HomeMy WebLinkAboutBUUILDING & DOOR INSULATION -iNSTALLATION DIVISIONI
SCANNED)
By
Stwviproanv
ST. LUCIE CO
PLANNING AND DEI
BUILDING AND CODE
HERBERT J. T. WILSON, II,
Complainant,
and
ST. LUCIE COL;N'IY and
DEBRA ZAMPETTI, Supervisor,
Respondents.
Re: Permit # 1804-0084 / Notice of Inquiry
SERVICE: US Postal Service Certified Mail N
Return Receipt Requested
NOTICE OF INQUIRY INTO SUBORD:
FORMER ST. LUCIE COUNTY
DAVID JOHNSON .
1. THIS IS NOTICE that current and
David Johnson and Teriy Chissoe committed
FLORIDA
MENT SERVICES
LATION DIVISION
MAY `:0 2019
Case No.: „a, 8,� ,.G�a �:��- '
� 4&_r`'!ate'�`3 Q 9 A 1 i d9\; di
Subordinate Misconduct,
E MISCONDUCT BY CURRENT AND
LOYEES GARY SCHEIGNER,
TERRY CHISSOE
St. Lucie County employees Gary Scheigner,
acts in the name of the County which amount
to misconduct, collusion, deceit, fraud, and/or sta ' 'ke causing irreparable harm. County employees
are public officials receiving public funds an subject to Section 112.311, Florida Statutes. This
NOTICE is made under the obligation of god faith in accordance with Section 671.203, Florida
Statutes. Therefore, upon receipt of this N(
Statutes, you have ACTUAL. KNOWLEDGE
2. Failure of a government official to
ordinances, county policy & procedure, and
thirty days, will result in repudiation of your c
ICE, in accordance with Section 671.203, Florida
d LLABILT y of the information contained herein.
action to correct violation(s) of State Law, local
s within a set period of time not to exceed (30)
(s) of office.
3. When a supervisor of a county
a subordinate's misconduct but fails to initiate
Herbert J.T.- Wilson, II
Notice of Subordinate Misconduct
May 20, 2019
/division has information or actual knowledge of
corrective action to correct said misconduct, this
would constitute misfeasance, dereliction of duty, and an omission of a duty to perform. Your duty
to perform is imposed by statute, ordinance, and e Constitution of the State of Florida.
4. A person, especially a supervisor of
knowledge of misconduct but fails to inquire c
official duty. Notice creates a right to immediate
Code Division of St. Lucie County having knowl
5. The employees alleged to have commi
Planning and Development Services, Building
this notice.
6. All subjects of this notice have signed a
United States and the State of Florida. Further,
State of Florida and the ordinances of St. Lucie
subjects of this notice had a ministerial duty
authority, including but not limited to Florida
7. The C.A. Hunter Trust ("the Trust") o«
Jensen Beach, St. Lucie County, Florida 349.
referred to as a duplex. The Trust owns one half
8. In January 2018, the Trust's
other half of the structure) about replacing the
two parties agreed to replace the roof and begs
re -roof of the structure. The parties agreed to
Ray"), a for profit corporation with its principal
Florida.
department/division of the county, who has
investigate such misconduct, is in breach of an
by the Supervisor of the Building and
misconduct were employees of St. Lucie County,
Code Regulation Division at all times material to
oath swearing to uphold the Constitutions of the
have taken an oath to uphold the laws of the
ity. See Section 112.311, Florida Statutes. The
Section 112.311, Florida Statutes to obey legal
s, Florida Building Code, and local ordinances.
UND
a residential property located. at 44 Aqua Ra. Dr.
The property contains a structure commonly
the structure and its surrounding property.
ve was approached by her neighbor (owner of the
)of on the duplex because his roof was leaking. The
talcing bids from roofing companies to perform the
)ntract with :Manta Ray Construction, Inc. ("Manta
)lace of business in Jensen Beach, St. Lucie County,
2
9. On February 27, 2018, the Trust, through
received a proposal that later became the cont
representative, Stephen Drake Marston ("Marsto:
License # CC1330490. Marston is the "Qualifying
Trust accepted the terms of the proposal and
Construction, Inc. for the re -roofing of the I
together they will be referred to as "the Contra
Herbert J. i'. Wilson, II
Notice of Subordinate Misconduct
May 20, 2019
legal representative Theresa Krupa ("Krupa"),
from Manta Ray through the corporation's
a certified/licensed roofing contractor, State
ent" for Manta Ray. On February 27, 2018, the
i into a construction contract with Manta Ray
T. When referring to Manta Ray and Marston
10. During the re-roofing/construction procIIss, the roof on the Trust's side of the structure
experienced a leak that resulted in extensive clam -age to the structure and the personal property of
the occupant and Trust representative, Theresa J. Krupa. Further, Krupa was forced to relocate
during the rebuilding of the interior of the
11. The Trust and Krupa are now in engaged an expensive and protracted legal battle with the
Contractor and his insurance carrier for negligen e, breach of contract, and fraudulent inducement.
Further, a formal complaint against the Contract
currently being prosecuted by the Department of
PRELIMIN
12. Herbert J.T. Wilson, II, is the Co-'
husband of Krupa.
13. Theresa J. Krupa is the legal represents
agreement was the leasee/tenant of the property
14. Steven Drake Marston was the last
Inc. Manta Ray was administratively dissolvt
September 22, 2017, some five months before
representative of Manta Ray. Marston was i
existence when he entered into the contract.
pursuant to Section 455.225, Florida Statutes is
and Professional Regulation.
STATEMENT
of the C.A. Hunter Trust and the common law
of the 'Trust and pursuant to a five year lease
all times material to this notice.
Director and Officer of Manta Ray Construction,
by the State of Florida Department of State on
arston entered into the construction contract as a
3
aware that the corporation was no longer in
STATEMENT
THE FACTS
Ilerbert J.T. Wilson, II
Notice of Subordinate Misconduct
May 20, 2019
15. On February 27, 2018, Marston presented 6 proposal to the Trust through its representative
for the re -roofing of the Trust's half of the strut 1 e. The proposal, which later became the contract,
was written on Manta Ray letterhead and outlined the scope of work, method of construction and
the materials to be used. Specifically, the proposal I contract stated. the Contractor was to remove the
existing asphalt shingle roof, install Tri-Built 1
underlayment with a NOA# of 15-1123.06 to
velocity wind zones and install Metal Fabricators
self -adhering, modified, high temperature, metal
the Florida Building Code requirements for high
-5V Crimp (R6) metal roofing panels.
16. On the same day the Trust accepted the t6rms of the proposal, including the scope of work,
method of construction and materials to be used) and entered into a legal and binding construction
contract with Manta Ray for the re -roofing of 44
17. The contract, as provided by the
statement explaining the Trust's rights under
Section 489.1425(1), Florida Statutes.
Ra Dr., Jensen Beach, Florida 34957.
and signed by all parties did not contain a
Construction Recovery Fund in violation of
18. The Contractor hired Florida Professional Engineer Paul Welch, Reg. # 29945 ("the
Engineer"), to engineer the project. On March 30, 2018, the engineer provided the Contractor with
the required engineering documents needed t , obtain the building permit. In the engineering
documents, the engineer detailed the scope o work and set the method of construction. The
engineer specifically required the Contractor to
This underlayment is an approved product of d
19. On April 4, 2018, the Contractor
engineering documents to St. Lucie County
20. On April 20, 2018, St. Lucie County
Building Permit #1804-0084
Tri-Built underlayment with NOA# 15-1123.06.
Florida Building Code.
4
a building permit application with the
Officials for the re -roofing of the property.
Officials approved the application and issued
21. On or about May 3, 2018, the
sending a crew to the residence to remove the e:
installed a number of different undcrlayment ma
Resisto Corporation of Ohio. The underlay
required by the Engineer, or approved by the
22. On May 11, 2018, County Building Insp
a "roof dry -in inspection". Inspector Johnson
was not made for metal roofs and materials w
roof should have failed inspection for
required by the Engineer.
23. Neither County Building Officials nor
roof failed inspection because it contained the
24. On May 12, 2018, Krupa became aware
Contractor and inquired about what needed
intrusion during the coming storm(s).
25. On the same day, Marston came to the
schedule and informed Krupa that the underlay
three days prior) forms a water tight seal and
against water intrusion.
26. On or about May 13, 2018, a wind a
inspection failed to provide a watertight seal a]
water to enter the residence causing extensive
Krupa.
27. On or about May 14, 2018, the Con
damaged the interior of the residence including
Herbert J.T. Wilson, II
Notice of Subordinate Misconduct
May 20, 2019
commenced performance of the contract by
isting asphalt shingle roof. Next, the Contractor
crials including a materials manufactured by the
s) were not materials described in the contract,
in the building permit.
David Johnson, License #BN5356, performed
l the roof because it contained a material that
not installed. per manufacturer's guidelines. The
materials not found on the Building Permit and
Contractor informed the property owners that the
building materials.
a coming rain and windstorm and contacted the
be done to protect the residence from water
Bence to pick up a check pursuant to the draw
t (the same underlayment that failed inspection
needed to be done to protect the residence
rainstorm occurred. The underlayment that failed
5
rain water to saturate the plywood decking and
e to the structure and the personal property of
was notified that the roof failed and water
onal property.
28. On or about May 14, 2018, the
to protect against further water intrusion.
29. After inspecting the roof, the Contractor
the roofing materials, specifically lie stated the
did not properly bond to the plywood decking.
inspection and contained the wrong building
30. It is not known if the Contractor
failure.
31. At this point, the Contractor decided to
was leftover building materials from prior j<
Corporation and advised them that their buildin
property. The Contractor failed to inform Resist
be on the roof in the first place and was not an
later learned that the Contractor led Resisto to b
32. Without the Trust's knowledge and
the method of construction and.materials to be
Herbert J.T. Wilson, II
Notice of Subordinate Misconduct
May 20, 2019
inspected the roof and had a crew tarp the roof
.ied Krupa the leak was caused by a defect in
yment did not contain enough adhesive and
Contractor did not inform Krupa the roof failed
informed County Building Officials of the roof
step responsibility for installing what probably
he completed and he contacted the Resisto
materials were defective and caused the leak at the
that their building materials were not supposed to
product on the Building Permit. The Trust
he was installing an asphalt shingle roof.
gaining the Engineer's approval for changing
County Building Officials, the Contractor and
Representatives of the Resisto Corporation met �nd devised an improper method of construction to
correct the failed undetlayment.
33. To correct the failed underlayment, the
David Johnson decided to alter the construct
the County in its Building Permit by allowing
failed underlayment (membrane) and mechaj
screws and then installing a new layer of and
Resisto and County Building Inspector
method ordered by the Engineer and approved by
Contractor to place a layer of 30# paper over the
lly attaching it to the substrate with tin tabs and
The County did not require the Contractor
to remove the failed underlayment or remove and replaced the damaged, water saturated plywood.
6
34. The construction method devised by the
Herbert J.T. Wilson, II
Notice of Subordinate Misconduct
May 20, 2019
violates the Florida Building Code and is in
direct contravention of the material's limitations found in the underlayment's Product Approval,
Further,
NOA# 15-1123.06, page 4, paragraph 4. is construction method will negatively affect the
serviceable life of the roof.
35. The Trust would have never agreed to
informed would have required the roof be re-eng
replaced, and proper methods of construction be
36. The Contractor was aided by the
application and they somehow tricked Plans
application. The revision application falsely states
was "switching Product Approval for metal L
installing 30# Vt then Tri Built HT DG". The ap:
roof failed and the contractor installed the wron
Contractor knew when he applied for the
because Resisto agreed to provide new
37. Had the County been informed this
underlayment be removed and would have
the Product Approval's Limitations.
method of construction and had they been
the water logged plywood be removed and
:d for correcting the problem.
Building Inspectors in filing a falsified revision
Terry Chissoe into signing off on the revision
t the revision is needed because the Contractor
to Miami -Dade because were (sic)
does not inform building officials that the
underlayment and this was in fact a repair. The
he was not going to use Tri Built underlayment
a repair they would have required the wrong
approved a method of construction that violated
38. Because of concerns about the integrity of the roof, changes to the method of construction
and the method used to correct the failed underlayment, the Trust hired licensed independent
roofing inspectors Jack Brown and Associates t I perform and inspection and evaluation of the roof
after it was completed and final inspection was performed by the County.
39. On or about July 25, 2018, Jack
and Associates inspected the roof and determined
there were significant construction defects and deficiencies in the repair of the failed underlayment
and the installed roofing system.
7
40. The roofing system as installed by
Officials contains the following defects and
a. Pwood Decking — Roof cone
that became wet when the und�
b. Underlayment — Roof contav
under metal roofing and not fc
underlayment should have b
underlayment New underlayn
with Florida Building Code a
Assemblies and installation me
Limitations by being installed c
c. Vents — Roof does not contai
rear plane of the roof as require
d. Metal Roofing — Metal roofin
Layout of panels results in n,
manufacturer which impedes
the manufacturer's installation
e. Sealant — Sealant not installed
Code 1507.4.2 and required
instructions. Sealant missing i
wrong locations preventing pre
f. Roofir System — Roofing Sys
water tight and continues to lea
41. On July 30, 2018, the Trust caused a
Contractor by certified mail as required by
a copy of the report of Jack Brown and
42. The Contractor failed to respond to the
inspect and/or repair the construction defects
43. As a result of the contractor
roof leaked again in November of 2018 and
Herbert J.T. Wilson, II
Notice of Subordinate Misconduct
May 20, 2019
Contractor and approved by County Building
ns water damaged plywood decking
layment failed.
undedayment that is not allowed
rid on the building permit. Incorrect
:n removed before installing new
nt was not installed in accordance
I the material's Product Approval.
Lod violates the Product Approval's
�r another membrane.
the two 4' Acrylume vents on the
by the contract.
panels were not installed properly.
capillary break as designed by the
Lter flow and drainage and violates
i compliance with Florida Building
)y the manufacturer's installation
required locations and installed in
esigned water drainage.
as installed by Contractor is not
of Construction Defects to be sent to the
558, Florida Statutes. Attached to the notice was
Notice and failed to return to the property to
deficiencies of the newly installed roof.
"558" notice and failing to repair the roof, the
Trust will be compelled to hire another roofing
contractor to correct the construction defects and deficiencies.
44. The cumulative effect of the many
Contractor require the roof to be removed
installed.
45. In order to properly repair the roof, the
Herbert J.T. Wrilson, II
Notice of Subordinate Misconduct
May 20, 2019
and deficiencies of the roof as installed by the
to the trusses, repairs made and a new roof
f on the entire structure (units 42 and 44) must
be removed and replaced as it was installed as oAe roofing system by the Contractor and contains
the same defects and deficiencies and if not replal ed as one roofing system it will negatively affect
the integrity and serviceable life of the roof.
46. In addition to the cost of having to
Trust has suffered damage to the interior of the
has suffered loss of personal property.
IMPROPER ACTIONS
a. County Building Officials failed to infort
inspection because it contained the wror
b. County Building Officials aided and allot
method of construction and materials to
property.
c. County Building Officials aided and allo`
method of construction and materials to
revising the Building Permit.
d. County Building Officials approved a mt
Notice of Acceptance and violated the F
e. County Building Officials participated in
owner and contractor without consuldi4
f. County Building Officials failed to requv
not approved and permitted.
g. County Building Officials aided and abet
Revision Application.
h. County Building Officials allowed the cc
Building Permit Revision. Roof does not
47. The primary purpose of having a p
public and their property by ensuring that
the construction defects and deficiencies, the
twice; loss of rent, loss of use and Krupa
COUNTY OFFICIALS
the property owners that their roof failed
materials.
;d a contractor to change the scope of work,
e used without consulting the owners of the
. a contractor to change the scope ofwork,
used without consulting the Engineer and
hod of construction that violates the materials
:)rida Building Code.
filtering a construction contract between a property
the property owner.
the contractor to remove underlayment that was
a contractor in filing a falsified Building Permit
to install a material not approved by the
contain Tri- Built Underlayment.
ijting authority and building officials is to protect the
9
engaged in building or remodeling adhere to the
Florida Building Code and local building ordinanc(
or damaged by someone else's shoddy constructi
taken on the added responsibility of protecting f
conmen. Although some contractors are county
Regulation Division or Building Inspectors the aut
on a job by aiding them in designing the least exl
gives the County the authority to design and de
engineer's method of construction and materials to
pro)ect.
48: Briefly, this notice/complaint arises out
discovered the contractor in this case installed se
made for metal roofs, then engaged with the o
correcting the problem without ever involving the
49. The inspector knew that the only reason
roof was the Contractor was improperly using lef
defrauding the property owners.
50. Then this same inspector helped the contracto
building officials approved it. Building Officials we
inspector (he also accepted the revision application for
repair NOT a revision. All work should have stoppec
permit application submitted for approval.
51. Every engineer the Trust has consulted
removed, the water damaged plywood replaced and
approve a method of construction that violates the:
states that the underlayment is not to be installed on
the Florida Building Code.
10
Herbert 1.T, Wrilson, II
Notice of Subordinate'Mixonduct
May 20, 2019
so that citizens and their property are not hurt
L. Over the years, building officials have also
citizenry from unscrupulous contractors and
sidents nothing gives the Building and Code
ity to protect contractors from losing money
;ive means of correcting a mistake. Nothing
a correction or participate in changing an
used without consulting the engineer for the
the fact that a county building inspector
different types of underlayment, some not
to devise the least expensive means of
owners or engineer.
were different types of underlayment on the
building materials to save money and this was
file a falsified revision application and other
not informed by the Contractor or the
ae counter) that the roof failed and this was a
the roof re -engineered, and a new building
the wrong building material had to be
underlayment installed. No engineer would
xal's Notice of Acceptance Limitations that
of another membrane. This would violate
52. It is unconscionable that a county employ
engaged in a scheme to defraud a tax paying citi
materials. If this inspector would have blown the
other county building officials when he discover
protect the residence from water intrusion when th
53. There should be no doubt that had the
never agreed to the method devised to repair the
remove the wrong underlayment and repair the dai
RELIEF
1. Immediately start an investigation
appropriate disciplinary action against the
involved.
2. Issue a statement from St. Lucie County
0
4.
5.
6.
Code Regulation Division stating:
a. The roof on 42 & 44 Aqua Ra Drive, Jer
building materials not approved by the b
b. The method of construction and materia
contractor.
c. The Contractor misled County Building
revision application.
d. That it was error to not require the contr
inspection.
e. The Contractor's workmanship fell beloc
Florida Building Code.
Immediately undertake an investigation and i
Marston for his construction practices and fc
Building Officials.
Answer in writing the enclosed questions cor
Fill the enclosed public records request withc
Immediately issue rules and policy and proce
tax payers in the future.
11
Herbert J.T. Wilson, II
Notice of Subordinate 11lisconduct
May 20, 2019
aided and abetted an unscrupulous contractor
i of the county by installing leftover building
whistle and informed the property owners and
d these facts, steps might have been taken to
roof failed three days later.
been privy to any of these facts, it would have
:)f and would have required the Contractor to
plywood decking.
UES'TED
building permit # 1804-0084 and take
and county employees who were
and Development Services, Building and
n Beach, St. Lucie County Florida contains
ding perinit.
to be used was improperly changed by the
fficials by filing a falsified building permit
to remove underlayment that failed
industry standards and the requirement of the
we against Florida Contractor Steven Drake
filing falsified revision applications with
the county's policies and procedures.
cost.
e to ensure this does not happen to citizen
54. If the above -mentioned terms are met, w4hi
C.A. Hunter Trust will waive all liability of the
concerning building permit #1804-0084.
55. Non-performance of your legal duty will
certified by issuance of an Affidavit of Non -Re
evidence of failure to perform your legal duty. Tht
public officers and employees is expressly prescribe
the mandate of legal authority without exercise of t
consideration as to the propriety of the action taker.
56. In the event the terms are not accepted,
indemnify the Trust and Theresa J. Krupa for li
related to the actions of the St. Lucie County
#1804-0084.
57. In addition, in the event the terms are not
the undersigned requests that you disclose the i
liability for each insurer for which you may have c
a copy of the subject policies. You are hereby
disclosure to your insurers in the event the Col
settlement.
If you should have any questions please feel
Theresa J. Krupa at (772) 206-1980.
12
Herbert J.T. Wilson, II
Notice of Subordinate Misconduct
May 20, 2019
a period not to exceed (30) thirty days, the
and hold the County harmless in all actions
go unnoticed and unreported and will be
;e that will be filed in future litigation as
standard of conduct demanded and required of
1 by legislative enactment, insuring obedience to
persons own judgment, discretion or personal
CA Hunter Trust demands the County fully
y, damages and other claims arising from or
its employees in processing Building Permit
)ted, pursuant to Florida Statutes 627.4137,
and coverage, together with the limits of
for any acts or omissions. Please provide
ed to forward the instant demand for
does not accept the terms of the offer of
to contact the or the Trust's representative,
Sincerely,
Herbert J.T. ilson, II