FILED Department of Business and Profesrional Regulation Deputy Agency Clerk STATE OF FLORIDA CLERK vette Lawson-Proctor DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATI Dets «3/2/2046 File # DEPARTMENT OF BUSINESS AND PROFESSIONAL REG ULATION, Petitioner, v. Case No. 2015-037979 JICE L. STOKES, Respondent. / ADMINISTRATIVE COMPLAINT The Department of Business and Professional Regulation (“Petitioner”) files this Administrative Complaint before the Construction Industry Licensing Board, Divisions I and II, against Jice L. Stokes (“Respondent”) and alleges: 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. At all times material hereto, Respondent was licensed as a Certified Roofing Contractor and a Certified General Contractor in the State of Florida, having been issued license numbers CCC 1325668 and CGC 58622. 3. Respondent's address of record is 17695 Oakwood Avenue, Boca Raton Florida 33487. 4. At all times material hereto, Respondent was the primary qualifying agent of Alpha South Construction, Inc. (“Alpha South”). 5. Section 489.1195(1)(a), Florida Statutes (2011), provides that all ptimary 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. 1 6. On or around February 17, 2015, Oswald Cooper (“Complainant”) entered into a contract with Leon Curtis Stewart (“Stewart”) for a re-roof at Complainant’s home located in Lauderhill, Florida. 7. The contract was for $3,300.00 8. Stewart was paid a total of $3,300.00 by Complainant. 9. Respondent applied for City of Lauderhill Building Permit No. 15030024 for the job contracted for by Stewart. 10. Respondent did not have a contract with the owner to perform the work specified in the permit. 11. At no time material was Stewart certified or registered to engage in the practice of contracting in the State of Florida. 12, Respondent knew or had reasonable grounds to know that Stewart was not certified of registered to engage in the practice of construction contracting in the State of Florida pursuant to Chapter 489, Part I, Florida Statutes. COUNT ONE 13. Petitioner re-alleges and incorporates by reference the allegations set forth in paragraphs one (1) through twelve (12) as though fully set forth herein. 14. Based on the foregoing, Respondent violated Section 489.129(1)(d), Florida Statutes, by assisting a person engaging in the unlicensed practice of contracting. COUNT TWO 15. Petitioner re-alleges and incorporates by reference the allegations set forth in paragraphs one (1) through twelve (12) as though fully set forth herein. 16. Based on the foregoing, Respondent violated Section 489.127(4)(c), Florida Statutes, by applying for or obtaining a building permit without entering into a contract to make improvements on the property referenced in the permit. 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 $10,000 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 15" day of February, 2016. KEN LAWSON, Secretary Department of Business and Professional Regulation ts/ SORIN ARDELEAN Assistant General Counsel Dept. of Business and Professional Regulation 1940 North Montoe Street, Suite 42 Tallahassee, Florida 32399-2202 (850)717-1226 Telephone (850)921-9186 Facsimile Sorin. Ardelean@myfloridalicense.com Florida Bar No: 734853 Probable Cause Found 01/26/2016 By: Korelishn/Pietanza Probable Cause Found 02/15/2016 By: Boyette/Burke NOTICE OF RIGHTS Please be advised that mediation under section 120.573, Florida Statutes, is not available for administrative disputes involving this type of agency action. Please be further advised that Respondent has the tight 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 present evidence and argument, to call and cross-examine witnesses and to have subpoenas and subpoenas duces tecum issued on his or her behalf if a hearing is requested. Rule 28-106.111, Florida Administrative Code, provides in part that if Respondent fails to request a hearing within 21 days of receipt of an agency pleading, Respondent waives the right to request a hearing on the facts alleged. NOTICE REGARDING ASSESSMENT OF COSTS Respondent is placed on notice that Petitioner has incurred costs related to the investigation and prosecution of this matter. Pursuant to section 455.227(3)(a), Florida Statutes, the Board, or the Department when there is no Board, may assess costs related to the investigation and prosecution of the case excluding costs associated with an attorney's time, against Respondent in addition to any other discipline imposed.

Docket for Case No: 16-005969PL