 Apalachee Parkway, MS-61, Tallahassee, Florida 32399, by checking the appropriate space, marked as “2” on the Election of Rights form, and ensuring the Office of the Hearing Officer, 2900 Apalachee Parkway, MS-61, Tallahassee, Florida 32399 receives it within 21 days from the date of your receipt of this Administrative Complaint. If you elect an evidentiary hearing, you must keep the Office of the Hearing Officer, 2900 Apalachee Parkway, MS-61, Tallahassee, Florida 32399, informed of your current mailing address; failure to do so may be considered a waiver of your right to an evidentiary hearing. In the event you fail to file your election in this matter with the Office of the Hearing Officer, 2900 Apalachee Parkway, MS-61, Tallahassee, Florida 32399, within 21 days from your receipt of this Administrative Complaint, your failure may be considered a waiver of your right to dispute the alleged facts and the Department may proceed to enter a Final Order. Pursuant to section 120.573, Florida Statutes, mediation is not available for this proceeding. WHEREFORE, the Department hereby gives notice of its intent to enter an Order imposing one or more of the following penalties: revocation or suspension of Respondent's license, imposition of an administrative fine, placement of Respondent on probation, imposition of testing requirements and/or any other relief deemed appropriate. ‘atl A. Ford, Direct Division of Motor Vehicles Department of Highway Safety and Motor Vehicles Neil Kirkman Building, Room B439, MS 60 Tallahassee, Florida 32399-0600 Filed in the official records of the Division p¥Motor Vehicles this_ Y= day of November, 2007. CAF:clb Copies furnished: Bureau of Mobile Home & RV Const. Wayne Jordan, Program Manager License Installer Program By certified mail to: Laurie Crews P. O. Box 19 Candler, Florida 32111-0019

Docket for Case No: 07-005539PL