HomeMy WebLinkAboutMinutes 02.28.202214a1ee71-ec15-49a3-8e03-9c913fa632d6Electronically signed by Karen M. Bellemare (301-293-169-3900)
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CONTRACTORS EXAMINING BOARD
Wednesday, February 28, 2022
TIME: 8:35 A.M. to 5:25 P.M.
PLACE: Commission Chambers of the Roger Poitras Annex
2300 Virginia Avenue
Fort Pierce, FL 34982
BOARD MEMBERS PRESENT:
James "Travis" Leonard (Chair)
Tony Jerger (Vice Chair)
Michael DiFrancesco (Secretary)
Michael Pride
Chris Langel
Adam Sampson
Sheila McCarthy-Taylor
ATTORNEYS:
Deana Falce, Esq.
Shubin & Bass, P.A.
46 SW 1st Street, Floor 3
Miami, FL 33130-1610
Walter Mathews, Esq.
Mathews Giberson LLP
1400 SE 11th Street
Fort Lauderdale, FL 33316-1377
COURT REPORTERS, INC.
108 North Depot Drive
Fort Pierce, FL 34950
info@court-reporters.com
772-464-2664
14a1ee71-ec15-49a3-8e03-9c913fa632d6Electronically signed by Karen M. Bellemare (301-293-169-3900)
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1 INDEX
2 Page
OPENING STATEMENTS
3 By Ms. Falce 5
By Mr. Mathews 8
4
Statement by Mike Ciccio 10
5
WITNESS: Mike Ciccio
6 Examination by Mr. Mathews 25
Questions from the Board 28
7 Examination by Mr. Matthew 34
Examination by Mr. Falce 61
8 Examination by Mr. Mathews 63
9 WITNESS: Nicki Crooks
Statement by Ms. Crooks 68
10 Direct Examination by Ms. Falce 88
Questions from the Board 105
11 Cross Examination by Mr. Mathews 125
Questions from the Board 184
12
WITNESS: David Johnson
13 Direct Examination by Ms. Falce 193
Cross Examination by Mr. Mathews 201
14 Redirect Examination by Ms. Falce 212
Recross Examination by Mr. Mathews 215
15 Questions from the Board 215
16 WITNESS: Clyde Heffelfinger
Direct Examination by Ms. Falce 219
17 Cross Examination by Mr. Mathews 224
18 WITNESS: Lindolph Campbell
Direct Examination by Ms. Falce 229
19 Questions from the Board 261
Redirect Examination by Mr. Mathews 282
20
WITNESS: Nicki Crooks
21 Questions from the Board 300
22 WITNESS: Todd Roberts
Direct Examination by Mr. Mathews 304
23 Cross Examination by Ms. Falce 338
Questions by the Board 343
24 Redirect Examination by Mr. Mathews 359
25
3 (Pages 3 to 6)
14a1ee71-ec15-49a3-8e03-9c913fa632d6Electronically signed by Karen M. Bellemare (301-293-169-3900)
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1 P R O C E E D I N G S
2 ---
3 MR. CHAIRMAN: It is 8:35 on Monday, February
4 28th. I call the Contractor's Examining Board
5 meeting to order. Madam Secretary, would you
6 please call the roll?
7 MS. JOHNSON: Good morning, everyone.
8 Mrs. Taylor?
9 MS. TAYLOR: Yes, ma'am.
10 MS. JOHNSON: Mr. DiFrancesco?
11 MR. DIFRANCESCO: Yes, ma'am.
12 MS. JOHNSON: Mr. Jerger?
13 MR. JERGER: Yes, ma'am.
14 MS. JOHNSON: Mr.Leonard?
15 MR. LEONARD: Yes, ma'am.
16 MS. JOHNSON: Mr. Pride?
17 MR. PRIDE: Yes, ma'am.
18 MS. JOHNSON: Mr. Sampson?
19 MR. SAMPSON: Yes, ma'am.
20 MS. JOHNSON: Okay.
21 MR. CHAIRMAN: I'm really happy to have a full
22 quorum here and everyone showed up for this special
23 meeting. Thank you guys for being here.
24 MS. JOHNSON: I'm sorry, Mr. Langel?
25 MR. LANGEL: Yes, ma'am.
Page 4
1 MR. CHAIRMAN: There you go. Next we have
2 swearing in of the staff members.
3 MS. JOHNSON: Please state your name for the
4 record.
5 MS. WATERS: Alphanette Waters.
6 MS. WILLIAMS: Danielle Williams.
7 MR. JOHNSON: Dave Johnson.
8 MR. HEFFELFINGER: Clyde Heffelfinger.
9 MR. CICIO: Mike Cicio.
10 MS. JOHNSON: Do you affirm to tell the truth,
11 the whole truth, and nothing but the truth?
12 STAFF MEMBERS: Yes.
13 MR. CHAIRMAN: Thank you, Madam Secretary.
14 Thank you staff.
15 Next on the agenda, we hold this time for
16 public comment. Anybody willing and wishing to
17 come up and speak at this meeting is more than
18 welcome to.
19 Seeing none, we'll close the public comment.
20 Next on the agenda, is a disciplinary case we
21 have in front of us.
22 Staff, would you please present the
23 disciplinary case?
24 MS. FALCE: Yes. Good morning, Chairman and
25 members of the Board. My name is Deana Falce. I
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1 work at Shubin & Bass, 46 SW 1st Street, Miami,
2 Florida 33130. I've been hired by staff as outside
3 counsel in this matter and so I will be presenting
4 the case along with staff and our other witnesses
5 this morning to you all. So good morning. Nice to
6 see you. Thank you for taking the time to -- to
7 hear this case. All right.
8 We are here on Case No. 104669 against
9 Abe Shultz Construction, LLC and Lindolph --
10 Mr. Lindolph Campbell. We are here because staff
11 has investigated a complaint received by the
12 homeowners, Ms. Nicki Ann Crooks, who presented the
13 complaint related to the construction on the
14 reroofing of her home.
15 You will hear testimony today showing you,
16 demonstrating to you that there are three bases to
17 suspend or revoke the construction license of
18 Mr. Lindolph Campbell and Abe Shultz Construction,
19 LLC.
20 Those are disregarding and violating an
21 applicable building code section for this reroof
22 project, performing an act which assists a person
23 or business in performing unlicensed contracting
24 work, and committing fraud or deceit or other
25 misconduct in the practice of contracting.
Page 6
1 Pursuant to Section 10-67 of the
2 St. Lucie County Code, any one of those reasons, as
3 you know, could be grounds to suspend or revoke the
4 license but here we have evidence of all three.
5 And so I'd like to start the proceedings by
6 calling Mr. Cicio to give his statement, present
7 the facts of what he investigated, what he found in
8 conjunction with the building inspectors employed
9 by St. Lucie County, and then we will follow that
10 with the homeowner which will present her
11 statement, and we will ask the building inspectors,
12 Mr. Clyde Heffelfinger and Mr. Dave Johnson to --
13 to also take the stand and present their testimony
14 as to what they saw during their in-person
15 inspections of this home.
16 And so without further adieu, I will have
17 Mr. Cicio begin his statement, and I do reserve
18 time at the end and during questioning for
19 rebuttal, whether that's questions of witnesses,
20 additional witnesses that opposing counsel may
21 call; and, also, at the end, to give a brief
22 closing statement to wrap it up.
23 MR. CHAIRMAN: Thank you.
24 MS. FALCE: So thank you. I appreciate your
25 time.
4 (Pages 7 to 10)
14a1ee71-ec15-49a3-8e03-9c913fa632d6Electronically signed by Karen M. Bellemare (301-293-169-3900)
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1 MR. CICIO: Good morning. And thank you, very
2 much.
3 MR. MATHEWS: Wait. Excuse me. Mr. Leonard,
4 do I get an opportunity to make an opening
5 statement?
6 MR. CHAIRMAN: Ms. Barbieri, you're going to
7 have to help me out on this one.
8 MS. BARBIERI: Yes. For the record,
9 Assistant County Attorney Katherine Barbieri. We
10 don't follow the formal rules of evidence. We do
11 due process; and if he wishes to do an opening
12 statement, I know that's not normal but that would
13 be within the -- for due process would be
14 acceptable.
15 MR. CHAIRMAN: Okay. Thank you,
16 Mrs. Barbieri. And please bear with me. I'm no
17 judge by no means, but I'm a pretty fair guy. So
18 you'll find that out.
19 MR. MATHEWS: Okay. I appreciate that and I
20 understand the formal rules of evidence don't
21 apply. There's certain decorum, and I think we're
22 both practicing lawyers so I think that we'll
23 respect each other, and the -- the panel in the
24 process.
25 MR. CHAIRMAN: Thank you.
Page 8
1 MR. MATHEWS: We just want the facts to come
2 out in sort of an orderly process with the ability
3 to inform the entire tribunal about what happened
4 with the underlying situation.
5 My name is Walter Mathews. I'm an attorney on
6 behalf of Abe Shultz Construction, LLC and Lindolph
7 Campbell, who's at my right. We're here to respond
8 to the allegations against Abe Shultz Construction
9 and Lindolph Campbell and protect their reputation.
10 Abe Shultz Construction is a small company.
11 It's not a large corporation. The evidence will
12 show that Abe Shultz and Lindolph Campbell were not
13 aware of Andrew Brown's initial repair work at the
14 4032 property until at least October of 2020, and
15 really, they didn't learn about it until
16 November of 2020.
17 When this job was brought to the attention of
18 Lindolph, he obtained the necessary permit and
19 sought to complete the job in a workman-like
20 manner. Lindolph was not aware that St. Lucie
21 County required him to have on-site inspection of
22 the sheathing and that would be -- we'll get some
23 more evidence on that. Instead, Lindolph was
24 advised to take photographs and submit them to
25 St. Lucie County. He completed the job, yet the
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1 homeowner immediately filed a complaint and refused
2 to pay the final amount due of $3,000. Of
3 importance, the homeowner wanted a full refund, or
4 at least a very deep discount. And in addition,
5 they wanted him to complete work that was beyond
6 the scope of what was agreed to -- to be done.
7 Later, the homeowner complained and an
8 inspector discovered at best some minor
9 deficiencies. Mr. Campbell returned to the job
10 site several times to do what was necessary to
11 close the permit. During this time frame, the
12 homeowner placed additional demands upon Abe Shultz
13 and prevented the work from being complete. Again,
14 the homeowner wanted either a full refund,
15 additional work, or a deep discount.
16 To be clear, Abe Shultz did not disregard
17 applicable building code, did not assist
18 Andrew Brown in unlicensed business and did not
19 engage in misconduct in the practice of
20 contracting. Abe Shultz is willing to complete the
21 work within the scope of what he agreed to do in a
22 reasonable amount of time, as long as there's a
23 meeting of the minds as to what work is to be
24 performed and the amount of compensation that he'll
25 be paid.
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1 I thank you for your time. I look forward to
2 presenting the facts and hopefully we can all
3 figure this out today.
4 MR. CHAIRMAN: Thank you, Mr. Mathews.
5 Mr. Cicio?
6 MR. CICIO: Good morning. My name is
7 Michael Cicio. I'm a contracting licensing
8 investigator for St. Lucie County. I've held this
9 position since August of 2019. Prior to my work
10 with the County, I was a Senior Compliance
11 Investigator for the State of Florida for seven
12 years. I am Code Enforcement Level 1 certified. I
13 am the contractor licensing investigator assigned
14 to investigate the case before the Board this
15 morning, Case No. 104669 against Abe Shultz
16 Construction, LLC and/or Lindolph Campbell.
17 For the record, I'm submitting the following
18 documents as evidence into the record of these
19 proceedings: Ten photos all taken by me, two taken
20 on February 10th of '21, three taken on April 14th
21 of '21, two taken on December 22nd of '21, and
22 three taken on February 11th of 2022. I'm
23 submitting a copy of the complaint affidavit filed
24 with the County by property owner, Nicki Ann Crooks
25 on January 15th of 2021, that is pages 1-5. A copy
5 (Pages 11 to 14)
14a1ee71-ec15-49a3-8e03-9c913fa632d6Electronically signed by Karen M. Bellemare (301-293-169-3900)
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1 of a proposal contract between Mrs. Crooks and Abe
2 Shultz Construction, LLC, signed on
3 September 16th, 2021 for the contracted price of
4 $7,000. This proposal contract is for the
5 following work: To do job repair flat roof on
6 shingle, change damaged board on rooftop.
7 The name of Milton Andrew Brown is listed on
8 top of this proposal. That is Page No. 6. A copy
9 of proposal contract between Mrs. Crooks and Abe
10 Shultz Construction, LLC signed on September 21st,
11 2020 for the contracted price of $11,000. This
12 proposal contract shows $4,000 paid, $4,000 due on
13 September 21st, 2020, and $3,000 due when the work
14 is completed with all payments to be made to
15 Milton Brown. This is Page No. 7.
16 Space Coast Credit Union cashier's check,
17 Check No 380422 dated September 18th of 2020 in the
18 amount of $4,000 made out to Milton Brown, that was
19 provided to me by the property owner. This is Page
20 8. A carbon copy of a personal check, Check No.
21 1024 in the amount of $4,000 dated September 21st,
22 2020 made out to Milton Brown, that was provided to
23 me by the property owner. This is Page 9.
24 I'm submitting a copy of the building permit
25 application dated November 11th, 2020 for a reroof
Page 12
1 at the address of 4032 Greenwood Drive in
2 Fort Pierce showing the cost of construction to be
3 $11,000. This application was signed by both
4 property owner, Nicki Ann Crooks and contractor,
5 Lindolph Campbell, owner and qualifier of
6 Abe Shultz Construction, LLC. This is Page No. 10
7 and 11. I'm submitting a copy of a Notice of
8 Commencement for the reroofing job at the address
9 of 4032 Greenwood Drive for permit number 2011-0365
10 under the contractor of Abe Shultz Construction,
11 LLC. This document was signed by Nicki Ann Crooks
12 and notarized on December 22nd, 2020. This is Page
13 No. 12.
14 I'm submitting a copy of the issued permit,
15 Permit No. 2011-0365 issued on December 8th of
16 2020, along with an inspection card showing that a
17 total of four inspections were required for this
18 project, roof sheathing, roof affidavit, roof dry
19 and tin tab and a final inspection. This permit is
20 for a reroof, tear off modified to bare deck,
21 install two No. 75 base anchor, install 9-inch
22 three by three galvanized drip edge, 26 gauge,
23 install a GAF Ruberoid HW 170 FR modified. All
24 supporting paperwork must be on site for
25 inspectors, Pages 13 through 18.
Page 13
1 I'm providing a copy of the inspection history
2 showing that the first inspection of roof sheathing
3 has not passed inspection to date. It's Page No.
4 19. I am providing a statement from Chief Building
5 Inspector, Dave Johnson, prepared after he
6 performed an investigation inspection with me on
7 February 10th of '21. I'm including 25 pictures
8 taken by building inspector, Dave Johnson, on the
9 inspection date.
10 We conducted this inspection as part of my
11 investigation of a complaint filed by the property
12 owner. That's Page No. 20.
13 I am submitting an Email response that I
14 received from Jose Lopez, the supervisor of the
15 West Palm Beach Bureau of Compliance, Division of
16 Workers' Compensation for the State of Florida,
17 dated February 15th of 2022. This is Pages 21
18 through 22.
19 I'm also submitting a photo taken of a
20 Property Damage Release form dated
21 February 1st, 2022 from the insurance company of
22 Abe Shultz Construction for damages occurring on
23 the property located at 4032 Greenwood Drive. It's
24 Pages 23 through 24.
25 I am submitting the Florida Division of
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1 Corporations and License Information for Lindolph
2 Campbell for certified roofing contractor and
3 certified building contractor, Pages 25 through 28.
4 I am providing a written statement of County
5 Building Instructor, Clyde Heffelfinger, regarding
6 the sheathing inspection he performed on
7 April 13th, 2021, and five photos taken by
8 Inspector Heffelfinger during that inspection.
9 That's Page No. 29.
10 I am submitting the contractor license file
11 for closed Case No. 104813 against Mr. Milton Brown
12 for unlicensed construction work on the property
13 located at 4032 Greenwood Drive. Those are Pages
14 30 through 39. A copy of two subpoenas served on
15 Lindolph Campbell and Mr. Milton Brown, served by
16 outside counsel for St. Lucie County. That's pages
17 40 through 43. A copy of the following sections of
18 the Florida Building Code, Section 110 Inspections;
19 in particular, (A) 110.1, General, Section (A)
20 110.3 Required Inspections, Section (A) 110.5,
21 Inspection Requests, and Section (A) 110.6,
22 Approval Required, Section 706.7.1.2 of the Florida
23 Building Code, Existing Building, Pages 44 through
24 49. A copy of the January 28th, 2022 notice to be
25 sent to Abe Shultz Construction, LLC for this
6 (Pages 15 to 18)
14a1ee71-ec15-49a3-8e03-9c913fa632d6Electronically signed by Karen M. Bellemare (301-293-169-3900)
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1 hearing, Pages 50 through 53.
2 On January 15th of '21, a complaint affidavit
3 was filed by Mrs. Crooks against Abe Shultz
4 Construction, LLC, whom she had contracted with for
5 a reroof at the address of 4032 Greenwood Drive in
6 Fort Pierce. An original agreement proposal on
7 invoice from Abe Shultz Construction, LLC texted to
8 Mr. and Mrs. Crooks on September 16th, 2020 by
9 Mr. Milton Brown, rebuild a quote for the roof in
10 the amount of $7,000. No representatives from
11 Abe Shultz Construction had been to the residence
12 prior to the quote being submitted to
13 Mr. and Mrs. Crooks.
14 Mr. and Mrs. Crooks will provide testimony
15 that Mr. Brown provided this quote based on aerial
16 image obtained on the Internet. Mr. and Mrs.
17 Crooks did provide the initial $4,000 payment via
18 cashier's check on September 18th of 2020. A work
19 crew arrived at the residence on or about Saturday,
20 September 19, 2020 and began nailing underlayment
21 over the pre-existing roof material. The work was
22 stopped by the property owner, as the roof was not
23 being stripped to expose the sheathing per the
24 construction agreement, as well as the building
25 permit not being on site.
Page 16
1 Mr. Brown came to the residence on September
2 21st, 2020 and provided a new contract proposal on
3 invoice from Abe Shultz Construction, LLC for the
4 amount of $11,000, which was agreed to, and signed
5 by Mrs. Crooks. At that time, a personal check in
6 the amount of $4,000 made out to Milton Brown was
7 provided to him.
8 Upon investigation it was found that Abe
9 Shultz Construction violated St. Lucie County Code
10 10-67(3), disregards and violates an applicable
11 state or local building code, regulation or law.
12 Construction activity began on this property
13 on September 19th of 2020 under the contract of Abe
14 Shultz Construction, LLC. The roofing permit was
15 applied for on November 11th of 2020 by contractor
16 Abe Shultz Construction, LLC, Mr. Lindolph
17 Campbell, and it was not issued until December 8th
18 of 2020.
19 The inspection history for Permit No.
20 2011-0365 showed that the first roof sheathing
21 inspection scheduled for January 20th, 2021 was
22 canceled. The roof sheathing was attempted to be
23 reinspected again by Building Inspector,
24 Clyde Heffelfinger, on April 13th, 2021 in which
25 myself, contractor Lindolph Campbell, and one of
Page 17
1 his workers was present. The inspection did fail.
2 The inspection notes read: "I'm unable to verify
3 proper nailing for the entire roof because it is
4 completed. Two of the 3x3 areas that were cut open
5 are nailed property and one 8x8 area was not nailed
6 properly."
7 On April 13th, 2021, inspection revealed that
8 Abe Shultz Construction and Lindolph Campbell had
9 violated multiple sections of the applicable
10 Florida Building Code. By failing to schedule the
11 required inspections for roof sheathing, roof
12 affidavit, roof dry and tin tab before the roof
13 work was completed, Mr. Campbell violated Sections
14 (A) 110.5, inspection requests, and (A) 110.6,
15 approval required, of the Florida Building Code.
16 Due to Mr. Campbell's failure to schedule the
17 required inspections at the appropriate times
18 during the construction process, three sections of
19 the roof were opened to inspect the installation of
20 the roof sheathing. An 8x8 section revealed that
21 the roof sheathing was not properly nailed. The
22 installation did not meet the requirements of
23 Section 706.7.1.2 of the Florida Building Code,
24 Existing Building.
25 Building Inspector Michael Lunsford, attempted
Page 18
1 the reinspection on October 14th of '21. The
2 inspection again failed. The inspector's notes
3 read: "Reinspection, request an early morning
4 around 9 A.M. No one on site for inspection." See
5 Chapter 9 of the Florida Building Code for proper
6 installation. No way to get an inspection.
7 St. Lucie County Code 1067.4, perform any act
8 which assists a person or business in engaging in
9 the unlicensed business of contracting as defined
10 herein, that the certificate holder knows or has
11 reasonable grounds to know that the person or
12 business is unlicensed.
13 Mr. Milton Brown was able to use proposals
14 contracts under the business name of Abe Shultz
15 Construction, LLC, certified building contractor,
16 License No. CBC1258575, and certified roofing
17 Contractor License No. CCC1331723, with the
18 knowledge of Mr. Lindolph Campbell.
19 The property owners will testify that after
20 questioning Mr. Milton Brown after finding no
21 permit on the job site, Milton Brown claimed that
22 his business partner or secretary will be applying
23 for the roofing permit. Mr. Milton Brown claimed
24 that he was indeed a licensed contractor and the
25 business owner of Abe Shultz Construction.
7 (Pages 19 to 22)
14a1ee71-ec15-49a3-8e03-9c913fa632d6Electronically signed by Karen M. Bellemare (301-293-169-3900)
Page 19
1 When the property owners finally spoke to
2 Mr. Lindolph Campbell about the permit,
3 Mr. Campbell himself claimed that he was only a
4 secretary and that he is business partners with
5 Mr. Milton Brown. It was not until later that
6 Lindolph Campbell admitted that he is indeed the
7 business owner of Abe Shultz Construction and the
8 license holder.
9 Computer checks revealed that Mr. Lindolph
10 Campbell only possesses a Workers' Compensation
11 exemption for himself. No additional workers'
12 compensation coverage was found. During the
13 exemption application process, Mr. Lindolph
14 Campbell would have to acknowledge that he cannot
15 have employees for his company without a separate
16 Workers' Compensation policy. Therefore,
17 Mr. Milton Brown cannot be an employee of
18 Mr. Campbell, he can only be a sub-contractor.
19 Mr. Milton Brown does not possess any Workers'
20 Compensation coverage or an exemption for himself.
21 This was confirmed by email from Jose Lopez, who is
22 the supervisor at the Florida Department of
23 Financial Services, Bureau of Compliance, Division
24 of Workers' Comp, West Palm Beach Office.
25 The Florida Division of Corporations Sun-Biz
Page 20
1 revealed that Mr. Milton Brown has an active
2 fictitious company by the name of AB Handyman. No
3 state or local license was found. No Workers'
4 Compensation coverage or exemption was found
5 required by state law.
6 During my telephone interview with Mr. Milton
7 Brown on January 3rd of 2022, Mr. Brown claimed
8 that Mr. Lindolph Campbell qualifies his company.
9 The Florida Department of Business and Professional
10 Regulations website does not confirm Mr. Brown's
11 claim. In fact, the only license information for
12 Mr. Campbell is for Abe Shultz Construction, LLC.
13 St. Lucie County Code 1067.10 commits fraud or
14 deceit or other misconduct in the practice of
15 contracting. Based upon the actions of
16 Mr. Lindolph Campbell of allowing Mr. Milton Brown
17 to contract under his license number and business
18 name by taking money from Mr. and Mrs. Crooks and
19 performing work, he has committed a deceit against
20 Mr. and Mrs. Crooks by allowing this job in
21 particular to be started without a permit and
22 completed without a single, passed inspection.
23 Mr. Campbell has deceived Mr. and Mrs. Crooks
24 by claiming that he is only a secretary who did not
25 want to take any responsibility. As a result of
Page 21
1 his work on the roof with unpassed inspections, the
2 interior and exterior of the property has been
3 damaged by water. A liability insurance claim was
4 filed by the property owners under the policy of
5 Mr. Lindolph Campbell's company, which was paid as
6 a result of the damages. Therefore, Mr. Campbell
7 cannot claim that he is not responsible for this
8 job. He cannot claim that he does not know
9 Mr. Milton Brown, as an insurance claim was filed
10 though the insurance company of Mr. Campbell's
11 company for work and damages that occurred during
12 the performance of a contract by and in between
13 Abe Shultz Construction, LLC and Mrs. Crooks signed
14 on behalf of Abe Shultz Construction by
15 Milton Brown.
16 To date, Mr. Lindolph Campbell has not filed
17 any police reports known to staff for Mr. Milton
18 Brown fraudulently using his contracts and
19 performing any work under his license. Staff has
20 tried to work with him, Mr. Lindolph Campbell, for
21 over a year on this case. After the roof was
22 inspected by Chief Building Inspector,
23 Dave Johnson, on February 10th, 2021, and Building
24 Inspector, Clyde Heffelfinger on April 13th of '21,
25 Mr. Campbell agreed to have the roof stripped down
Page 22
1 to bare decking for proper inspections to occur.
2 Mr. Campbell requested time to be able to come
3 up with the funds for the cost of this job which
4 was to be absorbed by his company. Time was
5 granted on multiple occasions, and to date, the
6 permit remains open with no inspections passed.
7 Based upon the facts of this case, staff is
8 recommending that the Board, number one, suspend
9 the permitting privileges of Mr. Lindolph Campbell,
10 LLC, Abe Shultz Construction, LLC, for a period not
11 to exceed 365 days; two, require that a written
12 request be made to the Board to reinstate Abe
13 Shultz Construction, LLC, Lindolph Campbell,
14 permitting privileges after the one-year
15 suspension; three, require that all inspections up
16 to and including the final inspection for a roofing
17 permit under Abe Shultz Construction, LLC, Lindolph
18 Campbell, for the address of 4032 Greenwood Drive,
19 Fort Pierce, shall be obtained within three months
20 of this Board's order date or a fine not to exceed
21 $10,000 shall be imposed; four, require that all
22 inspections be performed by a licensed St. Lucie
23 County building inspector.
24 Staff is also recommending that the Board
25 forward a copy of the Board's order to the Florida
8 (Pages 23 to 26)
14a1ee71-ec15-49a3-8e03-9c913fa632d6Electronically signed by Karen M. Bellemare (301-293-169-3900)
Page 23
1 Department of Business and Professional Regulations
2 and surrounding municipalities.
3 MR. CHAIRMAN: Thank you, Mr. Cicio.
4 MR. MATHEWS: I'd like to interpose a couple
5 of objections. The first is a reference to a
6 contract on Page 6 of the packet that was provided
7 to the panel. I've never received a copy of that
8 document, and I certainly can't read it. I've seen
9 a reference to it in some text messages, but I've
10 never seen that document before.
11 MS. FALCE: Just for the record, this exact
12 packet that you received before you on Page 6 was
13 provided to opposing counsel on Friday, and this is
14 the copy that staff has there. We gave him what we
15 have.
16 MR. CHAIRMAN: I can read this. To do job
17 repair, flat roof on shingle, change damage
18 boards . . . I can barely read it, but I see $7,000
19 total on it.
20 MR. MATHEWS: Okay. I can't read the date. I
21 can't decipher whose handwriting is on it. If I
22 were to examine a witness on this, those details
23 would be important to me. There's signatures on
24 the bottom, on the very bottom, but there aren't
25 signatures above that.
Page 24
1 So I can read this document in a rough format,
2 but I can't read it for details. So as evidence,
3 it's very difficult for me to be able to ask
4 questions and I would imagine that the Complainant
5 has it because I think that this text string
6 originated from her. And I actually did issue a
7 subpoena to Ms. Crooks, and I'm wondering if --
8 she's here, right?
9 Do you have the documents that are responsive?
10 MS. CROOKS: The image that you see was texted
11 to us and it wasn't originated by us. We were sent
12 that image by Mr. Milton Brown. We're unable to
13 print or have a visible copy of that. That was in
14 a text that was sent to us. You see on the left
15 it's from Milton Brown. The responses on the right
16 are from us.
17 MR. MATHEWS: Right, but if you -- if you
18 click on this document, it becomes bigger and then
19 you can print it. It's no different than like an
20 attachment to an email.
21 MS. CROOKS: It comes up the same way. You
22 can't -- you can't make it out.
23 MR. CHAIRMAN: I'm perfectly -- I got enough
24 information in this packet to go forward from here.
25 So I'm perfectly fine.
Page 25
1 MR. MATHEWS: Mr. Chairman, can you read the
2 date of this?
3 MR. CHAIRMAN: '20. That's what I can make
4 out of it. I have other contracts and proposals
5 and contracts and documentation that I have in this
6 packet as well so --
7 MR. MATHEWS: I understand, but with respect
8 to this job, there's -- there's a certain history
9 that goes along with it and this is part of that
10 history that is important to the Defense.
11 MR. CHAIRMAN: I understand. Fair enough. I
12 understand. I can't -- I understand.
13 MR. MATHEWS: So you have my objection. I
14 guess you're going to overrule my objection?
15 MR. CHAIRMAN: I am going to overrule your
16 objection.
17 MR. MATHEWS: Okay. The next issue is Mr.
18 Cicio -- is that how you --
19 MR. CICIO: Yes.
20 MR. MATHEWS: Okay. I pronounced your name
21 correctly?
22 MR. CICIO: Yes.
23 MR. MATHEWS: Okay. Thank you. You made
24 reference to some photographs, but I don't see
25 those photographs attached to this packet. Is
Page 26
1 there another set --
2 MR. CICIO: The photographs are on the
3 overhead, sir.
4 MR. MATHEWS: Okay. They're on the overhead
5 --
6 MR. CICIO: Yes, sir. There's no monitor in
7 front of you. I apologize for that, but the photos
8 are all being presented on the overhead monitors.
9 MR. MATHEWS: Okay. And is that the only form
10 in which you're publishing them or is there a hard
11 copy that -- that you have?
12 MS. FALCE: For the record, these are the
13 photographs that were also produced to you on
14 Friday in -- in the files by name. They were
15 taken, as Mr. Cicio has testified to, by himself,
16 Mr. Dave Johnson and Mr. Clyde Heffelfinger. They
17 were provided to you digitally just as they are
18 being presented here.
19 If the objection is that they are not in hard
20 copy, then I believe we may print them, but does
21 anybody --
22 MR. MATHEWS: Well, I was just trying to
23 clarify it.
24 MS. FALCE: -- hear it or see it in -- in hard
25 copy?
9 (Pages 27 to 30)
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Page 27
1 MR. MATHEWS: From my understanding, when you
2 handed this to me, this was the body of -- of
3 evidence that was being presented to the panel, and
4 it wasn't more than that. But now you're saying
5 there are also additional attachments as part of
6 your presentation in your body of evidence.
7 MS. FALCE: The presentation of evidence is as
8 Mr. Cicio has stated and entered into the record of
9 these proceedings. All of the documents that he
10 entered into the proceedings were part of the
11 production that we sent on Friday in advance of the
12 hearing.
13 Number one, in response to your subpoena that
14 asks that we bring documents to the hearing, but we
15 did, in fact, provide them prior to the hearing,
16 and also, with -- with the document packet that was
17 printed and provided to the -- to the Board. So
18 it's both.
19 MR. MATHEWS: I understand. Thank you.
20 MS. FALCE: Okay.
21 MR. CHAIRMAN: Thank you.
22 MS. FALCE: So just to clarify, the procedure
23 right -- right now since we're all sitting here
24 with objections being heard, would you like --
25 would you like -- would the Board like to ask
Page 28
1 Mr. Cicio any questions or would opposing counsel
2 like to ask Mr. Cicio any questions at this point?
3 MR. CHAIRMAN: I would. I'll defer to the
4 Board at first.
5 Mr. Cicio, this is a lot of information and
6 I've spent copious amounts of time reviewing this,
7 this entire document. We have a lot of data, a lot
8 of information going back to August of 2020, and
9 here we are sitting here February of 2022.
10 Does the Board have any questions of
11 Mr. Cicio?
12 MR. DIFRANCESCO: I think Mr. Cicio made it
13 clear that he was trying to work with Mr. Shultz or
14 Mr. Lindolph for the past year, and I have a
15 question about why it took so long to get here in
16 front of us. Was it because the homeowner had not
17 filled out a complaint until January or were they
18 okay with him taking his time on the -- on the
19 project because it was well over a year.
20 MR. CICIO: I may answer, Mr. DiFrancesco.
21 Thank you.
22 After the inspections were performed, February
23 and April, respectively, Mr. Dave Johnson will
24 testify he had a conversation with Mr. Lindolph
25 Campbell, and he said he needed some time to get
Page 29
1 some funds together to get the roof done properly.
2 We gave him until I believe it was July of last
3 year.
4 July came and went. I contacted Mr. Campbell.
5 He said I need more time. So we gave him until
6 around October of last year. When that time came
7 up, I think there was a little bit of
8 miscommunication. Mr. Campbell had called me and
9 said, look, I'm basically tired of dealing with the
10 property owners. Just send me to the Board. So
11 this is where we are.
12 MR. DIFRANCESCO: Okay. I also understand
13 that the job was started on September 19th, 2020?
14 MR. CICIO: That's correct.
15 MR. DIFRANCESCO: And no permits were pulled
16 until December?
17 MR. CICIO: That's correct.
18 MR. DIFRANCESCO: I believe it was
19 December 8th, 2020?
20 MR. CICIO: That's correct.
21 MR. DIFRANCESCO: So, obviously, there were no
22 inspections from then to then, right?
23 MR. CICIO: No inspections.
24 MR. DIFRANCESCO: And the homeowners had not
25 contacted you then in the meantime?
Page 30
1 MR. CICIO: I didn't hear from the owners
2 until -- it January-ish when I got the complaint.
3 MR. DIFRANCESCO: Okay.
4 MR. CHAIRMAN: Mr. Cicio, when you had a
5 conversation with Mr. Campbell, what did he tell
6 you his relationship was to Mr. Milton Brown?
7 MR. CICIO: He stated that it went back and
8 forth with Mr. Campbell, and in respectively
9 speaking, that -- my first conversation he knows
10 Mr. Milton Brown, try to get it worked out. My
11 next conversation with Mr. Campbell he would state
12 that I don't know Mr. Milton Brown at all. And
13 then my next conversation he would say that I know
14 him, but I don't know him that well, is the
15 conversations I had.
16 MR. CHAIRMAN: Staff, do we know if Abe Shultz
17 Construction, LLC has pulled any other permits in
18 St. Lucie County?
19 While staff is looking up information for me,
20 does anybody else on the Board have any questions
21 for Mr. Cicio?
22 MR. SAMPSON: I have a question, well, I guess
23 it was with the -- so the inspections, the -- the
24 canceled inspection was called -- was done through
25 the automated system, but the note said the
10 (Pages 31 to 34)
14a1ee71-ec15-49a3-8e03-9c913fa632d6Electronically signed by Karen M. Bellemare (301-293-169-3900)
Page 31
1 homeowner canceled it. Was that verifiable that
2 the owner -- the homeowner canceled it or did the
3 contractor, the inspection on January?
4 MR. CICIO: It was done through the automated
5 system. I would have to defer to Ms. Alphanette
6 Waters, Assistant Building Official. Maybe she
7 could shed some light on that.
8 MR. CHAIRMAN: What was the original permit
9 amount?
10 MS. WATERS: This is Alphanette Waters,
11 Assistant Building Official. Abe Shultz
12 Construction only pulled one permit in
13 St. Lucie County for a roofing.
14 MR. CHAIRMAN: And is this that one permit
15 that they pulled?
16 MS. WATERS: Yes.
17 MR. CHAIRMAN: Thank you. Thank you, staff.
18 And, Andrew, your question was?
19 MR. SAMPSON: Oh, with the permit amount.
20 Well, the inspection was the one but it's done
21 through they system I don't know how you --
22 MR. CHAIRMAN: Okay.
23 MR. SAMPSON: And then the original -- what
24 was the total permit amount -- or the total cost of
25 the job on the permit?
Page 32
1 MR. CICIO: I think it was $11,000.
2 MR. DIFRANCESCO: Andrew, I believe the first
3 contract stated it was $7,000? The second contract
4 by Mr. Campbell stated that it was $11,000.00.
5 MR. SAMPSON: And the $7,000 contract is the
6 little one or the one that's smaller.
7 MR. DIFRANCESCO: The one you can barely read.
8 But in the second contract it also states the two
9 payments were made at $4,000 a piece, when they
10 were paid, and I don't know who wrote it in there,
11 but it said $8,000 paid to Mr. Brown, $3,000 when
12 work completed.
13 MR. CHAIRMAN: So we have two copies of -- of
14 checks in here, both for $4,000 that were written
15 out to Milton Brown on pages --
16 MR. DIFRANCESCO: Yes. It was acknowledged on
17 the back of the proposal from Mr. Lindolph, the one
18 that we can read. I believe it was Page 6, Page 7.
19 MS. FALCE: Page 7 is the -- is the contract
20 and then the two checks are on Page 8 and 9 for the
21 record.
22 MS. BARBIERI: Ms. Waters has the answer on
23 who -- who canceled the appointments.
24 MS. WATERS: The notes in the system says,
25 January 20th, 2021, "The homeowner requested this
Page 33
1 inspection to be canceled." The second inspection
2 on 4/30/2021 says, "Unable to verify the proper
3 nailing for the entire roof because it is
4 completed. Two of the 3x3 areas that were cut open
5 are nailed properly, and one 8x8 was not nailed
6 properly."
7 The third inspection, no one was on the site,
8 so see Chapter 9 for proper installation, no way to
9 get an inspection. And that was October 14th,
10 2021.
11 MR. CHAIRMAN: So it was confirmed that the
12 homeowner canceled the inspection based on what the
13 notes are?
14 MS. WATERS: Yes.
15 MR. CHAIRMAN: I think that's what Andrew's
16 question was. Okay. Thank you.
17 Mrs. Barbieri, where do we go from here?
18 MS. BARBIERI: I believe if the Board is
19 ready, we can have Mr. -- the contractor's attorney
20 question Mr. Cicio. I believe he indicated he
21 wanted to do that.
22 MR. CHAIRMAN: Thank you. That works.
23 Mr. Mathews?
24 MR. MATHEWS: Thank you.
25 MICHAEL CICIO,
Page 34
1 After having been previously sworn, testified
2 as follows:
3 EXAMINATION
4 BY MR. MATHEWS:
5 Q. Mr. Cicio, have you performed hands-on
6 replacement of roofs in -- prior to joining
7 St. Lucie County?
8 A. Not roof replacement, but I've nailed roof
9 decking, yes.
10 Q. Okay. How long?
11 A. I worked in construction for about four to
12 five years.
13 Q. And how many roofs have you either installed
14 or repaired?
15 A. I was a -- I was a carpenter for many years,
16 so when you frame a house out, the roof decking kind of
17 goes with it. So a safe estimate, ten, 15, 20,
18 somewhere around there.
19 Q. What about flat roofs; have you worked on flat
20 roofs before?
21 A. I have not, no.
22 Q. Okay. Have you -- so you've never installed
23 sheathing on flat roofs?
24 A. I have not, no.
25 Q. Have you ever put any of the -- the tar paper
11 (Pages 35 to 38)
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Page 35
1 down or the -- whatever the top material is?
2 A. The dry-in material, yes.
3 Q. Exactly.
4 A. Yes.
5 Q. Okay. So you've done new installations, but
6 you haven't done any repairs?
7 A. That's correct.
8 Q. Okay. Have you ever had a contractor's
9 license?
10 A. No.
11 Q. Have you ever had a roofing license?
12 A. No.
13 Q. Are you familiar with the property located at
14 4032 Greenwood Drive, Fort Pierce, Florida?
15 A. I am.
16 Q. Did St. Lucie County receive a complaint from
17 the homeowner?
18 A. They did.
19 Q. What was the name of the Complainant?
20 A. The name of the Complainant on -- Nicki Ann
21 Crooks.
22 MR. MATHEWS: And I'll draw your attention to
23 Tab No. 1 of Respondent's book. If the -- the
24 panel can take a look at that. And your attorney
25 can provide you a copy of it as well.
Page 36
1 BY MR. MATHEWS:
2 Q Do you see this document?
3 A. I do.
4 Q. And it's a multi-page document, correct, it's
5 got hand -- it's a handwritten form?
6 MS. FALCE: Sorry. For clarification, when
7 you say Tab 1, are you referring to the documents
8 in front of the tab --
9 MR. MATHEWS: Yes.
10 MS. FALCE: -- or behind it? Okay. Okay.
11 We're on the same page now.
12 MR. MATHEWS: Great. Thank you.
13 BY MR. MATHEWS:
14 Q. Is this a copy of the complaint that was
15 filed?
16 A. Yes, it is.
17 Q. Do you see on the last page of this exhibit it
18 was -- it looks like it was signed before a notary on
19 January 15th, 2021?
20 A. Yes.
21 Q. And then the date received on the first page
22 says the same thing, January 1, 2015 (sic)?
23 A. Yes.
24 Q. Do you know if St. Lucie County issued a
25 citation to Milton Brown regarding the 4032 property?
Page 37
1 A. Yes.
2 Q. Okay. I'd like to draw your attention to Tab
3 No. 5 of Respondent's book. Is this the copy of the
4 citation that was issued to Milton Brown?
5 A. Yes, it is.
6 Q. Okay. And is -- you signed this document, is
7 that correct?
8 A. I did.
9 Q. Okay. Is your handwriting on this -- this
10 first page?
11 A. Yes, it is.
12 Q. There's a date in the top of
13 September 21, 2020. How was that date determined?
14 A. That was based off of the contract that was
15 written between Abe Shultz Construction and
16 Mr. Milton Brown, signed by Milton Brown and the
17 property owners.
18 Q. Okay. So just to be clear, you didn't
19 physically go to the premises and see Milton Brown there
20 and then issue the citation?
21 A. No.
22 Q. So --
23 A. No. It reads: "Has caused to believe that
24 on" such and such a date.
25 Q. Okay. So on what date were you aware that
Page 38
1 Milton -- that there was a problem with Milton Brown?
2 A. On the date that I received the complaint.
3 Q. Would that have -- okay, on the date -- so the
4 January date?
5 A. That's correct.
6 Q. Okay. And ultimately three page -- three
7 pages later in the same exhibit, Exhibit 6, Milton Brown
8 paid a fee, a fine?
9 A. That is correct, yes, sir, civil penalty.
10 Q. Civil penalty, total of $507.50?
11 A. That's correct.
12 Q. Okay. Did you do some research into a company
13 by the name of AB Handyman?
14 A. I did.
15 Q. I'd like to take you to Tab No. 14. Is this a
16 document that you pulled concerning your research into
17 AB Handyman?
18 A. Yes, it is.
19 Q. And the owner of AB Handyman is listed as a
20 Milton Brown?
21 A. That's correct.
22 Q. Did you determine that this Milton Brown is
23 the same Milton Brown that received the citation?
24 A. I believe he stated that to me in
25 conversation, yes. I had a conversation with
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Page 39
1 Mr. Milton Brown, yes.
2 Q. Okay. Did Mr. Brown indicate that he was a
3 handyman?
4 A. No, he didn't. He was basically stating
5 that -- all his statement was to me basically was
6 Mr. Lindolph Campbell qualifies his company.
7 Q. Did you review the building permit application
8 concerning the 4032 property?
9 A. I did.
10 Q. Let's look at Exhibit No. 7. Exhibit No. 7 is
11 actually a composite exhibit of some documents that I
12 received from St. Lucie County concerning the property
13 at 4032.
14 A. Okay.
15 Q. Is this the initial building permit
16 application?
17 A. It appears that way, yes.
18 Q. Okay. If you look on the first page, there's
19 a description of the work. Do you see that?
20 A. Detail of description of work, yes.
21 Q. Can you read that into the record, please?
22 A. Sure. It says: "Reroof, tear off modified to
23 bare deck, install two number 75 base anchor, install 9"
24 3x3 galvanized drip edge, 26 gauge, install GAF Ruberoid
25 HW 170 FR modified."
Page 40
1 Q. Okay. In layman's terms, can you describe
2 what that -- what's going to happen at that job?
3 A. I cannot. I'd have to defer to
4 Alphanette Waters, the Building Official on that,
5 Assistant Building Official.
6 Q. Okay. Does it say anything in there about the
7 type of bare deck to be installed?
8 A. It just says, "Reroof, tear off modified to
9 bare deck."
10 Q. Okay. I wanted to draw your attention back to
11 St. Lucie County's Exhibit No. 6, or Page No. 6, and
12 it's a blurry copy of what looks to be a proposal.
13 A. Uh-huh.
14 Q. You testified as to what the scope of the
15 description was in this. Can you reread that to me
16 because I can't read it at all?
17 A. Sure. To do a job repair, flat roof on
18 shingle, change damaged board on rooftop, $7,000 total.
19 Q. Okay. A job repair, would you say that's
20 different than -- than what was described in
21 Exhibit No. 7?
22 A. That I don't know, sir.
23 Q. Well, you can testify. I mean, does the
24 description in -- on Page 6 mimmick what's in this
25 building permit?
Page 41
1 A. I don't know, sir.
2 Q. Do you know who signed this -- this proposal?
3 A. I believe when I spoke to the property owners
4 about this, they stated this was signed by Milton Brown.
5 Q. Where?
6 A. On the bottom. His name appears on the top as
7 well, Andrew Milton Brown, right on top.
8 Q. Okay. And the date, can you read that?
9 A. I cannot read the date, no.
10 MR. MATHEWS: Just as a casual question, does
11 anybody have a magnifying glass that we could look
12 at this a little closer or can we blow it up on --
13 on the screen?
14 MR. CHAIRMAN: I have all intention of asking
15 the homeowner when they received it. I have all
16 intention of asking the homeowner when they
17 received this proposal, when they met with the
18 homeowner, and what they feel is that date on that
19 bottom left.
20 MR. MATHEWS: Okay. We'll figure it out then.
21 BY MR. MATHEWS:
22 Q. Okay. Let's look at the next page in
23 St. Lucie County's exhibits, Page 7. That's a full page
24 copy of a proposal which appears to be, I think, in the
25 same form, but I can't tell, as on Page 6. Do you see
Page 42
1 that?
2 A. It's the same layout form, correct?
3 Q. It's the same layout?
4 A. Uh-huh.
5 Q. Okay. So do you see the bottom box there
6 where it says acceptance of proposal?
7 A. Correct.
8 Q. Does that look like it's -- it's to be signed
9 by somebody from Abe Shultz or the customer?
10 A. Customer.
11 Q. Okay. So in the -- the copy that we're
12 looking at on Page 6, there's -- there's no execution
13 above that lower box; is that correct?
14 A. The execution being the line above the
15 signature, is that what you're referring to?
16 Q. Well, at the -- if you look on Page 7, there's
17 a box that says acceptance of the proposal.
18 A. Correct.
19 Q. And then there's a section above that which
20 would -- which says next to it --
21 A. Oh, respectfully -- Okay.
22 Q. Okay. Does that appear -- the -- where the
23 portion is that would be signed by somebody from Abe
24 Shultz Construction?
25 A. No.
13 (Pages 43 to 46)
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Page 43
1 Q. No, it doesn't?
2 MS. FALCE: For -- for the record, just what
3 page were you referring to when you said does it
4 appear to be signed, Page 6 or 7?
5 MR. MATHEWS: I'm looking at -- I'm trying to
6 compare what's on Page 7 --
7 MS. FALCE: Okay.
8 MR. MATHEWS: -- to what's on Page 6.
9 MS. FALCE: Okay.
10 BY MR. MATHEWS:
11 Q. So on the page 7, there's a respect --
12 respectfully submitted section, right?
13 A. Correct.
14 Q. And there's no signature next to that, right?
15 A. That's correct.
16 Q. Okay. And if we look at Page 6, is there a
17 signature next to that portion of that --
18 A. No, there's not.
19 Q. -- document? Okay. In Exhibit No. 7, if you
20 can flip forward, that's in Respondent's book, if you
21 can flip forward to the Notice of Commencement.
22 Do you see the date on that document?
23 A. I do.
24 Q. What's the date?
25 A. It was signed, acknowledged before the 22nd
Page 44
1 day of December of 2020.
2 Q. Okay. And if you look at -- flip a couple
3 more pages to the code notes, billing and code system
4 notes and it's Page 1 of 2, and I'm just going to --
5 unfortunately, I didn't put Bates numbers on these, but
6 I want to make sure -- is there a way that you would
7 describe this so the panel can follow along?
8 A. Do you want me to pass it along?
9 Q. No, no, no. Is there a way that you can
10 describe this document so the -- the panel makes --
11 we're all in agreement we're on the same page.
12 A. Hold on a second. Let me -- because it may be
13 in my packet here. So let me see if I can refer to it
14 in this one.
15 MR. DIFRANCESCO: Which page are we talking
16 about?
17 MR. MATHEWS: Can I show you?
18 MR. DIFRANCESCO: Sure. Because we're all
19 contractors up here --
20 MR. MATHEWS: So it's Page No. --
21 MR. DIFRANCESCO: -- and we see this all the
22 time.
23 MR. MATHEWS: Right. You guys might know how
24 to -- how to refer to it.
25 MR. DIFRANCESCO: Page 1 of 2. Sure.
Page 45
1 MR. CICIO: It's Page No. 19 in your packet.
2 MR. DIFRANCESCO: Yeah, we're all contractors.
3 We know what we're looking at up here. Well, the
4 ones that aren't contractors, I don't know.
5 BY MR. MATHEWS:
6 Q. This is a copy of internal notes from
7 St. Lucie County; is that correct?
8 A. It -- it's inspection notes, yes.
9 Q. Inspection notes. All right. Let's do it --
10 at the bottom, I'm interested in that portion at the --
11 at the -- at the bottom, the bottom box, and let's do it
12 in reverse chronological order. So there's
13 January 20th, 2021, right?
14 A. Uh-huh.
15 Q. And it says: "Canceled by
16 contractor/customer. . ." but we've determined already
17 that it was the homeowner that canceled that, right?
18 A. That -- that will be disputed.
19 Q. Okay. Let's look at the notes. The inspector
20 comments say, "Homeowner requested this inspection to
21 be canceled." Is that what it says?
22 A. That's what the notes say.
23 Q. Okay. But it doesn't say -- it doesn't say
24 contractor, right?
25 A. It does not say that.
Page 46
1 Q. Okay. Let's look at the next note up,
2 April 13th, 2021, and Clyde Heffelfinger, right? He
3 writes, "I am unable to verify proper nailing for the
4 entire roof because it is completed. Two of the 3x3
5 areas that were cut open were nailed properly, and one
6 8x8 area was not nailed properly." Right?
7 A. That's correct.
8 Q. Okay. Were you there for the inspection of
9 the property when those two portions were -- were opened
10 up?
11 A. Yes, I was.
12 Q. Okay. Were there two or three areas that were
13 exposed?
14 A. I believe there was three.
15 Q. You believe that there were three. Okay.
16 What happened to the third area? Were there any
17 problems with it?
18 A. I don't know, sir. I'm not -- I can't testify
19 to that. I'm not a building inspector certified by the
20 State of Florida. I can't make that determination.
21 That's why Mr. Clyde Heffelfinger was on the job site.
22 MR. CHAIRMAN: So excuse me. You said there
23 were three areas that were opened up, is that what
24 your impression was?
25 MR. CICIO: I believe it was, yeah. To
14 (Pages 47 to 50)
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Page 47
1 clarify, it was two 3x3 areas and --
2 MR. CHAIRMAN: And one 8x8?
3 MR. CICIO: -- one 8x8. That's correct.
4 MR. CHAIRMAN: So all three areas that were
5 exposed were inspected by --
6 MR. CICIO: That is correct.
7 MR. CHAIRMAN: Okay. I'm just making sure,
8 you know, based on -- I think Mr. Mathews's
9 question was --
10 MR. MATHEWS: Thank you. Thank you. You read
11 that closer than I did. I appreciate that.
12 BY MR. MATHEWS:
13 Q. Then the next comment in here is
14 October 14th, 2021, "Reinspection request early morning,
15 around 9 A.M. No one on site for inspection. See
16 Chapter 9 for proper installation. No way to get an
17 inspection," right?
18 A. Correct.
19 Q. Okay. I'd like to draw your attention to
20 Tab 6. Tab 6 I understand is the proposal at issue; is
21 that correct?
22 A. That's correct.
23 Q. Okay. There's a description of the work to be
24 performed. Do you see that box, just above where it
25 says $11,000?
Page 48
1 A. I do.
2 Q. Okay. And it looks like there's -- it says,
3 "Job description of work," right?
4 A. Uh-huh.
5 Q. And then there's a description, and then it
6 looks like there's either a date or a signature and some
7 additional stuff next to an asteric, right?
8 A. There is, yes. It talks about solar water
9 heater brackets.
10 Q. Okay. The part that's above the solar water
11 heater brackets, can you read that text to us, please?
12 A. Where it starts with "tear off"?
13 Q. Yes.
14 A. It says, "Tear off existing flat roof.
15 Replace damaged wood. Strip down to the deck as
16 required. Renail the existing wood deck to code.
17 Remove all trash and debris."
18 Q. Okay. That portion of the description, does
19 it reference anything about interior work?
20 A. No.
21 Q. Does it reference anything about drywall?
22 A. No.
23 Q. Okay. The job description that's on this
24 proposal at Exhibit 6, is that consistent with what we
25 saw as the detailed description of work at Tab 7 on
Page 49
1 the -- on the application?
2 A. Are you talking about just the top portion,
3 sir, minus the -- are you talking about minus the water
4 solar heater brackets, above that?
5 Q. Correct.
6 A. Okay. So it is similar in nature, just not as
7 detailed.
8 Q. Okay. It's more technical in the -- in the
9 permit application, correct?
10 A. Correct.
11 Q. Okay. I believe that you testified that you
12 visited the -- the site at 4032 and did inspections
13 there twice; is that correct?
14 A. That is correct.
15 Q. Okay. Why were -- why twice?
16 A. The first inspection that I did with
17 Building Inspector Dave Johnson was a result of the
18 complaint affidavit that's filed. He is certified as a
19 Florida Certified Building Inspector. I am not, and I
20 have to go through the inspection -- or actually the --
21 the affidavit, and his job is to do an inspection on the
22 roof.
23 A second inspection that was called is as a
24 result of Mr. Campbell agreeing to meet us on the job
25 site. So Mr. Campbell, after numerous appointments, I
Page 50
1 believe, decided to finally meet us on the roof on 4/13,
2 in which that's when Mr. Heffelfinger was present.
3 Q. Got it. If I can take your attention to
4 Tab No. 9, there's an inspection report. Have you
5 reviewed this inspection report prior to today?
6 A. I have.
7 Q. Did you review a draft of it before it was
8 signed or before it was provided by Dave Johnson?
9 A. Dave Johnson gave me a copy of it, yes.
10 Q. Did you review it before he -- he finalized
11 it?
12 A. No. Well, if there was a correction on a
13 date, if there was a date mess up, yes, but I didn't
14 read it and tell him to do anything with it, if that's
15 what you're asking.
16 Q. Okay. The first paragraph, it talks about the
17 property owners, Nicki Crooks and Ervin Tulloch?
18 A. Correct.
19 Q. Did you ever speak with Ervin Tulloch?
20 A. I have not.
21 Q. Okay. And also in the first paragraph it
22 says, "Owners had several issues regarding roof
23 replacement they wanted to discuss," right?
24 A. Uh-huh.
25 Q. Okay. And then the second paragraph, "No
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1 inspections were performed," right? And there's a
2 statement in there that says, "A roof sheathing
3 inspection and dry-in inspection should have been done
4 prior to installation of the final cap sheet," right?
5 A. That's what it says, yes.
6 Q. Okay. It says, in the third paragraph,
7 "Photos of the roof sheathing provided by the homeowner
8 were inconclusive as to whether the sheathing was nailed
9 sufficiently."
10 Have you seen -- are those pictures a part of
11 anything, any body of evidence that you presented today?
12 A. I think they were -- if I'm right, I think
13 they were included in what you just got this morning.
14 In that text format, I believe they're in there, if
15 anything.
16 Q. Okay. This morning I received this, correct,
17 this packet?
18 A. You did, yes.
19 MR. CHAIRMAN: What is -- what is the
20 information we're talking about, the ones that were
21 handed this morning, the pictures?
22 MR. MATHEWS: I can explain it to you, Mr.
23 Leonard.
24 MR. CHAIRMAN: Okay.
25 MR. MATHEWS: I provided, I guess, a
Page 52
1 document -- or a subpoena to a number of the
2 employees of St. Lucie County, and I requested all
3 the underlying documents, basically concerning the
4 432 (sic) property.
5 MR. CHAIRMAN: Got it.
6 MR. MATHEWS: On Friday at 5:33, I was given
7 -- I was given a series of files that were
8 responsive to this -- to the various subpoenas, and
9 I looked at those on Saturday and I emailed Deana
10 and I say, Hey, you've given me a copy of this
11 email, but it references a number of images and I
12 didn't get the attachments. Can you get those to
13 me? And then this morning, she handed those to me.
14 MR. CHAIRMAN: Okay.
15 MR. MATHEWS: Okay. So there is a text string
16 here. There are references -- and we're going to
17 get into this -- this later, a video and some
18 photographs, but as we've seen, one example, an
19 image of a document is very small. It's illegible.
20 I can't read it. I can't rely upon it and there
21 are multiple instances of documents that were
22 provided within this text string that I haven't
23 seen. Also, there's the video. I have requested
24 that information from the Complainant, and perhaps
25 after this -- this witness goes on, I can speak
Page 53
1 with her and view her production.
2 MR. CHAIRMAN: Okay. And is this what's in
3 reference in -- in your book in Tab 17?
4 MR. MATHEWS: Tab 17, yes. This was -- Tab 17
5 is what I understand a text string probably between
6 the Complainant and it says at the top "Melton
7 Brown," M-E-L-T-O-N. Not Milton Brown, but I think
8 it's the same person. I just don't know.
9 So in the production, there was this -- this
10 collection of documents. However, it wasn't behind
11 this email.
12 MR. CHAIRMAN: Okay.
13 MR. MATHEWS: So I don't know if -- at Friday
14 night, Saturday morning, I didn't know what this
15 was, what the attachments were.
16 MS. FALCE: Just for the record, the not --
17 the non-production of those attachments was
18 inadvertent. It was a mistake and thank you for
19 calling it out, and we provided those this morning.
20 BY MR. MATHEWS:
21 Q. Mr. Cicio, I want to get back to
22 Exhibit No. 9. In the second to last paragraph of this
23 inspection report it says, "There was also damaged
24 drywall on the undersides of the ceiling in several
25 places. It is unknown if the roof has any leaks
Page 54
1 currently."
2 The drywall damage, where was it?
3 A. Upon first inspection, it was brought to us
4 that there is a -- a bedroom on the back side of the
5 garage where a significant amount of drywall had come
6 down and it was being held up by plastic.
7 Inside the garage itself, there was also some
8 drywall that had come down, plus also a crack in the
9 seam of some of the drywall in the garage. That's the
10 damage that was referred to during that inspection.
11 Q. Do you know if that damage preceded any work
12 done on the roof?
13 A. I don't know.
14 Q. I'd like to draw your attention to
15 Exhibit No. 10. This is also an inspection report dated
16 April 13th, 2021. And it indicates -- can you see this
17 document?
18 A. I do.
19 Q. Great. It's not indented, but I'll take you
20 to the second paragraph of this inspection report. It
21 says, "The roofing contractor and one other man met us
22 and cut open two areas." Do you see that section?
23 A. I do.
24 Q. And that was Mr. Campbell that was there; is
25 that correct?
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Page 55
1 A. That is correct.
2 Q. Okay. So the description, there were two 3x3
3 areas exposed and those areas were nailed properly,
4 right?
5 A. If it's based off of the statement of
6 Clyde Heffelfinger then -- if that's what his statement
7 is, it's correct.
8 Q. The last sentence here says, "During
9 discussion with the contractor, he stated the only
10 option was for him to tear off new material and start
11 over correctly with proper inspections." Did
12 Mr. Campbell agree to do that?
13 A. I would have to honestly defer to the building
14 inspectors. They had communication with Mr. Campbell.
15 Q. If I can take your attention to
16 Exhibit No. 2., Exhibit No. 2 is dated October 4, 2021,
17 correct?
18 A. That's correct.
19 Q. And I'm going to describe this as a -- sort of
20 a Notice of Violation; is that fair?
21 A. It's a Notice -- it's a --
22 Q A Notice of -- of Hearing?
23 MR. CICIO: It's a Notice to Appear for
24 hearing, yes.
25 MR. MATHEWS: Okay. Thank you.
Page 56
1 BY MR. MATHEWS:
2 Q. And you signed this document, correct?
3 A. I did.
4 Q. After October 4, 2021, did you have
5 discussions with Mr. Campbell about the alleged
6 violations?
7 A. I don't recall, honestly.
8 Q. Okay. Do you recall initially that there was
9 an attempt to try to resolve this issue without having a
10 hearing?
11 A. There was, yes.
12 Q. Do you know why that broke down?
13 A. Again, this was -- we were working with
14 Mr. Campbell based off of him wanting to work, and I
15 think he had several conversations with Mr. Dave Johnson
16 about this. He was wanting to get the job done by July.
17 So we gave him time. He said he had no funds. We gave
18 him the time.
19 July rolls around. I have a conversation with
20 him, still doesn't have the funds. He needs more time.
21 We gave him until October. When October's Board date
22 rolls around, the roof is still not done, and I believe
23 at that time, like I stated, that he said he was fed up
24 with the property owners and send me to the Board is
25 what he stated, more or less in terms.
Page 57
1 Q. Is that timeline captured in -- in your notes?
2 A. It should be, yes.
3 Q. Were the notes produced?
4 A. Should be. I don't know.
5 Q. I don't have a copy of any notes that were
6 produced. I did provide you with a subpoena in this
7 case, correct?
8 A. You did, yeah.
9 Q. How many notes do you have concerning this
10 matter?
11 A. It's usually just pertinent points of when
12 certified mail is sent, delivered, so on and so forth,
13 one case -- one case notes.
14 Q. Do you have handwritten notes or they --
15 A. No. No, they're typed.
16 Q. You have typewritten notes?
17 A. Yeah.
18 Q. How many pages?
19 A. One, if that, not even a full page. It just
20 goes by -- line item by line item. When something
21 pertinent happens, you make a note.
22 Q. Let's look at Exhibit No. 3. Exhibit No. 3 is
23 a Notice of Hearing dated December 22, 2021?
24 A. Correct.
25 Q. And this is the operative Notice of Hearing
Page 58
1 that we're dealing with, correct?
2 A. That is correct.
3 Q. So there was an initial one in October and
4 then this -- this is, I guess, the revised notice?
5 A. This is the revised renotice because
6 Mr. Campbell was going out of town, so we agreed on
7 another date.
8 Q. Okay. I think it was myself going out of
9 town.
10 A. No, sir, it was before your time.
11 Q. Did you come to learn that Abe Shultz
12 Construction agreed to fix any issues concerning the
13 roof at the 4032 property?
14 A. No.
15 Q. I'd like to draw your attention to Exhibit No.
16 11. Exhibit No. 11 is a collection of photographs taken
17 by either Mr. Campbell or one of his representatives at
18 the 4032 property.
19 Does the -- do the pictures appear to reflect
20 work that was done at the 4032 property?
21 A. I'd have to say yes.
22 Q. The first and second picture, do those depict
23 certain areas of the sheathing?
24 A. And, again, I'm not an expert in this area of
25 building inspections, but I can say, yes, that is
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Page 59
1 sheathing pictures.
2 Q. Okay. And the next documents, I -- I don't
3 know the technical way, the nailing of the tar paper.
4 Do you see -- see those photographs?
5 A. I do.
6 Q. And then the priming of some of the drip and
7 -- and transition areas; do you see that?
8 A. I don't know what you're referring to on this,
9 sir. I'm not --
10 Q. The drip edge.
11 A I'm not --
12 Q Okay. I understand. Okay. Does it appear to
13 be the status of worked performed at the 4032 --
14 A. Yes.
15 Q. -- 4032 property?
16 A Yes.
17 MS. FALCE: Objection. It's without a status
18 when -- of the construction.
19 MR. MATHEWS: Fair enough. We'll -- we'll get
20 to it.
21 MS. FALCE: Okay.
22 MR. CHAIRMAN: Mr. Mathews, who provided you
23 these pictures?
24 MR. MATHEWS: My client.
25 MR. CHAIRMAN: Okay.
Page 60
1 MR. MATHEWS: And they were produced this
2 morning, so I should have produced them earlier,
3 but it was half a dozen photographs. So I figured
4 I could -- I could get those in.
5 MR. CHAIRMAN: Okay. No worries. Thank you.
6 MR. MATHEWS: There is -- you'll note that
7 there's a date at the top, February 25th, '22.
8 MR. CHAIRMAN: Uh-huh.
9 MR. MATHEWS: That's the date that I got this.
10 So that does not reflect when the pictures were
11 taken, and I believe Mr. Campbell can testify about
12 when they were taken or about the time frame.
13 MR. DIFRANCESCO: Mr. Cicio, do you know if
14 these pictures were provided to the building
15 inspectors before today?
16 MR. CICIO: No, sir. I don't believe they
17 were.
18 MR. MATHEWS: That's consistent with our
19 understanding.
20 MR. DIFRANCESCO: Pardon me?
21 MR. MATHEWS: That's consistent with our
22 understanding.
23 At this point, I have no additional questions
24 for this witness, but I may want to call him in my
25 defense.
Page 61
1 MR. CHAIRMAN: Okay. Thank you, Mr. Mathews.
2 MS. FALCE: If the Board could just give me a
3 few minutes, I just have a few follow-up questions
4 based on his -- his questions for Mr. Cicio.
5 EXAMINATION
6 BY MS. FALCE:
7 Q. Mr. Cicio, do you recall being asked about
8 your experience in reroofing homes by Mr. --
9 A. Yes, I do.
10 Q. And you were asked about whether you held a
11 contractor license, correct?
12 A. Correct.
13 Q. Okay. And your answer, I believe, was no?
14 A. That's correct.
15 Q. Okay. Do you need a contractor's license to
16 do your job as a contractor licensing inspector?
17 A. I do not.
18 Q. Investigator rather?
19 A. I do not. Thank you.
20 Q. Sorry. Okay. Is there any certification that
21 is required to do your job as an investigator?
22 A. Just a Code Enforcement Level 1 certification.
23 Q. Okay. And you do hold that --
24 A. Yes.
25 Q. -- license? Okay. And what's required to
Page 62
1 keep that license, certification?
2 A. Every 24 months you have to get 16 CEUs in
3 order to keep the certification.
4 Q. And those are continuing education?
5 A. That is correct.
6 Q. Do you work -- I believe you already testified
7 to this, but do you work alone when you're investigating
8 contractor licensing issues?
9 A. A majority of the time, yes.
10 Q. Okay. Do you involve any other specialties
11 within the County to help you with your investigation?
12 A. I do.
13 Q Okay.
14 A If need arises, I can call upon the building
15 official or building inspectors to help me.
16 Q. And in this case, you testified that you --
17 you asked Dave Johnson and also Clyde Heffelfinger to
18 accompany you to the property to actually inspect the
19 work, correct?
20 A. That's correct, yes.
21 Q. And what was the purpose of asking them to
22 help you?
23 A. Again, because I'm not -- I'm not certified
24 with the Florida Building Code. I'm not a certified
25 Florida Building Inspector, they are.
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Page 63
1 Q. Okay. And so they determined whether or not
2 the work completed that they inspected met the building
3 code or not?
4 A. That's correct.
5 Q. Not you?
6 A. That's correct.
7 Q. Okay. You were asked about your -- your notes
8 related to this matter by opposing counsel. Do you
9 recall those questions?
10 A. I do.
11 Q. Okay. Is there anything in your notes that
12 you can recall that would not have been included in your
13 testimony here today?
14 A. No.
15 MS. FALCE: Okay. I don't have any further
16 questions.
17 MR. CHAIRMAN: Thank you.
18 MR. MATHEWS: I'd like one moment, please.
19 EXAMINATION
20 BY MR. MATHEWS:
21 Q. Mr. Cicio -- Mr. Cicio, you received a copy of
22 my subpoena, correct?
23 A. I did.
24 Q. One of the -- one of the categories of
25 documents I asked for was any and all documents
Page 64
1 concerning your investigation of Lindolph Campbell
2 and/or Abe Shultz Construction, LLC, right?
3 A. Correct.
4 Q. Would your notes fall into that category as
5 responsive?
6 A. I'm not a hundred percent sure, honestly,
7 because everything that I have as far as case file has
8 been provided to you. Case notes is just an internal
9 system to document certified mail that went out,
10 certified mail that was received, stuff of that nature,
11 but all the majority of the information, like I said,
12 everything, you've received it.
13 Q. Did you engage in any direct communications
14 with the homeowners at 4032?
15 A. I have, yes.
16 Q. Did you produce those documents to your
17 counselor who produced them to me?
18 A. Am I -- are you talking about --
19 MS. FALCE: Objection. Go ahead.
20 MR. CICIO: Are you talking about my notes?
21 No.
22 BY MR. MATHEWS:
23 Q No, no, communications to the homeowners?
24 A Did I provide communications to the
25 homeowners --
Page 65
1 Q Right.
2 A -- to you?
3 Q. Correct. So I asked for email communications
4 between yourself --
5 A. Yes.
6 Q. -- and the homeowner.
7 A. That was all provided.
8 Q. Okay. What about communications between you
9 and Mr. Heffelfinger?
10 A. The only communication was from
11 Mr. Heffelfinger to me via statement, which you have in
12 your package.
13 Q. The internal notes that -- that you created,
14 are they dated?
15 A. They're dated and time stamped, yes.
16 Q. As to when they occurred, right?
17 A. Correct. Like I said, they're just basic
18 notes for again, you send out certified mail, it just
19 puts it there in the case file so you can go back to it,
20 know what the certified mail number is, so on and so
21 forth, just basic notes.
22 Q. Okay. Can you get a copy for us when you --
23 when you get off, when you're released and then present
24 it to us?
25 A. Sure.
Page 66
1 Q. Perfect.
2 MR. MATHEWS: No further questions.
3 MR. CHAIRMAN: Okay. Thank you.
4 MS. FALCE: Nothing further for Mr. Cicio.
5 MR. CHAIRMAN: Excuse me, some of the Board
6 members want to take a five-minute break. We'll
7 have a five-minute recess.
8 MS. FALCE: Sure.
9 (A brief recess was had.)
10 MR. CHAIRMAN: Next. Thank you.
11 MS. FALCE: We're going to call the homeowners
12 up to speak, and I will let them make their
13 statement to the Board. I just ask that I -- I be
14 given some time for some follow-up questions after
15 she speaks.
16 MR. CHAIRMAN: Sure. Ms. Barbieri, that's how
17 it works, so the homeowners will speak, then our
18 counsel, then their counsel?
19 MS. BARBIERI: Yes.
20 MR. CHAIRMAN: Okay. Thank you.
21 MS. FALCE: Thank you.
22 MR. MATHEWS: Deana, are they going to go one
23 at a time, just to keep things clear or is it --
24 MS. BARBIERI: That would make -- yes, I think
25 one homeowner at a time with cross-examination,
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Page 67
1 then the next one would be clearer for the Board.
2 MR. CHAIRMAN: And Ms. Barbieri, for my
3 clarification, when does the Board get to ask
4 questions?
5 MS. BARBIERI: The Board can ask pretty much
6 anytime they want. You're kind of like as quasi
7 judicial as the judge, and if you wanted to ask
8 them a question, you can ask.
9 MR. CHAIRMAN: Okay. Thank you. Ms. Crooks,
10 do you want to be sworn in, please?
11 MS. JOHNSON: State you name --
12 MS. CROOKS: Good morning.
13 MS. JOHNSON: -- and address for the record.
14 MS. CROOKS: Nicki Ann Crooks, 4032 Greenwood
15 Drive, Fort Pierce, Florida 34982.
16 MS. JOHNSON: Raise your right hand. Do you
17 affirm to tell the truth, the whole truth, and
18 nothing but the truth?
19 MS. CROOKS: Yes.
20 MS. JOHNSON: Thank you.
21 MS. CROOKS: Hi, good morning. So I'm just
22 going to start from the beginning sort of to follow
23 a timeline --
24 MR. CHAIRMAN: Please do.
25 MS. FALCE: -- the best of my ability.
Page 68
1 My husband, Todd, is here. He did most of the
2 correspondence with Mr. Campbell and Mr. Brown. I
3 was present for the majority of the conversations
4 but not all of them. So afterwards, I'll let him
5 speak as well.
6 So in late August, we were looking around. We
7 have pictures of our garage area. It had just a
8 spot that was -- the ceiling was saturated. It was
9 not a very large area. The water was not coming
10 through. The ceiling was not falling in at that
11 point. So we were seeking, being that we had just
12 moved here to St. Lucie County, we were calling
13 around to see who knows a good roofer. My
14 husband's brother -- sorry.
15 MR. CHAIRMAN: Sorry about that. There's
16 always one in every group.
17 MS. CROOKS: Sorry.
18 MR. CHAIRMAN: I apologize.
19 MS. CROOKS: It's okay. We had a conversation
20 with my husband's brother. He said -- he's a
21 painter. He said that he knows a few gentlemen
22 that does roofing. And so he put us on a three-way
23 call with a gentleman, he goes by Zeeks, and he
24 said his boss with Abe Shultz Construction or Abe
25 Shultz Roofing he said, can take care of us.
Page 69
1 His -- he went by Andrew at the time. That is
2 Milton Brown. He refers -- our first introduction,
3 he said his name was Andrew.
4 So the gentleman named Zeeks gave Andrew our
5 contact information, in which he did contact us.
6 He spoke with my husband and they talked about just
7 that small leak in the garage area. And being that
8 it was an older roof, we didn't want it to occur
9 again and so we wanted the entire flat roof done
10 and possibly the shingled side, the sloped side.
11 He guaranteed us that he's been doing business
12 for many years and he's very good at what he does.
13 Him and his partner, they've been doing this. So
14 my husband sent him, I think, one or two pictures
15 and a video of just a walk around on the roof and
16 Mr. Brown stated that -- that he -- well, sometimes
17 what they would do is do an aerial footage to do
18 the measurements of the roof to give an estimate.
19 That's when he sent us the -- the invoice for
20 $7,000. We received that text message from him
21 and, obviously, it was very vague. We couldn't
22 make it out, and so we contacted Mr. Brown and told
23 him that we don't want -- because the price was
24 pretty low for everything that we needed to get
25 done. We told him that we didn't want them to come
Page 70
1 up to the house and prices start to change and, you
2 know, I need more money for this, I need more money
3 for that.
4 So he said that the price will not change. He
5 will do everything as soon as he gets a deposit.
6 He will go ahead and get started on the work to
7 send his crew up. So after that, after discussing
8 all the costs and all of that, and everything that
9 was going to go into the job, he confirmed to be on
10 our property by September 19th of 2020.
11 We made a cashier's check. He required -- he
12 requested us to make it out to Milton Brown. He
13 said him and his partner agreed on that's how they
14 would take the payment. They would get the crew
15 paid faster and purchase the materials to get the
16 work started right away. And so we went ahead and
17 did that, made a cashier's check and deposited it
18 into his Chase Bank account.
19 Then the crew arrives on September 19th, in --
20 very, very late at night, around 11 to midnight.
21 They inquired about where they can stay in a hotel
22 nearby. I think my husband gave them some
23 recommendations. They left and came back the next
24 morning, which was a Sunday to start work.
25 They began. We were inside the home and then
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1 Todd heard -- well, we heard a lot of nailing
2 happening. Not a lot of, you know, tearing up.
3 There wasn't a dumpster at the time so we were
4 wondering what was happening. Mind you, we're
5 first time homeowners. So we have no idea what
6 permitting is about, what's required, what
7 documents -- you know, we have no idea at this
8 point.
9 Todd goes up and sees them nailing down stuff.
10 Actually -- yeah, he sees them nailing down
11 additional material on top of our existing roof.
12 He stops them and contacts Milton Brown and says,
13 "Your guys are doing a nail down. This is not what
14 we agreed on. What's going on?"
15 We demanded that he come to the property to do
16 a full assessment, because he said that that's not
17 what he told the crew to do. So for any further
18 confusion, we said you need to come to the property
19 and make a full assessment and let's get everything
20 in writing on paper physically.
21 He did arrive on Monday, September 21st. He
22 did an assessment of the roof and gave us that --
23 that invoice for $11,000, made it more detailed
24 like we requested. At this point, we had already
25 paid him that cashier's check of $4,000. That
Page 72
1 morning we actually wrote him a check for another
2 $4,000 because he claimed that the permits were
3 expensive and that they would take months. We
4 didn't know otherwise at that point.
5 So that morning, you know, we spoke -- we also
6 showed him on the inside just that part that was
7 saturated, and he said he would take care of that.
8 Also, he would put brackets -- this was all
9 verbally -- he would put the brackets back on so we
10 can put the solar water heater, pool heater back on
11 the roof. He said that he was not a great speller
12 so what you see on that second part was my
13 handwriting, and then I requested that he initialed
14 next -- and dated next to that. So that's what the
15 second part on the invoice is.
16 He signed it. That's his signature on the
17 bottom of that invoice and he left the property
18 that morning. He said that he would have his
19 secretary begin the permitting process to get all
20 the documents together and to gather the crew to
21 return to do the job.
22 The week of September 25th, within that week,
23 Lindolph Campbell initiates a phone call with Todd.
24 They discussed information about the City or the
25 County in order to pull the permit. Todd gave him
Page 73
1 some information on which avenues to go to pull the
2 permit in St. Lucie County. Time passes at that
3 point. We make quite a bit of attempts to -- to
4 reach Milton Brown. Most of those times we were
5 unsuccessful in reaching him. He did pick up maybe
6 one or two phone calls, but they were very brief.
7 It was, "I'm busy. I need to call you back."
8 In one of those attempts -- or one of those
9 conversations, we said, "You know what, this is
10 kind of, you know, taking a little bit longer than
11 we thought." We requested a refund at that point.
12 And insured (sic) that everything in the process,
13 the permitting doesn't take a day. It takes a
14 while to get the permits. They're also doing other
15 work, so -- and -- so they're busy. We go ahead
16 and give the time. He assured us that him and his
17 partner would get the work done in a timely manner.
18 He said his secretary will take care of all the
19 paperwork.
20 On the 5th of October, Milton Brown calls and
21 requests my driver's license. He stated that
22 Lindolph Campbell needed it in order to complete a
23 Notice of Commencement. He did send us a text
24 message with an image of a paper that said
25 something about a Notice of Commencement. It
Page 74
1 wasn't clear so we went ahead and asked him what
2 that was about, if they can explain it a little bit
3 more for us, you know, because I'm giving my
4 driver's license out. And at this time, our
5 understanding, the way that Milton Brown represents
6 Abe Shultz, he refers to Mr. Campbell as the
7 secretary, who was handling all the paperwork for
8 the company.
9 So he -- when we asked Mr. Brown about the --
10 what the Notice of Commencement was about, he
11 referred us to speak to Mr. Campbell. Mr. Campbell
12 did explain it to us at that time, and most of this
13 time, again, Milton Brown can't be reached for the
14 majority of the time. Mr. Campbell also stated
15 that the permit was being taken care of by him.
16 And I also have to note that I was assisting
17 Mr. Campbell in obtaining that permit, because,
18 initially, he sent the wrong permit application to
19 the wrong office. I believe he sent it to the City
20 of Fort Pierce. They did respond saying that, you
21 know, he's on the right track, but he has the wrong
22 avenue. They referred us to the unincorporated
23 St. Lucie County for the application to be
24 processed.
25 I gave Mr. Campbell that information and gave
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1 him the email, the submittals, email for him to
2 send the application to. He went ahead and sent an
3 application in, but it was the wrong application.
4 I referred him to the website to find the correct
5 information. It has a list of all of the different
6 applications on there. I referred him to that.
7 And this is over time. This is not within a week.
8 So we're -- I'm back and forth assisting him in
9 doing that.
10 We also did say in those conversations that,
11 you know, we -- we just need to get a refund at
12 this point, and he did say that that was not
13 necessary.
14 Mr. Campbell discusses with my husband on
15 October 16th of 2020 -- I'm sorry, in my note it
16 says 2022. It's because I'm used to writing that,
17 but he speaks with Todd about meeting up to handle
18 for the completed Notice of Commencement.
19 Mr. Campbell did not show up that -- that day.
20 Time progresses. On November 12th, Mr. Campbell
21 states that the permit was sent. This was one of
22 the times that he sent it to the incorrect place,
23 because when I called the permitting department,
24 they said that they did not receive any
25 applications.
Page 76
1 While I was on the phone with the permitting
2 department, I started to ask questions now that I'm
3 kind of in the midst of all of this situation. The
4 lady did ask -- say to me that she hopes that I
5 didn't give anybody any money as yet, and I told
6 her yes. She was very concerned. She did say that
7 permitting does not take months. In fact, if
8 they're backed up, it may take three to four days,
9 close to a week, and permitting does not cost
10 thousands of dollars like Mr. Brown stated to us.
11 That's one of the reasons why the amount went up to
12 $11,000 because he said that permits were
13 expensive.
14 On December 8th, Mr. Campbell pays for the
15 permit. He sent me confirmation with a receipt. I
16 called the permitting office and they did confirm
17 that it was paid for. I picked up the documents in
18 person that they were able to give me at the office
19 nextdoor.
20 On the 17th of December, the dumpster was
21 delivered by WastePro. Mary Young is the point of
22 contact for WastePro. I have an email from
23 Mary Young with the -- the agreement for the
24 dumpster that was signed and paid for by
25 Mr. Campbell.
Page 77
1 On December 22nd, the same crew, minus a
2 couple of the gentlemen that were originally there
3 on the 19th and the 20th of September, but same
4 crew, arrives in the morning with another gentleman
5 named Warren to begin work. At this time,
6 Mr. Brown is not there and Mr. Campbell is not
7 present either.
8 While they were working, the crews said they
9 were -- they didn't have enough funds to continue
10 to do the work. They needed to purchase more
11 material. They approached my husband and asked him
12 for money to purchase material, in which he
13 declined very, very strongly.
14 We called Milton Brown a few times and he did
15 not respond. We also called Mr. Campbell, but he
16 did not respond either.
17 Mr. Brown texts and claimed that he has an eye
18 problem at that point, that he was not able to take
19 care of funding the crew because he has an eye
20 problem. One of the guys from the crew gave
21 Mr. Brown a call, in which he did answer. He asked
22 -- and he was on speakerphone. We heard him ask
23 the gentleman, Why the, expletive, do you have him,
24 my husband, calling my phone?
25 There was that text exchange, I believe that
Page 78
1 you guys have, between Milton Brown and Todd. The
2 crew was unable to continue working and then they
3 leave.
4 The last text message or conversation I
5 believe that we had with Milton Brown was on
6 December 23rd of 2020. At this time, we're still
7 continuing to conversate (sic) and text
8 Mr. Campbell. He was easily reachable for the most
9 part.
10 On the 22nd to the 23rd, one of those days, my
11 husband speaks to Mr. Campbell over the phone. He
12 expresses his frustrations based on the events that
13 happened on the 22nd with the crew and Milton Brown
14 not having enough funds. He expressed to
15 Mr. Campbell that we were going to go ahead and
16 take legal actions because we are finding that
17 they're being dishonest the way that they are going
18 about business, the way that they represented
19 themselves to us was very dishonest from the
20 beginning. And as we were trying to work with both
21 of them, it became very, very difficult at that
22 point, and time is also passing.
23 This was the first time that Mr. Campbell
24 actually admits to being the sole owner of
25 Abe Shultz Construction and not a partner or
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1 secretary like he has been representing himself to
2 be beforehand. Mr. Campbell expresses to my
3 husband that Milton Brown was out to ruin his
4 company and that he would take control of the job
5 and get it done and that he would honor the
6 contract that we have. Mr. Campbell scheduled a
7 date and a time with us for them to visit -- for
8 him to visit the property.
9 I think January 1st or the 2nd of 2021 is when
10 he showed up with a gentleman named Warren. They
11 assessed the roof, took measurements. Mr. Campbell
12 stated to us that Mr. Brown had undercharged us for
13 the job and that if he would have made the contract
14 himself that he would have charged us another
15 $5,000 in addition to the $11,000. We immediately
16 refused in front of him and Warren on the roof. We
17 told them that so far the events that have been
18 happening, all of the -- the dishonesty -- and in
19 addition to that, the crew that first came on
20 September 20th, 19th and 20th, they went into the
21 garage that I have -- it's saturated a little and
22 began to rip the ceiling down. So it's exposing
23 the wood underneath the -- the roofing material.
24 They also went into the nanny suite and ripped the
25 ceiling down there as well. So now we have that
Page 80
1 opened up. It's no longer closed in. There were
2 -- there was mold in there. And so they had began
3 to do that ceiling work is what we were, you know,
4 explaining. And so that had to be, you know,
5 either fixed or completed. We expressed that to
6 Mr. Campbell, that we were not going to be issuing
7 anymore money to anyone at this point. He didn't
8 challenge at all or he didn't disagree.
9 We also said to him on the roof as well that
10 we were going to be contacting a lawyer, if him and
11 Milton Brown doesn't get it together and take care
12 of the situation. We're frustrated at this point
13 because the time lapse was -- was very ridiculous.
14 He, Mr. Campbell, calls Mr. Brown, in our
15 presence, and very sternly told him that he needs
16 to make sure that he pays Mr. Brown, gives him the
17 $5,000 to finish the job. He stated to Mr. Brown
18 that -- saying, These people are threatening to sue
19 me and I refuse to let you -- let you make me lose
20 my business.
21 Campbell tells Brown to get him the money
22 immediately or they're going to have a problem. He
23 told -- Mr. Campbell told Mr. Brown on the phone
24 that morning that he will not be doing any work on
25 the roof unless he receives that $5,000 from
Page 81
1 Mr. Brown. Mr. Campbell and Warren leaves.
2 Mr. Campbell and my husband has a conversation
3 about him returning to the property to begin work.
4 I believe the dumpster was delivered on
5 December 17th. I have it in an email from Mary at
6 WastePro.
7 On the 13th of January, Mr. Campbell, Warren
8 and the crew, same crew, arrives and they being
9 working. They run out of gas and Campbell inquires
10 with my husband about a nearby place to refill the
11 propane tank. My husband suggests a company
12 nearby. Mr. Campbell leaves to get gas, but never
13 comes back to the property that day.
14 There was a conversation, a phone conversation
15 in that -- that night of January 13th between
16 Mr. Campbell, my husband and I. Everyone was
17 frustrated at this point. Mr. Campbell gave his
18 word to us that he will complete the roof, fulfill
19 the contract, and honor the five-year warranty.
20 When I requested that to be in writing, he
21 declined. He said he's not putting anything in
22 writing. He's giving his word that he will honor
23 the contract and honor the five-year warranty. At
24 the point of that disagreement, him refusing to put
25 it in writing, everyone got a little bit
Page 82
1 frustrated, so the call does not end on a good
2 note.
3 He sends a text message threatening to put a
4 lien on the house, because we owe an additional
5 $3,000.00. He said that he's entitled to put a
6 lien on the house because I have not -- we have not
7 paid the full amount of the contract. We did let
8 him know that the contract was not fulfilled by --
9 on his side, on the contractor's side; therefore,
10 the $3,000 can't be paid because they're not doing
11 any -- they're not fixing any of the ceiling work
12 that they tore down.
13 The crew also comes back without Mr. Campbell
14 on January 14th and 15th. They finish up the work,
15 but none of the ceiling work was done because we
16 were -- we were unable to come to a resolution
17 about the ceiling.
18 In regards to the January 20th inspection that
19 was scheduled for that day, I originally went
20 online to look at the information about any type of
21 inspection that was -- that was ready to be done or
22 ready to be scheduled. I went on there because the
23 conversation that we had with Mr. Campbell, he
24 stated that he had six months to complete the
25 inspection and he was not in any hurry to do the
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1 inspection immediately or as soon as possible. I
2 believe that was a dig at us because of all the
3 frustration at that point, claiming that he had a
4 full six months to do the inspection; therefore, I
5 went online and found out that there was an
6 inspection for the sheathing that -- I don't know
7 what sheathing is.
8 I called the office and -- to schedule the
9 inspection for the 20th. They did schedule it. I
10 did inform them that the roof was already completed
11 at this point. The lady said, well, there needed
12 to be either pictures -- do you know if they sent
13 pictures? I told her I don't know if there were
14 any pictures. She said we didn't receive anything
15 in regards to the inspection, but when I told her
16 that the roof was already done, she said that was
17 going to be a problem.
18 I did not at all request to cancel any
19 inspection. I'm the one who scheduled it with
20 them, but I'm guessing when I told her that the
21 roof was already done they went ahead and put in
22 whatever notes. But I -- I did not expressedly
23 (sic) cancel the -- the inspection.
24 So then right after, because Mr. Campbell said
25 that he had a whole six months, which we didn't
Page 84
1 have, I went ahead and filed a complaint on
2 January 15th. The inspection -- there was an
3 inspection that was done where Mike was present.
4 Multiple problems were found, I guess. After the
5 complaint, I received some information about the --
6 this is -- time is progressing at this point.
7 I believe Mr. Cicio was speaking to
8 Mr. Campbell at this point trying to get him to
9 come back out to complete the work, fix it or --
10 for it to pass inspection. He did say that he
11 needed time. He sent us also a text message saying
12 that he was going to be back in July to complete
13 the work, that didn't happen. So it's a waiting
14 game for us. And at this point, we're not in
15 communication with Mr. Campbell or Mr. Brown. Over
16 the phone he sent that text message saying he was
17 going to be back out in July. From what we
18 understood, the permit was going to be expired in
19 October, and so we assumed that he was going to
20 come back before that to get the work done before
21 the -- the permit expired.
22 October came around and the permit did expire.
23 There was supposed to be a hearing in which -- I
24 don't know who requested more time. So the hearing
25 didn't happen. We were prepared to come to the
Page 85
1 hearing at that time, but he did say he would come
2 out to get the work done.
3 After the hearing date had passed it up, I
4 believe it was October 20th, is when Mr. Cicio
5 notified me that Mr. Campbell expressed that he
6 would no longer be fixing the roof for it to pass
7 inspection. And so time passes again, and at this
8 point, October of 2021, we receive a phone call
9 from Mr. Campbell stating that he was going to be
10 at our home the next morning with the crew to get
11 the work -- to get work done, and an inspection
12 person was also going to be there that -- that
13 morning.
14 At this point, we understand that the permit
15 had expired. There were, I guess, red flags to not
16 -- for Abe Shultz Roofing not to renew the permit.
17 I'm not sure what the technical aspect of that is,
18 but he did say that he did, in fact, renew the
19 permit. He sent a text message with an image of
20 the renewal, and he also sent it to my email.
21 A van comes the next morning, and my husband
22 went out to speak to them. There was no dumpster
23 at this point at -- at our home, and they didn't
24 have any material. Todd was expressing that, you
25 know, you have to give us a little more time if you
Page 86
1 wanted to come to the house and get work done. You
2 can't just text us the night before saying you're
3 going to show up to our house the next morning,
4 which is what Mr. Campbell did in October of 2021.
5 After that, they drove -- the crew drove away.
6 Another set of crew came behind them and we said,
7 Well, your other guys already left. The inspector
8 did come. We showed the inspector the notices that
9 Mike left for us. We didn't speak to him much. We
10 just showed it to him and said that, you know, as
11 far as we know that the permit was expired. I'm
12 not sure how he got it renewed, but he -- we just
13 got bombarded with this the night before. He left,
14 and I think that -- that was about it.
15 So -- I mean, it's all been pretty exhausting
16 and a nightmare, to be honest, going through it,
17 especially going through it for this period of
18 time, because we have given Mr. Campbell the
19 opportunity to get the roof done so -- just so that
20 it can pass inspection. Because we knew that we
21 would find another avenue to get the -- the
22 ceiling, the inside done. However, in that time,
23 because of the work that was done on the roof,
24 there were other places inside our house -- excuse
25 me -- that was damaged. There are pictures at --
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1 the front door of the ceiling caving in on the
2 inside. The ceiling is leaking, opened up, and
3 it's just been a nightmare. So I just want to get
4 it over with.
5 MR. CHAIRMAN: Thank you, Mrs. Crooks.
6 MS. FALCE: Would you like me to proceed?
7 MR. CHAIRMAN: Please.
8 MS. FALCE: Okay. Thank you. Mrs. Crooks, do
9 you need a moment? I apologize.
10 MS. CROOKS: I think so.
11 MR. CHAIRMAN: Anybody got any tissues?
12 MS. CROOKS: Thank you. Sorry about that.
13 MR. CHAIRMAN: No. No worries. Take your
14 time.
15 MS. CROOKS: Okay.
16 MS. FALCE: If at any point you need to -- to
17 take a break, please just let me know. I know this
18 is hard.
19 Thank you for taking the time to put together
20 that statement and to give it this morning. As a
21 matter of procedure, I'd like to enter into the
22 record the timeline that you -- you read from and
23 put together. I know you made -- made copies and
24 we all have copies, so I'd like to enter that into
25 the -- as evidence in the record of these
Page 88
1 proceedings below.
2 NICKI CROOKS,
3 After having been previously sworn, testified
4 as follows:
5 DIRECT EXAMINATION
6 BY MS. FALCE:
7 Q. Just -- I'd -- I'd like to go back to the
8 beginning in August of 2020 when you first heard about
9 Abe Shultz Construction and Milton Brown. Is that
10 correct, it was August, 2020?
11 A. Yes.
12 Q. Okay.
13 A. End of August, yes.
14 Q. And you stated that you had received that name
15 from your brother-in-law?
16 A. Correct, yes.
17 Q. And what I think I heard you say is that
18 Mr. Brown contacted you.
19 A. Yes, he initiated the contact.
20 Q. How did he get your contact information?
21 A. The -- so we were on the line with Todd's
22 brother and he said, Oh, yeah, you know -- because he's
23 a painter -- he said, I know a few guys who works for a
24 roofing company. They do roofing all the time. Let me
25 get you -- let me see if he'll answer the phone.
Page 89
1 When he called, it was on three-way because we
2 wanted to explain what we needed to get done, if they
3 were able to come up and do it because they're in
4 Broward, we're in St. Lucie County, but mostly everybody
5 that we know lives in Broward because that's where we
6 moved from.
7 The gentleman named Zeeks, he said, Yeah, you
8 know, I work for a guy named Andrew with Abe Shultz
9 Roofing, and, you know, just give me your information,
10 you know, we've be been doing it for years. I work for
11 him, and I'll give you -- I'll give him your contact
12 information. So Todd said, yeah, just have him give us
13 a call, and that's how our information got really to
14 Milton Brown.
15 Q. Okay. Did you ever have any further contact
16 with Zeeks?
17 A. He -- he was part of the crew.
18 Q. Oh, okay. So he's -- he's part of the crew
19 that showed up --
20 A. Yes.
21 Q. -- with Mr. Brown?
22 A. Correct.
23 Q. Okay. So when you -- well, strike that.
24 You received an invoice from Milton Brown for
25 $7,000 originally?
Page 90
1 A. Yes.
2 Q. Okay. And when you received that invoice, had
3 Mr. Brown ever visited the property to see what was
4 wrong?
5 A. No. And we did talk to him about that and he
6 said that they have an opportunity to do sort of
7 measurements for estimates and invoices from an aerial
8 view. We don't know how that worked, so we said okay,
9 you know, as long as the amount doesn't change once you
10 get here. And he said, No worries, we'll get the job
11 done. We're going to do the whole flat roof, you know,
12 replace the shingle side. I'm going to send my crew up
13 there, you know. The sooner you get us a deposit, the
14 sooner we'll be able to begin. And we said okay.
15 Q. And when the workers showed up on
16 September 18th --
17 A. It was September 19th they showed up very late
18 at night. Obviously, work can't be done. So I'm
19 guessing they were just there to spend the night to
20 begin the work the next morning, which they did. So
21 they started initially on the 20th, which was a Sunday.
22 Q. Okay. And was Mr. Brown with them when they
23 started that work?
24 A. No.
25 Q. Okay. So before the work started, Mr. Brown
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1 never visited your property?
2 A. Correct.
3 Q. Okay. And then it wasn't until September 21st
4 that Mr. Brown came to your property?
5 A. He did come, yes.
6 Q. Okay. And it's at that point that the invoice
7 changes?
8 A. Correct.
9 Q. Okay.
10 A. Which we -- we expected because, you know, we
11 were saying, I don't think he realizes how large the
12 roof is. So when he did come, the permitting came up
13 that was added to it as well, and that's when it
14 changed.
15 MR. CHAIRMAN: Excuse me, real quick. I don't
16 want to interrupt --
17 MS. FALCE: Yeah, of course.
18 MR. CHAIRMAN: -- but you're referencing an
19 invoice that's a proposal to do the work, not an
20 invoice, from what we're seeing.
21 MS. FALCE: Yes, you're correct. Yes. I
22 meant the proposal. Thank you for -- for
23 correcting me.
24 MR. CHAIRMAN: No worries.
25
Page 92
1 BY MS. FALCE:
2 Q. So the -- the proposal that you received via
3 text, is that the original one for $7,000?
4 A. Yes. He never printed that. We weren't able
5 to read it. You know, he did say that when he came to
6 the property he would bring that, but when he came to
7 the property, it was a whole other invoice.
8 Q. Okay. So you never saw the original of
9 that --
10 A. The one that he texted me, no. That was the
11 only image that we had was from that text.
12 Q. Okay.
13 A. Yeah.
14 Q. So as you move forward with the job with
15 Mr. Brown and the -- the proposal from Abe Shultz
16 Construction for the $11,000 --
17 A. Yes.
18 Q. -- that one, that's the contract that you
19 proceeded under?
20 A. Correct.
21 Q. That -- that's your understanding of what this
22 job involved, correct?
23 A. Correct.
24 Q. Okay. So not -- not the proposal from August
25 that you received via text photo that you couldn't read,
Page 93
1 correct?
2 A. No. We -- we expressed to him that it had to
3 be more detailed. He said that he understood, not a
4 problem. When I visit, we'll go ahead and take care of
5 that. So we did not take that seriously.
6 Q. Okay. And the notations on the proposal from
7 September for Abe Shultz Construction, the $11,000
8 proposal, there are notations that you paid $4,000
9 initially and then paid an additional $4,000 on
10 September 21st, 2020. Is that accurate?
11 A. Yes. On the 18th, the cashier's check was
12 made and deposited to an account belonging to
13 Milton Brown and then on the 21st, in his presence, we
14 gave him a physical check for another $4,000.
15 Q. Okay. And the balance to be paid when the
16 work was complete?
17 A. Complete, correct.
18 Q. So after -- after the 21st, after
19 September 21st, and you have the new proposal for
20 $11,000, you stated that Mr. Campbell initiated a phone
21 call with your husband on September 25th, 2020?
22 A. Yes.
23 Q. Okay. And how did -- do you know how
24 Mr. Campbell got your phone number?
25 A. We assumed through Milton Brown. Mr. Milton
Page 94
1 Brown referred to his partner and secretary as
2 Mr. Campbell. Mr. Campbell, whenever we had
3 conversations with him, did say, you know, I'm just a
4 secretary. I'm just the assistant. I'm doing the
5 paperwork. You know, I have -- I have a lot of things
6 that I'm doing, so this is going to take a little bit of
7 time, things like that.
8 Q. Okay. And when you spoke with Mr. Campbell,
9 did he ever tell you that this proposal for $11,000 is
10 not on his form or act unaware --
11 A. No.
12 Q. -- of the work that was going on at your home?
13 A. No.
14 Q. Okay. Never -- never told you that
15 Milton Brown is not working for him, is not part of the
16 -- the crew that does the roofing work for him?
17 A. No.
18 Q. Okay. In fact, when he called you and every
19 time you spoke with him, he was well aware of
20 Mr. Brown's work on your roof?
21 A. Absolutely, yes.
22 Q. Okay. About how long did he -- did
23 Mr. Campbell act like he was the secretary for
24 Abe Shultz Construction?
25 A. Up until we brought up calling a lawyer in
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1 late December --
2 Q Okay.
3 A -- or early December, around the time when he
4 did finally pay for the permit. That was when he said,
5 you know, I am the owner. I'm the sole owner of this
6 company, and you know, Andrew is out to ruin my company,
7 and I'll take charge. I will honor the contract and get
8 things done.
9 Q. Okay. And so from September 25th, 2020 when
10 you and your husband had the first conversation with
11 Mr. Campbell, all the way through the end of
12 December of 2020, you were unaware that he was the
13 contractor --
14 A. Correct.
15 Q. -- for Abe Shultz Construction, the owner?
16 A. Correct.
17 Q. Okay. You referenced a Warren as part of the
18 crew --
19 A. Yes.
20 Q. -- that came to do the work?
21 A. Yes.
22 Q. Do you -- do have any more of his name, do you
23 know the rest?
24 A. No. I believe he had a shirt with his name on
25 it. He showed up with the crew on December 22nd, and
Page 96
1 then the next time we saw him was with Mr. Campbell,
2 January 1st or 2nd, I believe, when they showed up to do
3 the assessment. It was just those two.
4 Q. Okay. And then the crew, from September when
5 they first show up at your home to do the work to the
6 end, was it the same crew, give or take a couple of
7 guys?
8 A. But yes, same.
9 Q. It didn't change after the permit was issued
10 to Abe Shultz Construction for Mr. Campbell?
11 A. No.
12 Q. Okay. Did Mr. Brown come to your house after
13 the permit was issued to do work?
14 A. No.
15 Q. Did you have any further contact with
16 Mr. Brown after the permit was issued by
17 St. Lucie County?
18 A. We made several attempts after the
19 December 22nd incident about his eye. We made several
20 text -- attempts to contact him, nothing.
21 Q. Okay. Did Mr. Campbell ever tell you why he
22 wasn't back on the property doing the work?
23 A. No.
24 Q. No. Did you ever ask?
25 A. Well, I believe we did have a discussion with
Page 97
1 Mr. Campbell about it and he was going to speak with
2 Mr. Brown. So it was going to be those two having a
3 conversation --
4 Q. Okay.
5 A. -- about what was going on.
6 Q. Okay. Towards the end of your testimony, you
7 -- you -- you spoke about the crew going inside your
8 home and tearing -- tearing the ceiling down.
9 A. Yes.
10 Q. And about when was that again?
11 A. That was the first time they came,
12 September 19th and 20th of 2020.
13 Q. Inside the home they came and tore out --
14 A. The garage and the nanny suite and the
15 bathroom, yes.
16 Q. Okay. And -- and do you know who instructed
17 them to come inside your home and tear down --
18 A. It was a part of the contract of the --
19 Q Okay.
20 A -- the invoice or proposal. So that's what
21 they understood was going to be done.
22 Q. Okay. And it's what you understood as well --
23 A. Yes.
24 Q. -- that would be part of the project?
25 A. Yes.
Page 98
1 Q. Okay. But that was never completed, inside?
2 A. After they tore down the -- the holes, nothing
3 else -- that was never touched again.
4 Q. Okay.
5 A. It was left like that.
6 Q. In the photos we saw the plastic covering the
7 ceiling within your home, do you know who placed that
8 there?
9 A. My husband placed it there because in between
10 the board and the ceiling, there was quite a bit of mold
11 and so now being that there was an open hole, the garage
12 was being exposed. The nanny suite was being exposed,
13 and we started to see spurs on the cars and on the stuff
14 inside the garage and the nanny suite.
15 Q. Do you recall when the plastic was -- was
16 placed?
17 A. Probably immediately after they ripped the
18 hole open because it was very unappealing to look at as
19 well, so yeah.
20 Q. So in September of 2020?
21 A. Just about or at the beginning of October,
22 yeah.
23 Q. Does it still look like that?
24 A. Yes.
25 Q. So you -- you also mentioned that there was an
27 (Pages 99 to 102)
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Page 99
1 insurance claim --
2 A. Yes.
3 Q. -- through Abe Shultz Construction?
4 A. Correct.
5 Q. Can you explain how that -- that came about?
6 What are the circumstances leading up to that?
7 A. I believe I -- we did some digging. I believe
8 Mr. Cicio told us or gave us -- it was something -- some
9 document and it had a phone number to an insurance
10 place. We called them and they said they don't have a
11 policy on that, but they have, like, a sister company
12 called Nautilus Insurance, and I just tried to do as
13 much research as possible.
14 And when we called Nautilus and gave them the
15 name of Abe Shultz Roofing, Abe Shultz Construction,
16 they did find a policy, and so we went through them to
17 go ahead and file a claim for the damages that started
18 happening inside the home. And I believe our first
19 initial contact with them was October of 2021.
20 Q. Okay. And was Mr. Campbell involved in that
21 process at all?
22 A. I believe he was. The woman, the adjuster who
23 we were in contact with, I guess, who was assigned to
24 that case, she did state in several occasions that
25 Mr. Campbell did give the insurance statements and
Page 100
1 documents to go with the claim, along with the
2 statements and documents that we provided to them.
3 Q. Okay. Was there ever a question of whether
4 Abe Shultz Construction was -- was responsible for what
5 you were claiming as damage?
6 A. Initially, no. I was told by the adjuster
7 that he said that he does business with Milton Brown and
8 he did do work at our property, and so they find --
9 found that the damages were caused directly because of
10 the work that his company came out to do.
11 I believe after some time during the end of
12 the claim, he said that he didn't know who Milton Brown
13 was, so yeah.
14 Q. Okay. But -- but ultimately, the insurance
15 company issued --
16 A. They --
17 Q. -- a check to you?
18 A. They sure did. They sent us a release letter.
19 We went ahead and signed and notarized that. I have it
20 here, and they wrote a check for $14,654. They actually
21 had an inspector or an adjuster come out to the
22 property. They took plenty of pictures and wrote a
23 report in which she used to assess to do this statement.
24 Q. Can I -- I'm going to ask you to take a look
25 at what's been marked as Page 23 and 24 of the packet
Page 101
1 that was introduced to the Board at the beginning of
2 these proceedings by staff.
3 MS. JOHNSON: Here you go.
4 BY MS. FALCE:
5 Q. There's page numbers at the bottom. So if you
6 could just open up to Page 23 for me. And it's going to
7 look like this (indicating). They're photographs.
8 A. I see 24 and then prior to that it's 18. So
9 this is 24.
10 Q So these numbers down here.
11 A Oh, the ones that --
12 Q I apologize.
13 A I got it. Okay. Sorry about that. Thanks.
14 Q. Okay. So can you take a look at this and just
15 let me know if this is the release that you just
16 referenced from Nautilus --
17 A. Yes, it is.
18 Q. -- Insurance. Okay. And this is what
19 resulted in the insurance claim process that you just
20 detailed, correct?
21 A. That's correct.
22 Q. Okay. And the money that was paid to you,
23 what was it for? What is your understanding of what
24 that money was for?
25 A. It did show in the -- in the email, it had an
Page 102
1 itemized thing. I believe part of it was for the
2 replacement for the solar water heater. Part of it was
3 for the drywall damage in the ceiling in the garage and
4 in the nanny suite, and also the new occurrences on our
5 veranda ceiling that's also come down, and on the inside
6 in our living area also has water damage.
7 Q. Okay. So it was not to use to finish the work
8 for the roof, correct?
9 A. Absolutely not.
10 Q. Okay.
11 A. And also -- I'm sorry. And also to repair the
12 screen. Our pool has an enclosure and part of the
13 screen goes along the back part of the roof where they
14 used the torch, and it burned the screen. So it was for
15 that as well.
16 Q. Okay.
17 A. So it was just to pay for the damages.
18 MR. MATHEWS: Okay. I'm going to object. The
19 document stands for itself at Pages 23 and 24.
20 MS. CROOKS: I have an email that she sent
21 with the list.
22 BY MS. FALCE:
23 Q. Okay. But what you just described, is that
24 your understanding?
25 A. Yes, it is.
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Page 103
1 Q. Okay. And it's based on the email that you
2 received from the insurance company; is that correct?
3 A. Yes.
4 Q. Okay.
5 MR. CHAIRMAN: And Mr. Mathews, with all due
6 respect, this is just a document that I'm reading.
7 It's from the liability for a claim from an
8 insurance company stating that they've cut a check
9 for $14,000. Clearly it does say that -- when you
10 look at it and -- but they did write a check. So
11 you're objecting to -- what are you objecting to?
12 MR. MATHEWS: I'm objecting to the
13 characterization of what the payment was for, and
14 what it included and what it didn't include. I'm
15 looking at a release and it does say in part, deny
16 liability, intend merely to avoid litigation, and
17 there is release language contained within that
18 first paragraph, which is very broad.
19 MR. CHAIRMAN: Uh-huh. I agree, but I'm going
20 to allow the documents to be part of this.
21 MR. MATHEWS: Oh, yeah, yeah. I'm objecting
22 to the testimony, not the document itself. Sorry
23 if there was confusion there.
24 MR. CHAIRMAN: Okay. Thank you. I apologize
25 again. Thank you.
Page 104
1 BY MS. FALCE:
2 Q. Okay. So since October 13th, 2021 when you
3 learned that the permit maybe had been extended after
4 its expiration --
5 A. Correct.
6 Q. -- has there been any further work done by Abe
7 Shultz Construction to complete the roof.
8 A. No, ma'am.
9 Q. Okay. And no inspections occurred prior to
10 the roof being covered by Abe Shultz Construction?
11 A. That's correct.
12 Q. Are there currently still openings in the roof
13 that -- from that -- from the April 13th inspection to
14 uncover what the sheath -- you know, how the sheathing
15 was nailed in?
16 A. The -- that same day, Warren did cover those
17 spots that were opened.
18 Q. Okay. But no new work has been completed
19 since then?
20 A. No, ma'am.
21 Q. Okay. As a result of this permit not being
22 finalized and the work not being done pursuant to the
23 building code, has there been any other ramifications or
24 resulting damage to you related to a homeowner's
25 insurance?
Page 105
1 A. Absolutely. Our homeowner's insurance had
2 expired in 2020. They had -- so we weren't able to
3 renew because of the open permit and the failed
4 inspection. We weren't able to renew that. So right
5 now our mortgage company is paying for homeowner's
6 insurance because we're required to have it, but it's
7 much higher than we -- what we normally would pay
8 ourselves.
9 MS. FALCE: Okay. One moment. I might be --
10 before I -- I conclude, I think this is it, but --
11 well, when your husband comes up, you -- you had
12 brought with you and referenced during your
13 testimony a few photographs.
14 MS. CROOKS: Yes.
15 MS. FALCE: Would you like to enter them into
16 the record of these proceedings as evidence or --
17 or is that going to be part of your -- your
18 husband's statement?
19 MS. CROOKS: I would like to submit it, yes.
20 MS. FALCE: Okay. So if we could have your
21 documents that you brought. Thank you. And for
22 the record, the reason she didn't have them before
23 her was because we were making a copy for her for
24 both sets of counsel.
25 So if there's anything that you would like to
Page 106
1 show, I will give you an opportunity to do so now
2 because you didn't have the benefit of your -- of
3 your own documents, but if -- if you would just
4 like to enter all of them, that -- it's your
5 prerogative.
6 MS. CROOKS: Okay.
7 MS. FALCE: Thank you very much.
8 MS. CROOKS: The one thing that came up that I
9 heard earlier was that when the permit, this permit
10 application was sent to me via email by
11 Mr. Campbell, when I printed the attachments,
12 there's a building -- building permit application
13 here that said that I signed this, but I did not.
14 It was notarized, but I was not present, nor -- I
15 didn't sign this building permit application here.
16 That happened, I guess, in November.
17 MR. CHAIRMAN: So the application that is in
18 our packet that has your signature on it, is not
19 your signature?
20 MS. CROOKS: That's not my signature, no. I
21 can show you my signature on the -- well, it's on
22 the -- the property damage only release from the
23 insurance, from Nautilus Insurance. I signed that,
24 and I sign like that all -- all the time.
25 MR. CHAIRMAN: So who signed the bottom of the
29 (Pages 107 to 110)
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Page 107
1 proposal, the Acceptance for Proposal?
2 MS. CROOKS: I did not. Mr. Brown signed or
3 Mr. Lindolph, one -- one of them.
4 MR. CHAIRMAN: It's not your signature
5 clearly.
6 MS. CROOKS: No, it's not.
7 MR. CHAIRMAN: But that is your signature on
8 the Notice of Commencement.
9 MS. CROOKS: The Notice of Commencement --
10 MR. CHAIRMAN: They look identical.
11 MS. FALCE: Which page?
12 MS. CROOKS: Twelve. Thank you.
13 MS. FALCE: For the record, is the
14 Notice of Commencement you're referring is Page 12
15 of the packet?
16 MR. CHAIRMAN: Page 12, yes, ma'am.
17 MS. CROOKS: Yes. That's my signature.
18 MR. DIFRANCESCO: Mr. Chairman?
19 MR. CHAIRMAN: Yes, Mr. DiFrancesco.
20 MR. DIFRANCESCO: For the record, when a
21 contractor is submitting a permit, he is allowed to
22 sign as an agent for the owner, which is what it
23 seems someone did. It doesn't appear that the
24 signature of the contractor and the signature of
25 the owner/agent --
Page 108
1 MR. CHAIRMAN: They're clear different.
2 MR. DIFRANCESCO: -- looks completely the
3 same.
4 MR. CHAIRMAN: Ms. Waters, is that correct
5 what Mr. DiFrancesco just stated, you can sign as
6 owner/agent? Because it just says signature of
7 licensed contractor, signature of owner, lessee
8 contractor as agent for owner.
9 MS. WATERS: Yes.
10 MR. CHAIRMAN: So do we know --
11 MR. MATHEWS: Mr. Chairman, which -- which
12 document are you looking at?
13 MR. CHAIRMAN: We are looking at Page No. 11.
14 Do we know whose signature that is?
15 MS. WATERS: I'm not sure whose -- whose
16 signature this is, but the contractor can sign on
17 both lines on this document.
18 MR. CHAIRMAN: Uh-huh. But for the record,
19 those are two clearly different signatures.
20 MR. DIFRANCESCO: It appears the notary is not
21 from the county. So the permit was notarized
22 somewhere else.
23 MR. CHAIRMAN: Uh-huh. Thank you,
24 Mr. DiFrancesco.
25 MR. MATHEWS: Mr. Chairman, can we take a
Page 109
1 break for five minutes?
2 MR. CHAIRMAN: Sure. Five-minute break.
3 MR. MATHEWS: And I would imagine after that,
4 the panel may have questions for Ms. Crooks and
5 then I may.
6 MR. CHAIRMAN: Absolutely.
7 MR. MATHEWS: Is that fair?
8 MR. CHAIRMAN: Yep. Fantastic. Thank you.
9 MR. MATHEWS: Thank you.
10 MR. CHAIRMAN: Five-minute break.
11 (Brief recess was had.)
12 MR. CHAIRMAN: Good morning. You were looking
13 for some pictures?
14 MS. FALCE: Yeah, just where we left off, did
15 you want to present any of the -- the photographs
16 that you didn't have access to during your -- your
17 testimony --
18 MS. CROOKS: Yes.
19 MS. FALCE: -- to the Board at this time?
20 MS. CROOKS: Yes, ma'am.
21 MS. FALCE: Okay. Go ahead.
22 MS. CROOKS: Where is it? I believe it's
23 here. So I brought some photographs. Do I bring
24 it up?
25 MR. CHAIRMAN: Madam Secretary?
Page 110
1 MS. BARBIERI: Can we clarify, are we
2 presenting the whole packet or just the
3 photographs? Just for clarification of evidence,
4 if it's just the pictures, then yeah, just display
5 the pictures, please, and then you need to keep
6 them, Madam Secretary.
7 MS. FALCE: So for the record, those are her
8 original copies. We've made copies of her entire
9 packet that she brought here today. So if -- I can
10 give you my copy and you can present the whole
11 package to -- to the Board.
12 MS. BARBIERI: Again, are we then -- is the
13 whole packet being made part of the evidence or is
14 it just the photographs? So we only just produce
15 to the Board to see what -- what's intended.
16 MS. FALCE: The entire package can be
17 presented as -- as evidence.
18 MS. CROOKS: Because some of it is what they
19 already have in their other package as well.
20 MS. BARBIERI: Okay.
21 MR. CHAIRMAN: So my understanding is you're
22 fine with us seeing the entire package, not just
23 the pictures?
24 MS. FALCE: Yes, you can see the entire
25 package.
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Page 111
1 MR. CHAIRMAN: So while we're getting past the
2 pictures, you're more than welcome to kind of
3 describe them as they get passed along.
4 MS. CROOKS: Okay. So what I first have here
5 is a picture that we -- that I have -- this was
6 my -- my little brother's room. So it shows the
7 wall there before they came out and ripped the
8 ceiling -- a hole in the ceiling on the 20th of
9 September. And then you can see that -- the
10 picture after that --
11 MR. MATHEWS: Excuse me, excuse me. Hold on.
12 I don't know what picture you're referring to.
13 MR. CHAIRMAN: Do you have that packet?
14 MR. MATHEWS: I do, but she's describing some
15 -- is it the first picture within the packet?
16 MS. CROOKS: The first picture where you see
17 the -- it says wall in nanny's suite before roof
18 work.
19 MS. BARBIERI: Yeah, can't we use the camera?
20 MR. CHAIRMAN: Can we do it on the overhead
21 projection? That way we can see it.
22 MS. BARBIERI: Yeah, let's do the projection.
23 This doesn't make sense.
24 MR. MATHEWS: It's this packet.
25 MS. FALCE: Yes, that packet.
Page 112
1 MR. MATHEWS: That's the first photograph. Is
2 that what she's referring to?
3 MS. BARBIERI: Roxann, you got to make sure
4 you get that package back.
5 MR. CHAIRMAN: Thank you.
6 MS. FALCE: Is that -- is that helpful to the
7 Board so everyone can see it at one time?
8 MR. CHAIRMAN: Can everybody see it?
9 MS. CROOKS: So this one is kind of a few
10 pages over. I don't think that's the beginning of
11 the -- the pictures.
12 MR. CHAIRMAN: Ms. Crooks, what you're trying
13 to show us --
14 MS. CROOKS: Yes.
15 MR. CHAIRMAN: -- is the pictures inside the
16 house; is that what we're looking at?
17 MS. CROOKS: Yeah. This first one with the
18 wall AC is the -- the wall before the ceiling got
19 ripped open. Then when it started to saturate the
20 walls, you can see on the next page the walls were
21 saturated and started to crack along the side
22 there. And again, these are just --
23 MR. CHAIRMAN: Real quick, that's the before
24 one. I just need to see the after ones, please.
25 MS. CROOKS: Okay.
Page 113
1 MR. CHAIRMAN: That's the after one. Okay.
2 Please flip that around. It's upside down. Okay.
3 Thank you.
4 MS. CROOKS: The next picture here -- just to
5 note, these pictures I've taken over time since
6 September up until now. So this was just a picture
7 that shows -- it was taken on -- the next one, here
8 for the outside.
9 MR. CHAIRMAN: Can you turn it upside -- thank
10 you. We'll get it right.
11 MS. CROOKS: The picture was taken on
12 September 29th. It just shows that they have left
13 the roofing materials from the -- from September
14 20th and they never returned to get the material or
15 complete the work until December 22nd, which is the
16 next time they came out.
17 The next picture here -- but it shows the
18 damages -- it just shows the damages here on the
19 veranda. It's -- it's just a point of reference
20 picture because along this side here of the house,
21 apparently it wasn't sealed properly. So that's
22 where we have water coming in. So it's coming into
23 the veranda, which coincides with the next image
24 which is the ceiling of the veranda at the front
25 door where it's come down.
Page 114
1 I believe Mr. Cicio did show a picture
2 earlier. It was coming up on the screen where we
3 put like a waterproof cloth. We stapled it all
4 around so that the ceiling wouldn't just cave in.
5 MR. CHAIRMAN: And that's the one with the
6 blue tape around it and --
7 MS. CROOKS: Yeah. No. No. It has like a
8 cloth.
9 MR. DIFRANCESCO: Excuse me, Ms. Crooks, are
10 you saying that -- those leaks are still
11 persisting?
12 MS. CROOKS: We have put tarp over it. So
13 there are no --
14 MR. DIFRANCESCO: After the job is complete
15 and inspected --
16 MR. CHAIRMAN: Or not inspected.
17 MR. DIFRANCESCO: -- or not inspected, you
18 still have leaks?
19 MS. CROOKS: Yeah, in -- in areas that we did
20 not have leaks before.
21 MR. CHAIRMAN: That's that one. Thank you,
22 Mr. Cicio.
23 MS. CROOKS: The next image here, it's a bit
24 dark, but it shows our interior living room wall.
25 It goes along that same line on the top there in
31 (Pages 115 to 118)
14a1ee71-ec15-49a3-8e03-9c913fa632d6Electronically signed by Karen M. Bellemare (301-293-169-3900)
Page 115
1 front of the veranda, but this is inside in our
2 living area where there -- the water started to
3 come in as well.
4 We first noticed the water -- water marks on
5 the wall before we noticed that the ceiling was
6 being compromised.
7 The next picture I believe is along the same
8 line here where the water is leaking underneath
9 inside our home. This is just the outside part on
10 the roof here. So around the side here going
11 around, that's where the -- the water's coming
12 through, and I don't know exactly from which spots,
13 but it's along the same line here, those two
14 pictures.
15 This other one shows along the side the same
16 thing here. The veranda and the front door is
17 right at the -- the top of this picture here. So
18 we're having leaks along this side.
19 The next one, two, three, it should show image
20 one, image two, and image three. This just shows
21 that the crew was out on January 13th of 2021, work
22 being -- work being done on this day. So there are
23 three images that show that.
24 The next five photos are the next day when
25 they came back to complete the roof. I just took
Page 116
1 this through a bedroom window upstairs while they
2 were working. You can see on the third page, there
3 -- there's a beer bottle, one of many that were
4 being consumed on the roof while they were working.
5 That night, on January 14th, we went up on the
6 roof. They left pretty late on the 14th. Todd and
7 I went up there and took a picture of what -- the
8 contents of the dumpster, and that same side that
9 we're having the leaks, you can see how that was
10 left on the 14th. We called Mr. Campbell and he
11 had Warren come back out the next morning to nail
12 it down, and I will show you photos to show that as
13 well. And you can see the cases of beer -- empty
14 cases in the dumpster.
15 The next series of pictures were -- we took
16 them on January the 18th. This is when the work
17 was already complete, and then it starts to show
18 when Warren -- the nails in the side there. I'm
19 not sure what you call that material, but it was
20 just tapped down with a hammer and nailed in, and
21 that's how it is right now. That's where we have
22 the water coming in.
23 When the inspection did get done in April, I
24 believe, we mentioned how this wood was -- was put
25 in, but apparently the way it was done, it's fine,
Page 117
1 even though very sloppy and we didn't want to
2 accept it that way. It wasn't any cause for any
3 red flags, I guess, during the inspection. So we
4 took pictures of those.
5 You also can see the burns that were on the
6 screen as you go further down. They got worse
7 because they used the torch against the pool
8 enclosure. One thing to note on this -- this
9 picture here, it shows one color material. That's
10 the work that was done on December 22nd of 2020,
11 and they stopped there. Those three rows, that was
12 it.
13 On January 13th, when the work resumed and was
14 completed on the 15th, you can see where the other
15 color material, that's where they picked -- picked
16 up and completed the rest. Just other pictures
17 that we took on the 18th, pictures of the -- the
18 pipes for the solar water heater that are laying on
19 the ground, pictures of the materials that they
20 left behind. They stated that they're leaving it
21 there just in case they have to use it again when
22 they come back. It also shows the solar water
23 heater panels that are laying on the ground. After
24 a certain amount of time, they can't be put back on
25 the roof and used.
Page 118
1 More pictures of the -- the -- the dumpster,
2 and I believe that is all the pictures that we
3 brought today.
4 MR. CHAIRMAN: Ms. Crooks, thank you. Anymore
5 questions for Ms. Crooks, Ms. Deana?
6 MS. FALCE: Yes. We -- she had sent us an
7 email that she referenced earlier and asked us to
8 make copies for her. So I'd just -- I'd like to
9 provide that to her on the record and so she can
10 present it to the Board.
11 MR. CHAIRMAN: Okay.
12 MS. CROOKS: Should I put that with this?
13 Thank you.
14 MR. CHAIRMAN: Mr. Mathews, you -- you've
15 received this?
16 MR. MATHEWS: I don't know.
17 MS. CROOKS: I mentioned earlier that the
18 claims adjuster or the person assigned to the claim
19 with Nautilus Insurance did itemize what the payout
20 was for, the damages, and she states in the email
21 that it's for screen repair, drywall and painting
22 and to replace the solar -- the solar panels.
23 MR. MATHEWS: I'm objecting to the use of this
24 exhibit for -- for two reasons. I've issued two
25 subpoenas, one to St. Lucie County and one to this
32 (Pages 119 to 122)
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Page 119
1 witness for precisely this type of information.
2 This is the first time I'm receiving it.
3 MR. CHAIRMAN: Do you know --
4 MR. MATHEWS: Now, it's being presented for a
5 piece of evidence. I've never seen it before.
6 MR. CHAIRMAN: I one hundred percent agree
7 with you. Please, Madam Secretary, take this from
8 the Board, that way the Board doesn't see it, and
9 I'm going to go ahead and not allow that into
10 evidence.
11 MS. FALCE: For the record, St. Lucie County
12 did not have this document prior to the moment I
13 just made -- made on the record to present it. The
14 homeowner asked that we print it so she could refer
15 to it. So just to set the record clear, the
16 subpoenas to any county staff would not have
17 produced that because we did not see it.
18 MR. MATHEWS: I disagree. The recipient is --
19 is your witness Cicio.
20 MS. FALCE: She sent it to us to print --
21 MR. CHAIRMAN: I got you.
22 MR. CICIO: Just ten minutes ago.
23 MS. FALCE: -- ten minutes ago is what I'm
24 stating on the record.
25 MR. CHAIRMAN: Okay.
Page 120
1 MS. FALCE: So just so the record is clear.
2 MR. CHAIRMAN: No, I understand.
3 MR. MATHEWS: That appears to be accurate.
4 However, I did not receive it from -- from the
5 Complainant.
6 If -- if I can just take a moment to look at
7 it.
8 MR. CHAIRMAN: I'm not going to allow it into
9 evidence. It doesn't matter.
10 MR. MATHEWS: Okay. Thank you.
11 MS. FALCE: I don't have any further
12 questions. I was just making a record for that.
13 MR. CHAIRMAN: Thank you.
14 MS. CROOKS: Thank you.
15 MR. CHAIRMAN: Thank you, Ms. Crooks.
16 MR. DIFRANCESCO: Can I ask a question?
17 MR. CHAIRMAN: Mr. DiFrancesco, absolutely you
18 can ask a question.
19 MR. DIFRANCESCO: Ms. Crooks, I got a few
20 questions for you. One of the reasons why
21 Mr. Shultz is here today because we're trying to
22 find out, one, was a job started without a permit.
23 You stated that the job was started
24 September 19th, 2020, and I was going to ask you if
25 you were sure that it was Mr. Shultz's crew, but
Page 121
1 then later on you clarified to me and said that he
2 came back with the same crew.
3 MS. CROOKS: They were the same crew. It was
4 maybe two people that were --
5 MR. DIFRANCESCO: So you're pretty sure it was
6 his crew --
7 MS. CROOKS: Yes, the same men.
8 MR. DIFRANCESCO: -- as far as September 19th?
9 MS. CROOKS: Three different occasions,
10 September, December, and January.
11 MR. DIFRANCESCO: Okay. And you never saw a
12 permit on the job before that?
13 MS. CROOKS: No, sir.
14 MR. DIFRANCESCO: You never saw a job -- a
15 permit on the job before 12/22 or 12/8, which ever
16 the permit was finally issued?
17 MR. CHAIRMAN: 12/8.
18 MS. CROOKS: No, sir.
19 MR. DIFRANCESCO: Okay. You stated that you
20 wrote a check to Mr. -- Mr. Brown.
21 MS. CROOKS: Yes, Milton Brown. Yes.
22 MR. DIFRANCESCO: I guess by now you -- you've
23 learned never write a check to an individual --
24 MS. CROOKS: Too late, yes.
25 MR. DIFRANCESCO: -- and only to a business.
Page 122
1 Did you write a check to Mr. Campbell --
2 MS. CROOKS: No, sir.
3 MR. DIFRANCESCO: -- or did you write it to
4 Abe Shultz?
5 MS. CROOKS: No.
6 MR. DIFRANCESCO: You haven't wrote any --
7 anything since those two checks that you wrote to
8 Mr. Brown?
9 MS. CROOKS: No.
10 MR. DIFRANCESCO: Okay. Did you have that
11 mold remediated by a -- I mean, you didn't have
12 drywall work done without having the mold fixed,
13 being taken care of, did you?
14 MS. CROOKS: Well, we had -- we called a mold
15 company. They sent out the machines. They gave us
16 an estimate, and it was up there in the six, seven
17 thousand range to remediate and fix the problem,
18 and we did not have those funds at that time --
19 MR. DIFRANCESCO: Okay.
20 MS. CROOKS: -- so we covered it.
21 MR. DIFRANCESCO: If you covered it up, it's
22 still going to be a problem.
23 MS. CROOKS: It is.
24 MR. DIFRANCESCO: And it's not healthy.
25 MS. CROOKS: No. And the insurance, his
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1 insurance said they don't cover mold damage either.
2 MR. DIFRANCESCO: When you said that you
3 checked on Abe Shultz Construction and you verified
4 that they were licensed --
5 MS. CROOKS: Correct. That was --
6 MR. DIFRANCESCO: -- did you verify --
7 MS. CROOKS: I'm sorry.
8 MR. DIFRANCESCO: -- did you verify that they
9 were licensed in St. Lucie County or just with the
10 state?
11 MS. CROOKS: Just with the state. That's the
12 only thing I know how to check.
13 MR. DIFRANCESCO: So you don't know if Mr. --
14 if at the time they started construction whether he
15 was licensed in St. Lucie County or not. Okay.
16 MS. CROOKS: I believe --
17 MR. DIFRANCESCO: Maybe staff can find that
18 out.
19 MS. CROOKS: I believe we had a conversation
20 with Mr. Campbell and he did state that he had to
21 obtain something with St. Lucie County before he
22 can do work in that county.
23 MR. DIFRANCESCO: A Certificate of Competency,
24 would that be it?
25 MS. CROOKS: I think so, because he had to
Page 124
1 give his Workers' Comp and insurance and all that
2 stuff to them.
3 MR. DIFRANCESCO: But -- but when they started
4 the job September 19th, you had no contact with
5 Mr. Campbell?
6 MS. CROOKS: No. Mr. Milton Brown represented
7 Abe Shultz Construction and said him and his
8 partner are in business together.
9 MR. DIFRANCESCO: Did Mr. Brown say they were
10 licensed in St. Lucie County or had a competency
11 card in St. Lucie County?
12 MS. CROOKS: I'm not sure. I would have to
13 refer to my husband. He had most of the --
14 MR. DIFRANCESCO: Okay. So the --
15 MS. CROOKS: -- conversations.
16 MR. DIFRANCESCO: That's okay. The staff can
17 actually look and see when Mr. Campbell got his
18 competency card for St. Lucie County.
19 MS. WATERS: Mr. Campbell applied on
20 October 5th, 2020, 2020 for his --
21 MR. DIFRANCESCO: So it was after the job was
22 -- was started.
23 MR. CHAIRMAN: So excuse me, Mr. DiFrancesco
24 and staff. And Alphanette Waters, I appreciate you
25 letting me know that. So on 12/8/2020 when the
Page 125
1 permit was issued, he -- he applied for his
2 competency about two months prior to that, that I'm
3 looking at as a timeline?
4 MS. WATERS: (Indicating.)
5 MR. CHAIRMAN: Okay. Thank you.
6 MR. DIFRANCESCO: But the job was started
7 September 19th?
8 MR. CHAIRMAN: The job was started on
9 September 19th and 20th.
10 MR. DIFRANCESCO: I think that's all I have.
11 MR. CHAIRMAN: Does any other member of the
12 Board have a question for Mrs. Crooks?
13 Ms. Deana, I believe you were done already,
14 correct?
15 MS. FALCE: I was done, yes.
16 MR. CHAIRMAN: I believe Mr. Mathews --
17 MR. MATHEWS: Thank you.
18 CROSS EXAMINATION
19 BY MR. MATHEWS:
20 Q. Ms. Crooks, what's your occupation?
21 A. I'm a Realtor.
22 Q. Are you licensed?
23 A. Yes, sir.
24 Q. Do you also -- do you do any tax preparation
25 work?
Page 126
1 A No, I --
2 MR. CHAIRMAN: Excuse me. Why is that
3 question relevant to this?
4 MR. MATHEWS: It's relevant to her education,
5 background, and how she deals with people. It's
6 only a couple of questions to establish her
7 background.
8 MR. CHAIRMAN: Okay.
9 MS. CROOKS: I mean, I don't --
10 BY MR. MATHEWS:
11 Q. Do you do any tax preparation work?
12 A. No, I don't.
13 Q. Are you affiliated with PB3 Performance Tax
14 and Multiservices, Inc.?
15 A. No.
16 Q. What is PB3 Performance Tax and Multiservices,
17 Inc.?
18 A. I think you'd have to ask my husband.
19 Q. Do you know what it is?
20 A. Yes.
21 Q. What is it?
22 A. It's a company that he owns.
23 Q. What's that company do?
24 A. I would -- I would have you ask him that
25 question.
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1 Q. But I'm asking you, ma'am.
2 A. I want to stick to what I -- what I do. If
3 you want to ask me what I do all day, I'll answer.
4 MR. CHAIRMAN: Mr. Mathews, I highly, highly
5 recommend you -- you don't continue down that path.
6 MR. MATHEWS: I'll move on.
7 BY MR. MATHEWS:
8 Q. Ms. Crooks, were you served with a subpoena
9 from my firm?
10 A. Yes.
11 Q. Did you look for documents responsive to it?
12 A. I gathered everything that I have.
13 Q. And that was provided in this packet to me
14 this morning, correct?
15 A. That's correct. There are a few emails that
16 are -- I still have that weren't in the package.
17 Q. Okay. So I'm looking at a packet. It's maybe
18 about 30 pages. Is that about right?
19 A. I'm not sure how many pages.
20 Q. Within the packet, the first page is a
21 proposal that we've been discussing, correct?
22 A. Yes. Quite a bit of the package is what you
23 already have in your information, the other packet that
24 everyone has, text messages, and the proposal. I
25 believe you guys have that as well.
Page 128
1 Q. Okay. At this point, I'm going to share with
2 you a copy of the subpoena that was provided -- provided
3 to you.
4 A. I have it.
5 Q. Great.
6 MR. MATHEWS: I have a few copies of it for --
7 for publication, but not a lot. So can I share
8 three copies with the -- with the panel and maybe
9 you can pass it back and forth.
10 MR. CHAIRMAN: Sure.
11 MR. MATHEWS: I'll go this way.
12 MR. CHAIRMAN: Thank you.
13 MS. FALCE: Is there a copy that staff can
14 also take a look at?
15 MR. CHAIRMAN: I'm familiar with it.
16 MR. MATHEWS: Actually, I think it's in my
17 packet. I'm sorry. Yeah, Exhibit 13.
18 MR. CHAIRMAN: Okay.
19 BY MR. MATHEWS:
20 Q. Ms. Crooks, the first document is -- or the
21 first request is documents to establish the main contact
22 information of the, quote, family friend, unquote, that
23 referred Lindolph Campbell, Milton Brown, and/or
24 Abe Shultz Construction to you as described in your
25 complaint.
Page 129
1 Do you have any documents responsive to that?
2 A. No documents. As I -- I just explained in the
3 timeline exactly how it -- it occurred that we came
4 across Abe Shultz Construction.
5 Q. And the family friend was -- you said it was
6 your brother-in-law?
7 A. No, it's -- yeah, correct.
8 Q. What's the brother-in-law's name?
9 A. His name is Orlando.
10 Q. And what's his last name?
11 A. It's up to him if he wants to share his last
12 name.
13 Q. Do you know Orlando's last name?
14 A. No. I know his last name, but it's his
15 brother, so I don't --
16 MR. CHAIRMAN: Ms. Barbieri?
17 MS. BARBIERI: You're under oath.
18 MS. CROOKS: What's his last name?
19 MR. ROBERTS: Young.
20 MS. CROOKS: Young. Young.
21 BY MR. MATHEWS:
22 Q. Okay. I'm not trying to play any tricks here.
23 I'm just trying to get some information. And if you
24 don't know the information, you can -- you can say that.
25 You don't need to rely --
Page 130
1 A. I just verified.
2 Q. Okay. You don't have contact information for
3 Orlando Young?
4 A. No. I -- I don't keep in contact with him.
5 Q. Okay. Next question or next area of inquiry
6 was, Any all copies of contract documents,
7 correspondence, as identified in your complaint.
8 Did you produce those documents?
9 A. The only thing that's a contract that's here
10 in the proposal or invoice. That's what I take as the
11 contract.
12 Q. Okay. Let's go to -- well, let's hold onto
13 that for now. Item No. 3, Any and all correspondence
14 provided to you in August of 2020 concerning details for
15 a company, Abe Shultz Construction, because you needed
16 our roof repaired in your complaint.
17 Is that -- did you contact Orlando for that
18 information?
19 A. I don't recall who contacted who. I know it
20 was just in a conversation that my husband was having
21 with him. I'm not sure who contacted who.
22 Q. Okay. Item No. 4, A copy of all documents you
23 received from Milton Brown concerning your property.
24 Did you produce those documents?
25 A. Yes. The only thing I got from Milton Brown
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Page 131
1 is the contract.
2 Q. Item No. 5, A copy of pictures and video of
3 your roof that were sent to Milton Brown on or about
4 August 26th, as described in your complaint.
5 Did you produce those pictures?
6 A. The video we were unable to open. It's -- it
7 was sent back in October -- I mean, August of 2020, and
8 maybe it was deleted or something, but when we tried to
9 open it up in the text message, it would not open.
10 Q. Who made the video?
11 A. My husband did.
12 Q. Item No. 6, A copy of the invoice for $6,000.
13 Did you produce that?
14 A. For $7,000?
15 Q. $7,000. I'm sorry, I misspoke.
16 A. Again, we were unable to open that because it
17 was an image that was sent by text. So we don't have a
18 physical copy of that.
19 Q. Number 7, Documents to demonstrate the payment
20 of funds to Milton Brown, including, but not limited to
21 bank statements reflecting that funds were paid. There
22 was a deposit ticket that I saw regarding Chase.
23 A. Yes.
24 Q. And then there was a -- another document that
25 looked like it was a copy of a check register.
Page 132
1 A. Correct. It's the -- the carbon copy when I
2 write the check.
3 Q. Right. Request No. 8, All photographs
4 depicting roof -- roof and work performed on the roof.
5 Did you produce those?
6 A. Yes, I did.
7 Q. Item No. 11, Communication with Ervin Tulloch
8 about the roofing issue. Who is Ervin Tulloch?
9 A. Ervin is on the mortgage as a co-borrower, but
10 he did not have any communication at all in regards to
11 the roof. It was just Todd and I.
12 Q. Okay. I'll take your attention to item number
13 or -- sorry, Exhibit No. 17 in respondent's book.
14 Is this print screen something that you
15 produced?
16 A. I'm sorry, I don't know what you're looking
17 at.
18 Q. Exhibit No. 17. Do you have a copy of my
19 book?
20 A. No, I don't.
21 Q. Ah, let me get you one then.
22 Ms. Crooks, this is a document that was
23 produced to us today, and I think we received it before
24 as well from the County. The first one on the first
25 page is -- it looks like it's a video of your -- of your
Page 133
1 roof, and I think it's dated August 26th, 2020.
2 A. That's correct.
3 Q. Do you have that video?
4 A. That's the video I was referring to that it's
5 -- because it was sent that long ago, when we tried to
6 open it, it wouldn't open.
7 Q. Okay. What was in the video?
8 A. It was just a walk around my husband did on
9 the roof. He would be able to better explain because he
10 did the video and he sent it to Milton Brown.
11 Q. On the top of this, there's a text. There's a
12 string, it says M., and then it looks like it says
13 Melton Brown.
14 A. That's Milton Brown. My husband just spelled
15 it with an E instead of an I.
16 Q. Okay. So was this a text string that came off
17 his phone?
18 A. So that video is what my husband sent. So
19 everything on that side is from my husband, then
20 everything on the left is what Milton Brown sent to us
21 or to my husband's phone.
22 Q. Okay. On this next page of this exhibit,
23 there's a -- looks like a copy of a document that has
24 three holes in the right side.
25 A. Yes.
Page 134
1 Q. It's -- it's -- I can't see a lot of the
2 detail on it, but it looks to be maybe in the form of
3 the Abe Shultz proposal.
4 A. Yes. It looks exactly to be the same invoice
5 that I have a physical copy of, but it's blank. So I'm
6 not sure why that was sent. Maybe my husband would have
7 more clarification.
8 Q. Okay. And that looks like it was dated
9 September 16th?
10 A. Correct.
11 Q. And that was for $7,000?
12 A. No. I'm not sure. As far as I knew, that was
13 blank. I don't know if there's any writing on that one.
14 Q. The next page, there's an -- an image of the
15 top of a proposal, looks like it says September 16th.
16 Do you see that?
17 A. You're talking about the image of the proposal
18 for the $7,000?
19 Q. Well, the -- the top portion of that text
20 string has a -- a picture of a roof --
21 A. Oh, okay, yes.
22 Q. -- and then beneath it there's some redacted
23 information on an account number, and then there's a
24 portion of perhaps a proposal.
25 A. Right. You can see the full thing on the
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Page 135
1 other page of the proposal.
2 Q. All right. So that's then September 16th as
3 well?
4 A. Yes.
5 Q. And there's a proposal there -- this is the
6 $7,000 proposal, right?
7 A. That's correct.
8 Q. Okay. At this point in time, September 16th,
9 were you operating under the assumption that you had a
10 $7,000 contract with Abe Shultz Construction?
11 A. Correct.
12 Q. Okay. And I think that the text of that one
13 says that there was a repair there.
14 A. That's what we clarified with Milton Brown.
15 He did state that he would come on the property to give
16 us a proposal that was better filled out, more detailed.
17 We did tell him he needed to change the detail because
18 it was too vague, and he agreed.
19 Q. Okay. As of August 16th, were you trying to
20 get a repair of your roof?
21 A. September 16th? No. It was not going to be a
22 repair. It was going to be to replace. There were --
23 there were some parts that needed to be repaired, but
24 the flat roof needed to be replaced and the shingles
25 needed to be replaced.
Page 136
1 Q. Okay. The proposal that we're looking at on
2 this page, is that your signature at the bottom of it?
3 A. No, it's not.
4 Q. Do you know whose signature it is?
5 A. I'm assuming it was Milton Brown's signature.
6 He sent that image to us.
7 Q. Okay. But he didn't sign it in your presence?
8 A. No.
9 Q. Okay. And you don't have a copy of -- a clear
10 copy of this proposal?
11 A. Exactly. How you see it, it's exactly how we
12 see it, so no.
13 Q. Okay. Let's go to the next page,
14 September 16th. There's another document. Do you know
15 what that document is?
16 A. The next page or the previous page?
17 Q. The following page.
18 A. On the 17th of September?
19 Q. I --
20 A. Or the 18th, sorry.
21 Q. It looks like it's maybe September 18th,
22 there's a phone number there, and then there's a -- a
23 picture of a document.
24 A. That number is actually, I think, is an
25 account number that should probably be marked out as
Page 137
1 well, but he sent that to us. We never -- I don't think
2 -- you'd have to talk to my husband about this because I
3 never really understood what that picture or that
4 document was.
5 Q. Were you able to print that document for us?
6 A. No. It's just an image of the -- the
7 document.
8 Q. But does that document reflect some sort of
9 communication with Abe Shultz Construction?
10 A. You'd have to ask my husband. I don't know
11 what this document is about.
12 Q. Okay. Let's look at the next page. It looks
13 like there's another copy of maybe a similar document, I
14 don't know. Do you have a copy of that document?
15 A. That's the same document.
16 Q. And flip over several more pages. It looks
17 like maybe it's -- it could be a date in October.
18 A. October 5th.
19 Q. Your eyes may be better than mine. Do you
20 know what this document is?
21 A. That was sent to us when they requested my
22 driver's license for them to complete the
23 Notice of Commencement. When I asked what it was, he
24 sent an image -- this image. This was a document that
25 Mr. Campbell was supposed to meet my husband to hand
Page 138
1 over to him but was a no show.
2 I believe Mr. Campbell made an attempt to
3 explain what this was, but they were supposed to fill it
4 out and they needed my driver's license. That's why
5 you -- you can see when I sent my license, he sent over
6 text with Mr. Campbell's phone number for us to give him
7 a call to talk to him more about what the document was
8 for.
9 Q. So based upon Exhibit 17, the earliest that
10 you were aware of Milton Brown was -- was on or about
11 August 26th, 2020?
12 A. That's correct.
13 Q. Okay. When's the first time that you met
14 Milton Brown, Milton Brown?
15 A. September 21st when he came to the property in
16 person.
17 Q. Was he driving an Abe Shultz truck?
18 A. I just saw the front of the vehicle. I didn't
19 walk around his vehicle to see if he had any signs or
20 anything on there.
21 Q. Did he present you with an Abe Shultz business
22 card?
23 A. I -- I don't remember.
24 Q. If you had a visit -- have you ever seen an
25 Abe Shultz business card that said Milton Brown on it?
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1 A. No, I don't think so.
2 Q. Was he wearing a shirt that said Abe Shultz
3 Construction on it?
4 A. I don't remember what he was wearing.
5 Q. Did you get an email address from him?
6 A. I don't believe so. I'm not sure.
7 Q. Did you ever see an email address that said
8 Milton Brown at Abe Shultz Construction or something to
9 that effect?
10 A. I'm not sure. I don't think so.
11 Q. Did there come a point in time when you
12 learned that Milton Brown was Andrew Brown?
13 A. When we first was introduced, the -- his --
14 the name was Andrew and then shortly after, we -- he
15 told us Milton Brown. So when we had that first initial
16 conversation with him when he called us, he introduced
17 hisself as Andrew, and then I'm not sure how many more
18 conversations, but he spoke to my husband and made clear
19 his name is -- is Milton Brown.
20 Q. Did you ever see any documents that had him
21 listed as Milton Brown?
22 A. I don't remember.
23 Q. Okay. You have one email address that I'm
24 aware of. It's i.m.woman.1213@gmail.com; is that
25 correct?
Page 140
1 A. That's correct. Minus the last dot.
2 Q. Okay. Do you go by any other names?
3 A. Other than -- other than what? I'm sorry.
4 Q. I've seen in the -- I think in the complaint
5 your name is Nicki Ann Crooks.
6 A. Yes.
7 Q. But there's also -- are you legally known as
8 Nicki Ann Roberts?
9 A. I tell people my name -- my last name is
10 Roberts, but on -- legally, it's still Crooks.
11 Q. And is there -- are you associated with
12 Angel Roberts?
13 A. That's just an email fictitious name.
14 Q. Okay. If you can take a look at
15 Exhibit No. 14. Are you familiar with the website
16 Sunbiz?
17 A. Yeah, I think I've been on it a couple -- a
18 handful of times, yes.
19 Q. What type of information can you find on
20 Sunbiz?
21 A. How to create a annual filing or something
22 like that for a business with the State. I'm guessing
23 that's where you go to file with the State, if you have
24 a business.
25 Q. Okay. Have you ever done that; have you ever
Page 141
1 performed that function for somebody?
2 A. Yes, I have, once.
3 Q. Do you have your own corporation?
4 A. It's not a -- no, it's not a corporation.
5 It's an LLC. We started a little clothing website, but
6 that was -- that was it. We're not in business. It was
7 just a great idea that we had that we didn't follow
8 through with.
9 Q. Okay. Exhibit No. 14 is a fictitious name
10 detail for AB Handyman. Have you ever heard of
11 AB Handyman?
12 A. I don't -- I'm sorry, I don't have that in
13 front of me. I only have this small packet that you
14 just gave me.
15 Q. Good point.
16 A. Is it in this packet?
17 Q. No.
18 MR. MATHEWS: Can we borrow one from the panel
19 members so the witness can have one?
20 Mr. Chairman, can you look on with somebody
21 else?
22 MR. CHAIRMAN: No worries.
23 THE WITNESS: Okay.
24 BY MR. MATHEWS:
25 Q So this is a fictitious name detail report for
Page 142
1 a company by the name of AB Handyman. Did you know
2 about that company on or about August of 2020?
3 A. No, I did not. The first time I actually saw
4 this was in an email that Mr. Cicio had sent to me when
5 Milton Brown paid a fine. This was a part of the
6 attachment in that email.
7 Q. Okay. And I apologize if I'm reasking you a
8 question, but are you related in any way to
9 Ervin Tulloch?
10 A. That's my step-dad.
11 Q. And he's listed in property records with
12 St. Lucie County as a co-owner of the property of 4032,
13 correct?
14 A. That's correct.
15 Q. Okay. So you own that property with your
16 step-father?
17 A. That's correct.
18 Q. Does your step-brother -- does Mr. Tulloch
19 have a brother?
20 A. I think he has multiple brothers.
21 Q. Ah, what are their names?
22 MR. CHAIRMAN: Relevant? Where are you going
23 with this?
24 MR. MATHEWS: I'm trying to establish a
25 relationship with AB Handyman.
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Page 143
1 MR. CHAIRMAN: Okay.
2 THE WITNESS: I -- I honestly don't know. I
3 think one of them is named Clyde, but I don't -- I
4 don't know.
5 BY MR. MATHEWS:
6 Q. Is there another one by the name of Jason?
7 A. No, I don't think so. No, not to my
8 knowledge.
9 Q. Okay. You referenced a guy by the name of
10 Zeek, right?
11 A. Correct.
12 Q. And Zeek was a painter?
13 A. He works as the -- one of the crew when they
14 do roofing jobs, Abe Shultz.
15 Q. Did you come -- did you know that Zeek also
16 did work for Milton Brown or Andrew Brown?
17 A. That's how we were introduced to Milton Brown.
18 Q. Did you know that Zeek was affiliated with
19 AB Handyman?
20 A. No. Zeek claimed -- Zeek said he works with
21 Abe Shultz Roofing and introduced us to Milton Brown,
22 who claimed to be the owner at the time of
23 Abe Shultz Roofing.
24 Q. Did you look up Sunbiz to find out who the
25 owner was of Abe Shultz?
Page 144
1 A. I did not, no.
2 Q. But you could have, right?
3 A. I wish I had.
4 Q. Did you file a complaint with the
5 St. Lucie County Board of Commissioners?
6 A. Yes.
7 Q. That's at Exhibit 1, correct?
8 A. Exhibit 1 in --
9 MR. CHAIRMAN: Excuse me. May I have my book
10 back, please? Actually, you know, you keep it.
11 I'll go by with Tony.
12 MR. MATHEWS: Thank you. I apologize. I
13 really wasn't expecting a full panel.
14 THE WITNESS: It's in the back of the
15 subpoena, so I can take a look at it that way.
16 MR. CHAIRMAN: You're fine. You're good.
17 THE WITNESS: Okay.
18 MR. CICIO: Ms. Crooks, it's before one. The
19 documents before you get to the tab of one.
20 THE WITNESS: Thank you. Okay.
21 BY MR. MATHEWS:
22 Q. This is the complaint you filed?
23 A. Yes.
24 Q. And your handwriting is on this document?
25 A. Yes.
Page 145
1 Q. Everything in here true and correct?
2 A. Yes. And as you can see, it's -- it's pretty
3 lengthy, so I just went with the best of my knowledge.
4 Q. On Page 2, Item No. 2, "I first learned about
5 the above-named person or company through. . ." and it
6 says ". . .referred by family friend."
7 Who is the family friend?
8 A. At the time, you know, I had to speak with my
9 husband about that initial contact, how Milton Brown
10 called us, and he explained it a lot better. I just --
11 I was being very general.
12 Q. Who's the family friend?
13 A. It's -- it's not technically a family friend.
14 I just put that in there to be general because I knew it
15 was a referral. I knew someone that we knew had
16 referred Abe Shultz to us. So usually when I -- when
17 you say who referred us, it's either online, Google,
18 newspaper, whatever, or family friend. So I was just
19 being general at that point.
20 Q. So it was an acquaintance or somebody that you
21 knew?
22 A. I explained, it's my husband's brother. He
23 does painting and things like that and he said he knew
24 guys that works on roofs. He knows a guy who works for
25 a roofing company. He put us on the three-way, and the
Page 146
1 gentleman that was put on the call with us went by the
2 name Zeeks, who is actually one of the guys that showed
3 up to do work at our house.
4 Zeek gave -- Zeeks took our -- my husband's
5 phone number and contact information and had
6 Milton Brown give us a call.
7 Q. In August of 2020, did you have a leak in your
8 roof at the 4032 property?
9 A. It was a very small leak, yes.
10 Q. How many -- just one leak or more than one
11 leak?
12 A. I believe it was just one.
13 Q. So was it -- and you said it was a small leak?
14 A. It was.
15 Q. Is that something you just want to get
16 repaired then as opposed to a whole new roof?
17 A. No, the roof was -- it's very old. It was at
18 the end of its life. When we moved in and the
19 inspection was done, we were told that. So we just
20 wanted the whole thing replaced.
21 Q. If -- so you wanted the whole front -- flat
22 roof replaced?
23 A. The flat roof goes along from the front on the
24 right-hand side of the home down to the back, and then
25 it goes along side the pool enclosure in the back.
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1 There's very little shingles. Most of it is flat.
2 Q. Okay. Is it in an L-shape?
3 A. Correct.
4 Q. Okay. Is it a pretty large area, surface
5 area?
6 A. I guess you would say large, yes.
7 Q. Okay. The first quote that we are -- the
8 first proposal that we saw a portion of talks about a
9 repair. So did you want a repair or did you want
10 replacement?
11 A. No. We spoke about a replacement of the flat
12 roof.
13 Q. Why didn't that first proposal then reflect
14 that it was a replacement?
15 A. We did have that conversation with
16 Milton Brown that his -- his wording was very vague and
17 it was not what we initially spoke about, and he did say
18 that he would come up physically and take a look. And
19 when he did arrive, it -- it did change.
20 Q. The video that was presented to Milton Brown,
21 was there a voice that went along with it; was there
22 like -- was it like a little movie?
23 A. I don't remember if there was voice. My
24 husband took the video, so he would better know. He
25 would better tell you whether he was speaking in the
Page 148
1 video or not. I honestly don't remember.
2 Q. Did you ever see the video?
3 A. I did, I think once. I looked at it once when
4 he said I sent him this video. Hopefully, he takes a
5 look at it, because he said that he used an aerial view
6 to do the -- to get an estimate. So after that -- I
7 mean, I really don't know. It was so long ago.
8 Q. Do you think that that video would be
9 instructive as to what type of work you wanted performed
10 in August of 2020?
11 A. That would be a question for my husband. I'm
12 not sure.
13 Q. But he can't locate it, right?
14 A. No, it's -- we can't, no.
15 Q. Your written description at Exhibit 1, at
16 Page 3 of 4 there's the beginning of a written
17 description. Do you see that?
18 A. Yes.
19 Q. And the third sentence begins, "On August
20 26th, 2020. . ." Do you see that?
21 A. Yes.
22 Q. "We sent pictures and videos of roof and told
23 him the problems we need fixed." So it talks about
24 problems being plural. What problems needed to get
25 fixed?
Page 149
1 A. Well, we spoke about the -- the leak, the
2 initial small leak that we have, but we also informed
3 him about the solar water heater that needed to be taken
4 up and then put back down once the roof was complete.
5 So the solar water heater also had -- they
6 were sitting on panels up there or brackets that needed
7 to be either fixed or replaced once the panels were put
8 back on.
9 Q. And the solar panel work, that wasn't in the
10 initial proposal dated August, 2020, correct?
11 A. Again, no, because it was very vague.
12 Q. Did the solar panels work at that point?
13 A. Yes.
14 Q. With the August, 2020 proposal, was it your
15 understanding that a repair would be conducted without
16 getting a permit?
17 A. No. It was not a -- we did not agree to -- at
18 the time, I did not know what needed to be done with a
19 permit or without a permit. My husband was mainly
20 informing himself about that. And we have neighbors who
21 were getting their roof done at the same time.
22 So when we began going into the website,
23 that's when we found that if, I guess, a certain
24 percentage of the roof was going to be repaired or
25 replaced, they had to do the whole thing and it needs a
Page 150
1 permit. I don't remember what the percentage was, but
2 that's what I read when I researched it online. It said
3 that if a contractor or someone was going to be doing
4 more than a certain percentage of the roof that it
5 needed a permit and the entire roof needed to be done.
6 I'm not sure whether that's correct
7 information or -- that's just what I read. So that's
8 when we knew it needed a permit.
9 Q. Your neighbors were getting a roof. Did you
10 get a quote from -- from your neighbors' roofing
11 company?
12 A. We had -- we had just moved there at that
13 point. I -- I mean, after. This is afterwards, yeah.
14 Q. Oh, okay. Other than the proposal you got
15 from Brown, did you get any other estimates for the
16 work?
17 A. I'm not sure. I think we got one, but they
18 were not going to replace the roof. They were talking
19 about some type of rubber material that was going to be
20 placed over everything, and that's not what -- that's
21 not what we wanted to do.
22 Q. Were you looking to save money on this -- this
23 repair?
24 A. Not necessarily save money, but we were
25 looking to get what we needed to get done at -- with
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1 quality work, and, also, you know, with a -- with a
2 decent price. I don't know what -- we've never had a
3 roof done, so we wouldn't know what price points it
4 would be.
5 Q. So as a homeowner with -- with little
6 experience in roofing, do you think it would be prudent
7 to get multiple estimates for work?
8 A. Like I said, we did get that other one. They
9 were very brief with us. They didn't seem to want to do
10 what we wanted to get done. Their price was around also
11 the same. They just didn't -- they weren't going to do
12 what we wanted to get done, which was to replace the
13 whole flat roof and the shingles as well.
14 Q. How much was the alternative proposal?
15 A. It was also for $11,000, I believe.
16 Q. For $11,000 a company was going to put some
17 sort of rubberized texture stuff on there?
18 A. It was --
19 MR. ROBERTS: Coating --
20 MR. MATHEWS: Okay, excuse me, sir, I'm going
21 to ask her. And if she doesn't know the answer,
22 I'll ask you later.
23 THE WITNESS: Yeah. I think he would be
24 better to explain exactly what it is. It was some
25 type of -- some type of rubber seal that they were
Page 152
1 going to do on the entire flat roof, some type of
2 new thing that was being done, but my husband would
3 better explain exactly what it is.
4 BY MR. MATHEWS:
5 Q. Do you have a copy of that proposal?
6 A. I'm -- if -- I'm sure if I look far enough I
7 can find it, but I'm not -- not here, no.
8 Q. What was the name of that company?
9 A. I don't recall.
10 Q. The company that was going to put the sealing
11 agent on there, was that something that was going to
12 require a permit?
13 A. I'm not sure.
14 Q. Okay. So did you have -- have the $7,000
15 proposal from Brown and the $11,000 proposal at the same
16 time that you were contemplating?
17 A. No. That text message, we actually ended up
18 disregarding because we had the conversation about the
19 wording being vague and that we didn't want them to come
20 here and find extra to keep tacking on the price. So he
21 said he would show up in person to make sure that would
22 not happen. But he did say that the -- the aerial view
23 that he did is very accurate and that it -- it was going
24 to be about that same price. We just needed the wording
25 to be better on -- on that proposal, which it wasn't.
Page 153
1 Q. So ultimately -- let's look at Exhibit No. 6.
2 A proposal is provided to you, is that correct?
3 A. Correct.
4 Q. Okay. So did you meet with -- when did you
5 meet with Milton Brown that he gave you this proposal?
6 A. September 21st, 2020.
7 Q. Okay. So he shows up and does he go on the
8 roof?
9 A. Yes.
10 Q. Okay. At that point, this -- sorry if I'm
11 being repetitive. Any Abe Shultz characteristics on
12 him, shirt, business card, truck?
13 A. I -- I don't recall.
14 Q. Does he go onto the roof?
15 A. Yes.
16 Q. And did you go up there with him?
17 A. I don't remember if I did, but I know my
18 husband did.
19 Q. Okay. And were you involved in discussions
20 with Milton Brown about the scope of the job?
21 A. Yes.
22 Q. Okay. And what did he say?
23 A. He said pretty much what's on here. They
24 would -- he would tear off the whole flat part of the
25 roof, replace it, replace any damaged wood. He would do
Page 154
1 the -- replace the shingle side as well, and measure the
2 ceiling on the inside, cut what was necessary to replace
3 the pieces of ceiling that had the leak spot, and
4 replace the solar panel -- the solar panels as well when
5 -- when everything was done.
6 Q. Okay. In your prior testimony, you talked
7 about the $7,000 proposal, right, and then there was the
8 $11,000 proposal.
9 A. Yes. This one we got in person.
10 Q. And one of the -- the statements that you made
11 was that it was more expensive because you needed to get
12 a permit for it, that justified the expense.
13 A. That was one of the reasons. He said that
14 when he got to the property and got on the roof, it was
15 a little bit larger than what he initially expected,
16 which was what my husband and I kind of figured what was
17 going to happen. You're trying to avoid that, which was
18 why he came to the property. And he said -- Milton
19 Brown said that permits were very expensive and takes
20 months. That was his statement to us.
21 Q. Okay. The proposal at Exhibit 6, where is
22 your handwriting on this document?
23 A. Where it says, "Install water solar heater
24 brackets, replace damaged shingles and damaged wood,
25 knock out ceiling and drywall, replace and seal." He
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1 told me to write that because his spelling was not that
2 great and he went ahead and initialed and date to the
3 left of that.
4 Q. Okay. What about the portion that it -- where
5 it says, "$4,000 paid." Is any of that your
6 handwriting?
7 A. I believe this is Milton Brown down here.
8 Q. And what about where it says, "Five-year
9 warranty"?
10 A. Milton Brown wrote that in.
11 Q. And where it says: "$11,000" twice? Who
12 wrote -- whose handwriting is that?
13 A. Milton Brown.
14 Q. Okay. At the top it says, "October 5th, 2020"
15 and then has a number of 31981. Do you know what the
16 31981 is?
17 A. The -- you know, I was trying to figure that
18 out, and I know I was trying to look up something online
19 and I just happened to write it down on the top of that
20 paper. It was just like a little note of something, and
21 I don't -- I don't remember exactly what it was.
22 Q. And what's the October 5, 2020 relate to?
23 A. I'm guessing that's when I got that number.
24 Q. And then it says -- it looks like it says
25 Lindolph Campbell?
Page 156
1 A. Yes.
2 Q. So what -- what do these notes reflect?
3 A. So the Lindolph Campbell, I wrote his name
4 when we -- I think when we initially had the
5 conversation with him.
6 Q. Okay.
7 MR. MATHEWS: I just want to show this
8 document to the panel and have them look at it
9 quickly. So this is the original that was produced
10 this morning, and there are several different -- it
11 looks like at least three different pens were used
12 on this document, and at least two different types
13 of handwriting.
14 So I think it would be instructive for -- for
15 the Board to look at this document, and then I'll
16 ask some more follow-up questions.
17 Is that all right?
18 MS. FALCE: No objection.
19 (Published to the panel.)
20 BY MR. MATHEWS:
21 Q. Ms. Crooks, is -- whose signature is at the
22 bottom of this proposal?
23 A. Milton Brown.
24 Q. And who put that date in there, 9/21/20?
25 A. Milton Brown.
Page 157
1 Q. So initially -- let me see if I can understand
2 the sequence of events. Milton Brown, your testimony
3 is, he comes there on September 21, he walks the
4 property or goes on the roof with your husband, comes
5 down and says, Well, it's going to be an $11,000 job,
6 right?
7 A. Correct.
8 Q. Okay. So I'm guessing he gets in his truck or
9 something, he writes then a job description of work,
10 tear off existing flat roof, replace damaged wood,
11 stripe [verbatim] down to the deck as required, renail
12 the existing wood deck to code, remove all trash and
13 debris. Right?
14 A. Right.
15 Q. And then did you or your husband have a
16 further conversation to say, Hey, we want this
17 additional work done too?
18 A. We had that conversation prior. So when he
19 showed this to us with what he wrote, we asked, you
20 know, what about the ceiling on the inside? Did we
21 forget about that? And he said, Oh. Oh, yes. He went
22 to write it and he handed it to me and said, Why don't
23 you write it for me. My -- my spelling is not that
24 great. So I wrote that in and I said, Go ahead and take
25 a look at that; and if it's okay, if it's what we agreed
Page 158
1 on, initial -- go ahead and initial, and he initialed
2 and date -- dated it.
3 Q. Okay. So where it was initialed and dated,
4 that wasn't done later at another point in time?
5 A. No, the same -- same morning.
6 Q. And the section where it says, $4,000 -- as of
7 the date of this contract, $8,000 was paid to
8 Milton Brown?
9 A. Correct.
10 Q. Okay. And so where it says, "$4,000 paid" and
11 then another $4,000, that was all written
12 contemporaneously on September 21st, is that --
13 A. Correct.
14 Q. Did you see a copy of this proposal that was
15 countersigned by anybody at Abe Shultz?
16 A. No.
17 Q. You're a Realtor so you regularly deal with
18 contracts, right?
19 A. I don't do many sales. I usually work with a
20 partner at Keyes. So, yeah, I look over contracts, but
21 I get help with all the paperwork because I'm a fairly
22 new Realtor, haven't been in the business for a long
23 time.
24 Q. But you're a licensed Realtor, right?
25 A. Yes.
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1 Q. Okay. And you're aware that contracts are --
2 are generally signed by both parties?
3 MS. FALCE: Objection.
4 MR. MATHEWS: It should be based upon her
5 knowledge of being a Realtor.
6 MR. CHAIRMAN: She's not been a Realtor for
7 that long, so strike that question, please.
8 BY MR. MATHEWS:
9 Q. Did you ever request that anybody from
10 Abe Shultz countersign this proposal?
11 A. As far as we knew, Milton Brown represented
12 Abe Shultz Roofing. He represented hisself as the owner
13 of Abe Shultz Roofing and his partner as
14 Lindolph Campbell.
15 Q. Okay.
16 A. So I wouldn't expect anyone else to
17 countersign.
18 Q. Well, there's a signature spot for somebody to
19 sign it.
20 A. I don't -- I'm not sure. He signed it. He
21 gave it to us and that's -- this is just what we've
22 always had from the beginning.
23 Q. So did you pay Milton Brown $8,000 before he
24 completed any work on your roof?
25 A. The work had started on September 20th. That
Page 160
1 was the only thing that happened. We were told that the
2 permitting takes a long time. So we were working on --
3 during the space of the time from September 20th to when
4 the permit was finally paid for, we were back and forth
5 with Mr. Campbell and Mr. Brown about obtaining the
6 permit. During that time, we've learned from the
7 permitting department quite a bit of discrepancies in
8 what Mr. Brown and Mr. Campbell was telling us about how
9 to pull permits.
10 Q. So actually, pursuant to your complaint at
11 Exhibit No. 1, you state that the workers go to the
12 house and begin work on September 19th?
13 A. They came to the home on September 19th and I
14 just wrote a little note that's the day they came. So
15 when I filled this out, that's the date that I put.
16 They did arrive on the 19th, but it was very late in the
17 night and they showed up the next morning on the 20th to
18 do work.
19 Q. Okay. Your description says, "On September
20 19, 2020, workers came to our home and began work. We
21 went on roof to find a mess of a coverup job being done.
22 Nothing agreed to on contract and no permit in sight.
23 We stopped it."
24 A. That's right.
25 Q. Okay. So they start on the 19th --
Page 161
1 A. No. That -- that -- I'm sorry. That's the
2 only thing that's incorrect. They started on the 20th.
3 They came to the property on the 19th, but they found a
4 hotel nearby and they came the next morning. So that's
5 the only thing that changed.
6 Q. Okay. So they -- Brown and his crew started
7 work on the 20th --
8 A. Yes.
9 Q. -- under a proposal for $7,000, right?
10 A. Right.
11 Q. And then did he come back after he pulled the
12 roof off and say, Well, wait a minute. This is a lot
13 bigger job now. Now, it's got to be $11,000?
14 A. The roof wasn't pulled off. They were nailing
15 some type of material on top of our existing roof.
16 There was nothing being pulled -- pulled off at that
17 point. They started nailing -- they had a huge nail gun
18 and they had -- they brought rolls. It's in one of my
19 pictures, the rolls that they left on the top underneath
20 my solar panel, our solar panel. They started nailing
21 that down. It was black.
22 I believe it's in a picture that I submitted,
23 and they did about maybe -- maybe 20 feet or something
24 like that, and after a little bit of hearing the nailing
25 happening, my husband went up there and spoke to them
Page 162
1 about it. And they did end up leaving, yes.
2 Q. Okay. So they start work on the 20th pursuant
3 to the contract -- $7,000 contract in August that
4 described the repair, right?
5 A. No, not the details of that. That contract,
6 the details, were -- it's not what we discussed with
7 Milton Brown, and he said he would come on the property
8 to give us a more detailed contract, which is what I
9 have here.
10 We made a request for him to be more detailed,
11 because the one that he sent us by text, first we
12 weren't able to print that out because you can barely
13 see what's written on it, and the way he wrote in the
14 description was very vague, and we -- he assured us that
15 he was going to come to the property and do it more
16 detailed, and that's when it changed to $11,000.
17 So we weren't going by the work that was on
18 that $7,000 text message.
19 Q. So your understanding of -- of the work to be
20 performed under the August contract was that the roofing
21 -- the flat roofing on the L-shape was going to get
22 removed and they were going to fix the -- the -- replace
23 the wood that was -- needed to get replaced and then
24 reseal the area. That was your understanding?
25 A. And replace the shingled part as well.
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1 Q. And replace the shingle -- so if that was your
2 understanding in August, why did you agree to pay him
3 $3,000 more dollars in September?
4 A. We paid him another $4,000 --
5 Q. No, no, no. The -- oh, sorry, you're right.
6 Your math is better than mine. Yeah, $4,000 difference.
7 If it was -- if you were getting the same work
8 performed, why didn't you just say, No way, Brown, you
9 said you'd do it for $7,000?
10 A. Well, we wanted the job to get done properly.
11 When he did this one in person and did the details, the
12 ceiling on the inside was a part of it, and he took a
13 look at that as well. The permitting he said was
14 expensive, so we agreed. We gave him the check after we
15 got this invoice. We didn't pay him before we got this
16 invoice.
17 So the first $4,000 was paid on the 18th
18 before I got this, but the second $4,000 was on the same
19 day when he arrived at the property.
20 Q. Did you see in the proposal, the September
21 proposal, you paid $4,000 and then you paid $4,000. Why
22 didn't you pay the amount that is described within the
23 contract, the 25 percent, 25 percent; do you see that?
24 A. Well, we just went by what -- what
25 Milton Brown was instructing us to do. You know, he
Page 164
1 said he needed another $4,000 to go ahead and pay for
2 the permits and get everything done because the -- the
3 roof was a little bit larger than what he initially
4 expected.
5 Q. But pursuant to the contract, you were
6 initially -- if -- if there was an $11,000 amount,
7 that's for the total of the contract, you were required
8 to pay 25 percent or $2,750 to start the work, right?
9 A. I'm sorry. Could you repeat that?
10 Q. If the contract price is $11,000, 25 percent
11 of that is $2,750.
12 A. To be honest, we weren't -- we weren't even
13 going by that. What Milton Brown wrote and what he --
14 what we discussed is what we paid to him. We didn't go
15 by this 25 percent here.
16 Q. Let's look at Exhibit 4. Exhibit 4 there --
17 it looks like it's a combination of two documents,
18 Space Coast Credit Union teller check for $4,000 --
19 MR. CHAIRMAN: Are you talking Exhibit 4 in
20 your book?
21 MR. MATHEWS: Yes.
22 BY MR. MATHEWS:
23 Q. Do you see that document?
24 A. Yes.
25 Q. Okay. But there are two different probably
Page 165
1 pieces of paper that were combined to photocopy this,
2 right?
3 A. To make a copy. I have the originals.
4 Q. Okay. So you make a -- there's a check
5 written out to Milton Brown for $4,000.
6 A. Yes, on September 18th.
7 Q. And that's a bank account that you own or
8 you're -- you have a -- an interest in?
9 A. Yes.
10 Q. Okay. Did you find it shady that Milton Brown
11 was asking for a check to be given to him personally and
12 not the company?
13 A. We honestly had no idea at the time what shady
14 business looked like, so I'm -- I'm -- you know, we were
15 told that they have to pay the crew, get the work
16 started. Him -- his partner will start to gather
17 whatever they need and -- to get the work started as
18 soon as possible. So that's what we did, unfortunately.
19 Q. Okay. Then the -- there's a deposit ticket
20 for Chase and that amount's $4,000. I think the date is
21 September 18th also.
22 A. Yes. That's the deposit of the cashier's
23 check to Milton Brown's Chase Bank account.
24 Q. Okay. Then on -- a couple pages later, it
25 looks like there's a -- it looks like a receipt for a
Page 166
1 check that was -- that was issued.
2 A. It's the carbon copy of the checkbook. So the
3 check that we wrote to Milton Brown on the 21st when he
4 gave us this invoice in person, that's the $4,000 check
5 that we handed to him.
6 Q. Okay. So prior to Milton Brown completing
7 very much work on your project, you paid him
8 approximately 73 percent of the total amount; is that
9 correct?
10 A. At that point, because we knew he had to come
11 back out to get the work done and he had been at our
12 property on that day, yes.
13 Q. Later you became aware of Lindolph Campbell;
14 is that correct?
15 A. Shortly -- shortly after Milton Brown came --
16 came to our property. It was still in September.
17 Q. Okay. On the proposal, there's, in green
18 highlighting at the top, there's a date that says:
19 "October 5th, 2020, Lindolph Campbell."
20 Does that refresh your recollection about the
21 point in time when you learned about Mr. Campbell?
22 A. No. I wrote those two, I believe, on two
23 separate occasions. They were just little note --
24 notations that I had just written at the top because
25 this was the only document that we had at the time
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1 dealing with Abe Shultz and Milton Brown and
2 Lindolph Campbell. So I just wrote a little notation
3 there.
4 Q. What was the notation that was written on two
5 separate instances?
6 A. The October 5th, 2020 with the 31981 was
7 written at a different time than I believe when I wrote
8 the Lindolph Campbell. I just wanted to have his name
9 on -- on paper because we have never been like formally
10 introduced.
11 Q. Was the Lindolph Campbell written before or
12 after October 5, 2020, in your recollection?
13 A. I -- I don't recall, to be honest. I don't
14 recall. Probably before that.
15 Q. So your testimony is that you wrote
16 Lindolph Campbell on one date, and then a separate -- at
17 a separate time, you wrote October 5th, 2020, star 31981
18 star?
19 A. I -- I do believe so. I'm not sure the exact
20 timing, but, yes, I think they were on two separate
21 occasions.
22 Q. And you do recognize or realize that all of
23 that penmanship was done in the same color?
24 A. Yes.
25 Q. You just happened to pick up another green pen
Page 168
1 on two different instances --
2 A. Well, we have -- I have a counter that I had
3 this document on and we have a cup with a lime green pen
4 in it. So I just --
5 Q Okay.
6 A -- used that.
7 Q. Did you provide this -- a copy of this
8 proposal to Lindolph Campbell?
9 A. Yes, we did.
10 Q. When?
11 A. I don't -- I don't remember. I think my
12 husband would be better to answer that.
13 Q. Did he --
14 A. I don't remember.
15 Q. -- email it to him, did he mail it to him?
16 A. I'm not sure if it was in an email. I don't
17 think so.
18 Q. There's no fax number up here, so it probably
19 wasn't faxed?
20 A. I'm not sure. I'm not sure how we got it to
21 him whether it was he -- whether it was when we -- he
22 was on the property, but I -- I'm not a hundred percent
23 sure when we handed it over to him, at least what we
24 have. We just made him a copy of what -- of what we
25 have.
Page 169
1 Q. Do you recall when that was?
2 A. No, I can't recall.
3 Q. Was it in October, November, December? It
4 would have been prior to --
5 A. Yeah, I'm -- I'm not exactly sure when we gave
6 it to him.
7 Q. Okay. Let's take a quick look at
8 Exhibit No. 7. It's a composite exhibit. It's the --
9 on the top it says, "Building Permit Application." The
10 building permit appears to have a date of
11 November 11, 2020 and there's a description of the work
12 there. Do you see that application?
13 A. I'm sorry. Where's the date?
14 Q. On the second page.
15 A. Well, we're looking at the Building Permit
16 Application on Tab 6, right?
17 Q. Yes. Oh, it's at Tab 7. So you'll -- when
18 you open up the document, you'll see 7 behind it.
19 A. Okay. Yes, yes, I see where the notary is,
20 yes.
21 Q. Okay. And do you see the detailed description
22 of work?
23 A. On the first page?
24 Q. Yes.
25 A. Yes.
Page 170
1 Q. Does that mention anything about drywall or
2 interior work?
3 A. No.
4 Q. Did you have a discussion with Mr. Campbell
5 who came to learn about the September proposal saying
6 that he wasn't aware of it?
7 A. No. He never stated that he wasn't aware of
8 it. I don't think he's ever said that.
9 Q. Did he ever say to you, Well, I'll do the work
10 that says job description of work and the four lines
11 after that, but not the stuff that has the initial next
12 to it and the star?
13 A. We had a conversation with Mr. Campbell. He
14 did say he had to get a third-party company to do the
15 drywall and the ceiling because his company doesn't
16 specialize in drywall. He said he would have to hire
17 out someone else to get that work done.
18 Q. Did he ever say to you, I'll do the job
19 description of the -- of the roof work but not the
20 interior work?
21 A. No. He stated he would fulfill the contract
22 and the -- the warranty.
23 Q. Did Mr. Campbell present you with another
24 proposal, not in this form, but in a different form that
25 had a description of the work and $11,000?
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1 A. No.
2 MR. MATHEWS: My understanding is that such a
3 document would accompany a Building Permit
4 Application, but I haven't seen that document. You
5 know, we had a quick discussion about it, but I
6 don't know the result of it, and there were, in the
7 text string that we saw, there was a reference to
8 other perhaps Abe Shultz documents that I don't
9 have.
10 Do you know if there's another --
11 MS. FALCE: You -- you have -- as I've stated
12 previously, you have everything that I have and
13 that the County has provided related to this
14 matter. If you'd like to call a witness from the
15 County and ask them -- I'm happy to do -- but I've
16 been sitting here with you.
17 MR. MATHEWS: Board members, in your
18 experience, when a permit application is filed, is
19 some underlying contract provided?
20 MR. CHAIRMAN: So Mr. Mathews, there are some
21 municipalities that do require a copy of the
22 contract. St. Lucie County is not one of them. I
23 work in 16 different municipalities around the
24 state.
25 MR. MATHEWS: Okay. Is that consistent with
Page 172
1 -- with everybody's understanding?
2 (Multiple Board members responded in the
3 affirmative.)
4 BY MR. MATHEWS:
5 Q. Let's look at Exhibit No. 7. Exhibit No. 7 is
6 the Building Permit Application, which I understand was
7 obtained December 8, 2020. Is that consistent with your
8 recollection?
9 MS. FALCE: Just a point of clarification, are
10 you still on Tab 7, because I'm not sure that --
11 MR. MATHEWS: Yep, Tab 7.
12 MS. FALCE: December --
13 MR. MATHEWS: The receipt for the payment
14 is --
15 MS. FALCE: Oh, I see. It's further -- I
16 apologize. Go ahead.
17 MR. MATHEWS: Third page?
18 MS. FALCE: Uh-huh.
19 MR. MATHEWS: Third page, December 8th.
20 MS. FALCE: I thought you had flipped to the
21 next tab. Thank you for clarifying that.
22 BY MR. MATHEWS:
23 Q. Is that consistent?
24 A. Yes.
25 Q. Okay. And the Notice of Commencement was
Page 173
1 signed by you on December 20th -- sorry,
2 December 22nd, 2020?
3 A. Yes.
4 Q. Do you recall on January 1st of 2021 that
5 Mr. Shultz -- sorry, Mr. Campbell, spoke with you about
6 -- about the project on your roof?
7 A. Yes. I believe that's when him and Warren
8 came to our property.
9 Q. Okay. And work -- substantial work was
10 performed on January 13th and 14th?
11 A. And 15th.
12 Q. And 15th, right. During that period of time,
13 was Andrew Brown on the premises?
14 A. No.
15 Q. Was the work completed on January 15th?
16 A. Yes, it was.
17 Q. Okay. And then do you know what time of day
18 it was completed, like in the evening, first -- or in
19 the morning?
20 A. They were supposed to be finished on the 14th.
21 They left around evening time. However, in one of the
22 pictures on the side, the metal or aluminum, they were
23 all kicked up and so we spoke to Mr. Campbell about it
24 and he had Warren come back the next morning, I believe
25 Warren and another gentleman, and they nailed it down.
Page 174
1 So they did a -- they did a few touch-ups on the 15th
2 and left pretty early.
3 Q. Okay. And that's the same date in which you
4 filed a complaint with St. Lucie?
5 A. Correct. Because of the conversations that we
6 had with Mr. Campbell, he did not seem like he wanted to
7 get an inspection done anytime soon. He --
8 Q. Did you advise Mr. Campbell that you weren't
9 going to pay the amount due under the contract or the
10 proposal that you were working under, the $11,000
11 proposal?
12 A. We discussed with Mr. Campbell that if the
13 contract was fulfilled, that we would pay the -- the
14 balance of the $3,000. However --
15 Q. Did you pay -- sorry.
16 A. I'm sorry.
17 Q. No, I'll let you finish.
18 A. However, not everything on the contract was
19 being completed. So we were not going to give out
20 anymore money.
21 Q. Did you place any demands on Mr. Campbell to
22 perform any additional work?
23 A. All we wanted once the roof was completed was
24 for him to get an inspection done. He stated that he
25 had a whole six months, so he's going to take his time,
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1 in which I scheduled an inspection myself.
2 At that point, he -- when he was on the roof
3 with Warren, he stated that he personally would have
4 charged us an additional $5,000 to complete the work on
5 top of the $11,000. He never put anything in writing.
6 My husband and I did tell him because at -- at that
7 point, we were -- everyone was already frustrated, and
8 you know, wanted to get everything resolved.
9 When we told him that because they ripped the
10 holes in the ceiling that we weren't going to pay
11 anymore money at that point, he did not challenge that.
12 He proceeded to call Milton Brown, put him on speaker
13 phone and go after Milton Brown for $5,000 that he
14 initially said he would have charged us extra.
15 Q. Did Mr. Campbell come back to your property in
16 October and November of 2021 in an attempt to repair the
17 roof?
18 A. We received a text message on -- I'm sorry.
19 Give me a moment. Okay. On -- on October 13th at
20 9:51 P.M., Mr. Campbell sent us a text message saying,
21 I'm coming by tomorrow to finish the roof. The
22 inspector and the work crew will be there tomorrow -- as
23 we replied, As you may know, the permit has expired per
24 the building inspector. As far as we know, the -- that
25 it was expired. There is a hearing on the 20th of
Page 176
1 October, told him that he cannot do work on our roof
2 with an expired permit.
3 He then replied that the permit is current and
4 paid, and they're going to be by -- by in the morning.
5 That was not sufficient time for us because that was
6 very late the night before. We were not aware previous
7 to this that he was coming to our property to do
8 anything. We weren't aware that he had renewed a permit
9 or that he was willing to come by in October to finish
10 the roof until the night before.
11 Q. Did, at any point in time, you demand that the
12 tar paper, et cetera, be removed from -- from the roof
13 in totality?
14 A. I'm not sure what you mean by tar paper.
15 Q. Well, you were aware that there were some
16 cutout sections that were done to inspect the -- the
17 sheathing or the plywood, right?
18 A. In April?
19 Q. We've seen a couple photographs of it and
20 there was testimony of a report that came in --
21 A. I believe that was in April.
22 Q. Right. So that's the material. Did you
23 request Abe Shultz, Lindolph, to remove all that
24 material?
25 A. No. As far as we know, he had to do whatever
Page 177
1 was necessary to pass the inspection.
2 Q. Okay. Did you ever make any demands upon him
3 to replace all the plywood?
4 A. No.
5 Q. You submitted a claim to -- to the insurance
6 company, right, for Lindolph?
7 A. Correct.
8 Q. And that's at Page 23 and 24 of St. Lucie's
9 exhibits; do you see that?
10 A. Give me just a moment here. This was not the
11 initial claim. It's just the release that we were sent
12 in the end to receive compensation for the damages.
13 Q. Okay. Is that your signature?
14 A. Yes, it is.
15 Q. And it was dated February 1, 2022, right?
16 A. Correct. That's when I got it notarized.
17 Q. And you received $14,654.30?
18 A. Correct.
19 Q. And that relates to damage that was at the
20 property; is that correct?
21 A. That's correct.
22 Q. At that point in time -- well, as of February
23 22nd, do you anticipate being able to submit another
24 claim?
25 A. There's no need to submit another claim.
Page 178
1 Q. Okay. So you're not expecting any additional
2 compensation relating to damage to the interior based
3 upon any roofing issues?
4 A. Well, that's -- I think that's what the
5 release is for. They have compensated us for the
6 damages that have already -- that's already there
7 unless -- we were made clear by the claims adjuster that
8 if Abe Shultz Roofing was to do any other work in the
9 future on our roof and it did result in any additional
10 new damages, that we would be entitled to another claim;
11 however, I don't see that happening.
12 Q. Okay. Did you have a lawyer represent you
13 with respect to this?
14 A. We did have legal advice, but we did not hire
15 a lawyer.
16 Q. Who was the legal advice provided by?
17 A. I believe it was Dawn Stayton (phonetic) is
18 her name. This was a while. This was before we got in
19 contact with the insurance.
20 Q. Have you separately filed a civil action
21 against Abe Shultz or Lindolph Campbell?
22 A. No, we have not.
23 Q. If Abe Shultz were to come to the property at
24 3042 (sic) and remove the tar paper and renail the
25 sheathing, such that it passes inspection, and then
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1 repaper the roof, and then put on the top material and
2 it passes those inspections, are you going to be
3 satisfied?
4 A. I -- you said quite a bit there and it's a lot
5 of terms that I don't really understand about the
6 material there. What the -- what I would -- what we
7 would expect, I believe, is ultimately for the work to
8 pass inspection. However, the work that was done that
9 caused the water damage inside would also have to be
10 rectified, because we don't want any further damage to
11 the inside of our home.
12 So there was -- the parts in the picture that
13 I showed that caused the leak along the side, you know,
14 that -- that would have to be resolved as well. We just
15 want the roof done with a pass inspection and for it to
16 cause no damages to the inside of our home. That's all
17 we want. In a timely manner because it's been dragged
18 out where we've been waiting on Mr. Campbell saying he's
19 going to come on this day or come in this month, and
20 never shows up. It's just getting -- gets pushed back,
21 and then once a permit is renewed, they're allowed a
22 certain amount of time to get work done and to get an
23 inspection. And I don't want it to be dragged out out
24 of spite because -- not because you have six months to
25 do an inspection or to get work done. That doesn't mean
Page 180
1 that he should take the entire six months to get it
2 done.
3 Q. The release was signed on February 1st, not
4 very long ago, correct?
5 A. That's correct.
6 Q. So you should be aware of any damage that --
7 that happened as a result -- any alleged damage that
8 happened as a result of the roof that was put on in
9 2021.
10 A. That's right. We contacted the insurance
11 initially in October of 2021 and we've been in back and
12 forth contacting them. They took a little while to get
13 an inspector or an adjuster out to the property.
14 Once that adjuster left, he completed a report
15 that was submitted to the insurance company; however, he
16 was deployed back to the military, so they found it
17 difficult to get another adjuster to come back to the
18 property. So it did take a while, but we -- we've been
19 in contact with them since October of last year.
20 Q. Did you hire your own adjuster?
21 A. No. I -- we -- I don't know that's possible.
22 Q. Okay. But -- so you relied upon the insurance
23 company's adjuster to provide you with information?
24 A. Yes. We just went along with the process.
25 Q. Okay. Are you aware of more damage that
Page 181
1 occurred to the inside of your property past
2 February 1st?
3 A. It's the same -- the same areas. They're
4 progressively getting worse, but there's no additional
5 -- there are no other areas that -- that we see right
6 now. It's just the same area. It's getting worse.
7 Q. But do you realize you signed a release
8 relating to -- to that damage?
9 A. Yes.
10 Q. Okay. But -- but now you're saying you want
11 additional compensation from Abe Shultz and
12 Lindolph Campbell --
13 A. No, sir.
14 Q. -- for the interior problems?
15 A. No, sir.
16 Q. Then I'm confused. What do you want done on
17 the interior?
18 A. We're -- we've already been compensated on the
19 interior. We're getting that done based on the monies
20 that we received from the insurance. We just need the
21 roof situated. We've already rectified the inside,
22 because the damages have been paid for.
23 Q. Okay. And I just want to -- want to clarify
24 what Mr. Campbell and Abe Shultz is willing to do, and I
25 said, Hey, if he repairs the roof and they close the
Page 182
1 permit, is that acceptable to you? And then I think you
2 said you wanted interior work done also.
3 A. No, sir, I didn't say that.
4 Q. Oh, okay. So just the roof?
5 A. Yeah. We -- we want the roof done and for it
6 to pass inspection. The -- the only thing that I said
7 was that the contract stated that the ceiling on the
8 inside was supposed to be cutout and replaced. That's a
9 part of the $11,000. That's not being done. It started
10 to be done, but it hasn't been completed.
11 So we were saying for the monies that we've
12 already paid, the roof just needs to pass inspection and
13 that's it. We will -- we will use what we have here to
14 fix the interior. The work that they started on the
15 ceiling, we're going to use these funds to go ahead and
16 get that started. So we're just worrying about the
17 roof. The only discrepancy is saying we owe another
18 $3,000. However, the water -- the solar water heater
19 wasn't put back. In fact, it was damaged. The drywall
20 and the ceiling also damaged, and they started, but
21 never finished. So we have incomplete work and a
22 balance owed. So I just feel if we -- if we have to pay
23 the $3,000, the full description has to be completed.
24 But if they're not doing the inside, anything to the
25 ceiling, then all we need to get done is the -- the roof
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1 for it to pass inspection. And I -- I -- we feel that's
2 pretty fair, just to get it -- just to get everything
3 finished.
4 Q. So it sounds like there are perhaps two
5 alternatives; one is roof only, pass inspection, and
6 then you're not going to pay Abe Campbell (sic) any more
7 money?
8 A. Correct.
9 Q. Or sorry, Abe Shultz. I'm sorry. I'm getting
10 all mixed. Any money. The alternative is that he does
11 the roof and the interior work and then you pay him the
12 $3,000?
13 A. Correct.
14 Q. But didn't you just say the interior work was
15 done already?
16 A. No. The holes are still there. The -- no
17 work has been done. The only thing that we have done
18 was put tarp on the part that is leaking on the in -- on
19 the veranda on the inside. We've tarped barely the best
20 way that we could to stop the leak.
21 Q. What do you think would be a reasonable amount
22 of time to complete the roof on the work -- the roof
23 work?
24 A. I -- I would definitely need to get advice on
25 that. I would like it done as soon as possible in a
Page 184
1 timely manner. I just don't want it to be dragged out
2 another six months. I believe I recalled Mike Cicio
3 saying something about three months, and I think that
4 would be -- that would be fair.
5 MR. MATHEWS: No further questions at this
6 time. I will reserve the right to call her on --
7 on my case, if need be.
8 MR. CHAIRMAN: I understand.
9 MS. FALCE: I don't have any further questions
10 for her.
11 MR. CHAIRMAN: Ms. Crooks, I have a question
12 for you, and please bear with me on timelines.
13 August 26th is when you first contact Milton Brown
14 -- Milton Brown gets contacted with you, long story
15 short. You then go down this path of back and
16 forth, back and forth, back and forth. We're still
17 trying to figure out if Milton Brown and
18 Mr. Campbell actually know each other. I'm sure
19 they do, but that's -- I'm sure we'll find that
20 out, represents very well, here you go, here's a
21 proposal, here's this, here's that, and then
22 Mr. Cicio gets contacted by you. You have a
23 complaint you want to file, contractor's here, not
24 doing -- not performing, not doing this, some
25 sketchy things are going on here, paperwork's not
Page 185
1 lining up, all the rest of that good stuff.
2 Mr. Cicio then gets ahold of the general
3 contractor, who's actually the permit on the
4 record. Mr. Cicio then goes ahead and allows him
5 ample amount of time to do his job, and, yet, here
6 we are February 28th at one o'clock in the
7 afternoon. Okay. Just want to make sure.
8 Does anybody on the Board have any questions
9 for Ms. Crooks?
10 MR. DIFRANCESCO: I do. Ms. Crooks, did you
11 ever receive a formal contract from Mr. Campbell?
12 MS. CROOKS: No. This is all I have.
13 MR. DIFRANCESCO: Why do you think you didn't?
14 He came out -- he came out to visit you. He -- he
15 said he would honor Mr. Brown's contract?
16 MS. CROOKS: That was the agreement.
17 MR. DIFRANCESCO: Did he say why?
18 MS. CROOKS: He just didn't want his business
19 to be ruined at that point, so he wanted to take
20 control of the situation. I don't want to make any
21 assumptions on why he made the decisions that he
22 made.
23 He -- like I said, he mentioned $5,000. He
24 said, I would have charged you another $5,000, but
25 there was nothing else on paper, nothing that was
Page 186
1 proposed to us because we immediately declined
2 that.
3 MR. DIFRANCESCO: Well, in your complaint, you
4 did mention that you contacted Mr. Campbell and you
5 explained the proposition at this point, told him
6 that if he doesn't rectify this right away, we will
7 have no choice but to seek litigation. He stated
8 he would take responsibility and take charge of the
9 job. He stated he will honor the work listed in
10 the contract and deal with Mr. Brown himself. This
11 is when we learned that Mr. Campbell, from his
12 statement, that he pulls permits under license as a
13 favor to Mr. Brown in exchange for compensation on
14 documented.
15 Did he tell you that?
16 MS. CROOKS: That is correct. He used the
17 word favor. He's just doing a favor for Mr. Brown,
18 and when Mr. Campbell, Warren, my husband and I
19 were on the roof on January 1st, they did openly
20 speak about other instances where Milton Brown did
21 similar deeds with Mr. Campbell to other customers
22 and have not paid Mr. Campbell. So he claimed that
23 Mr. Brown still owes him money from previous work
24 that he had not paid him. Then my husband asked
25 why do you continue to partner with him and do
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1 business, and, you know, he just kind of shrugged
2 it off.
3 So that's when we found that they -- they sort
4 of do this thing all the time.
5 MR. DIFRANCESCO: Was that other work in
6 St. Lucie County that you know of?
7 MS. CROOKS: I'm sorry?
8 MR. DIFRANCESCO: Was that other work done in
9 St. Lucie County that you know of?
10 MS. CROOKS: Not that I know of, no.
11 MR. DIFRANCESCO: Would your husband know?
12 MS. CROOKS: I'm not sure. Maybe. I don't
13 know.
14 MR. DIFRANCESCO: Are you say that
15 Mr. Campbell told you that his cut was $3,000?
16 MS. CROOKS: He didn't tell me exactly what
17 his cut was.
18 MR. DIFRANCESCO: Did he say that you would
19 pay him $3,000 or did you say -- did he say --
20 because you don't have a contract with him.
21 MS. CROOKS: No, he did -- he did state in one
22 of the text message, and the conversation that we
23 had the night of January 13th when he was at our
24 property, we had a conversation and he said that
25 the contract states that you still owe me $3,000,
Page 188
1 and I can go after you and put a lien on your
2 property, if you don't pay me the $3,000. That's
3 what he stated.
4 MR. DIFRANCESCO: Why didn't you tell him
5 that's not his contract? If indeed it's
6 Milton Brown's contract, why is he demanding money
7 on that contract?
8 MS. CROOKS: Well, the -- the -- the way they
9 both represented themselves to us was that they
10 were both with Abe -- under Abe Shultz Construction
11 so -- and you know, we've heard them speaking to
12 each other. He has relayed messages to
13 Milton Brown. Milton Brown has relayed messages to
14 him. I just assumed they were under -- under the
15 same umbrella. I'm not sure what his cut was, but
16 he -- at that point, he was pretty much trying to
17 intimidate us when he made that statement, and it's
18 in a text message as well.
19 MR. DIFRANCESCO: Thank you.
20 MR. CHAIRMAN: Any other questions,
21 Mr. DiFrancesco?
22 MR. LANGEL: Yes, I have a question.
23 MR. CHAIRMAN: Mr. Langel.
24 MR. LANGEL: Ms. Crooks, how are you?
25 MS. CROOKS: Great. Thank you.
Page 189
1 MR. LANGEL: Are you aware that your roof --
2 there's a possibility your roof may need to come
3 completely off and you have to pay for it again?
4 Is -- is that possible or can you get it fixed and
5 make sure you have a contractor, licensed
6 contractor with St. Lucie County to fix it, and how
7 much would that be to make you happy?
8 MS. CROOKS: I -- to be honest, I don't know.
9 I have no clue.
10 MR. CHAIRMAN: So you have not hired a
11 licensed contractor to come out there to give you
12 an estimate?
13 MS. CROOKS: No. We -- no, we haven't. There
14 was, I think, after that inspection was done, it's
15 -- I'm guessing -- we were talking -- my husband
16 and I were talking about it. As soon as we -- we
17 said as soon as we had our roof done, there were
18 two other neighbors that found companies to get
19 their roof done.
20 Right after the inspection in around April,
21 two doors down, they got their roof done. They got
22 a metal roof, and, you know, we stopped one of the
23 gentlemen and said, Hey, you know, can we --
24 where's the owner? Who -- you know. And he called
25 the owner over. He spoke to us, and we said, Hey,
Page 190
1 you know, can you take a look at this? We -- we
2 explained the problems that we were having, and he
3 felt -- he was really empathetic with us.
4 We went up on the roof with him and, you know,
5 he said, first and foremost, you'd have to get all
6 that permit and contractor stuff sorted out before
7 you even hire us. And he said secondly, you know,
8 we're licensed. He did give us a business card.
9 He said you can look us up, do your research this
10 time, and -- you know, we were telling him that we
11 have done so much research over this process that
12 we're kind of a little bit more --
13 MR. CHAIRMAN: But no costs ever came up in
14 that conversation, that casual conversation.
15 MS. CROOKS: No. Well, he did throw around
16 numbers, but it was not -- he didn't give us
17 anything on paper. He just said whenever we have
18 everything situated to give him a call and start
19 the process, but he wouldn't go any further because
20 of the -- the issue.
21 MR. JERGER: One more bit of advice. The
22 rainy season is coming. You've already signed off
23 on the inside and the rain hits your roof, you're
24 going to have another problem inside. So just be
25 aware of -- of the timing. You -- you could come
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1 into the rainy season and the roof leak and inside
2 you already signed off on. So just be cognizant of
3 that.
4 MS. CROOKS: Absolutely. Another -- another
5 one, we've been -- this is why we have the damage
6 inside because we had last year weeks of rain,
7 heavy rain.
8 MR. JERGER: Right.
9 MS. CROOKS: And that's when we started to see
10 inside interior ceilings coming in, and we had to
11 go up there ourselves and put sandbags down and
12 tarp. We were trying to figure out exactly where
13 it was. We couldn't really get it at first, but
14 tried to move it and we finally got it where it's
15 not leaking anymore, but it's still open.
16 MR. DIFRANCESCO: Well, I can tell you,
17 according to the pictures that I see, it -- it
18 appears to me that it's in the flashing, flashing
19 problem. Your house is old, your wood is rotted
20 along the edge. Most likely it's going to be a
21 flashing problem up against the house. That's
22 where you're leaking.
23 MS. CROOKS: I had no idea what it was called,
24 but I knew it was along that area where they had
25 torched and put the material up under, but because
Page 192
1 it had been kicked up so much, and they only nailed
2 it down, it -- it was pretty bad. So --
3 MR. CHAIRMAN: Any other Board members have
4 any questions for Ms. Crooks?
5 Ms. Deana, do you have any?
6 MS. FALCE: I don't.
7 MR. CHAIRMAN: Mr. Mathews?
8 MR. MATHEWS: No.
9 MR. CHAIRMAN: Ms. Crooks, thank you for your
10 time.
11 MS. CROOKS: Thank you so much.
12 MR. CHAIRMAN: Thank you.
13 MS. FALCE: Just a quick request. Before I
14 call our next witness, I'll be moving onto the --
15 the building inspectors, but can we take a
16 five-minute break for --
17 MR. CHAIRMAN: I'd -- I'd also like to make a
18 comment. Everybody sitting up on this Board here
19 either is business owners and we're all here for
20 volunteer time. My time is very precious just like
21 your guy's is. We all want to make sure we have
22 the right information, make the right decision.
23 Please be aware.
24 MS. FALCE: I -- I intend on being very brief
25 with -- with the building inspectors.
Page 193
1 MR. CHAIRMAN: Thank you. Five minutes.
2 MR. MATHEWS: Mr. Chairman, are we going to
3 take a lunch break at all or no?
4 MR. CHAIRMAN: No.
5 (Brief recess was had.)
6 MS. FALCE: At this time, county staff would
7 like to call Dave Johnson, Building Inspector,
8 Chief Building Inspector as their witness.
9 MR. CHAIRMAN: Fantastic.
10 DAVID JOHNSON,
11 After having been previous sworn, testified as
12 follows:
13 DIRECT EXAMINATION
14 BY MS. FALCE:
15 Q If you could just state your name for the
16 record?
17 A David Johnson, Chief Building Inspector,
18 St. Lucie County.
19 Q. Okay. And as Chief Building Inspector, what
20 certifications do you hold?
21 A. I currently have a standard inspector's
22 license with a one- and two-family dwelling endorsement,
23 and a building endorsement, and I have a standard plans
24 examiner with a building endorsement.
25 Q. Okay. Thank you. Did there come a time when
Page 194
1 you inspected 4032 Greenwood Drive --
2 A Yeah.
3 Q -- the property at issue here?
4 A. Yes.
5 Q. Okay. And do you recall what date that was?
6 A. February 10th, I believe.
7 Q. Of 2021?
8 A. 2021.
9 Q. Okay. And did you visit the site with Michael
10 Cicio?
11 A. Yes.
12 Q. Okay. And were you visiting the site related
13 to this Contractor Licensing Board case?
14 A. Yes. It was a complaint that Mike wanted me
15 to go out on.
16 Q. Okay. Can you briefly describe what you found
17 when you showed up to the property?
18 A. The roof had been completed. There was some
19 drywall that appeared to be damaged. There was damaged
20 drywall underneath. A couple of spots in the roof felt
21 kind of soft. When you walk around the roof, sometimes
22 you can feel maybe it's not properly nailed, and it
23 never had any inspections so --
24 Q. So when you showed up on February 10th, the
25 roof work looked complete, but no inspections had
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1 occurred prior to that date?
2 A. That's correct.
3 Q. Okay. And what inspections should have
4 occurred prior to that date?
5 A. A roof sheathing inspection and then an
6 underlayment inspection.
7 Q. Okay. Go ahead.
8 A. Yeah. That's it.
9 Q. Okay.
10 A. I'm sorry.
11 Q. And during that inspection, you took
12 photographs which were included in Mr. Cicio's statement
13 earlier today?
14 A. Yes.
15 Q. What, if anything, did you do after that
16 inspection relating to this property?
17 A. I believe -- like I said, I believe I was in a
18 phone call conversation to Mr. Campbell that he needed
19 to get an inspection done and he'd have to open the roof
20 up so we can see if it was properly nailed.
21 Q. Okay. And was Mr. Campbell willing to -- to
22 do that when you spoke with him?
23 A. I believe that's when Clyde went out there and
24 was on-site with Mr. Campbell and whoever was there, and
25 that's when they opened the roof up in those spaces.
Page 196
1 Q. Okay. And when you say Clyde, you mean
2 Clyde Heffelfinger, the building inspector with
3 St. Lucie County?
4 A. Yes.
5 Q. And when Clyde was out on the property for his
6 inspection, I believe it was April 13th, 2021, did you
7 have any further conversations with Clyde related to
8 this property?
9 A. He may have called me and said that he had
10 found a couple of spots that appeared to be nailed
11 properly, and then there was one that was not, and I
12 said, Well, then my -- my answer to him was that you'd
13 have to fail the inspection. And they probably have to
14 uncover the whole roof. If we seen, you know, three
15 spots that were nailed correctly, we can assume the
16 whole thing is nailed correctly, but when one was not,
17 we don't know what the rest of the roof looked like that
18 we didn't see.
19 Q. Okay. Did you have any other subsequent
20 conversations with Mr. Campbell related to the roof?
21 A. I believe after Clyde's inspection, I believe
22 having a conversation with Mr. Campbell that he was
23 willing to take it down to the plywood, get it properly
24 renailed, and go through all the inspections, but he
25 needed some time.
Page 197
1 Q. Okay. Did that ever occur, to your knowledge?
2 A. Not to my knowledge.
3 Q. Have any further inspections been conducted by
4 you or anyone else within the -- within the building
5 inspector's department?
6 A. I believe after Clyde was there, the
7 inspection was called in and that's when Mike Lunsford
8 went out there and there was no contractor on-site. I
9 believe he had some brief words with the owners and they
10 said that nothing was done and there's no reason to do
11 an inspection here, that, you know, you need to take
12 off.
13 Q. Okay. Do you have an understanding of exactly
14 what is wrong with the roof, what -- what needs to be
15 fixed?
16 A. Well, we definitely need to make sure that the
17 roof decking was properly nailed, and we also need to
18 see that the underlayment was put down according to the
19 approval that was submitted, and there does appear to be
20 some issues with the flashing around where the metal --
21 where the flat roof adjoins to the shingle roof and the
22 other layer, the other roof section.
23 Q. Okay. And those items that you just listed,
24 are all in their current state, they violate the
25 building code provisions that apply to this -- this
Page 198
1 home?
2 A. Yes. The roof should be to where it will
3 prevent moisture from getting into the structure. So if
4 there's a flashing issue, obviously, it's going to be a
5 building code issue because it's going to leak.
6 Q. Okay.
7 MS. FALCE: So can I have -- do you have
8 another copy of the packet that we --
9 MR. CICIO: This one?
10 MS. FALCE: Yes.
11 MR. CHAIRMAN: I should have brought mine. I
12 got it.
13 BY MS. FALCE:
14 Q. If you could, can you turn to Page 19 of the
15 St. Lucie County package that was handed out at the
16 beginning of the meeting? Just let me know when you're
17 there.
18 A. At the inspection card?
19 Q. Yes.
20 A. Okay.
21 Q. And so looking at the inspections here, this
22 is a complete list of what you just testified to
23 related -- related to all of the -- the inspections that
24 have occurred on 4032 Greenwood Drive?
25 A. Yes, ma'am.
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1 Q. Okay. Looking at the next page, Page 20 of
2 the package --
3 A. Yes, ma'am.
4 Q. -- is this -- is this a copy of your
5 inspection report from the February 10th, 2021 site
6 visit that you had?
7 A. This is a summary of the investigation that I
8 did with Michael, yes.
9 Q. Okay. And then just looking at the bottom
10 there are a few notes where it says original draft date
11 and then a revised date, could you just explain what
12 those notes are for?
13 A. When I drafted this, I did not put a date to
14 it, so I was going back on trying to put the date in
15 when I went back through the computer and put the date
16 in when it was first drafted.
17 Q Okay.
18 A And then the revised date was because I had a
19 typo in the very first paragraph where it said 2/10 and
20 I had 2022 and that was, obviously, a typo and I
21 corrected it to be 2021.
22 Q. Okay. Thank you. Looking at your statement,
23 you have -- you have a note that says: "Photos of the
24 roof sheathing provided by the homeowners were
25 inconclusive as to whether the sheathing was nailed
Page 200
1 sufficiently." Do you see that?
2 A. Yes.
3 Q. It's in the second paragraph. Is that one of
4 the reasons why it's important to have inspections along
5 the way and to not rely on photographs?
6 A. Absolutely.
7 Q. Okay. And what would be the purpose of having
8 the sheathing nailed properly.
9 A. The building code requires it on a reroof that
10 you must -- if it's not previously nailed with 8D ring
11 shanks six inches on center that you need to put
12 supplemental fasteners in --
13 Q. Okay. And that --
14 A. -- to hold the roof down.
15 Q. Okay. And that's what the inspections would
16 be checking for, correct?
17 A. That's what the inspector would be checking
18 for, yes.
19 MS. FALCE: Okay. No further questions for
20 you at this time, but I reserve the right to ask
21 some follow-up questions.
22 MR. CHAIRMAN: Thank you, Ms. Deana.
23 MS. FALCE: Thank you.
24 MR. CHAIRMAN: Thanks, Dave. Mr. Mathews?
25 CROSS EXAMINATION
Page 201
1 BY MR. MATHEWS:
2 Q. Mr. Johnson, you inspected the 4032 property
3 on April 13th?
4 A. I don't believe I was there in April. I was
5 there February 10th.
6 Q. And later there was an inspection of three
7 different areas of that roof?
8 A. After -- yes. At a later date, yes.
9 Q. Were -- and two out of the three areas were --
10 were no problems, correct?
11 A. According to the notes on the inspection card,
12 yes.
13 Q. And there was 8x8 section that was reported
14 that there was an instance of nails not being in the
15 proper distance apart, right?
16 A. According to -- according to the notes, yes,
17 sir.
18 Q. And what's the code requirement on the -- how
19 far apart nails should be spaced?
20 A. Six inches on center.
21 Q. Okay. And how many instances are you aware of
22 that that 8x8 panel didn't meet the 6x6 parameter?
23 A. Can you repeat that question again?
24 Q. Sure. How many -- how many times was there --
25 was there an omission to have the nails within 8 inches?
Page 202
1 A. I wouldn't know. I didn't do that inspection.
2 Q. Was it -- okay. So no -- no idea if it's --
3 it's a dozen times or two times?
4 MR. CHAIRMAN: Mr. Mathews, with all due
5 respect, Mr. Johnson was not on that inspection
6 that -- where the plywood was taken up and it was
7 shown. That was Mr. Heffelfinger.
8 MR. DIFRANCESCO: Lunsford.
9 MR. CHAIRMAN: Heffelfinger.
10 MR. DIFRANCESCO: Lunsford.
11 MR. CHAIRMAN: Lunsford.
12 THE WITNESS: Heffelfinger.
13 MR. CHAIRMAN: I have Heffelfinger here on
14 there.
15 MR. MATHEWS: Is Mr. Heffelfinger here?
16 THE WITNESS: Yes.
17 MR. MATHEWS: Perfect. We'll --
18 MR. CHAIRMAN: And it's six inches on center,
19 by the way, not eight.
20 MR. MATHEWS: That's what I thought I said.
21 MR. CHAIRMAN: You said eight. He said six.
22 THE WITNESS: 8D ring shanks.
23 MR. CHAIRMAN: There you go. Hey, we're going
24 to law school today. You're coming to contractor's
25 school.
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1 MR. MATHEWS: That's good. I'm learning.
2 BY MR. MATHEWS:
3 Q. Mr. Johnson, did you ever get on the roof?
4 A. Yes, sir.
5 Q. Okay. But there was an email on there that
6 said that you can't get on the ladder. Did you have a
7 problem at one point in time where you couldn't get on a
8 ladder?
9 A. Not me.
10 Q. Okay. Let's look at Exhibit 12. It's an
11 email from yourself to Mike, correct?
12 A. Okay. This would be -- this would be my
13 inspection report, because I have the county's?
14 MR. CHAIRMAN: He doesn't have this.
15 THE WITNESS: I have the county's.
16 MR. MATHEWS: It should be in the tab book.
17 THE WITNESS: I do not have that. I got the
18 county's which --
19 MR. CHAIRMAN: He doesn't have your book.
20 MR. MATHEWS: Oh, did you take it back?
21 THE WITNESS: My Page 20 is --
22 MR. CHAIRMAN: I'm going to start charging.
23 BY MR. MATHEWS:
24 Q. Can you read that first -- that first email
25 exchange from yourself to Mike?
Page 204
1 A. I'm looking for Exhibit 12. I'm trying to get
2 through here.
3 MS. WATERS: Go to 11 in tab -- page back from
4 11.
5 THE WITNESS: It's a page back from there?
6 MR. CHAIRMAN: Go to 11 and there you go.
7 THE WITNESS: Okay. The email. What was your
8 question?
9 BY MR. MATHEWS:
10 Q. Can you read that first two sentences?
11 A. "I just got a phone call with Mr. Shultz and
12 he wants to meet at the job to do an inspection next
13 week, Tuesday, 4/6/21. I will need to have Clyde meet
14 me there for the inspection as I can't get on a ladder.
15 Let me know if you want me to meet there. I have not
16 contracted (sic) the owners yet. Get with me later
17 today or call me so I can discuss this."
18 Q. Okay. So I was just trying to refresh your
19 recollection about not getting on a ladder.
20 A. That -- that -- yeah, I don't -- that came
21 from me. I don't recall why I would say I couldn't get
22 on a ladder.
23 Q. Yeah, and I don't know if you hurt your foot
24 or you don't like heights or --
25 A. 4/6. I had had an injury. I don't know if
Page 205
1 that was when I had an injury when I wasn't using the
2 ladder then.
3 MR. CHAIRMAN: It was ten months ago, Dave.
4 THE WITNESS: Huh?
5 MR. CHAIRMAN: It was a long time ago.
6 THE WITNESS: That may have been when I was
7 unable to get on a ladder for a short period of
8 time from an injury.
9 BY MR. MATHEWS:
10 Q. Okay. The area that was inspected, the three
11 different areas, do you know if they were original
12 sheathing or new sheathing?
13 A. I do not know.
14 Q. When inspections are done of the sheathing
15 process, are you involved in that process?
16 A. Yes, sir.
17 Q. Do you physically walk the -- the site?
18 A. Yes, sir.
19 Q. And do you eyeball where the nails are; do you
20 get out a ruler or tape measure?
21 A. If need be, we get out a tape measure. We can
22 -- we've seen enough nail patterns to know, and most of
23 the time it's shorter than -- it's less than six inches
24 on center where they nail it, but if we need to get a
25 tape measure, if something looks out of whack, yes, we
Page 206
1 will get a tape measure and -- and verify.
2 Q. Okay. And then if it's rejected or if it
3 doesn't pass, the permit doesn't -- sorry, if the
4 inspection doesn't go through for the sheathing process
5 and it's rejected, can you tell the contractor, Hey, you
6 gotta put more nails in this area?
7 A. Yes. Quite often we try to work with
8 contractors and they usually are there on-site to
9 correct things, because these are existing homes. We
10 don't want them to get damages but -- with rain, and
11 generally they're on-site and make the corrections right
12 there.
13 Q. If the nail pattern's not correct, is that
14 something you -- you circle with like a marker or
15 something or you just -- it doesn't -- it fails, and
16 then you move on?
17 A. Sometimes we would circle it to help the
18 contractor out but not always.
19 Q. Okay. Have you ever heard about the process
20 used in St. Lucie County where a contractor can submit
21 photographs to satisfy the requirement to get the
22 inspection done with the sheathing?
23 A. We have used photographs at times.
24 Q. And so you -- you've seen that process where
25 somebody doesn't have to physically go there and you can
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1 rely upon photographs?
2 A. If it's -- if it's pre-arranged, yes, we -- we
3 can work with the contractors that way. We've also done
4 virtual inspections as well.
5 Q. What is a virtual inspection?
6 A. With an app on your phone, either a WhatsApp
7 or a Facetime and the contractor is there and is showing
8 us the roof deck while they're tearing it off or while
9 they're -- after they've torn it off and have put the
10 nails back on.
11 Q. In your experience, would it be -- could it
12 have happened that Mr. Campbell called for the
13 inspection of the sheathing and somebody in the
14 permitting department said, Don't worry about it, just
15 take some pictures, and submit them with an affidavit?
16 A. Generally, the permit techs would refer them
17 to a building inspector to answer that question.
18 Q. But could that happen?
19 A. I suppose it's possible.
20 Q. Did you come to learn in this instance that
21 Mr. Campbell had called to get an inspection and
22 somebody from St. Lucie County said don't worry about
23 it, just take pictures and submit an affidavit?
24 A. I do not know that to be true.
25 Q. I'd like you to take a look at Tab No. 11. Do
Page 208
1 you see the first picture in this composite exhibit?
2 A. Yes.
3 Q. It's a bunch of sheets of plywood, right?
4 A. Yes, sir.
5 Q. And then the next picture is a kind of a close
6 up of some of the plywood?
7 A. Yes, sir.
8 Q. And so there's a blank page in there. Then
9 there's a picture of the -- the tab?
10 A. The underlayment?
11 Q. Underlayment, yes.
12 A. Yes, sir.
13 Q. And then the next one is a more complete
14 picture of a larger portion of the roof?
15 A. Yes, sir.
16 Q. And then the next one is another, I guess,
17 version of that L-shaped roof?
18 A. Yes, sir.
19 Q. And then the following paper is that the
20 flashing, that's the front flashing?
21 A. Yeah, it looks like a flashing in a valley
22 where the shingles meet the flat deck.
23 Q. Okay. And then finally the drip edge?
24 A. I don't see any others.
25 Q. There's two pictures of the drip edge. Three
Page 209
1 pictures.
2 A. I have a couple of blank pages.
3 Q. If the first couple of pages were submitted to
4 St. Lucie County with an affidavit, would that satisfy
5 the sheathing inspection requirement?
6 MS. FALCE: Objection. It calls for
7 speculation, and if an affidavit would accompany it
8 stating what exactly?
9 MR. CHAIRMAN: Agree, Deana.
10 Your question was, again, Mr. Mathews?
11 BY MR. MATHEWS:
12 Q. Would these be -- would these be -- would
13 these pictures reflect work on the sheathing that would
14 meet the requirement in order to issue the permit? It's
15 a badly worded question. Let me rephrase it.
16 MS. FALCE: You could rephrase --
17 MR. CHAIRMAN: I think I know exactly what you
18 want to say.
19 MR. MATHEWS: I'm trying. I'm working my way
20 through it.
21 BY MR. MATHEWS:
22 Q. Mr. Johnson, if -- if these -- these pictures
23 were present to St. Lucie County, would they satisfy the
24 requirement to have photographic evidence that the
25 sheathing was nailed to code?
Page 210
1 MS. FALCE: Objection. Answer if you can.
2 MR. CHAIRMAN: Or would this picture be too
3 small of an area to be able to have -- to really
4 showcase what this space would be?
5 THE WITNESS: I would probably -- if it was
6 me, I would probably request a few more photos.
7 This isn't quite enough for me to be satisfied.
8 BY MR. MATHEWS:
9 Q. In photographs that are provided to St. Lucie
10 County, are you able to measure how far the nails are to
11 be sure that they're six inches apart?
12 A. No, sir, but if you have a full sheet of
13 plywood, you can do the math and you can see the nails.
14 You can see how many you need for the four foot.
15 Q. And when you're repairing a roof or fixing a
16 roof that has leaks like that, typically there's some
17 portion that has sheathing on it already, right, and
18 it's good, and then there's other areas that's -- that's
19 rotten and it needs to get replaced, right?
20 A. Correct.
21 Q. That's kind of standard?
22 A. Sure.
23 Q. What is the minimum thickness of plywood that
24 can be utilized on these flat roofs?
25 A. An existing roof may have half-inch plywood on
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1 it.
2 Q. So is it up -- is it consistent with code if
3 you're replacing a sheet of plywood to have a consistent
4 thickness of the one next to it, the old versus the new?
5 A. You should keep the plywood the same
6 thickness.
7 Q. Do you know what the plywood thickness was in
8 -- on that property?
9 A. I do not.
10 Q. Obviously, the thinner the plywood, the more
11 it would buckle and give, right?
12 A. Yes.
13 Q. Did you look at the inspected joists that
14 would be underneath the sheathing?
15 A. No, sir.
16 Q. And in -- for joists, does it -- is there --
17 there's probably a minimum and a maximum in terms of how
18 far it can be apart?
19 A. Yes.
20 Q. And the further it's apart, the more kind of
21 spongy it will feel on the top?
22 A. Yes, it could. Yes.
23 MR. MATHEWS: No further questions at this
24 time.
25 MR. CHAIRMAN: Thank you, Mr. Mathews.
Page 212
1 Ms. Deana, do you have any?
2 MS. FALCE: I just have a -- a few --
3 MR. CHAIRMAN: Sure --
4 MS. FALCE: -- as follow-up.
5 MR. CHAIRMAN: -- by all means.
6 REDIRECT EXAMINATION
7 BY MS. FALCE:
8 Q. Mr. Johnson, under what circumstances does the
9 County use photos instead of going in person to inspect
10 buildings?
11 A. If it's kind of unfeasible to make it at a
12 time when the contractor needs to cover the roof up,
13 rainy days, things of this nature.
14 Q. Okay. And would there be a record kept or a
15 note made to the permit file if a contractor called in
16 to request an inspection and they were told photos are
17 fine, we don't need to go out there?
18 A. Not always, but there could be.
19 Q. Okay. Do you remember any circumstances
20 related to this case, 4032 Greenwood Drive, that it
21 would have been not feasible for an inspector to go out
22 there if Mr. Campbell had called for an inspection?
23 A. I see no reason why we couldn't have done the
24 inspection.
25 Q. Okay. Seeing the photos that were presented
Page 213
1 to you by opposing counsel, could they take the place of
2 an in-person inspection that found a part of the roof to
3 be in violation of the building code?
4 A. Typically if we see a section that's not
5 nailed to code, we'd want to see exactly that section
6 again, but there again, if one section wasn't nailed to
7 code and we didn't see hardly any of it at all, we'd be
8 concerned of the whole roof being nailed to code.
9 Q. Okay. Your -- your inspection report talks
10 about -- during the visual inspection of the finished
11 roof, it appeared that there was some roof sheathing
12 that was not properly fastened or the sheathing was weak
13 or damaged. Is that -- is that what caused you to
14 schedule an inspection later to pull up some of those
15 portions?
16 A. Well, the roof sheathing would have to got --
17 had -- had to have been inspected regardless. I was
18 there to just assist Mike with the investigation of what
19 was going on there and see how far the roof had gotten.
20 So the sheathing inspection still would have needed to
21 be inspected and -- much like Clyde did, cut it open in
22 a few spots and if it looks good, we're going to be okay
23 with it.
24 Q. And in this case, you were asked a few
25 questions about, you know, how far apart joists had to
Page 214
1 be and the thickness of the plywood and -- and if it
2 would be a little bit -- it was sag or bow, depending on
3 those. Are those issues in -- in this matter that
4 you're aware of related to the building code violations?
5 A. They wouldn't be issues because you do have
6 spongy plywood. I -- I recall it felt like the plywood,
7 when you get to an end of a sheet, it may bounce up or
8 down a little bit like it wasn't nailed properly on an
9 end. That's what concerned me.
10 Q. Okay. But you didn't make any final decisions
11 whether or not this roof was built to code based on a
12 feeling of mushiness when you were on that roof, right?
13 A. No, ma'am.
14 Q. Okay. Any determinations that were made
15 related to the building code and whether this roof
16 sufficiently met code or based on an in-site inspection
17 looking at this property, not a feeling of mushiness?
18 A. No. There was no way I could speak to how the
19 roof was -- roof decking was nailed off, nor could I
20 speak to how the underlayment was installed, if it were
21 installed properly or improperly or -- because I didn't
22 see it.
23 Q. Right, during your site visit on
24 February 10th?
25 A. Correct.
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1 MS. FALCE: No further questions. Thank you.
2 MR. MATHEWS: Just one.
3 RECROSS EXAMINATION
4 BY MR. MATHEWS:
5 Q. Mr. Johnson, is there a requirement that the
6 sheathing be replaced with 3/4-inch plywood?
7 A. No.
8 MR. DIFRANCESCO: Excuse me, Mr. Johnson, from
9 what I see here, from what I understand, when they
10 did have the roof off, no inspection was ever
11 called in?
12 THE WITNESS: That's correct.
13 MR. DIFRANCESCO: Okay. The -- and no one
14 ever called to say will you accept pictures? I
15 know because I -- I've done this before and I've
16 called ahead and I said, Look, we want to get this
17 roof covered up because we know we've got rain
18 coming. Is it okay if we Facetime you, which I've
19 done before, and we Facetime them and walk the roof
20 -- the whole roof just like that and they -- they
21 can actually see that everything is nailed
22 properly. So I'm just asking you, so no one had
23 contacted you ahead of time; they just went ahead
24 and covered the roof up?
25 THE WITNESS: No one contacted me.
Page 216
1 MR. DIFRANCESCO: Because what I see here is
2 when Mr. Heffelfinger went out there, they called
3 for a roof sheathing inspection. It was
4 disapproved because -- well, they were told to open
5 up three areas, which they did, and one of the
6 areas, the 8x8 area, failed.
7 THE WITNESS: That's correct.
8 MR. DIFRANCESCO: Okay. So then it would -- I
9 understand that Michael Lunsford was called in.
10 Roof sheathing was called in again on 10/14, six
11 months later, for a roof sheathing inspection
12 again, and the roof was completed at that time?
13 THE WITNESS: I -- to my knowledge, the roof
14 was probably just the way it was after Clyde left.
15 MR. DIFRANCESCO: It says here: "Reinspection
16 request, early morning around 9 A.M. No one
17 on-site for inspection. See Chapter 9 FBC for
18 proper installation." No way to get an inspection.
19 THE WITNESS: That was Michael's notes, and I
20 spoke with Michael and he said that there was no
21 contractor on-site. And he spoke with the owner
22 briefly, and they said no work was done and they
23 didn't want him on to do any inspections because no
24 work had been done.
25 MR. DIFRANCESCO: So you don't know if the
Page 217
1 roof was still open or not?
2 THE WITNESS: No, I do not.
3 MR. DIFRANCESCO: But the homeowner would know
4 if the roof was still open on that date?
5 THE WITNESS: I would assume so.
6 MR. DIFRANCESCO: I just want to -- what I'm
7 trying to find out is if -- did they come back and
8 cover the roof up and say let's call for a roof --
9 a roof sheathing inspection anyway and see if we
10 can get it passed?
11 THE WITNESS: I couldn't speak for that.
12 MR. DIFRANCESCO: At any point, did you ever
13 receive these paper -- these pictures or did you
14 just now see them today?
15 THE WITNESS: These are the first time I've
16 seen these photos.
17 MR. DIFRANCESCO: They were never submitted to
18 the building department?
19 THE WITNESS: Not to my knowledge.
20 MR. DIFRANCESCO: Okay. Thank you.
21 MR. CHAIRMAN: Mr. Johnson, I have a question
22 for you. Whose responsibility is it to call in for
23 the inspection?
24 THE WITNESS: Generally the contractors.
25 MR. CHAIRMAN: And how often is it the
Page 218
1 contractor is the one that calls in for the
2 inspections, how on a percentage basis?
3 THE WITNESS: I would assume 90 percent of the
4 time they call it in.
5 MR. CHAIRMAN: And this -- this particular
6 permit had how many individual inspections?
7 MR. JOHNSON: Oh, three total. Three required
8 inspections.
9 MR. CHAIRMAN: Three are required.
10 THE WITNESS: Three required inspections.
11 MR. CHAIRMAN: So we have one to make sure the
12 sheathing is nailed down properly?
13 THE WITNESS: Correct.
14 MR. CHAIRMAN: Two, make sure that the
15 underlayment is installed correctly?
16 THE WITNESS: Correct.
17 MR. CHAIRMAN: And then three, the overall
18 final?
19 THE WITNESS: Yes.
20 MR. CHAIRMAN: Thank you. Any other
21 questions?
22 No further questions from the Board.
23 MS. FALCE: I don't have any further
24 questions.
25 MR. CHAIRMAN: Okay. Thank you, Mr. Johnson.
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1 THE WITNESS: Thank you.
2 MS. FALCE: Thank you. The next witness the
3 county staff would like to call is
4 Mr. Heffelfinger.
5 MR. CHAIRMAN: Good afternoon, sir.
6 MR. HEFFELFINGER: Good afternoon.
7 MR. CHAIRMAN: Thank you for being here.
8 MR. HEFFELFINGER: You're welcome.
9 CLYDE HEFFELFINGER,
10 After having been previous sworn, testified as
11 follows:
12 DIRECT EXAMINATION
13 BY MS. FALCE:
14 Q Good afternoon. Could you state your full
15 name for the record.
16 A My name is Clyde Heffelfinger.
17 Q. And what is your position with the County?
18 A. I'm a standard inspector, licensed by the DBPR
19 with a one- and two-family endorsement.
20 Q. Okay. Did there come a time where you
21 inspected the property located at 4032 Greenwood Drive?
22 A. Yes.
23 Q. And was that on or about April 13th, 2021?
24 A. Yes.
25 Q. Okay. Do you recall -- just tell us about
Page 220
1 that inspection. Do you recall what you found, what you
2 saw?
3 A. Yes. It was -- I went to meet Mike Cicio
4 there because it was -- it was a code case, and when we
5 got there, the roof was completed. The inspection I was
6 there for was a roof sheathing inspection, which has to
7 be exposed, and the roof was completed.
8 So the contractor, Mr. Campbell, was there
9 with another man and they -- I directed them to cut two
10 holes that were approximately three feet by three feet,
11 and I saw new nails and the sheathing appeared to be
12 properly nailed in those places. And I directed him to
13 cut another hole, a bigger area, in the northwest
14 corner, which was approximately eight feet by eight feet
15 and discovered there that the nails were not six inches
16 on center as they had been where I -- the first two
17 holes they'd cut.
18 I have one photograph of that area, and the
19 nails that I took the photograph of are about 13-inches
20 apart.
21 MS. FALCE: If we could -- Ms. Williams, if we
22 could pull up the photographs that we have.
23 Mr. Cicio has already submitted these into the
24 record of the proceedings.
25 MS. WILLIAMS: Is that it?
Page 221
1 MR. HEFFELFINGER: No. There's the one with
2 the tape measure. There was another one that's
3 actually a tape measure on the plywood.
4 MS. FALCE: There we go.
5 MR. HEFFELFINGER: That's it. That may be it
6 there. I'm not sure.
7 MR. DIFRANCESCO: That was it.
8 MR. HEFFELFINGER: There it is. There's -- 13
9 and 13-and-a-half inches from nail to nail on that
10 picture right there.
11 BY MS. FALCE:
12 Q. Okay. And is that -- this -- you took this
13 picture during your inspection on April 13th?
14 A. Yes.
15 Q. Okay. And can you please explain what -- what
16 is wrong with what you found in this picture
17 particularly?
18 A. The building code requires the nail spacement
19 (sic) to be a maximum of six inches on center, and these
20 nails were 13 inches or so apart, and the area that they
21 took off, all of the nails were -- they're never
22 perfectly aligned, but they're -- most of them were more
23 than six inches or were about a foot apart.
24 Q. And that was in that eight by eight area on
25 the northwest area --
Page 222
1 A. It was a pretty large area, yes.
2 Q. -- corner? Okay. What, if anything, did you
3 do after discovering the -- the nails were too far
4 apart?
5 A. I called my Chief Inspector, David Johnson,
6 and was talking to him about it and -- because I wanted
7 some input from him as to what, you know, where to go
8 with this. And he was in the office, and our building
9 official, Doug Harvey, was there, and they talked about
10 it for a couple of minutes, or a minute or two, and then
11 said that if that area was not satisfactory we couldn't
12 approve the inspection because that was a fairly large
13 area. It's twice the size of what -- the other two
14 areas that were cut open. And since it was not correct,
15 we couldn't assume the rest of the roof was correct.
16 Q. And so that's why that inspection did not
17 pass?
18 A. That's why I disapproved the inspection was
19 because of -- of that area that wasn't nailed correctly.
20 Q. Did you have any conversations with
21 Mr. Campbell while you were on -- on the property?
22 A. Yes. We talked -- you know, I explained to
23 him, you know, what we'd seen and he -- and he to me
24 acknowledged that it wasn't nailed correctly, it had
25 never been renailed, and I said I can't approve it, and
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1 we're going to have to disapprove the inspection, and
2 before I left there, his -- basically he said I'm going
3 to have to tear it off and start over again. I don't
4 have another option.
5 Q. Okay. Did you have any other conversations
6 with Mr. Campbell about this property after that?
7 A. Just that day. I don't remember exactly what,
8 you know, exactly word for word or anything, but I never
9 spoke to him again. I just assumed -- I left there
10 assuming it would get torn off and redone.
11 Q. Okay. If you could turn to Page 29 in the --
12 the St. Lucie County package that's up there.
13 A. I think it's this one here, right? Okay.
14 Q. Okay. I just would like you to confirm this
15 is an accurate copy of your inspection report for the
16 April 13th, 2021 inspection that we were just
17 discussing, correct?
18 A. Yes, it is.
19 Q. Okay. I --
20 MS. FALCE: Yep. No further questions. Thank
21 you, very much.
22 MR. CHAIRMAN: Thank you, Ms. Falce.
23 Mr. Mathews?
24 MR. MATHEWS: Yeah, I got a couple questions.
25 CROSS EXAMINATION
Page 224
1 BY MR. MATHEWS:
2 Q. Mr. Heffelfinger, we saw photographic evidence
3 of two instances of, I don't know -- or one instance, I
4 think, of -- of 13 inches where there wasn't a nail in
5 place. You said that there were multiple other
6 instances?
7 A. Yes, sir.
8 Q. But that's not part of your evidence other
9 than your oral testimony, right?
10 A. If I had known I'd here today, I'd have taken
11 a bunch of pictures of that area.
12 Q. Fair enough. Did you notice in -- in some of
13 those pictures, did you see any -- did you look at any
14 of the shingles?
15 A. No.
16 Q. Did you notice the condition of the roof, roof
17 shingles while you were there?
18 A. I don't recall what they looked like, no.
19 Q. Do you know if it was a new roof, or original
20 roof, or old roof?
21 A. My guess -- well, I can't answer that question
22 because I really wasn't looking for that.
23 Q. The -- how did you -- how were the areas
24 selected where you would open up the roof?
25 A. I just told them to cut an area. Just pointed
Page 225
1 to this area and said, Cut this open. I want to see the
2 nails here.
3 Q. Okay. So in two out of the three test areas,
4 no problems, right?
5 A. Right.
6 Q. The areas that were opened, were they
7 replacement plywood or sheathing or original?
8 A. I think they were probably original.
9 Q. Okay. Do you see the nailheads on that one;
10 do you see that they look a little rusty?
11 A. Yeah, that's right. You can see the
12 difference between new nails and old nails because the
13 old nails are generally rusty.
14 Q. Okay. But -- and I think Mr. Leonard will
15 probably point me in the right direction on this. If --
16 if -- or you can -- if an entire roof is replaced,
17 right, and you've got let's say two sheets has to get
18 replaced, right, and that's nailed every six inches;
19 that's good, right? That's -- that's good work, but my
20 guess is the site for it to pass inspection, the entire
21 surface, would need to -- need that six-inch
22 requirement?
23 A. The building code calls for supplemental
24 nailing to not exceed six inches on center.
25 Q. Okay. So if there's a deficiency in this, it
Page 226
1 was a deficiency not in the Abe Shultz crew installing
2 the sheathing. It was -- it was a shortcoming that
3 dealt with inspection of other work, is that fair?
4 A. I don't think so.
5 MR. CHAIRMAN: Well, Mr. Mathews, and just
6 stop me if I'm wrong, but the code requires whoever
7 is doing the roof install to go back in and do
8 supplemental nails. Supplemental nails means you
9 look at an entire roof that you're working on and
10 you nail that every six inches, no matter where it
11 is.
12 MR. MATHEWS: Okay. And -- and I think my
13 point, I'll just try to make --
14 MR. CHAIRMAN: Sure.
15 MR. MATHEWS: -- it a little bit more narrow.
16 MR. HEFFELFINGER: Sure.
17 MR. CHAIRMAN: Uh-huh.
18 BY MR. MATHEWS:
19 Q. Did you find any instances of new plywood that
20 didn't meet that requirement -- that didn't meet the
21 six-inch requirement?
22 A. No, I don't recall that.
23 MR. MATHEWS: No further questions.
24 MR. CHAIRMAN: I have a question. Thank you.
25 Mr. Heffelfinger, the three spaces that were
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1 removed for you to see, was there new plywood in
2 those three spaces or was that just all existing
3 plywood based on your --
4 THE WITNESS: I think it was all existing
5 plywood.
6 MR. CHAIRMAN: Okay. But if there was plywood
7 that was changed during the construction, which I
8 believe there was in some photos that were provided
9 today, that would be new plywood, new nails, but by
10 code, they have to go back in there and nail --
11 renail off the entire roof?
12 THE WITNESS: That's correct.
13 MR. CHAIRMAN: Thank you, sir.
14 Any questions from the Board?
15 MR. DIFRANCESCO: Mr. Chairman, I can see on
16 -- in the photos on --
17 MR. CHAIRMAN: Section 11?
18 MR. DIFRANCESCO: -- Section 11, second page,
19 you can see that there are new nails there, but
20 that was the only photo that was -- and they appear
21 to be six -- four inches and six inches, but that's
22 the only photo that kind of shows the nailing
23 pattern that you can see.
24 MR. CHAIRMAN: Uh-huh.
25 MR. DIFRANCESCO: I mean, it appears it could
Page 228
1 be some new nails in there.
2 MR. CHAIRMAN: Mr. Heffelfinger, I have a
3 question for you. Would it be safe to assume that
4 if those three spaces were nailed off correctly you
5 would have passed the inspection?
6 THE WITNESS: Most likely.
7 MR. CHAIRMAN: Thank you, sir. You guys good?
8 MS. FALCE: Okay. You're good? Okay. Sorry.
9 I think we were all looking at each other. Just
10 one moment.
11 Our next -- our next and hopefully final
12 witness for -- for the county staff would be
13 Mr. Campbell, if you could take -- take the stand.
14 Thank you, sir.
15 MR. CHAIRMAN: Mr. Campbell, you're going to
16 need to be sworn in so if you could state your
17 name, address, for the record, the secretary will
18 take care of you.
19 MR. CAMPBELL: My name is Lindolph Campbell.
20 My address you said?
21 MR. CHAIRMAN: Yes, sir.
22 MR. CAMPBELL: 11510 Northwest 20th Court,
23 Plantation, Florida 33323.
24 LINDOLPH CAMPBELL,
25 MS. JOHNSON: Do you affirm to tell the truth,
Page 229
1 the whole truth, and nothing but the truth?
2 THE WITNESS: I do.
3 MS. JOHNSON: Thank you.
4 MR. CHAIRMAN: Thank you, sir.
5 DIRECT EXAMINATION
6 BY MS. FALCE:
7 Q. Good afternoon, sir. How long have you held a
8 contractor license?
9 A. Um -- it depends --
10 Q. About. About.
11 A. -- what I'm saying, it depends on what you
12 meant, you know. I have contractor's license for over
13 40 years --
14 Q. Okay.
15 A. -- but this particular one, the roofing
16 license about four years and I have another contractor's
17 license over 12 years.
18 Q. Okay. And when did you apply for your
19 Certificate of Competency for St. Lucie County?
20 A. The same time that I was doing this roof.
21 Q. Okay. So it was for this specific project
22 that you applied?
23 A. Yes.
24 Q. Okay. And how did you find out about this
25 job; who contacted you related to 4032 Greenwood Drive?
Page 230
1 A. Mr. Andrew Brown told me about this job, said
2 he got a job up here and -- and they -- they tell me
3 that, you know, things not working well and they asked
4 me to help them. I said -- I write a permit. I didn't
5 fill it out completely. Not a permit, a proposal, and I
6 gave it to him and I took to the lady because I know --
7 but she didn't -- she didn't give it back to me.
8 When I gave her in October, 2020, she just
9 keep it, kept it to herself and, you know, she gave it
10 back to me when the roof was finished.
11 Q. Okay. So when you say you gave -- gave her a
12 proposal in October and then -- then you got it back
13 when it was finished, is it the -- is it the proposal --
14 if you could turn to right before Tab 6 in the packet
15 that's up there --
16 A. Tab 6.
17 Q. In the book. I'm sorry.
18 A. In the book?
19 Q. Yeah, in the book.
20 MR. MATHEWS: Mr. Leonard?
21 MR. CHAIRMAN: Yes, sir?
22 MR. MATHEWS: I actually do have -- I have an
23 old one that I can use so --
24 MR. CHAIRMAN: Oh, no worries. I'm just here
25 with Mr. Jerger. Not big deal.
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1 MR. MATHEWS: -- materials.
2 (Multiple voices.)
3 BY MS. FALCE:
4 Q. All right. Are you on the page? Is this the
5 proposal that you're speaking of?
6 A. Yes. I -- I gave it to her on the first week
7 of October. I sent it to her about the first week of
8 October, and I had like her on three or four lines here.
9 When she returned it back to me in -- around the 12th or
10 13th of January, all of these things been added. She
11 asked me at the time to sign it, and I said there's no
12 way I could sign something like this because, you know,
13 this is not what I sent to you. I leave it like that.
14 Q. So is this -- the proposal where it says "Abe
15 Shultz Construction, LLC," is this your form --
16 A Yes.
17 Q -- that you use?
18 A. Yes. Definitely, yes.
19 Q. Okay.
20 MR. MATHEWS: Lindolph, can I remind you just
21 to wait until she finishes her question?
22 THE WITNESS: Okay.
23 BY MS. FALCE:
24 Q. So this is the form that -- that Abe Shultz
25 Construction, LLC uses?
Page 232
1 A. Generally, yes.
2 Q. And what is your position within Abe Shutlz
3 Construction, LLC?
4 A. I'm the owner.
5 Q. Are you the sole owner?
6 A. Yes.
7 Q. Okay. Do you have any employees?
8 A. No.
9 Q. Do you employ contractors --
10 A. Subcontractors, yes.
11 Q. Okay. And how do you employ them; what --
12 what type of documentation do you have for those
13 contractors?
14 A. I usually employ a subcontractor per job.
15 Like for example, the house up here, I employ a set of
16 subcontractors and they came by and do the work, yes.
17 Q. Okay. And when -- you said Mr. Brown
18 contacted you related to this work; is that correct?
19 A. Yes.
20 Q. Okay. And that's how you first found out
21 about the project?
22 A. Pardon me?
23 Q. You first found out about this project from
24 Mr. Brown?
25 A. Yes.
Page 233
1 Q. Okay. And when he contacted you, why did you
2 agree to -- to step in and -- and file the permit
3 application for him?
4 A. Well, it's -- it's something that I not
5 normally do, maybe about three or four times before with
6 him. He -- he would get a job for me and I would just
7 give him a small fee for it, and I will go and do the
8 job, and just -- just a normal practice. I met him like
9 around three months before this particular job, yeah.
10 Q. And then when you -- when you applied for the
11 permit through St. Lucie County, did you -- did you read
12 the permit that was issued back once it was approved?
13 A. Yes.
14 Q. Okay. And did you know that inspections
15 needed to take place throughout the process --
16 A. Yes.
17 Q. -- the construction process?
18 A. Yes.
19 Q. Okay. And for this particular project, for
20 instance, once the sheathing had been nailed down, was
21 -- was an inspection requested?
22 A. Yes. I called --
23 Q. Okay.
24 A. Can I say it? I called the County and I
25 talked to the lady there for about -- maybe about ten
Page 234
1 minutes. I said how can I -- what do I need to do? And
2 said -- like he said something to me that, Go ahead.
3 Just take pictures and send it. And it was sort of
4 funny to me, crazy. And I was, like, worried about it.
5 When I came to the job site the following day, the
6 homeowner said the same thing to me that he called the
7 -- the -- the County office and they said to him the
8 very same thing. And what he did was -- I'm talking
9 about the homeowner now. What he did was to -- he give
10 me a copy of the affidavit. I asked him to give me the
11 pictures then and I said -- he want me to sign off on
12 the affidavit so that he could go ahead and get the
13 whole thing there. They promised me -- let me say this,
14 too.
15 This job, the guy told me it was -- was -- was
16 18 square. Turned out to be about 22 square. The guy
17 promised the -- I said the homeowner owed me like about
18 a back balance of five -- of $3,000 on it. They -- the
19 guy said he would pay me $5,000 and nobody gave me
20 anything. It cost about $9,000 to do the job. So I
21 said to him. He said to me straight in my eyes that I'm
22 not going pay you anything because you guys take this
23 job -- so I said, Why me, because you're the one who
24 employ an unlicensed person, not me? If you had come to
25 me initially, I would have done it. That was it.
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1 Q. But when you say the -- when you said the guy
2 was going to pay me $5,000, what -- what guy? I just
3 want to make sure.
4 A. Andrew Brown.
5 Q. Mr. Brown?
6 A. All right. You know what, I heard from you
7 that his name is Milton Brown. I know him as
8 Andrew Brown.
9 Q. Yeah. That's why I keep referring to him as
10 Mr. Brown.
11 A. Mr. Cicio said I keep changing that I know him
12 and I said -- he asked about Milton Brown. I said, Hey,
13 I don't know Milton Brown. I -- I never met him because
14 I -- I didn't know that they were talking about -- about
15 the same person. You know what I'm saying? They were
16 showing me this, which I didn't -- not too sure about
17 either.
18 Q. Okay. So you meant Mr. Brown had promised to
19 pay you $5,000 related to --
20 A. At the time -- all right. At the time when we
21 start the job -- at the time when I'm about to start a
22 job, I didn't know that Mr. Andrew Brown collected any
23 money on the job before. I wasn't aware of that. You
24 know, I -- I thought it was just a regular job that I
25 would be getting.
Page 236
1 So what I did, I gave him a copy of a
2 proposal. I expect the homeowner to sign the proposal
3 and bring it back to me. I waited and I didn't see
4 anybody response, so I didn't make any move. So what
5 had happened around in the middle of the month, in
6 October, they start calling me up and say, Hey, they
7 need paperwork from me around the middle of October, and
8 just keep asking me for things and I -- I -- I was a
9 little bewildered. But anyway, I was supposed to meet
10 up with the -- the -- that's the homeowner, the man. I
11 forget what his name. I -- and he was like a -- and I
12 couldn't get to meet up with him. But up to that time,
13 I was just wondering why they were rushing me like that
14 and they didn't return back the proposal to me. You
15 know, because I was waiting for the proposal before I
16 make the next move.
17 Then they start telling me that they have
18 insurance issue, they need this thing to clear away. So
19 I -- I fill out the application, and I submit the
20 application to get the permit, you know. A couple
21 months after that they start calling me to do the work,
22 and I said nobody paid me anything yet. So they ask the
23 question, Why did you do it if nobody pays you? I said,
24 you know, I did it as a favor. I was talking like
25 pulling the permit before I collect anything. Because
Page 237
1 remember now, I was like 100 miles away, and I'm trying
2 to get things done.
3 At the time after I get the permit, Andrew --
4 I tried calling Mr. Brown, call maybe a dozen times, I
5 couldn't get him. I imagine the homeowner call him
6 also. So the homeowner called me and I tell him that,
7 Hey, I don't get any money to start work. Anyway, long
8 story short, I went to her home one evening to walk
9 around and they showed me what to do, flat roof, nothing
10 more. They tell me, Hey, this thing here, the contract
11 said $11,000. I said fine. They said they already paid
12 Andrew $8,000 already. I was shocked. I was saying to
13 myself, the contract that I send stated clear pay 25
14 percent down and 25 percent -- I was waiting for my
15 25 percent that I didn't get it.
16 Anyway, I -- I -- I look around and I saw the
17 situation, which wasn't -- and I reason to myself and I
18 said if I -- maybe if I put an effort, if she gives me
19 the $3,000 and Andrew give me the five, you know, I
20 could try and see if I could finish it for her. And I
21 tried. I tried. So I -- I get my subcontractor to come
22 up here with me, and I spent two days there working on
23 it, two full days. And when I finish, I was expecting
24 to get a $3,000 from her. She looked me straight in the
25 eye and said, I will pay you nothing. I was shock.
Page 238
1 Q. You said "when you finished," you meant when
2 the work was finished, but not when all of the
3 inspections were?
4 A. Well, at the time, I -- I thought -- at the
5 time I thought, based on what they said to me, I thought
6 I would be good because they told me that they -- that
7 all I need to do was to take pictures. I forget, I
8 should have get my phone record to show you that the
9 morning that I was intended to get, but I forget to show
10 it to you. They told me that. They told the homeowner
11 the same thing. It wasn't just me, because I thought I
12 was crazy when they say that to me because I've never
13 experienced that before. I expect the inspector to come
14 there and inspect the -- the nailing, and then give me
15 word to finish and that didn't happen. They ask me,
16 they said -- I asked her over and over. She said, No,
17 this is not necessary. And they keep doing it over and
18 over and over, and I slow (sic) my phone down and I
19 walked out and I shake my head.
20 When I reached the job site the next day, the
21 homeowner said the same thing to me, right? Yes. He
22 can verify that. At least I expect them to do that.
23 Q. So putting aside whether or not pictures would
24 be -- would be satisfactory for the inspections, when
25 the inspector did show up on April 13th, 2021 and -- you
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1 were there, correct?
2 A. No.
3 Q. The day that the certain sections of the -- of
4 the roof were taken off?
5 A. No, that's not -- wasn't the day when it was
6 taken up.
7 Q. Okay.
8 A. What -- that occurred, which day you said?
9 Q. April 13th, 2021?
10 A. Oh, sorry -- sorry about that. Yes, I was
11 there then.
12 Q. Okay. So when you were there, did you assist
13 in taking up the portions of the -- of the roof --
14 A. Yes.
15 Q. -- covering? Okay. And you were there when
16 Mr. Heffelfinger used the tape measure --
17 A. Yes.
18 Q. -- and showed you the -- the spacing of the
19 nails, correct?
20 A. Yes.
21 Q. Okay. Did you do anything after that
22 inspection once you were notified that the nails weren't
23 appropriately placed --
24 A. Can I -- can I --
25 Q. -- to fix it?
Page 240
1 A. Can I say something? I'm a man of low means.
2 And I just -- I have few grandkids. I just put $5,000
3 -- $9,000 to fix that roof, and the inspector come to me
4 and said, I have to come up with $9,000 to redo this
5 roof. That's $18,000.00. I need time. I asked them
6 for time. Mr. Cicio did give me time, and I went out --
7 finally I got enough money to go and buy the -- the
8 material. I put in my truck. I call inspection and
9 tell them I will be there.
10 When I was on the way coming up, about 8
11 o'clock that morning, 8, not 9, the inspector called me
12 and he said to me, The gentleman said he doesn't want
13 anybody in his house. He doesn't want anybody there.
14 Q. On what date? Do you recall the date of that?
15 A. I -- it's sometime in October. I don't
16 remember the spec --
17 Q. In October of 2021?
18 A. Yeah, October of '21.
19 Q. Okay. So that inspection didn't -- but had
20 you done work to -- to fix the nails between April and
21 October?
22 A. No, I didn't because I went there to do it the
23 next time. The next time -- again, I call again, and
24 when I call them again said, I want to go and fix. The
25 guy said to me, Hey, I want thick pressure treat plywood
Page 241
1 all over the house. I said, Do I have to put up with
2 this again? Thick pressure treat plywood to put down on
3 that house is another ten, twelve grand to do that. I
4 don't have those type of money. That's why I said to
5 myself, the last place I want to come is here. I -- I
6 don't want you guys to determine my livelihood. I
7 don't. That's the last thing I want.
8 Q. Do you need --
9 MR. CHAIRMAN: Mr. Campbell, do you need a
10 minute?
11 MS. FALCE: Yes.
12 THE WITNESS: No disrespect to you guys, but I
13 don't want you to do it. I work hard for my one
14 livelihood, for my one business. I've always been
15 -- I always put that extra effort to please people.
16 My -- my -- my -- my clients, they recommend me to
17 others, and others, and others. That's how I work.
18 That's how I make a living.
19 This thing here has never happened to me,
20 never.
21 So I don't know, ma'am. I'm sorry.
22 MS. FALCE: Just a few more questions,
23 Mr. Campbell. Do you -- do you -- if you need a
24 moment to get some water --
25 THE WITNESS: No, I'm good.
Page 242
1 MS. FALCE: -- just let me know --
2 THE WITNESS: I'm good.
3 MS. FALCE: -- and we'll take a break.
4 BY MS. FALCE:
5 Q. Okay. So there -- there was testimony that at
6 first when the homeowners were contacting you they were
7 told that you were the secretary for Abe Shultz
8 Construction, LLC.
9 A. That's a lie.
10 Q. I understand that you're the -- the owner.
11 A. That's a lie.
12 Q. Why do you think -- did Mr. Brown tell them
13 that?
14 A. I don't know, ma'am.
15 Q. You're not aware of any --
16 A. No.
17 Q -- statements from Mr. Brown?
18 A I have never failed to represent my business.
19 Q. Okay. So at no point in time were you the
20 secretary --
21 A. No time.
22 Q. -- you've always been the owner?
23 A. I always be the owner.
24 Q. Okay. Was there ever anybody else --
25 A. No, ma'am.
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1 Q. -- in your company that they, you know --
2 A. My --
3 Q. -- have been the secretary?
4 A. My -- I alone. My business is just me and me
5 alone, nobody else.
6 Q. Okay. So we served you a subpoena for
7 today --
8 A. Pardon me?
9 Q. -- for your -- we served you with a subpoena
10 today for your appearance here, and it asked for certain
11 documents, if you have them. And so I'm going to ask
12 you to -- if you take up the -- this packet, from the --
13 the County --
14 A. Yes.
15 Q. -- that County package. And if you turn to
16 Page 40, there's handwritten numbers at the bottom. And
17 if you could find Page 40 and let me know when you're
18 there.
19 A. Yeah, I'm here.
20 Q. And it says: "Subpoena Duces Tecum." Do you
21 see that --
22 A. Pardon me?
23 Q. -- page? It says: "Subpoena Duces Tecum"
24 near the top. It's underlined and bold.
25 A. Yeah.
Page 244
1 Q. And your name, right?
2 A. Uh-huh.
3 Q. Did you receive this document?
4 A. Yes.
5 Q. Okay. Did you take a look at the -- the three
6 numbered paragraphs requesting documents?
7 A. Yes.
8 Q. Okay. The first one is, Any and all documents
9 relating to or evidencing the employment relationship
10 between Milton Brown and Abe Shultz Construction, LLC
11 and/or Lindolph Campbell, including but not limited to
12 employment contracts, day labor ticket, staffing or
13 leasing company agreements and pay stubs or canceled
14 checks.
15 A. I have no association with him whatsoever,
16 nothing.
17 Q. Okay. Other than the -- the two to three jobs
18 that --
19 A. Yes.
20 Q. -- that you told us about?
21 A. Yes. Somebody I just know recently.
22 Q. Okay. And in those two to three instances
23 where you did work together --
24 A. Yes.
25 Q. -- putting aside this one for -- did -- you
Page 245
1 were paid a fee -- he was paid a fee --
2 A. I paid him -- I paid him money. I paid him --
3 the first job, I think I paid him like about $500.
4 Another one was 700 and something dollars, yeah.
5 Q. Okay. And what was he paid for?
6 A. Uh?
7 Q What was he paid for?
8 A Well, Mr. Brown is a guy that do handyman
9 work, do small jobs, and I told him that if you come
10 across any jobs that is beyond his pedigree, he should
11 call me and I'll give him a stipend on it, and that's
12 what it takes -- that is what he did.
13 Q. And on those jobs where you paid him the $500
14 or $700 for bringing you the project, did he do work on
15 the project with you?
16 A. No.
17 Q. So he just --
18 A. All he did was to point me to the job. That's
19 all.
20 Q. And then no further work?
21 A. Yeah.
22 Q. Okay. So you have your own -- you would hire
23 other contractors to do those projects?
24 A. Yes.
25 Q. Okay. In this particular instance, when you
Page 246
1 got the call from Mr. Brown, did he continue to work on
2 the project with you?
3 A. No.
4 Q. No?
5 A. Once I take charge of the work, I -- I take
6 charge of it. Apparently though -- I will just add, we
7 were -- when I get a permit on December the 8th, and I
8 start to hunt him down to get my -- I start calling him,
9 you know, to give me the down payment, because I wanted
10 a quarter for the down payment. And he said to me -- I
11 never get it. And I keep calling him. I didn't get
12 him. And after about a couple of weeks, I start getting
13 message from the homeowner, and I stated to the
14 homeowner that I didn't get any money. And that's when
15 this all happened.
16 Q. Okay. So you don't have any documents that
17 would -- that would show the payment that you made?
18 A. No.
19 Q. Or any payments on this project --
20 A. No.
21 Q. -- related to his employment? Okay. Number
22 two, Any and all communications by and between you and
23 Milton Brown regarding the property located at
24 4032 Greenwood Drive, Fort Pierce, Florida 24982 (sic).
25 Do you have any written communication with
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1 Mr. Brown related to this property?
2 A. No.
3 Q. Okay. No text messages?
4 A. I don't -- I -- honestly, with the text
5 messages I'm not sure. I never really check my record
6 on that --
7 Q Okay.
8 A -- you know, but I -- my phones are old so --
9 Q. Did you -- did you have phone conversations
10 with Mr. Brown --
11 A. Yeah, I did.
12 Q -- as well?
13 A Yeah. I still have -- I still have phone
14 conversation because he was supposed to give me $5,000
15 on the job and I didn't get it. So I still -- I still
16 call him up for it.
17 Q. Have you demanded -- well, not -- demanded
18 might not be the right word. But have you filed a -- a
19 lawsuit against Mr. Brown for -- to get your money?
20 A. You know -- you know, ma'am, I -- I've never
21 filed a lawsuit against anybody. And that's my record.
22 You can look it up.
23 Q. Including Mr. Brown?
24 A. Including Mr. Brown.
25 Q. Okay. Number three, Any and all documents
Page 248
1 relating to any insurance claim filed by you, and/or
2 Abe Shultz Construction, LLC for the property located at
3 4032 Greenwood Drive, including, but not limited to
4 Nautilus Insurance Company, Claim No. N00010118937.
5 A. No.
6 Q. You don't have any documents related to that
7 claim?
8 A. I have no claim whatsoever from nobody.
9 Q. Okay. We -- you heard test -- do you recall
10 the testimony earlier related to the release and the
11 insurance claim payment --
12 A. Yes, I heard.
13 Q. -- for the -- for the damages --
14 A. Yeah.
15 Q. Were you involved in that insurance process?
16 A. No.
17 Q. Your insurance company didn't contact you
18 related to this claim?
19 A. They -- they did contact me. They did ask me
20 about it, and I said, when it happened, I wasn't aware
21 of it. The contract I gave her at the 5th of October,
22 it -- this -- those things my understanding happened
23 long before I come into the picture. I told them that.
24 Q. Okay. So then what happened because --
25 A. I don't hear from --
Page 249
1 Q. -- the claim was --
2 A. Obviously, they didn't want to fight the case
3 because, you know, they -- it probably would cost them a
4 lot of money. So I imagine they settled with them, you
5 know, but what the point I'm saying is that -- go on to
6 the next.
7 Q. I didn't want to cut you off. If you'd like
8 to finish your statement, that's fine.
9 So were you asked to sign off on -- on the
10 insurance claim --
11 A. No.
12 Q. -- from your -- from Nautilus?
13 A. No.
14 Q. Okay. Did you point them towards Milton Brown
15 if -- if you thought that it was his project and -- and
16 had --
17 A. I didn't point them to anybody. I just simple
18 tell them I -- that the claim that they're -- they're
19 showing -- and when I submit my application to them was
20 after the fact, because they were saying that they paid
21 Milton Brown what 19 -- $8,000 in September the 19th,
22 and I never heard of them or no -- them or they never
23 get anything from me before October the 5th.
24 Q. So the proposal that's at Tab 6, right before
25 Tab 6 that we looked at already from Abe Shultz
Page 250
1 Construction is for the $11,000 that you say you sent
2 the homeowners --
3 A. Yeah.
4 Q. -- and then you never got anything back?
5 A. Yes.
6 Q. Then why did you --
7 A. When I said --
8 Q. Why did you apply for a permit that you don't
9 have a -- an agreement with the homeowners? I'm just
10 trying to understand the sequence of events.
11 A. Yeah, you know, they -- they -- there are
12 sometime when you work in a community -- because
13 Mr. Brown is new to me, but the guys that I work with,
14 my subcontractors, is not new to those subcontractors
15 and -- and they do tell me that he was in some trouble
16 with the homeowner on it, you know, and he -- he needs
17 my assistance, and I said fine. So I decided to work
18 for them for the cohesiveness of my -- my -- my
19 subcontractors. These people are my friends, put it
20 that way.
21 So I go ahead and I apply for the permit
22 expecting by the time -- to be honest with you, I didn't
23 know that he collect any money, but expecting to be --
24 by the time the permit is approved, I would start
25 getting money. I -- in my dear life, I've never seen a
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1 person get 60, 70 percent of the money up front before a
2 permit being -- being submitted. It didn't occur to me
3 that was possible, you know, because she said they --
4 she gave him $8,000 for my $11,000 job. I'm not saying
5 it's not true, but I'm saying he gave her -- gave him
6 that and -- and -- and I've never seen that before in my
7 dear -- so as a normal person, you know, I -- I submit a
8 permit, and when I submit a permit to the building, I
9 get -- once I get it passed or whatever it is, come
10 back, I go to the homeowner and said, you know, Pay me
11 some money and all that so I can start the work.
12 I never heard of a situation where the
13 homeowner actually pay out the money to the man before
14 he start anything, you know. That was a little unusual
15 to me. Do you understand what I'm saying? So that's
16 why I did it, because I couldn't believe this was
17 possible what goes on.
18 Q. So what you're -- so you're -- if we look at
19 Tab 6, the -- the document before Tab 6 that we already
20 had open, it's the proposal from your company,
21 Abe Shultz Construction, LLC -- I think you were on it
22 already.
23 A. Yeah. Uh-huh.
24 Q. Yeah. Do you see it?
25 A (Indicating.)
Page 252
1 Q Okay. And it's the one with -- it's a copy
2 with the homeowner -- these notes on it,
3 October 5th, 2020, star 31981 star, on the top?
4 A. Uh-huh.
5 Q. Do you see that?
6 A. Uh-huh.
7 Q. We're looking at the same page, right?
8 A. Yeah.
9 Q. Okay. So what you're saying is the job
10 description of work, tear off existing flat roof,
11 replace damaged wood, strip down the deck as required,
12 the existing -- all of -- is that your handwriting?
13 A. No, it's not my handwriting, but that's what I
14 approve.
15 Q. Okay. Whose handwriting is that, do you know?
16 A. To be honest with you, I am not sure. I
17 suspect it may have been Andrew.
18 Q. Mr. Brown?
19 A. Mr. Brown, yeah.
20 Q. Okay. So Milton Brown put that on this --
21 A. I'm being honest, I don't know.
22 Q. Okay. But you didn't write this --
23 A. No, I didn't.
24 Q. -- that's not your handwriting? Okay. But
25 this is the proposal that you --
Page 253
1 A. It's normal proposal --
2 Q -- that you were referencing?
3 A -- that I would normally write.
4 Q. Okay. Is -- is it your handwriting at the top
5 where it says, "Nicki Ann M. Crooks --
6 A No.
7 Q -- 4032?"
8 A. No.
9 Q. Do you know whose handwriting that is --
10 A. No.
11 Q. -- that would have addressed it?
12 A. No.
13 Q. Okay. Is there anyone else that would have
14 drafted this --
15 A. What I did was, I tell you --
16 Q. -- other than Mr. Brown?
17 A. I tell you, the -- the day when he told me
18 about a job in Port St. Lucie -- it's like up here from
19 where I live is like 100-plus miles. So what I did, I
20 just gave him a proposal and I said just jot in these
21 things which, you know -- and he said fine, and he
22 submit it to the lady, these things here. I was
23 expecting to get back a signed -- I was expected to get
24 back a signed document to me and then I would probably
25 sign it, and he didn't. I -- I -- I was working on it,
Page 254
1 and then they were -- actually, they were calling me
2 like really, really often telling me that they were
3 being pressured, you know, and -- you know --
4 Q. When -- when they called you often that they
5 were being pressured by the homeowner insurance company,
6 I think was your testimony --
7 A. Yeah.
8 Q. -- did you ever ask them where the -- the
9 proposal was, ask them why you hadn't seen the -- the
10 signed proposal back?
11 A. You know, that's -- I don't remember. Most
12 likely I would probably ask Andrew, you know, because
13 when -- when she normally called me and ask me something
14 about a job, I generally at the time refer back to
15 Andrew because he was more acquainted with the job than
16 I was, to be honest with you, and I -- I would more
17 inclined to -- to -- didn't want to rock the boat. If
18 you ask me to -- by around they end in October, I
19 figured more or less that Andrew may have collect some
20 money, but I couldn't put my hand on it, you know, so I
21 didn't want to accuse him of anything. I didn't want to
22 say anything to the homeowner and -- to rock the boat.
23 I'll be honest with you.
24 Q Okay.
25 A Other than that -- I --
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Page 255
1 Q. Okay. So did you -- did you see this version
2 of the proposal with the change where it's initialed and
3 dated --
4 A. When --
5 Q. -- to install water solar heater brackets, did
6 you see this before you submitted the application for a
7 permit --
8 A. No.
9 Q. -- with the County?
10 A. I definitely didn't see it.
11 Q. No. Okay. So you submitted the permit
12 application --
13 A. Yes.
14 Q. -- for this work based on information that
15 Mr. Brown gave you?
16 A. Yes.
17 Q. Okay. And he was still involved during the
18 permitting process?
19 A. Mr. Brown --
20 Q. -- with St. Lucie County?
21 A. By -- by the -- by the end of October,
22 Mr. Brown is finally, you know, come silent on this
23 particular job until, you know, I start to communicate
24 with the -- the gentleman and -- and the lady, and we
25 did communicate until the permit -- until the -- until I
Page 256
1 finish the roof.
2 Q. And when this says -- so even looking at the
3 payment schedule that's typed in here, first payment 25
4 percent, second payment 25 percent, third payment 25
5 percent, final 25 percent when finished --
6 A. Uh-huh.
7 Q. -- what -- does finish include final
8 inspection?
9 A. Finish means final inspection, yeah.
10 Q. Okay. And that has not happened on this
11 project yet, correct?
12 A. No. But remember now the lady told me that
13 she wasn't going to pay me a dime.
14 Q. Okay. But under even that provision, all of
15 the money isn't due yet, right --
16 A. Pardon?
17 Q. -- under this proposal because it's not
18 finished --
19 A That is true?
20 Q -- right?
21 A. Yeah.
22 Q. How much work is left to -- to do? How long
23 would it take for you to, once you're on the property,
24 to do the work that needs to be done to fix the roof to
25 bring it to code; do you know?
Page 257
1 A. Yeah, you know -- all right. I went there and
2 they show me the place where I should work. My -- you
3 know, and my understanding is that I'm doing flat roof
4 and nothing more. So then I realize I'm doing slope and
5 I'm doing -- I'm doing -- I'm doing what you call --
6 MR. DIFRANCESCO: Flashing.
7 A -- flashing for different years in the
8 building that I was -- she never said and nobody say
9 anything to me regarding that. And then they look at me
10 again and said they want pressure treat three-quarter
11 inch plywood. The roof need about 80 sheets of plywood.
12 You know, so I realize that it's -- they're beyond
13 reason. They know the situation -- they know that the
14 guy screws me. They know that, because the guy screwed
15 them. I'm sorry. Pardon my language. But I'm just
16 saying they -- they get screwed. I know that. The guy
17 screwed me, too. And all I was there doing was trying
18 to make things work, and I'm trying to work with what I
19 could and -- and they wouldn't cooperate. You know,
20 they're vicious. Not only that, they -- they -- they --
21 they submit claim to my insurance company, and my
22 insurance suddenly I saw they raise it by $2,000 a year
23 over the whole incident. And this is what it done to
24 me, you know. And I know that they know better than
25 that. I know they know that I have nothing to do with
Page 258
1 what they're doing because they choose not to pay
2 Abe Shultz nothing. They didn't write a check and give
3 me. Nothing.
4 Q. If you could quickly just turn to the -- the
5 photographs before Tab 11, we were discussing a little
6 bit earlier that -- the project.
7 A. Uh-huh.
8 Q. Do you see them?
9 A. Yeah.
10 Q. Do you recall when you took these photographs,
11 a date?
12 A. This was between the 12th -- no, between the
13 13th and the 14th, and in my phone it comes up as the
14 14th, but it was actually, you know, text to me, you
15 know, a text that I receive it on the 14th.
16 Q. The 14th of -- of what month?
17 A. Of January.
18 Q. 2021?
19 A. 2021, yeah.
20 Q. Okay. So more -- more than a year ago you
21 took these photographs?
22 A. Yeah.
23 Q. Okay. And did you -- did you submit them to
24 the County --
25 A. No.
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1 Q. -- prior to today?
2 A. I -- I told the guy they were supposed to --
3 based on our agreement, I was supposed to give them an
4 affidavit that -- that -- that -- that stated that --
5 you know, she and I we did talk about it a week before.
6 I would give them an affidavit, and I would give them
7 the pictures, and they would submit that to the County,
8 and they would pay me my money; and the gentleman look
9 at my face and say under his dead body he wouldn't pay
10 anything. And that's what -- that's what he said.
11 So I -- I did argue with him. I did send him
12 a text the next day and I said, Man, I settle for
13 $3,000. Just pay me that, I pay my guys there. And
14 they in turn submit a -- a complaint the very same day,
15 the very same day they did. And they want to look at
16 you and tell you that I -- I was there the Wednesday
17 when I wasn't there -- they lie because it was a
18 Thursday he told me that. It's a -- I -- I'm not really
19 an angry person, just that to deal with this, you know,
20 I can't what get -- I can't understand, honestly. I've
21 never dealt with people like this in all my life.
22 Q. So I just have one or two more questions. So
23 the photographs that appear at Tab 11 of your counsel's
24 presentation to the Board, these are pictures done prior
25 to the April 13th, 2021 inspection?
Page 260
1 A. Between 13th -- most likely was done in
2 January. Most likely this was done January the 13th.
3 Q. Okay. So then Mr. Heffelfinger, then later,
4 after these photographs, inspected the property and
5 found that the nails were not sufficient --
6 A. Yes.
7 Q. -- in that one section. Okay. Do you have
8 any -- there are no updated pictures taken thereafter
9 that could --
10 A. No. I have not -- I have not done anything
11 since. I was never allowed to do it.
12 Q. Okay. All right.
13 MS. FALCE: Nothing further right now, but I
14 reserve the right to -- to ask a few more
15 questions.
16 MR. CHAIRMAN: Yes, Ms. Falce.
17 MS. FALCE: Thank you, sir.
18 THE WITNESS: Okay. Everybody finished with
19 me?
20 MR. CHAIRMAN: Does anybody have questions
21 for, Mr. Campbell?
22 MR. DIFRANCESCO: Oh, sure, I've got some
23 questions.
24 MR. CHAIRMAN: Mr. DiFrancesco?
25 MR. DIFRANCESCO: One second. Let me find my
Page 261
1 notes here.
2 Mr. Campbell, is Mr. Brown a subcontractor to
3 you?
4 THE WITNESS: No.
5 MR. DIFRANCESCO: When he first called you --
6 I mean you already say -- when he first called you
7 and told you about this job, you agreed to pay him
8 a cut for getting you the job, right?
9 THE WITNESS: It was -- I don't know if I said
10 I agree or what, but it was --
11 MR. DIFRANCESCO: You know I'm saying.
12 THE WITNESS: It was understood, yeah.
13 MR. DIFRANCESCO: Did you know he started that
14 job?
15 THE WITNESS: No.
16 MR. DIFRANCESCO: Can you explain to me why
17 you gave him your contract?
18 THE WITNESS: Pardon me?
19 MR. DIFRANCESCO: Can you explain to me why
20 you gave him your contract to get them to sign it?
21 MR. CHAIRMAN: Proposal.
22 THE WITNESS: All right. I -- my -- he has a
23 guy that works for him that is related to them.
24 I'm not sure. I'm just telling what I heard.
25 MR. DIFRANCESCO: The other guy?
Page 262
1 THE WITNESS: Another guy. So he was saying
2 that the other guy is like a go-between between the
3 two of them. So I -- at the time, I think it was a
4 good idea for him and the other guy to deal with
5 it.
6 MR. DIFRANCESCO: And to make money. So you
7 didn't know -- or didn't you even feel that the
8 other guy and Mr. Brown were not licensed to do
9 this type of work?
10 THE WITNESS: I know -- I don't know the other
11 guy. I know Mr. Brown and I suspect the other guy
12 wasn't licensed either.
13 MR. DIFRANCESCO: Okay. So what I'm saying is
14 how did -- how did it come about -- why would you
15 give him your contract and say get them to sign the
16 contract? I mean, you're not -- obviously, you're
17 okay with the contract, correct? You're okay that
18 Mr. Brown made the contract up?
19 THE WITNESS: The contract is fine with me. I
20 have no problem with it. No, no, cross that out.
21 The way I intended it to be structured, I'm fine
22 with it, but there's stuff that the lady -- they
23 add onto it, I wasn't fine with that.
24 MR. DIFRANCESCO: Okay. Why would you -- when
25 Mr. Brown called you and said, I'm having problems
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1 with these people, I need a permit --
2 THE WITNESS: No, no, no. He didn't say --
3 all right. I don't want to get it confused.
4 MR. DIFRANCESCO: I don't want to get confused
5 either.
6 THE WITNESS: Yeah. When Mr. Brown --
7 whatever they say, when Mr. Brown -- when Mr. Brown
8 called me initially about the -- the roof up here,
9 I wasn't aware of the trouble that they were
10 having, but, you know, I was uncertain to a
11 question earlier, why did I do it? And I said I
12 was aware that they had some problem so I -- I just
13 move ahead and -- and work with it, yeah. So what
14 I'm saying, initially, I didn't know. I just
15 talk -- thought it was just a regular roof.
16 MR. DIFRANCESCO: Why would you come 100 miles
17 for such a small job in a town that you weren't
18 licensed in?
19 THE WITNESS: I -- I -- I figure more or less
20 I -- I could make about three grand off it.
21 MR. DIFRANCESCO: I mean, there's probably
22 going to be a cost --
23 THE WITNESS: I -- I -- I --
24 MR. DIFRANCESCO: -- do you know what I mean?
25 THE WITNESS: Yeah. I think I could make
Page 264
1 three grand off it, to be honest with you.
2 Instead I'm going to lose at least 25 grand
3 off it. It's one of those things, man.
4 MR. DIFRANCESCO: I think I had some other
5 notes, but I -- so did you receive -- did you
6 receive any money at all from Milton Brown?
7 THE WITNESS: Nothing.
8 MR. DIFRANCESCO: So he got $8,000 of their
9 money?
10 THE WITNESS: Yes.
11 MR. DIFRANCESCO: And you got nothing?
12 THE WITNESS: And what make it worse, the
13 material that they use on the job was -- it was not
14 up to code.
15 MR. DIFRANCESCO: But you said you were in
16 negotiations with Mr. Brown to give you $5,000 of
17 that money.
18 THE WITNESS: Yeah, I didn't get it.
19 MR. DIFRANCESCO: Well, don't you feel that
20 that's aiding and abetting an unlicensed
21 contractor?
22 THE WITNESS: No.
23 MR. DIFRANCESCO: You don't think so?
24 THE WITNESS: No.
25 MR. DIFRANCESCO: He's not licensed.
Page 265
1 THE WITNESS: But I don't see --
2 MR. DIFRANCESCO: You don't see that he -- he
3 -- he -- he portrayed himself as an unlicensed
4 contractor?
5 THE WITNESS: I -- I -- all right, the way I
6 look at it, to be honest with you --
7 MR. DIFRANCESCO: Sure.
8 THE WITNESS: -- at the time when I was
9 dealing with him, I think of him like a man who
10 know and leads and he gave me the leads up here.
11 That's how I look at it at the time.
12 MR. DIFRANCESCO: How come you didn't -- when
13 you agreed to take over his contract, am I -- am I
14 correct in saying that, that you agreed to take
15 over his contract when you met with them and finish
16 the job?
17 THE WITNESS: Take over the -- pardon me?
18 MR. DIFRANCESCO: Mr. -- Mr. Brown's contract
19 -- Mr. Brown had a contract, although it was under
20 Abe -- under your -- your paperwork. It was on
21 your letterhead. I'm just trying to find out.
22 MR. MATHEWS: It's a proposal, not a contract.
23 MR. DIFRANCESCO: Oh, okay. I'm sorry. Go
24 ahead.
25 MR. MATHEWS: I think you're also -- the way
Page 266
1 you're phrasing your question it's as if he -- he's
2 taking over that contract. I would use a different
3 choice of words, but I guess he can answer the
4 question.
5 MR. DIFRANCESCO: The reason why I asked that
6 is because he didn't -- he didn't give them -- when
7 he met with them, he didn't give them a proposal.
8 THE WITNESS: When I --
9 MR. DIFRANCESCO: He said -- he said --
10 THE WITNESS: No, no. Can I -- can I --
11 MR. DIFRANCESCO: -- he would take $3,000 more
12 to finish. That's my understanding and that's what
13 makes me confused.
14 THE WITNESS: Yeah, yeah. Where the confusion
15 is, when I met them for the first time was the 1st
16 of January.
17 MR. DIFRANCESCO: Okay.
18 THE WITNESS: You understand what I'm saying?
19 MR. DIFRANCESCO: Yes.
20 THE WITNESS: That's when I met them for the
21 first time.
22 MR. DIFRANCESCO: After you pulled the permit?
23 THE WITNESS: After I pulled the permit, yes.
24 MR. DIFRANCESCO: So you pulled the permit
25 without going to look at the -- at the job?
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1 THE WITNESS: Well, to be honest with you, the
2 guy told me he measured it up and it was
3 18 squares, so I take his word for it.
4 MR. DIFRANCESCO: What guy?
5 THE WITNESS: Huh?
6 MR. DIFRANCESCO: What guy?
7 THE WITNESS: Mr. Brown.
8 MR. DIFRANCESCO: Mr. Brown?
9 THE WITNESS: Yeah. I did take his word.
10 I'll be honest with you that's a mistake.
11 MR. DIFRANCESCO: He didn't tell you that he
12 started the job?
13 THE WITNESS: No, he didn't tell me he started
14 the job.
15 MR. DIFRANCESCO: Then why did you pull the
16 permit?
17 THE WITNESS: Huh?
18 MR. DIFRANCESCO: Why did you pull a permit?
19 THE WITNESS: Why did I pull a permit?
20 MR. DIFRANCESCO: In -- in December, why did
21 you pull a permit in December?
22 THE WITNESS: Because I -- I -- I correspond
23 with them, talk to them over the phone, whatever,
24 and I said if job was available. Mr. Brown told me
25 that, you know, these people he knows and good. I
Page 268
1 was expecting that in December when the permit was
2 completed they would have given me my two 25
3 percent. That's what I was expecting.
4 MR. DIFRANCESCO: So when they --
5 THE WITNESS: Pardon me?
6 MR. DIFRANCESCO: Okay. Deduct the 25
7 percent.
8 THE WITNESS: No, no, I said I was expecting
9 two 25 percent.
10 MR. DIFRANCESCO: You were expecting 25
11 percent?
12 THE WITNESS: No, two 25 --
13 MR. DIFRANCESCO: But you didn't give them a
14 contract.
15 THE WITNESS: I -- I sent them a proposal.
16 MR. DIFRANCESCO: You did send a proposal to
17 them?
18 THE WITNESS: Yes. I --
19 MR. DIFRANCESCO: Not the same one, a
20 different one?
21 THE WITNESS: No, no, no, no. I -- this one
22 here I sent them.
23 MR. DIFRANCESCO: You sent the same one?
24 THE WITNESS: Yeah. I sent the proposal.
25 MR. DIFRANCESCO: But that contract was signed
Page 269
1 -- not signed by you, was it?
2 THE WITNESS: No.
3 MR. DIFRANCESCO: It was signed by Mr. Brown,
4 isn't it?
5 THE WITNESS: Nobody signed the contract
6 because where the section --
7 MR. CHAIRMAN: Proposal.
8 THE WITNESS: -- the lady --
9 MR. DIFRANCESCO: The proposal. I apologize.
10 THE WITNESS: Yeah.
11 MR. DIFRANCESCO: I'm sorry.
12 THE WITNESS: But the proposal itself, you
13 know --
14 MR. DIFRANCESCO: You didn't send them a
15 proposal.
16 THE WITNESS: I sent her a proposal.
17 MR. DIFRANCESCO: This proposal?
18 THE WITNESS: Yeah, but it was not signed by
19 me.
20 MR. DIFRANCESCO: Okay.
21 THE WITNESS: It was not signed period.
22 MR. DIFRANCESCO: Okay. And then she sent you
23 stuff with a bunch of writing on it --
24 THE WITNESS: Yes.
25 MR. DIFRANCESCO: -- for you to sign?
Page 270
1 THE WITNESS: Yes.
2 MR. DIFRANCESCO: I kind of think there's a
3 bunch of shady stuff going on on both sides, I'll
4 be honest with you.
5 THE WITNESS: No, no, no, no. It's -- no,
6 what I'm saying to you, I believe that -- no, no,
7 in my mind, a lot of shady stuff goes on. You
8 understand what I'm saying?
9 MR. DIFRANCESCO: Yeah, I see it on both
10 sides.
11 THE WITNESS: You know, I -- I -- I -- the
12 problem is with -- all right. Put it this way, I
13 don't want to blame people. Maybe I'm a trusting
14 guy or probably a little too trusting. You
15 understand what I'm saying?
16 MR. DIFRANCESCO: You're probably right.
17 THE WITNESS: You know, so it's difficult for
18 me to comment by -- the lady and Mr. Brown, but the
19 point I'm getting at, they know what they were
20 doing. Do you understand? They know that I'm an
21 innocent man in the mids here. They know that, you
22 know. And they know that once I found out the
23 issue, I decide in mind to step forward and correct
24 the issue, which I did. And I was anticipating
25 that they would have given me the $3,000 that they
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1 promised they would.
2 MR. CHAIRMAN: See now, Mr. Campbell, I think
3 that that's where the disconnect happens. You feel
4 in your heart that you actually completed what you
5 had said you were going to do, when in fact, you
6 did not pass a final inspection, you don't have an
7 approved inspection on that entire project, you did
8 not finish that project based on this proposal that
9 you just said you sent them, which is in writing --
10 THE WITNESS: I agree with --
11 MR. CHAIRMAN: -- you started the project --
12 and by the way, you are the license holder in the
13 State of Florida. It is your responsibility to
14 make sure that that job is completed, both through
15 the County -- now, if you guys want to do a civil
16 matter with money, we don't involve civil. We are
17 only here to simply hear the facts of the case.
18 How did we get to this point? I believe firmly in
19 my mind that Milton Brown is a sales guy for you.
20 He represented based on your paperwork, your
21 documentation, your proposal.
22 I've been in business for 22 years. I've had
23 a license for 13 years. I'm going to be darned if
24 I'm going to give anybody a proposal that's not
25 representing me to go out there and sell for me,
Page 272
1 let alone in a municipality that I'm not licensed
2 in. So I think that's probably where the
3 disconnect comes in that you feel in your heart of
4 hearts you were trying to do a favor. Am I correct
5 when I say that?
6 THE WITNESS: So the only problem with what
7 you said, that proposal was given after Mr. Brown
8 collect the money. Do you understand -- do you
9 understand what I'm saying? It's not -- in other
10 words, it's not before he collect. It's after he
11 collects the money. That's when the proposal was
12 sent. I was duped.
13 MR. CHAIRMAN: I have no further questions.
14 MR. JERGER: I've got a question for
15 Mr. Campbell or maybe some advice for you. I feel
16 your compassion. I really feel like you're sorry,
17 and I really appreciate you bringing your attorney
18 here today. Most of the time, guys don't.
19 However, you got caught up. You sent a guy, you
20 hired a guy to do a job for you. It just so
21 happened, he sent the proposal and did some of the
22 work unlicensed, where he was wrong. If you're
23 going to make a business, you go to them yourself.
24 You don't send somebody, because you are the
25 responsible party. That's why you're here and
Page 273
1 Mr. Brown isn't. I feel your passion, but we're
2 only here to decide, did you send somebody there to
3 do work unlicensed.
4 THE WITNESS: No, sir.
5 MR. JERGER: I'm not here to decide if you
6 gave a $5,000 -- six -- that's not my job. My job
7 is to decide, did you send somebody on a job site
8 with your name on it to do work that wasn't
9 licensed. That's my only decision here.
10 THE WITNESS: I'm saying I didn't do that.
11 That's what I'm saying.
12 MR. JERGER: Well, apparently, our staff found
13 that out, but I commend you for bringing your
14 attorney here trying to straighten it out, and I do
15 believe that you want to get this together;
16 however, the money is not there. It's gone. Why
17 did they give him the money? Because you sent him
18 there to get the money from them.
19 THE WITNESS: No, I didn't do that.
20 MR. JERGER: According to your proposal --
21 THE WITNESS: No, sir. What I'm saying --
22 MR. JERGER: Your name is on it though.
23 THE WITNESS: Yeah, yeah -- that --
24 MR. JERGER: Let me finish. Let me finish.
25 THE WITNESS: That was done -- that was
Page 274
1 done --
2 MR. CHAIRMAN: Mr. Campbell, excuse me, sir,
3 please.
4 MR. JERGER: Let me finish. Let me finish.
5 The reason why you're so passionate is because
6 Mr. Brown took your money and didn't give it to
7 you. It's not their fault. It's your fault to go
8 to them and make the connection. Going forward, if
9 you're going to do that, you make the connection
10 with the homeowners and that way all the middleman
11 is out of the way. And also, make sure whoever you
12 hire, they're licensed. That's my only job is to
13 decide that.
14 I'm not here to get their money back. I'm not
15 here -- I would love for you to make it right with
16 them. I would love to see that, especially before
17 the rainy season, because if it doesn't happen,
18 they're going to have more issues. So if you could
19 make that right, that'll make me real happy. And
20 that's my only job here is to decide did you send a
21 unlicensed contractor to do work. Apparently you
22 did, intentionally or unintentionally, we don't
23 know that. But that's the only thing we're here to
24 decide.
25 Thank you for your compassion. I really feel
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1 it, but our job is just to decide did you do that.
2 MR. CHAIRMAN: You know, Vice Chairman Jerger,
3 I really appreciate that as well. And I think that
4 if you look back on County staff's notes, and I've
5 got timelines through here, that they were provided
6 back in April, the opportunity to make it right and
7 he asked for an extension til July to get the
8 monies. Then another extension was asked until
9 October to get the monies, and then here we are in
10 January for the Board meeting -- or February for
11 the Board meeting, and I firmly believe he had
12 every ample opportunity to make the right business
13 decision, not personal, not financial, but business
14 decision as licensed contractors, as we all
15 licensed contractors have to make a proper business
16 decision sometimes that we don't always like
17 financially to avoid situations like this.
18 MR. MATHEWS: Mr. Leonard, I'm a little
19 concerned that the Board is airing decisions and
20 they haven't heard the entire case. They haven't
21 allowed me to cross examine this witness. So I
22 urge you all to have an open mind --
23 MR. CHAIRMAN: Absolutely.
24 MR. JERGER: We are.
25 MR. CHAIRMAN: Absolutely, that's what we're
Page 276
1 here for. Oh, no, no one's made a final decision.
2 MR. JERGER: Nope.
3 MR. MATHEWS: It seems like there have been a
4 number of opinions that have been --
5 MR. CHAIRMAN: I'm stating facts.
6 MR. SAMPSON: I do have one question. Was
7 there anything produced as far as paperwork, 1099,
8 subcontractor agreements, any -- any sort of
9 declaration as far as with the, quote,
10 subcontractors, unquote pertaining to -- excuse me,
11 Mr. Brown or any of your other subcontractors?
12 Currently listed, you're listed only as a
13 Workmans' Comp exempt, and unless those other
14 companies can provide some sort of Workmans' Comp
15 insurance certifications for you -- I mean, then
16 that's part of the crux of the issue there.
17 THE WITNESS: I -- I didn't hear what he said
18 good, but if I -- I -- I think he was talking about
19 1099.
20 MR. SAMPSON: For -- for your subcontractors,
21 Mr. Brown --
22 THE WITNESS: I have no --
23 MR. SAMPSON: -- or any of the other
24 subcontractors that you use --
25 THE WITNESS: I -- I -- I --
Page 277
1 MR. SAMPSON: -- on this project in
2 particular; is there any --
3 THE WITNESS: -- I never considered Mr. Brown
4 as a -- a worker for me. It's never occurred to me
5 that I have to give my -- I paid him a couple of
6 hundred -- when I say couple, 575, whatever,
7 dollars over a period of time, you know, so I never
8 think I should give him a 1099 for that.
9 MR. CHAIRMAN: Mr. Campbell, how did you pay
10 him?
11 THE WITNESS: I just pay him cash.
12 MR. CHAIRMAN: Does staff have any more
13 questions or the Board have any more questions?
14 MR. DIFRANCESCO: Mr. Campbell, when your
15 workers -- when you showed up with your workers to
16 do the job, Ms. Crooks said that they were the same
17 workers that were working with Mr. Brown. Are
18 they --
19 THE WITNESS: Subcontractors.
20 MR. DIFRANCESCO: -- subcontractors to you?
21 THE WITNESS: Yes, sir.
22 MR. DIFRANCESCO: Are they licensed
23 subcontractors?
24 THE WITNESS: Yes, sir. At the time for sure
25 this guy Warren Byrd that she talks about, he's --
Page 278
1 he's a licensed to, you know, do things like remove
2 shingle off a house, peel off, dry-in, things like
3 that.
4 MR. DIFRANCESCO: You -- you think that Warren
5 is a licensed roofer?
6 THE WITNESS: No, he's not.
7 MR. DIFRANCESCO: He's not?
8 THE WITNESS: No.
9 MR. DIFRANCESCO: But you hired him as a
10 subcontractor?
11 THE WITNESS: Yes, but for the specific
12 purpose that he -- he can do, for certain areas.
13 You don't really need a roofer to do tear off.
14 MR. DIFRANCESCO: You don't?
15 THE WITNESS: No, you have a special license
16 for that.
17 MR. DIFRANCESCO: You have a special license
18 to tear off roofs?
19 THE WITNESS: Yeah.
20 MR. DIFRANCESCO: Apparently I was unaware of
21 that. Okay.
22 MR. CHAIRMAN: A state license for roof
23 removal?
24 THE WITNESS: Here's what -- I don't remember
25 it was a state license or what, to be honest with
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1 you, but I did check through before I started work.
2 MR. DIFRANCESCO: Maybe Ms. Waters can fill us
3 in on that or Mr. Johnson.
4 MS. WATERS: Danielle, can you help? Special
5 license to remove --
6 MS. WILLIAMS: As far as it has to be a
7 roofing contractors to remove anything on the roof.
8 MR. CHAIRMAN: Can we ask Mr. Cicio?
9 MR. CICIO: Yes. In my knowledge, they have
10 to be a state certified roofing contractor to even
11 take off roofing material.
12 MS. WATERS: Yes.
13 THE WITNESS: My understanding is that they --
14 they -- they -- they have a special provision for
15 them, for a person who do tear off. Well, I mean,
16 you can contradict me honestly. I will have to go
17 back and do research on it, you know, but I --
18 that's my understanding.
19 MR. CHAIRMAN: Does anybody on the Board have
20 anymore questions for Mr. Campbell?
21 MR. SAMPSON: Did you receive any certificates
22 of insurance for liability from any of your
23 subcontractors --
24 THE WITNESS: No.
25 MR. SAMPSON: -- or do any due diligence?
Page 280
1 THE WITNESS: They have their own insurance.
2 MR. SAMPSON: But did -- did you verify it as
3 the prime contractor?
4 THE WITNESS: I -- you know, I -- I used to
5 have a more diligent -- I've not done it for the
6 past year, to be honest with you, but it's
7 something that I normally do.
8 MR. DIFRANCESCO: Mr. Campbell, why did you
9 allow your insurance company to pay them $14,000?
10 I would have been kicking and fighting the whole
11 way.
12 THE WITNESS: I -- I -- to be honest with you,
13 I -- I -- I wasn't aware of that.
14 MR. DIFRANCESCO: If you had no liability --
15 you were unaware that they -- that they -- they
16 paid those people $14,000 to --
17 THE WITNESS: Yeah, I do.
18 MR. DIFRANCESCO: Really?
19 THE WITNESS: Yeah. It's the first time I'm
20 learning about it.
21 MR. DIFRANCESCO: I'd kind of go back and see
22 them also.
23 THE WITNESS: One thing I can say though, back
24 in November they -- they increase my -- my
25 insurance by over $2,000.
Page 281
1 MR. DIFRANCESCO: How long have you been a
2 licensed contractor? Not a roofing contractor.
3 You said four years for a licensed roofing
4 contractor?
5 THE WITNESS: I live in Florida here for --
6 for 16, 17 years now, and I have a license, general
7 building contractor's license from '09.
8 MR. DIFRANCESCO: You have a building
9 contractor from '09?
10 THE WITNESS: Yeah.
11 MR. DIFRANCESCO: And then you recently four
12 years ago got the roofing license?
13 THE WITNESS: Yeah.
14 MR. DIFRANCESCO: Okay. If I may ask staff,
15 Mr. Cicio --
16 MR. CICIO: Yes.
17 MR. DIFRANCESCO: -- which license of his is
18 on the line here?
19 MS. BARBIERI: Mr. Chairman, at some point,
20 Mr. -- his attorney has the right to -- I don't
21 know if he's going to cross him or if he's going to
22 reserve the right to redirect. So before we start
23 going off to other people --
24 MR. CHAIRMAN: I apologize. Again, you're
25 going to have to keep me in line here. I
Page 282
1 appreciate that.
2 MS. BARBIERI: Yeah, so I -- I think if we're
3 -- if we're done with -- with the contractor here,
4 then maybe his attorney -- I'm not sure how he
5 wants to handle it, but he should have an
6 opportunity.
7 MR. CHAIRMAN: Okay. I appreciate it,
8 Ms. Barbieri.
9 MR. DIFRANCESCO: Okay. I'm done.
10 MR. CHAIRMAN: I apologize. You know, keep us
11 on track here, Mr. Mathews.
12 Any other questions from the Board for
13 Mr. Campbell?
14 MR. DIFRANCESCO: I was just told to shut up
15 so --
16 MR. CHAIRMAN: That's basically what we were
17 told.
18 REDIRECT EXAMINATION
19 BY MR. MATHEWS:
20 Q. Mr. Campbell, how many roofs have you
21 installed or repaired in the past four years?
22 A. Maybe around 400.
23 Q. Out of those 400, how many have -- how many
24 roofs have you had problems with?
25 A. Zero. Well, this one here. This is the only
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1 one.
2 Q. And are you -- do you have a rating with the
3 Better Business Bureau?
4 A. Yes, I do.
5 Q. And what is that rating?
6 A. A plus.
7 Q. Have you ever had an instance where there has
8 been a failure in your work that you had to do a repair?
9 A. Yes, I do.
10 Q. Do you honor that --
11 A. Of course I do.
12 Q. -- work is complete?
13 A. Yeah, I do. I did.
14 Q. You testified that you met Andrew Brown
15 approximately three months prior to the Crooks' job?
16 A. Yeah.
17 Q. And is AB -- is Andrew Brown, to your
18 understanding, the person who is AB Handyman?
19 A. AB Handyman, yeah.
20 Q. And is it your understanding that there was a
21 relationship between AB Handyman or Andrew Brown and the
22 homeowners in this case?
23 A. Yes.
24 Q. And what was the connection there?
25 A. I think the husband had a guy -- my
Page 284
1 understanding is that the husband is the guy's brother
2 or something like that.
3 Q. All right. And in your dealings with
4 Andrew Brown, you agreed to pay him some sort of a
5 finder's fee --
6 A. Yeah.
7 Q. -- if he referred roofing jobs to you?
8 A. Yes. Uh-huh.
9 Q. And if that happened, you were the one
10 performing the work, right?
11 A. Yes, sir.
12 Q. Did you authorize him to provide work on his
13 own?
14 A. No.
15 Q. When you provided him with a blank proposal,
16 was it for the purpose of estimating a job?
17 A. Yes, sir.
18 Q. Was it your understanding -- let me withdraw
19 that.
20 Did you instruct Mr. Brown that if he
21 submitted a proposal it should be provided to you?
22 A. I -- I didn't hear what you said clearly.
23 Q. If a proposal was -- was provided to a client,
24 were you also to receive a copy of it?
25 A. I -- it's -- I always have to sign before the
Page 285
1 proposal itself turn into a contract.
2 Q. In -- for the Crooks' proposal, I didn't -- I
3 heard you say that you thought the job was about a
4 certain amount of square feet; is that correct?
5 A. Yes, sir.
6 Q. And is that how you base -- is that how you
7 come up with an estimate or a proposal now --
8 A. Yes.
9 Q. -- for a job?
10 A. Uh-huh.
11 Q. Was the amount of $11,000, was that consistent
12 with the number of square feet that was contemplated
13 that was being -- that was meaning to get reroofed?
14 A. No.
15 Q. Was it -- was it consistent with what
16 Mr. Brown had told you was the amount of the this roof?
17 A. No.
18 Q. No. So it was off by how much?
19 A. It was off by about approximately 400 square
20 foot.
21 Q. In the case of the Crooks' house or project,
22 did Andrew Brown ask you to pull a permit for him?
23 A. No.
24 Q. Did you ever provide Andrew Brown with an
25 Abe Shultz business card?
Page 286
1 A. No.
2 Q. Did he have a work truck of yours?
3 A. No.
4 Q. Did he have any clothing that had your name on
5 it?
6 A. No.
7 Q. Were you surprised to find out that
8 Andrew Brown was performing work under a proposal, an
9 Abe Shultz proposal?
10 A. Yeah, I was. I didn't even -- I didn't know
11 -- to be honest with you, I didn't even know that he had
12 done it until recently.
13 Q. Let's look at the proposal at Tab 6. Did
14 there come a point in time when you came to learn about
15 the proposal?
16 A. Where are we?
17 Q. Yes, Tab 6. Are you looking at the proposal
18 dated September 21?
19 A. If I -- pard -- what is it?
20 Q. I -- I want to just get you to the exhibit
21 first --
22 A. Uh-huh.
23 Q. -- the proposal --
24 A. Yeah.
25 Q. -- Tab 6, are you there?
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1 A. Yeah.
2 Q. Did there come a point in time when you
3 learned about this proposal?
4 A. Yes.
5 Q. Did you have a discussion with Ms. Crooks
6 about this proposal or the homeowners?
7 A. Yes.
8 Q. Did you agree to perform the work that was
9 above where the signature was?
10 A. No.
11 Q. No?
12 A. No. That's why I wouldn't sign it. And could
13 I say something? She has five-years warranty here.
14 Normally, I would give 15-years warranty for a job like
15 this. I choose not to sign it because of the stuff that
16 all here. And if I do the work, I would give her a
17 15-years warranty.
18 Q. When you did come to learn about this proposal
19 and that money had been accepted by Andrew Brown, how
20 were you trying to remedy the situation?
21 A. How?
22 Q. How were you trying to remedy the situation?
23 Were you going -- were going to make good and try -- try
24 to put the roof on?
25 A. Yes, I did. I went up there with my
Page 288
1 subcontractors and I put the roof on.
2 Q. So out of an accommodation -- would it -- is
3 this consist -- or is this accurate, that as an
4 accommodation to the homeowner, even though you didn't
5 agree with the proposal for the -- for the roof, you
6 agreed to repair -- to replace the flat roof?
7 A. Yes. And not only that, sir, I -- I would
8 have done it before, but because when I send my crew up
9 there, they would not allow me to do it. And when I
10 start arrange them a second time, they said to me they
11 want me to reply the whole thing. And I said these
12 things, I said to myself -- I called this gentleman here
13 and tell him that these people are not being reasonable.
14 There's no way I'm -- I can afford to reply the whole
15 house. I told him that, and I said arrange -- you know,
16 let me talk to the Board, you know, and that's when I
17 choose to come here because I -- I -- I rest my -- I
18 want to rest my case on you guys because, you know, I --
19 there's no way I can afford to put 80 sheets of
20 three-quarter inch pressure treat ply on top of your
21 roof.
22 Q. I asked you a different question.
23 When you first became aware that there was a
24 proposal with your company's name on it.
25 A. On January the 1st, 2021.
Page 289
1 Q. That's when you became aware of this proposal?
2 A. Yes, sir.
3 Q. And -- the written proposal?
4 A. That's the written proposal.
5 Q. And -- but prior to that, you'd pulled a
6 permit?
7 A. Yeah.
8 Q. And that's -- on or about January 1, you came
9 to learn that Mr. Brown had been paid $8,000?
10 A. Yes.
11 Q. But you agreed to -- to do the work anyway?
12 A. Yes.
13 Q. And part of your thought process was that
14 Brown had received a certain amount of money, right?
15 A. Yeah.
16 Q. He received $8,000?
17 A. Uh-huh.
18 Q. And your thought process was he's going to pay
19 you $5,000, right?
20 A. Well, at -- at the time, I was trying to
21 figure out something that makes sense from it, and, you
22 know, so I -- I was just saying if they have $3,000, if
23 I'm doing that roof for 18 square foot, 1,800 square
24 foot, you know, I probably could survive by that, by --
25 by $8,000, even though I wouldn't make any money there.
Page 290
1 So --
2 Q. So you were trying to cover your costs?
3 A. Yeah, that's what I was trying to do.
4 Q. So you thought that if you could get $5,000
5 back from Brown, because he didn't earn it --
6 A. Yeah.
7 Q. -- and you could get another $4,000 --
8 A. $3,000.
9 Q. -- $3,000 from the property owner --
10 A. Uh-huh.
11 Q. -- you'd -- you'd then come close to covering
12 your costs?
13 A. Yeah.
14 Q. And that was maybe at that point going to be a
15 painful lesson to you.
16 A. It is -- it would have been a painful lesson,
17 yes.
18 Q. And you personally showed up on -- on the
19 project and worked on that roof?
20 A. Yes, sir. I spent two days there.
21 Q. Did you also personally pay for the materials
22 used on that project?
23 A. The what?
24 Q. Did you personally pay for the materials used
25 on that project?
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1 A. Yes, sir.
2 Q. Did you personally pay for workers to stay in
3 a hotel room?
4 A. Yes, sir.
5 Q. So you didn't make money on that project, it
6 cost you money?
7 A. It cost me a lot of money.
8 Q. What are you prepared to do to try to make
9 this right?
10 A. I -- I just want to build the roof in a legal
11 way, in other words, up to code and nothing more. I
12 don't want somebody telling me that they need
13 three-quarter inch pressure treated ply.
14 Q. When you went back to the job site in
15 September or October --
16 A. October.
17 Q. -- October --
18 A. About the middle October, the 12th of October,
19 somewhere around the time.
20 Q. -- did the homeowners request that you perform
21 additional work?
22 A. No. I -- I didn't go on the job site. What
23 had happened, I called for inspection, and the inspector
24 -- I realized I was running a little late because I have
25 my truck with the material in it. And when I called the
Page 292
1 inspector, the inspector said he went there and the
2 homeowner said that he's not allowed on the compound.
3 And I said okay. By the time, my crews were already
4 there and I was like around 20 minutes away; and when
5 the homeowner said that, I called Mr. Cicio and I
6 explain the situation to him. He said all right he will
7 take charge of it, you know. So he call them up so --
8 he did call them up and he did rectify that and he call
9 me again and said, you know, the way is clear for me. I
10 have a conversation with the guy and he said to me that,
11 you know, that I -- I need to fix the side of his house,
12 the siding, something that was not on the contract. And
13 I -- I -- I have no problem doing it anyway, and -- but
14 the big turned off was to reply the whole place. I
15 couldn't. I need a permit for that. That's the first
16 thing, and it's -- it's expensive.
17 Q. So is it your testimony that the homeowner
18 placed additional demands upon you that --
19 A. Yes.
20 Q. -- were unreasonable enough that you could not
21 go back and complete the job?
22 A. Yes, sir.
23 Q. But there was a period of time in which there
24 was a delay because you were trying to earn some money
25 for the materials; is that correct?
Page 293
1 A. Yes, sir.
2 Q. Part of this proposal at Exhibit 6 says:
3 "Install solar heater brackets." Is that something that
4 --
5 A. I -- I'm not in that kind of business, sir.
6 Q. It says: "Replace damaged shingles and
7 damaged wood." Do you know what that is, what that
8 referred to?
9 A. I -- I -- I -- my understanding from the
10 discussion I had with her, both of them, I was only
11 supposed to do the flat.
12 Q. Okay. And the other portion it says: "Knock
13 out ceiling and drywall, replace and seal." Do you have
14 experience with drywall?
15 A. Yeah. I'm a contractor.
16 Q. Is that something that you can do?
17 A. Yes, but I don't want to leave Fort Lauderdale
18 to come up here to do that, you know, because that's
19 like a little -- I -- I -- I -- I don't mind -- at the
20 time though, at the time I tried to reason with them
21 that I will do it. I would pay to get it done. And
22 I -- I said to him take $1,400 to get it done and he
23 said no, and I said to him just give me the rest of the
24 money after that. And he said no. But it's not
25 something I particularly would want to do, to be honest
Page 294
1 with you.
2 Q. At this point, you're prepared to go back to
3 the home, remove the coverings on there, renail the
4 sheathing?
5 A. I'm willing to bring the house up to code.
6 Q. Just -- just the flat roof portion, correct?
7 A. Just the flat roof portion.
8 Q. And I still don't know about whatever flashing
9 issues there are. I don't know where they are, but if
10 it's not in that immediate vicinity, then it's not
11 something that you were initially -- it was discussed
12 that you would do?
13 A. I -- I -- I'm in agreement with them to do the
14 flat roof. I -- I pull a permit to do the flat roof and
15 I -- if -- I don't want to touch a can of worm. If it's
16 something that I can do, I -- that's not going to take
17 much out of me, I would do it, you know. Because like
18 for example, the flashing, there's a slope on the
19 flashing running to the side of the -- of -- of plastic
20 roof house and all of that. And sometime you don't know
21 what you're -- because water been running there all the
22 time. If you touch it, I'll own it, you know. So when
23 she explained it to me, I said that's not a part of my
24 contract. That's not part of -- my -- my agreement.
25 MR. DIFRANCESCO: I totally understand what
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1 you're talking about, because once that's -- once
2 you get up that wall, and the wall is rotten in the
3 back where the flashing is --
4 THE WITNESS: Yeah.
5 MR. DIFRANCESCO: -- which is probably where
6 it's leaking because you can see in the pictures
7 that the house is an older house, and there is
8 rotten siding on the side of the house --
9 THE WITNESS: Yes.
10 MR. DIFRANCESCO: -- and I can see how that
11 would be -- would not be part of your contract.
12 THE WITNESS: Yeah.
13 MR. DIFRANCESCO: But I can also see where
14 that has to be repaired in order to stop the rain
15 from going down the back of the flashing.
16 THE WITNESS: I mean --
17 MR. DIFRANCESCO: We've -- I've done roof
18 myself also, and we -- so you know what I'm talking
19 about --
20 THE WITNESS: Yeah.
21 MR. DIFRANCESCO: -- but I can see how that
22 would not be a part of your contract --
23 THE WITNESS: Yes.
24 MR. DIFRANCESCO: -- to replace any rotten
25 siding so that you can hide the flashing --
Page 296
1 THE WITNESS: Yeah, that's --
2 MR. DIFRANCESCO: -- and seal the flashing
3 properly.
4 THE WITNESS: That's the point I'm saying.
5 MR. DIFRANCESCO: Yeah, you can open up a can
6 of worms, you can just keep going.
7 THE WITNESS: Exactly. But you know, it's not
8 that I wouldn't go there and it's leaking and I
9 stop the leak. You understand what I'm saying now,
10 but I do not want to take that as a responsibility
11 to -- to bring to code then.
12 MR. DIFRANCESCO: They would have the burden
13 -- they -- they would have to bear the burden of
14 the extra costs --
15 THE WITNESS: Yes.
16 MR. DIFRANCESCO: -- of the -- whatever siding
17 and rotten wood that has to be repaired.
18 THE WITNESS: Yes.
19 MR. DIFRANCESCO: Fair enough. Right?
20 THE WITNESS: Yes. And they would have to
21 understand that if they want pressure treated
22 three-quarter inch ply --
23 MR. DIFRANCESCO: No, that's -- even from
24 sitting where I'm at, that's not going to happen.
25 THE WITNESS: Thanks.
Page 297
1 BY MR. MATHEWS:
2 Q. Mr. Campbell, did Abe Shultz Construction
3 intentionally disregard the building code?
4 A. No -- no, sir.
5 Q. Did you knowingly file -- request a permit
6 from St. Lucie County for the work at 4032 property with
7 the intention that Andrew Brown would do that --
8 A. No, sir.
9 Q. Was it your intention that you were going to
10 do that work?
11 A. Yes, sir.
12 Q. Is that the work that you performed in
13 January?
14 A. Yes, sir.
15 Q. And did you know about the prior work being
16 done?
17 A. No, sir, I didn't.
18 MR. MATHEWS: I have no additional questions
19 at this time. Thank you.
20 MR. CHAIRMAN: Thank you, Mr. Mathews.
21 Ms. Falce, do you have any follow-up?
22 MS. FALCE: No.
23 MR. DIFRANCESCO: I would like to ask
24 Ms. Crooks a question. And are we not going to
25 hear any testimony from her husband? Does the
Page 298
1 attorney for Mr. Campbell not want to know
2 anything?
3 MR. MATHEWS: Actually, I do have some
4 questions. I'm going to have some questions for --
5 MR. DIFRANCESCO: I -- I -- I -- sorry, I have
6 a question for Ms. Crooks because she said that --
7 MS. BARBIERI: She needs to get to a
8 microphone and I don't know if --
9 MR. CHAIRMAN: I don't know if the Board --
10 MS. BARBIERI: -- if we're done with
11 Mr. Campbell, then I guess --
12 MR. CHAIRMAN: Anybody on the Board have any
13 questions for Mr. Campbell?
14 MS. BARBIERI: Yeah, but I don't know -- I
15 don't know if, before the Board, if the attorneys
16 have any other people they're planning on
17 presenting.
18 MR. MATHEWS: It's still her case. So she has
19 rested.
20 MS. FALCE: So let -- the County staff doesn't
21 have any further testimony that they wish to bring
22 to the Board; however, at this time, I do reserve
23 the right if additional facts are brought out that
24 I do need to follow up with and call -- recall a
25 witness or call her husband, I -- I may need to do
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1 that, but right now, we -- we've presented our --
2 our case.
3 MR. CHAIRMAN: Okay.
4 MS. FALCE: Thank you.
5 MR. CHAIRMAN: Thank you.
6 Ms. Crooks, do you want to come up to the
7 podium, please?
8 MR. MATHEWS: I was going to call Mr. Roberts
9 up.
10 MR. CHAIRMAN: Oh, well, he -- how does this
11 work, Ms. Barbieri, we have a question for
12 Ms. Crooks even though it's resting?
13 MR. MATHEWS: Oh, sorry, you're question is
14 for Ms. Crooks. Okay.
15 MR. CHAIRMAN: Yes.
16 MS. BARBIERI: Yeah, normally if you're
17 sitting like a judge, you ask the questions when
18 they're up here, but they don't normally recall
19 them.
20 MR. CHAIRMAN: Okay.
21 MS. BARBIERI: It's usually the attorneys that
22 call the witnesses.
23 MR. CHAIRMAN: Okay. Okay.
24 MR. MATHEWS: I'm fine with asking questions
25 if he wants to of this witness.
Page 300
1 MS. BARBIERI: If -- if the attorneys have no
2 objection, then obviously --
3 MR. CHAIRMAN: Do you have any objection,
4 Ms. Falce?
5 MS. FALCE: No objection.
6 MR. CHAIRMAN: Okay. Thank you.
7 MS. FALCE: No objection.
8 MR. CHAIRMAN: Thank you for coming up.
9 MR. DIFRANCESCO: Ms. Crooks, I'm sorry. The
10 only question I have for you is, when we were
11 discussing the proposal --
12 MS. CROOKS: Yes.
13 MR. DIFRANCESCO: -- and they asked you -- the
14 attorneys asked you who wrote the installed
15 water -- solar system, solar heater brackets and
16 everything on there --
17 MS. CROOKS: Yes.
18 MR. DIFRANCESCO: -- you said you did, and you
19 said you did so because Mr. Brown said his writing
20 wasn't --
21 MS. CROOKS: His spelling.
22 MR. DIFRANCESCO: -- his spelling wasn't that
23 good?
24 MS. CROOKS: Correct.
25 MR. DIFRANCESCO: Okay.
Page 301
1 MS. CROOKS: And that's why he initialed on
2 the side. I requested that he do that.
3 MR. DIFRANCESCO: Who -- who filled out the
4 rest of the proposal where it says "job description
5 of work." Descriptions for a guy who can't spell
6 is pretty good. His handwriting is pretty good.
7 MS. CROOKS: Yes.
8 MR. DIFRANCESCO: So did you not fill that out
9 or -- or did Mr. Brown fill it all out?
10 MS. CROOKS: Mr. Brown filled out everything
11 else. The only thing that I wrote in was that that
12 piece that he initialed. That's why I had him
13 initial it, because I'm the one who wrote that.
14 MR. DIFRANCESCO: Okay. I was -- I was
15 misunderstanding. I thought you said his -- his
16 writing wasn't that good, and I'm looking at that
17 and going that's some pretty good writing. I
18 couldn't do that.
19 MS. CROOKS: Yes. We received this directly
20 -- this paper from Milton Brown on September
21 21st --
22 MR. DIFRANCESCO: Yes.
23 MS. CROOKS: -- that's when we got this.
24 MR. DIFRANCESCO: And -- and it was from a
25 text from Mr. --
Page 302
1 MS. CROOKS: No. He gave us this -- this
2 physical paper.
3 MR. DIFRANCESCO: Oh, he gave it to you?
4 MS. CROOKS: Yes. I mean the original -- I
5 believe, Mr. Mathews has the original, but yes.
6 MR. DIFRANCESCO: And -- and Mr. Campbell
7 brought the original?
8 MS. CROOKS: Mr. Campbell did not hand us
9 anything.
10 MR. DIFRANCESCO: You -- you gave the original
11 to Mr. --
12 MS. CROOKS: Correct. Well, I gave him a
13 copy.
14 MR. DIFRANCESCO: When did he get the
15 original?
16 MS. CROOKS: Today. Mr. Mathews, he -- to
17 make copies --
18 MR. DIFRANCESCO: Right.
19 MS. CROOKS: -- I have the copy now. Earlier
20 today, I had the originals.
21 MR. DIFRANCESCO: Oh, okay, so you did have
22 the original?
23 MS. CROOKS: Yes.
24 MR. DIFRANCESCO: It's just a copy of the
25 first proposal you don't have?
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1 MS. CROOKS: Correct. That was just by text
2 message. We didn't print that or you know,
3 anything. This is the -- the one that we went by.
4 MR. DIFRANCESCO: Okay. And you gave him a
5 $4,000 check without signing -- signing a contract
6 or signing the proposal. You actually gave him
7 $8,000 without signing anything.
8 MS. CROOKS: We gave him the other four after
9 we received this one, yes.
10 MR. DIFRANCESCO: Thank you.
11 MS. CROOKS: Thanks.
12 MR. CHAIRMAN: Thank you, Ms. Crooks. Do you
13 have any questions, Mr. Mathews or -- he can't do
14 that, right? I'm just making sure.
15 MS. BARBIERI: Yeah.
16 MR. CHAIRMAN: Okay.
17 MS. BARBIERI: Typically yeah, then if that
18 generated a new question on new items only. We try
19 not to rehash the --
20 MR. CHAIRMAN: Awesome. Thank you.
21 Ms. Falce, I believe you said the County's
22 case is --
23 MS. FALCE: Yeah. Yeah. We're done
24 presenting our case. Thank you. We rest.
25 MR. CHAIRMAN: Mr. Mathews.
Page 304
1 MR. MATHEWS: I'd like to call the other
2 homeowner, but before we do that, he has the
3 subpoena -- so what I'd like to do is get the
4 documents from him, and if we can take a break,
5 I'll take a look at them.
6 MR. CHAIRMAN: Sure. Take a five-minute
7 break. Okay.
8 (A brief recess was had.)
9 MR. CHAIRMAN: Ready when you are.
10 MR. MATHEWS: For our response, we'll call
11 Todd Roberts.
12 MR. CHAIRMAN: Mr. Roberts, as you've seen
13 earlier, please come up, state your name, address
14 and be sworn in.
15 MR. ROBERTS: Good afternoon everyone. I'm
16 Todd Roberts, 43 -- I'm sorry, 4032 Greenwood
17 Drive, Fort Pierce, 34982. That's my address.
18 TODD ROBERTS,
19 MS. JOHNSON: Do you affirm to tell the truth,
20 the whole truth, and nothing but the truth?
21 THE WITNESS: Yes.
22 MS. JOHNSON: Thank you.
23 DIRECT EXAMINATION
24 BY MR. MATHEWS:
25 Q. Mr. Roberts, you're not a property owner of
Page 305
1 the 4032 property, correct?
2 A. Not per se, no.
3 Q. You're not listed on the documents of the
4 County that you own the property, correct?
5 A. No, but I'm on the deed.
6 Q. So you're a witness in this case, right?
7 A. Yes.
8 Q. What's your occupation?
9 A. I own a business.
10 Q. What business do you own?
11 A. Two at the moment.
12 Q. What are they called?
13 A. PB3 Performance Tax and Multiservices.
14 Q. What is the complete name of PB3?
15 A. PB3 Performance Tax and Multiservices, but is
16 this relevant for me to --
17 MR. CHAIRMAN: I'm going to let him go.
18 BY MR. MATHEWS:
19 Q. Are you a licensed CPA?
20 A. No.
21 Q. Are you an accountant?
22 A. No.
23 Q. Do you have an accounting degree?
24 A. No.
25 Q. Do you complete tax returns?
Page 306
1 A. Yes.
2 Q. So you're a tax preparer?
3 A. Yes.
4 Q. Okay. And what's the other company that you
5 have?
6 A. It's -- well, it's not up and running at the
7 moment.
8 Q. Is that the clothing company?
9 A. Correct.
10 Q. What was the name of that one?
11 A. Take Five.
12 Q. Take Five. With PB3 Performance Tax, does it
13 have any employees other than you?
14 A. No.
15 Q. Do you supervise anybody?
16 A. No.
17 Q. How many tax returns did you approximately
18 complete last year?
19 A. That's not relevant. That's not relevant.
20 This is personal.
21 MR. CHAIRMAN: Mrs. Barbieri, this is a little
22 out of my --
23 MS. BARBIERI: Questions are supposed to be
24 directed to elicit information relevant to it. I
25 don't know how much leniency you want to give him.
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1 Maybe you could ask counsel why they -- I mean,
2 it's not the witness's decision, but you could ask
3 the attorney why -- what -- what he's eliciting
4 this to, how he feels it's relevant to this
5 proceeding.
6 MR. CHAIRMAN: Mr. Mathews, please.
7 MR. MATHEWS: Sure. It goes to
8 sophistication. If he's a tax preparer, if he's
9 preparing 10 -- 1040's that's one thing. If he's
10 doing tax returns that were making corporations,
11 that's another level of specialty and
12 sophistication. If he does ten returns, one year,
13 that means something to me. If he does 400, that
14 means something. And I think it should mean
15 something to the panel as to his business acumen.
16 MS. FALCE: I'm going to place a relevance
17 objection on the record. These questions aren't
18 tailored to the relevant issues before the Board.
19 MR. CHAIRMAN: Thank you.
20 THE WITNESS: Well, just on the record, my --
21 I'm certified and licensed to do the business.
22 MR. CHAIRMAN: I understand. You're more than
23 welcome to answer the question.
24 THE WITNESS: I won't, no. No. I'd rather
25 not.
Page 308
1 MS. BARBIERI: You're under oath. It's up to
2 the Chair. If he asks you to answer it and -- and
3 you refuse --
4 THE WITNESS: How many I did last year? Give
5 or take between 70 to 80.
6 MR. CHAIRMAN: Okay. Thank you for answering
7 the question.
8 THE WITNESS: Give or take, I'm not sure.
9 BY MR. MATHEWS:
10 Q. Do you do corporate filings or just individual
11 filings?
12 A. Personal, and some business if it's under
13 $400,000.
14 Q. Under 400,000 --
15 A. If the company makes under $400,000. The
16 software that I use allows it to work with personal and
17 business.
18 Q. Are you familiar -- did you receive the
19 subpoena that my firm issued to you?
20 A. Yes.
21 Q. Did you look for documents that were
22 responsive to it?
23 A. Yes, the same one my wife provided.
24 Q. That was a little bit -- little bit different.
25 I'd like to admit this into -- into the record. What I
Page 309
1 have, these documents are consistent with the subpoena
2 that was sent to Mr. Leonard for his signature. I
3 believe that he signed it on Friday, Thursday or Friday.
4 I issued it the same day and --
5 MR. CHAIRMAN: I tried to sign as fast as I
6 possibly could for you.
7 MR. MATHEWS: And -- and I appreciate that.
8 I was -- I was out of town the week before and I
9 missed it and I tried to get it. So I'm going to
10 present -- I'm giving it to her counsel -- opposing
11 counsel. Attached is an subpoena. I'm in the
12 process of having it executed and then I'll return
13 it to you. Thanks for agreeing to accept service
14 via email rather than -- so then -- and I'm only
15 giving this to you in this form or this capacity
16 because I don't have the copies of the executed one
17 -- executed one with me. So it's representative as
18 to the areas that -- or the requests that were
19 propounded on Mr. Roberts.
20 MR. CHAIRMAN: Okay.
21 MR. MATHEWS: Is that --
22 MS. FALCE: Yeah. No objection. This is
23 exactly the same as the one that you sent me in the
24 document request --
25 MR. MATHEWS: Correct.
Page 310
1 MS. FALCE: -- they're one and the same?
2 Okay.
3 MR. MATHEWS: All right. So I have one for
4 the Chairman and -- but I'll try to read the
5 relevant portions so you get the gist of the
6 documents.
7 MR. CHAIRMAN: Please. Thank you.
8 MR. MATHEWS: It is largely similar to the one
9 -- to the requests that were provided to Ms.
10 Crooks.
11 BY MR. MATHEWS:
12 Q. So the first request says, Documents to
13 establish the name and contact information of the County
14 firm that referred Lindolph Campbell, Milton Brown and
15 Abe Shultz Construction to you. There were no documents
16 produced responsive to that request, correct?
17 A. We did. The same documents my wife provided.
18 Q. That individual request, are there any
19 documents that were responsive to that request?
20 A. That was the one. That's the only one.
21 That's the only one we have.
22 Q. Okay. So what I -- what I'm hearing is there
23 was a packet of information that was provided to me, but
24 it doesn't -- there's no individual document in that
25 collection of documents that is responsive to request
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1 No. 1; is that correct?
2 A. For me -- the request No. 1 was for me to
3 provide documents regarding the family friend? That's
4 in the package.
5 Q. Oh, in my --
6 A. That was in the package.
7 Q. Where is it?
8 A. Well -- well, maybe it's not on the packet,
9 but it's in the -- the timeline that we created that you
10 guys should have a package -- a copy of.
11 Q. Okay. Do you have any document -- who is the
12 family friend?
13 A. Well, it's a family and the friend is the guy
14 named Zeeks. My family is Orlando and his friend is the
15 guy named Zeeks. Zeeks is the one that works for
16 Abe Shultz.
17 Q. Okay. And did you have the -- do you have the
18 contact information for Zeeks?
19 A. No, because it was a three-way call. I was
20 speaking with my brother, he put me on the phone with
21 Zeek and it was a three-way call. And then Milton,
22 eventually he gave me a call afterwards representing
23 Abe Shultz.
24 Q. Okay. Request No. 2, Any and all copies of
25 the contract, documents, correspondence as well as email
Page 312
1 as identified in the complaint filed with St. Lucie
2 Board of County Commissioners. Was -- were are those
3 documents?
4 A. I did not hear you. I'm sorry.
5 Q. Any and all copies of the contract, documents,
6 correspondence, email as identified in the complaint
7 filed with the St. Lucie County Board of County
8 Commissioners. Did you produce those document?
9 A. Well, the documents -- whatever my wife
10 produced, that's what we have. I normally go through
11 the channel of my wife. She normally take care of that
12 part. So I didn't physically do any -- do it myself --
13 Q. Okay.
14 A. -- if that's what you're asking.
15 Q. Two different subpoenas were sent, right --
16 A. Correct.
17 Q. -- one was sent to -- to your wife and one was
18 sent to you, right?
19 A. Correct. And that's the same copies so we can
20 make a copy of the same copy, if that's what you're
21 asking.
22 Q. No. It sounded like you were saying you
23 delegated some of the responsibilities to Ms. Crooks to
24 make the response on your behalf, is that --
25 A. No, we went through it together. We went
Page 313
1 through the timeline of the incident of whatever
2 happened when we send over the documents.
3 Q. Okay. The -- in the book there's a --
4 MR. CHAIRMAN: Excuse me, Mr. Mathews --
5 MR. MATHEWS: Thank you. We have our book.
6 MR. CHAIRMAN: Yeah, but this is your copy
7 with the --
8 MR. MATHEWS: Oh.
9 MR. CHAIRMAN: That's the first time I saw
10 anything --
11 MR. MATHEWS: Okay.
12 MR. CHAIRMAN: -- written on it so --
13 BY MR. MATHEWS:
14 Q. Request No. 4, A copy of all documents you
15 received from Milton Brown concerning your property
16 located at 4032 Greenwood Drive. Did you produce those
17 documents?
18 A. Where is --
19 Q. That's request No. 4, the Roberts' subpoena.
20 A. Oh, it's in the Roberts' subpoena?
21 Q. I'm asking you whether you produced those
22 documents.
23 A. Yes. It was produced.
24 Q. A copy of pictures and the video of your roof
25 that were sent to Milton Brown, did you produce those?
Page 314
1 A. The picture screen, the screen shot that we
2 take of it that we submitted to you guys, that's what we
3 had. The videos -- the video itself, the reason for --
4 that I'm unable to play the video or get the video after
5 -- I think after two years or a year, it deleted from my
6 phone. The message got deleted, but the -- the video
7 wasn't a video that was done that saved into my photo of
8 my phone.
9 I went on the -- through a text I record the
10 video, because he asked me, Milton, ask me, go on the
11 roof. So I took out my ladder, went on the roof, on the
12 top part of the roof and he told me to record the entire
13 roof. The video was recorded through the message on the
14 roof, because it gave the option, as you're sending
15 message, you can record a video of what's happening, and
16 that's what I sent over to him.
17 Q. So if we look at your phone now, can you pull
18 up that text string?
19 A. No, all my text -- because it's been almost
20 two years, all the text from that date is gone.
21 Q. And you don't have -- the video is not
22 within --
23 A. No. It's not saved to -- oh, my phone is over
24 here. It's not saved to my phone, because it was done
25 through the message of the text. I'm not sure if you
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1 guys -- with the iPhone, you can record a message, a
2 video message and send it through a text and it doesn't
3 save to your phone.
4 Q. Okay. Item No. 11 says, Any and all
5 communications with Nicki Ann Crooks concerning the
6 roofing issue as described in Exhibit A. Milton Brown,
7 Ervin Tulloch, Lindolph Campbell and/or Abe Shultz
8 Construction. Do you have any documents responsive to
9 that?
10 A. I -- I did not hear you clearly. I'm sorry.
11 Q. Sure. I'll reread it. Any and all
12 communications with Nicki Ann Crooks concerning the
13 roofing issue. Let's just stay in there. Any
14 communications with Nicki Ann Crooks concerning the
15 roofing issue; do you have anything responsive to that?
16 A. The copies we sent over to you guys.
17 Q. Did you communicate with your wife at all on
18 this topic?
19 A. Well, any known -- the communications she had
20 with them? I'm -- I'm not following the question
21 correctly because I can't hear it properly.
22 Q. Any and all communications that you had with
23 Nicki Ann Crooks concerning the roofing issue.
24 A. Uh-huh.
25 Q. Did you email your wife about the topic?
Page 316
1 A. No, because we were right there together. We
2 went through it together. We experienced this whole
3 thing together. Every phone call we ever had, every
4 text message, we were side by side. Every phone call we
5 ever had with Mr. Campbell or Milton was always side by
6 side. We were there together.
7 Q. Did you text your wife about this issue?
8 A. No, it was on -- no, I did not text her, but
9 we made the print out regarding everything, and that's
10 what you should have a copy of it.
11 Q. So your testimony today is you've never texted
12 your wife about the roofing issue that went on for two
13 years?
14 A. I -- I can't recall. I can't recall if I ever
15 text her because we were going through it at the same
16 time. We're experiencing everything at the same time.
17 The videos -- if -- the video or the screen shots, I've
18 sent over to her so she can print them, so you can go
19 through the channel for an email because when she had to
20 get it over to Mr. Cicio -- Cicilo (sic), I had to
21 forward those message to her. So I'm not sure if that's
22 what you're asking.
23 Q. I'm asking you whether you had any
24 communications with your wife, text message, about the
25 roofing issue with Abe Shultz Construction or Milton
Page 317
1 Brown.
2 A. Other than sending her the text that I had in
3 my phone, screen shots, so she could send them over to
4 the email, that's the only thing I -- that I recall.
5 Q. So nothing back and forth, Oh, the guys didn't
6 arrive today or they did a lousy job today?
7 A. No, because we were there on the phone
8 experiencing the same thing at the same time. Whenever
9 I called Milton, my wife was there. It was always
10 speaker. Whenever I called Mr. Campbell, it was always
11 there, speaker. So she would listen on the conversation
12 the same way I'm listening in on the conversation. So
13 we experienced everything, the trauma, the -- the
14 greediness of Mr. Campbell and Milton, everything the
15 same exact way. There was nothing different.
16 The only thing that happened that was
17 different that I can recall, is when I set up the
18 meeting to meet Mr. Campbell and I drove from here to
19 Fort Lauderdale for like over two hours and waited for
20 about five or six hours and no one showed up -- and I
21 waited. No one picked up my call. They picked up my
22 call and spoke to me on the way there; and when I got
23 there, I sat there and wait in front of a funeral home
24 and no one picked up my call until days later. That's
25 the only thing that I -- that I experienced separately
Page 318
1 without her being there.
2 Q. Okay. So other than that one instance, you're
3 one hundred percent --
4 A. I can't say a hundred. I said I don't recall.
5 I don't recall sending her anything other than what we
6 experienced together in the texts -- the screen shots
7 that I sent over for her to send it to her email.
8 Q. In any event, you didn't produce any text
9 communications between your wife and you concerning this
10 incident, right?
11 A. Not on a personal level, if that's what you're
12 asking, if we sat and had a conversation in front of the
13 same space. I can't recall that.
14 Q. But my question is, you didn't produce any
15 texts to me concerning any communications you had with
16 your wife concerning this roofing issue, right?
17 A. Only what's on the paper, what's -- what we
18 for -- we gave you guys today or whenever it was
19 submitted. Those are the information.
20 Q. Okay. Well, that was a text string that was
21 between you and Milton Brown, right?
22 A. Correct. And Lindolph and Mr. Campbell, as
23 well.
24 Q. Okay. So I think this is a yes or no. You
25 didn't produce any documents to me reflecting text
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1 communications between you and your wife regarding this
2 roofing issue?
3 A. No.
4 Q. Okay. And it was two years, it was traumatic,
5 right?
6 A. It is.
7 Q. Okay.
8 A. Since this -- can I say something if you
9 guys --
10 MR. MATHEWS: You're generally supposed to
11 wait.
12 MR. CHAIRMAN: I was going to say you got to
13 wait until he asks you a question.
14 THE WITNESS: I didn't know. That's why I
15 asked, I didn't know. My apologies.
16 BY MR. MATHEWS:
17 Q. Mr. Roberts, who takes the lead in getting the
18 property maintained at 3042 (sic)?
19 A. We both do.
20 Q. We've seen a couple versions of proposals from
21 Abe Shultz, a $7,000 proposal and an $11,000 proposal.
22 Is that an expensive home repair?
23 A. Anything is an expensive homeowner to repair,
24 anything could be expensive.
25 Q. When did you first get the house?
Page 320
1 A. This is in 2019.
2 Q. 2019. So you haven't had the house that long.
3 A. Correct.
4 Q. Other than the roofing issue, was there
5 anything else that you spent more than a couple thousand
6 dollars on?
7 A. Possible, but I can't recall.
8 Q. Nothing -- anything come to mind?
9 A. Not that I can think of when we first got the
10 house, if that's what you're asking.
11 Q. Okay. So on or about August of 2021, there
12 were some leaks, right?
13 A. Yeah, there was a leak.
14 Q. But you -- you knew from the inspection of the
15 property that there was some problems with the roof; is
16 that correct?
17 A. No. Well, when we first got the house, they
18 stated that the roof needed to be -- if that's the
19 inspection you're asking about, right?
20 Q. Yes.
21 A. When we first got the house, they said the
22 life on the roof was between, like, six -- five or six
23 years remaining on the roof. That's what he told us, if
24 I'm not mistaken. My wife can probably correct me on
25 that. So it wasn't long that the roof was left -- had
Page 321
1 left from what he told us.
2 Q. Okay. But then you were experiencing some
3 leaks, right?
4 A. Yeah, we experienced a leak, correct. And the
5 reason for the leak, there was a -- a nail on the roof
6 because of the bracket for the solar water heater.
7 There was a nail that I guess had got rusty or water was
8 passing through and it just kept drifting -- dripping
9 inside, but it wasn't leaking through the hole that we
10 saw in the picture.
11 Q. Did you determine that, that it was this nail
12 hole that caused the leak?
13 A. Correct. The company that we first initially
14 had come out, they wanted to coat the roof. What my
15 wife was talking about earlier, they wanted to put a
16 coating down on the roof, and they're the ones told us
17 this isn't the reason for your leak, is that nail that's
18 holding on the bracket of the solar panel, the solar
19 power water heater.
20 Q. Did you contemplate at that point repairing
21 that nail head, plugging the leak and getting another
22 six years out of it?
23 A. No, because the guy said he would do a
24 coating. He doesn't do -- he doesn't take the roof up
25 or do roof repair. He was like he only do coating; he
Page 322
1 would just coat the roof.
2 Q. But if you had a problem with one nail head,
3 you felt the need to replace the entire roof?
4 A. No. Milton, Mr. Brown, it was easier for him
5 to replace the whole roof because he said it's a old
6 roof. I told him the life expect -- expectancy of the
7 roof and then he proposed the whole roof would be
8 better. That's how that conversation came up.
9 Q. At the same time, did you contemplate putting
10 new shingles on the roof?
11 A. Yes.
12 Q. Did you get a quote for the shingles?
13 A. No. Milton was the first one because he
14 mentioned it, if I'm not mistaken. I'm not a hundred
15 percent, but I know Milton mentioned the shingles. He
16 was trying to -- if Milton were here, you guys would see
17 he's a fast talker. So he's like perfect to be a
18 salesman. He's a very fast talker, and he sold us on
19 everything that he would have done, that he would do on
20 the property, you know, and that's the reason why we
21 ended up going with him.
22 Q. Do you see Milton in this room --
23 A. No, he's not here.
24 Q. -- or Andrew Brown in this room, any --
25 anybody --
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1 A. No.
2 Q. -- that you met with?
3 A. Abe Shultz or Mr. Lindolph.
4 Q. I was talking about the Brown contingency.
5 A. No.
6 Q. Okay. Do you know if he was subpoenaed to be
7 here today?
8 A. No, I'm not sure. Possible, but I'm not sure.
9 Q. In -- in or about August of 2020, were you
10 familiar with a company by the name of AB Handyman?
11 A. No.
12 Q. Never heard about it before?
13 A. No, sir.
14 Q. Ever know anybody who worked for AB Handyman?
15 A. No, sir.
16 Q. Do you know that a complaint was filed to
17 St. Lucie County Board of Commissioners concerning
18 Abe Shultz and Mr. Campbell?
19 A. Yes.
20 Q. Who signed that complaint?
21 A. If I'm not mistaken, my wife did, Nicki Ann
22 Crooks.
23 Q. Why didn't you sign it?
24 A. Because she made the complaint.
25 Q. But I thought both you guys experienced
Page 324
1 everything together.
2 A. I wasn't there at the time when she did it. I
3 knew of it, but it wasn't through a text. Verbally
4 we -- we spoke on it. I was fully aware of it, that it
5 was going to take place. And the reason for that is
6 because the runaround Mr. Campbell and Milton Brown gave
7 us. They -- from -- there's timelines that's missing
8 where Mr. Campbell -- my first initial time I spoke with
9 Mr. Campbell was --
10 MR. MATHEWS: I'm going to object. I don't
11 have a question pending. He's just speaking.
12 MR. CHAIRMAN: Okay. That's fine.
13 Mr. Roberts, you don't have to -- you're not --
14 THE WITNESS: Okay.
15 BY MR. MATHEWS:
16 Q. Mr. Roberts, you're a businessman, right; you
17 have this company, PB3 Performance Tax, right?
18 A. Correct.
19 Q. When you're performing work for
20 PB3 Preparation Tax, do you accept payment from your
21 clients personally?
22 A. No.
23 Q. Would you?
24 A. You mean like paying me cash upfront? I
25 don't.
Page 325
1 Q. Or a check.
2 A. No. It goes through a system that I work
3 with.
4 Q. Does it go -- if you're doing work for a
5 client, does the check go to the company?
6 A. It goes through our automated system, yes,
7 correct.
8 Q. No. So you do a tax return for a client --
9 A. Uh-huh.
10 Q. -- they owe you $500 for a tax return --
11 A. Uh-huh.
12 Q. -- are they paying you personally or are they
13 paying the business?
14 A. They're paying the business.
15 Q. Why is that?
16 A. Because it's going through the business. I
17 don't accept cash from anyone.
18 Q. Do you find anything suspect that you and your
19 wife agreed to give a check directly to Milton Brown for
20 work?
21 A. For -- we have no idea about roofing. We
22 are -- roofing is new to us, so we didn't understand how
23 the process work. I did mention to him, Why is it not
24 going through the company? And he stated, This is how
25 me and my partner -- this is how him and his partner
Page 326
1 conduct business, and it went from there. We asked him,
2 you know, why is it not going through the company. He
3 stated this is between him and his partner and that's
4 why he's going that route.
5 Q. Did you read the proposal at Exhibit 6?
6 A. Yes.
7 Q. Did you see the payment plan in there?
8 A. Well, I didn't -- yeah, I saw the payment
9 plan, but that's not what we spoke on over the phone.
10 The partner that he have is a very fast talker. He's
11 super -- I don't how he got us, but he got us.
12 Q. Do you think there's anything you could have
13 done to have prevented this?
14 A. Afterward I learned my lesson, yeah.
15 Q. What lesson did you learn?
16 A. Never deal with shady companies.
17 Q. How do you know somebody's shady?
18 A. Because Mr. Campbell and -- and Milton played
19 this game of like good guy, bad guy. My first initial
20 phone call I spoke to Mr. Campbell, was with
21 Milton Brown in the room with Mr. Campbell, and I spoke
22 to him through Mr. -- Milton Brown phone at the office,
23 wherever they were. That was on the 25th roughly of
24 September, if I'm not mistaken.
25 Q. But there was a proposal dating back to
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1 August, correct?
2 A. Yeah, this was on September -- yeah, September
3 -- the proposal was in August, but no one shows up to
4 our home until September.
5 Q. Okay. In September, did you ask for a
6 business card?
7 A. No, we did not.
8 Q. Did you see a truck that had Abe Construct --
9 Abe Shultz Construction on the side?
10 A. They came in a van, but I didn't -- how they
11 park -- they came in so many cars. There was a lot of
12 cars that was on our property at the time. And they
13 came in a white van with a lady who was driving.
14 Q. When their -- when you discovered that there
15 were leaks at the property --
16 A. Uh-huh.
17 Q. -- did you take steps to mitigate your damages
18 or protect your property?
19 A. We did, but it was -- in September -- just to
20 answer that question, in September when they came, they
21 put down a sheathing material on top of our existing
22 roof, and -- you know, you were saying the roof is
23 shaped like a L, but it's not actually L. It goes one
24 way like a half of a square. It goes one way this way
25 and then back this way. They put down a material that
Page 328
1 they nailed down. We have pictures that we had that
2 they nailed the material down over our existing roof;
3 and when I heard that noise, that's when I -- I went up
4 there and like, "Hey, I thought you guys were supposed
5 to be taking off material." That was September 20th.
6 Then Milton came on the 21st and they never
7 came back. So they left everything they -- they nailed
8 down all the way to December. So we had leaks in
9 multiple places throughout the house because they had
10 the material on top that nothing was covering it, but
11 the nails just going straight through. And they left it
12 up until December when they came back.
13 Q. Did you cover it up in the interim?
14 A. I can't. It was -- it was too large of an
15 area. I covered up the small ones that we could have
16 with the tarp and sandbags and stuff like that, but the
17 roof is -- it's a long roof. There's nothing that we
18 could have done to cover it. There's pictures that
19 shows the area where they have the material down and
20 they nailed it. There's nothing we could have done.
21 Q. Do you have pictures of the coverings that you
22 -- that you put on?
23 A. Yes, I send the pictures.
24 Q. I saw -- saw one. There was one of -- and I
25 believe that was early in the project, and there was --
Page 329
1 it was on the corner. Maybe perhaps --
2 A. No, it wasn't early in the project, because a
3 lot of them are recent.
4 Q If you look at Tab 8, the first picture there
5 depicts -- it looks like the front of the house, and
6 there's a tarp on part of it at the left.
7 A. I'm guessing I'm not seeing Tab 8. I can't
8 find it. This here.
9 MR. CICIO: Go to 7.
10 THE WITNESS: Yeah, this is how it looks right
11 now, probably give or take a couple of more
12 sandbags and the tarp shifted, because how the
13 water coming, we couldn't -- we couldn't catch it,
14 even when I put the tarp down. So I had to went
15 back up there and kind of shift it a little bit
16 better.
17 BY MR. MATHEWS:
18 Q. Okay. And when was this picture taken?
19 A. I'm not -- this is after everything was done.
20 So this had to have been this year or late last year,
21 because we still have the Christmas lights that we put
22 up, or last year some time.
23 Q. Okay. Do you have any other pictures of tarps
24 on the property reflecting where there were leaks?
25 A. And where that tarp is is not just a small
Page 330
1 area. It's a big area that it covers, a good amount of
2 area. You're just seeing it from the front. It make it
3 look like it's a small area, but it's really large.
4 Q. No other pictures, correct?
5 A. Not -- not after we put the tarp on, but we
6 have pictures of the reason why we put the tarp on where
7 the leak was --
8 Q. I think -- I think we've gone through those,
9 but any videos of -- of water pouring into the house?
10 A. No. I'm not sure if we have videos. We have
11 pictures and we have buckets that we put up to catch the
12 water in.
13 Q. Any pictures of the buckets?
14 A. I'm not sure if we brought any with us, but,
15 you know, we had pictures of the buckets that will
16 collect the water.
17 Q. Okay. So maybe those are documents that are
18 -- are -- those would be pictures that would have been
19 responsive to my subpoena?
20 A. Well, I'm -- like I said, I'm not sure because
21 this is when it happened from back then. I remember
22 pictures were taken, but I don't think we have them.
23 Q. Did you file an action against Andrew Brown?
24 A. No. Well, with the County, yes, if that's
25 what you're asking. With the County, yes.
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1 Q. Did you ever seek to get a refund from him?
2 A. We tried.
3 Q. What did you do?
4 A. Called him. He blocked our number going
5 through -- Mr. Campbell. Like I was saying earlier,
6 they played good guy, bad guy. Andrew Brown -- Milton
7 Brown wouldn't pick up my phone call, but Mr. Campbell
8 would, and then every time we would vent to Mr.
9 Campbell, because we thought he was the secretary or the
10 assistant the entire time, and we would just vent to him
11 because he will always pick up his phone call -- pick up
12 our phone call. And he was saying, Oh, Milton is doing
13 this, Milton is doing that, but he never said, at the
14 time, Milton is running his company until December
15 sometime.
16 Q. Is it Milton or did he refer to him as Andrew?
17 A. I'm not sure how he called him, what he called
18 him. I think it was Andrew or Milton because he -- I
19 don't know Andrew personally. We know him -- when he
20 spoke to me, he said his name was Andrew. We found out
21 his name was Milton through Mr. Campbell, if I'm not
22 mistaken. If I'm not mistaken. I'm not sure. I'm not
23 sure.
24 Q. Ultimately, you gave Milton Brown $8,000,
25 right?
Page 332
1 A. Yes, sir.
2 Q. And you didn't receive $8,000 worth of
3 service, right?
4 A. Well, I don't know what money worth of service
5 that I received, but it wasn't good. The service wasn't
6 good. No one in their right mind would pay for that.
7 Q. Did you file a criminal complaint against him?
8 A. No, because Mr. Campbell assured us that he
9 would take care of everything. He would tell me, Oh,
10 I'm going to talk to Milton. I'm going to talk to
11 Milton. I'm going to talk to Milton. But he never said
12 to me it was his company up until we told him in
13 December -- this is from September 20-something all the
14 way back to December. That's when he told us, hey --
15 when we told him we were going to take action against
16 his company, Abe Shultz, because we didn't know Milt --
17 Mr. Campbell was the owner. And that's when he said,
18 Oh, he's not going to allow Milton Brown to ruin his
19 company. And we're like what? It's your company? And
20 he was, like, yeah.
21 And he stated that he would come in and finish
22 the work and honor whatever it is on the -- on the
23 contract, but he was aware of the contract from day one,
24 but he pretend and portrayed this image like he was the
25 good guy when he knew all about it the entire time from
Page 333
1 September what was going on. And that's the reason why
2 we didn't take any legal action, because Mr. Campbell,
3 you know, was playing the nice guy that he would get,
4 you know, Mr. Brown to get the work done.
5 And we never met Mr. Campbell, so I didn't
6 know who I was talking to or how he looks, you know,
7 because he never referred to hisself, like, I'm
8 Mr. Campbell. This is my company. It was Abe Shultz.
9 When he pick up the -- when you called, they say
10 Abe Shultz. The paperwork say Abe Shultz so it's the
11 right person. Milton Brown said it's his assistant --
12 no, at first he said he was his partner and then he send
13 us a message saying this is his secretary and then when
14 we speak to him, Mr. Campbell, he said he's just the
15 assistant. He just do paperwork. So we didn't know
16 what to follow, whatever. Mr. Campbell always picked up
17 the phone and he was being nice. He's always nice, but
18 it was his company the entire time. And I vent to him
19 countless times, like, can you please have him give --
20 give us back our money so we can move onto another
21 company. And he assured us, no, I'm going to talk to
22 him. I'm going to have him come up and do it, and it
23 never happened. I call Milton Brown and he just lied to
24 me, hang up the phone on me, but Mr. Campbell will pick
25 up.
Page 334
1 So we kind of felt like -- the balance was so
2 weird because why is the secretary picking up and pretty
3 much consoling us about what we are through and feeling
4 our -- our pain and our sympathy. At the same time, he
5 knew exactly what we were going through, and I expressed
6 to him that please have the guy give me back my money so
7 I move -- move onto another company.
8 Q. Did you tell Mr. Campbell that you wouldn't
9 pay the $3,000 that was due under the proposal that we
10 saw?
11 A. Yes. After he showed up on our roof of the
12 January 1st -- on January 1st when he showed up, we
13 stated -- as soon as he got on the roof, he stated, Oh,
14 you gotta give me $5,000 to finish this roof. And we're
15 like what? We're not giving you any more money because
16 you told us you're going to honor the contract and
17 finish -- because we didn't know they were two separate
18 -- we -- the whole time, we thought it was Milton Brown
19 was the owner with a partner, but we didn't know the
20 partner was Mr. Campbell.
21 So when he got on the roof -- when he told us
22 in December, December 20-something, after Lindolph came
23 -- Milton came on the roof and did what he did, we spoke
24 to Mr. Campbell and he said, Don't take action. It's
25 his company he will come out and look at the roof. And
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1 he came out on the 1st. When he came out on the 1st and
2 we spoke to him, I told him, There's no way I would
3 give -- the last guy you sent -- took $4,000 from me and
4 I haven't heard from that guy. Now, they have $8,000 of
5 ours and you want me to give you $5,000 for you to
6 finish the job. And he said, Well, I have to get my
7 money some -- some way, and he got on the phone in front
8 of me and as -- this guy Warren, and he called Milton
9 and he was yelling and cussing and shouting at Milton,
10 and he said to Milton, If you don't give me my -- give
11 me the $5,000, he's not going to complete this job.
12 That's what he told Milton. And he left.
13 The next time, you know, he was coming out on
14 the 13th. This was on the 1st. So we assume, Oh,
15 Milton must have gave him the $5,000, and he came out
16 and started to work. The day of him being there,
17 Mr. Campbell, he told me, Oh, yeah, I'm going to go --
18 he asked me where there's a propane company that he can
19 get gas to refill for this torch. And I told him,
20 There's one on Oleander that's down there. I'm not sure
21 if they're open, or he can go to the one on US One -- I
22 can't remember the company that -- that does right off
23 of US One a little bit above Midway. And he said, Okay.
24 Send me the address, and I send it to him.
25 He hopped on the highway and he -- he drove
Page 336
1 off. He never went there. And then he called me, while
2 he was driving back home, and telling me, Oh, you have
3 to give me my $3,000 for me to finish this job. And I'm
4 like what? I thought we agreed that you -- we're not
5 going to give you any money and you got your money from
6 Milton. And he said, No, you need to pay me the $3,000,
7 and then he claimed that this is -- the contract is not
8 real. So I said, What were you doing on my roof if it's
9 not real? And he -- he was quiet about it.
10 And he said some words, some mean words to my
11 wife, called her the "B" word. He's not going -- he's
12 not going to agree to that, but he did. He called her
13 the "B" word. This was on speaker while he was -- I
14 guess by that time -- we were on the phone for a lengthy
15 time. By that time, he was already there at his office
16 or whatever it was, and we went from there.
17 The conversation was really nasty, mostly
18 coming from him because he's saying we're ripping him
19 off, and we're telling him that we're down $8,000, How
20 is that we're ripping you off when we gave you money?
21 And he was fully aware of the $8,000 to Milton Brown,
22 but he can pretend and play like he didn't know, but the
23 entire time, he was there with Milton Brown.
24 Q. Okay. I want to go back to the question that
25 I asked you. You spoke for a long time. There was
Page 337
1 $8,000 that was paid to Mr. Brown, correct?
2 A. Uh-huh. Correct.
3 Q. It was a proposal for $11,000, right?
4 A. Correct.
5 Q. And there was a difference then of $3,000.00.
6 A. Correct.
7 Q. Did you advise Mr. Campbell after he was
8 completed with his work on -- in January of 2021 that
9 you weren't going to pay him the $3,000?
10 A. This is after he left we spoke about the
11 $3,000.00. When he was there, he spoke about $5,000
12 that he needed.
13 Q. Okay. I'm not -- not talking about the
14 $5,000.
15 A. This is after he left. He already did the
16 work and left. That's when he --
17 Q. Okay. Did you tell him you weren't going to
18 pay him another dime?
19 A. Yes. We're not going to pay him the $3,000 if
20 the work is not complete. He was supposed to do the
21 drywall that he ripped down in the -- in the -- the
22 rooms. He was supposed to do it as well. And he stated
23 that he wasn't going to -- because he had to hire
24 somebody to do the work. That's how that conversation
25 started.
Page 338
1 Q. Did you insist upon him resheathing the flat
2 roof with three-quarter inch plywood?
3 A. How would I know this? No, sir. How would I
4 know this?
5 Q. Okay. So that's --
6 A. That's his -- that's what he's stating,
7 treated plywood that he mentioned earlier. How would I
8 know what plywood goes on the roof? I wouldn't know,
9 sir. This matter have been very frustrating, man.
10 MR. MATHEWS: No further questions at this
11 time.
12 MR. CHAIRMAN: Thank you, Mr. Mathews.
13 Ms. Falce, do you have --
14 MS. FALCE: Yeah. I -- I just have a few
15 questions for him.
16 MR. CHAIRMAN: By all means.
17 CROSS EXAMINATION
18 BY MS. FALCE:
19 Q. Good afternoon.
20 A. Good afternoon, ma'am.
21 Q. So you -- you were asked a -- a few times and
22 so were other witnesses, if you had seen trucks come to
23 your house with Abe Shultz Construction on the side or
24 received a business card with Abe Shultz Construction,
25 correct?
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1 A. Uh-huh.
2 Q. Do you -- do you recall those questions?
3 A. Yes. Yes.
4 Q. And you didn't receive --
5 A. No.
6 Q. -- that business card or see the truck?
7 A. No. Only the paperwork that he brought.
8 Q. Right. But you did receive a proposal --
9 A. Yes.
10 Q. -- on a form contract that says Abe Shultz
11 Construction, LLC, correct?
12 A. Yes, that's correct.
13 Q. The work that you are -- that you're asking
14 Mr. Campbell to perform for you before you'll pay the
15 $3,000, is it -- is it to make the roof code compliant?
16 A. That would be nice, and the -- if he's going
17 to fix the damages that he caused, when they ripped down
18 the ceiling -- because the damage on the picture looked
19 very small, but it's really a big area when they ripped
20 down the ceiling, the entire bathroom they ripped down.
21 Q. But your -- your understanding of this
22 proposal would be the remaining amount --
23 A. Yes.
24 Q. -- that's due under it is only due when the
25 work is complete. Does that also mean it passes
Page 340
1 inspection; is that your understanding?
2 A. For the -- to give him the $3,000?
3 Q. Yes.
4 A. If the work is complete, is that with the
5 rooms as well or just the roof itself?
6 Q. I'm just asking about the roof. Would the
7 inspection have to be completed and finalized and passed
8 before you consider the roof work complete?
9 A. Correct.
10 Q. When you stated Mr. Campbell came to your --
11 to your home, correct?
12 A. Uh-huh.
13 Q. Did he have a vehicle that was marked
14 Abe Shultz Constructing --
15 A. No.
16 Q. -- Construction, LLC?
17 A. No.
18 Q. No?
19 A No.
20 Q Did he have a -- did he give you a business
21 card --
22 A. No, he did not.
23 Q -- Abe Shultz Construction?
24 A No, he did not. He didn't.
25 Q. Okay. Did he wear a shirt that said
Page 341
1 Abe Shultz Construction?
2 A. No.
3 Q. Did any of the workers that appeared at the
4 property, putting aside Mr. Brown, did anyone have a
5 truck --
6 A. No.
7 Q. -- with Abe Shultz Construction?
8 A. No.
9 Q. Okay. So it wasn't -- it wasn't out of the
10 ordinary if Mr. Brown showed up without an Abe Shultz
11 Construction truck?
12 A. Correct.
13 Q. No one had one.
14 A. No one had one. It's in the pictures when
15 they're on the roof working. They had on regular
16 clothes, drinking beer, smoking, throwing their food in
17 our yard. All nonsense.
18 Q. And you stated in your testimony, too, that
19 you were -- you were connected on speaker phone --
20 A. Yes.
21 Q. -- when Mr. Brown and Mr. Campbell were in the
22 office together?
23 A. Correct.
24 Q. How do you know that they were in the office
25 together?
Page 342
1 A. Well, I was speaking through Milton phone to
2 Mr. Brown and they were in the office, because this is
3 when the permit supposed to start taking place.
4 Q. So you called Mr. Brown --
5 A. Correct.
6 Q. -- at his phone number --
7 A. Yes.
8 Q. -- and then in the background you could
9 hear --
10 A. Him and Milton was out -- and Mr. Campbell,
11 Milton was having a conversation. That's my first time
12 speaking to Mr. Campbell.
13 Q. Do you recall about what time, time frame?
14 A. I'm not sure.
15 Q Okay.
16 A It had to be some -- some time in the daytime.
17 Q. Okay. Well, I mean during -- like what month
18 or day?
19 A. This was in September.
20 Q. September?
21 A. Correct.
22 Q. Okay. So Mr. Campbell was aware of -- of your
23 project, and do you recall what was being said? Did you
24 mention that some of the work had been done and this was
25 in September where Mr. Campbell would -- would know the
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1 status of the job?
2 A. Yeah. Yeah, Mr. Campbell did. The reason for
3 the call is well, Mary, from -- for the dumpster --
4 yeah, I send a message to -- it was Milton regarding the
5 dumpster, and I think I sent it on the 24th. So on the
6 25th when I spoke to him, me and Mr. Campbell and Milton
7 had that conversation regarding the permit and the
8 dumpster and all this stuff that supposed to be picked
9 up -- supposed to be dropped off, the arrangement. But
10 that was just a phone call just to blow me off until
11 December sometime when they actually finally dropped the
12 dumpster.
13 MS. FALCE: I -- I don't think I have any
14 further questions, but thank you.
15 THE WITNESS: Okay. You're welcome.
16 MR. CHAIRMAN: Ms. Falce, thank you.
17 Mr. Mathews, any --
18 MR. MATHEWS: No additional questions.
19 MR. CHAIRMAN: No additional questions.
20 Does the Board have any questions of
21 Mr. Roberts?
22 MR. DIFRANCESCO: Of course. Mr. Milton --
23 you do have an iPhone?
24 THE WITNESS: Yes.
25 MR. DIFRANCESCO: And I'm not calling you a
Page 344
1 liar, but I have a video that I saved that went to
2 my brother's in 2018, right before my mom died, the
3 first thing -- and I can play it for everybody
4 right here, right now. So how you lost your video,
5 I don't know, but I -- I still have mine. I keep
6 it on my phone and I play it all the time.
7 THE WITNESS: No, the video wasn't done
8 through my phone. It was done through the message
9 of my phone.
10 MR. DIFRANCESCO: Yeah. It was a message?
11 THE WITNESS: Yeah, it was a message, but my
12 phone is different. A lot of my previous message,
13 after a year, I think it get erased.
14 MR. DIFRANCESCO: I've got an older iPhone.
15 It's about two years old now.
16 THE WITNESS: Yeah. I don't have that video
17 on my phone at all. I wish I did, because I was on
18 the roof doing it because he sent me on -- on the
19 roof.
20 MR. DIFRANCESCO: Did you and your wife ever
21 have insurance on the house when you bought it?
22 Didn't you have to have insurance on the house when
23 you bought it?
24 THE WITNESS: Correct.
25 MR. DIFRANCESCO: And it got canceled
Page 345
1 because -- I think your wife had said that the
2 insurance got canceled?
3 THE WITNESS: Yeah. It was supposed to be
4 renewed and they wanted to -- I mean, we -- it was
5 supposed to be renewed, if I'm mistaken, if I can
6 remember -- or it got canceled in July or August.
7 I'm not sure when it got canceled. I can't recall.
8 MR. DIFRANCESCO: Do you think it was because
9 it needed a new roof? Because what insurance
10 companies are doing now, if your roof is over
11 15 years old, they're actually dropping people and
12 making them get a new roof before they'll pick them
13 back up again or is it wasn't because of
14 non-payment?
15 THE WITNESS: No. There is no way. It
16 wouldn't be for non-payment, I know that for a
17 fact, yeah.
18 MR. DIFRANCESCO: I didn't think it was so --
19 THE WITNESS: Yeah.
20 MR. DIFRANCESCO: You said that you were told
21 by the inspector, I guess, when you bought the
22 house that you had a few more years left on the
23 roof?
24 THE WITNESS: Correct.
25 MR. DIFRANCESCO: Your wife said the inspector
Page 346
1 said that it was the end of the life line on that
2 roof --
3 THE WITNESS: Which was --
4 MR. DIFRANCESCO: -- so which one was it?
5 THE WITNESS: Which was five to six years.
6 That's what he told us.
7 MR. DIFRANCESCO: That's --
8 THE WITNESS: Yeah. Which is -- I don't know
9 how long the roof is supposed to last, if it's 20
10 years or 15 years, but it was close to the -- the
11 life from what they stated.
12 MR. DIFRANCESCO: Did you ever discuss with --
13 I mean, I know as a contractor if I have a problem,
14 and never had it, but if I couldn't afford to come
15 and do your roof and redo your roof, and I needed
16 more time, then I would possibly try to go through
17 my insurance company. I wonder why he didn't go
18 through his insurance company but you-all did.
19 THE WITNESS: Through his insurance company.
20 MR. DIFRANCESCO: Did you all consult him to
21 go through it --
22 THE WITNESS: We told him.
23 MR. DIFRANCESCO: -- through his insurance
24 company?
25 THE WITNESS: We explained to him that would
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1 happen. And this is one of the things that he
2 stated. He said if you ever go to court, he would
3 deny being on our roof, he would deny knowing
4 Milton, he would deny that he ever -- all kind of
5 nonsense behind it, that he would deny, because he
6 didn't know that we were actually going to go
7 through that process. We told him --
8 MR. DIFRANCESCO: I'm trying to find out --
9 THE WITNESS: -- but he didn't believe us.
10 MR. DIFRANCESCO: I'm trying to find out how a
11 customer can go through a contractor's insurance
12 company without his knowledge.
13 THE WITNESS: He knew about it. He knew
14 because the -- the insurance adjuster for him
15 called us and told us that he said, Mr. Campbell
16 said he never been on our roof and he don't know
17 Milton. So we were like what? But he just renewed
18 a permit -- he just renewed a permit to be on our
19 roof, and she was like, what, send it over to us,
20 and we sent it over to her. And that's when she
21 realized, Why is he lying? She -- she can't take
22 his story for it, because he been telling her --
23 that's what took so long. He'd been telling her
24 that he don't know us. He never been on our roof,
25 and he doesn't know Milton.
Page 348
1 MR. DIFRANCESCO: So you're saying that you --
2 if he was to -- one of staff's recommendations were
3 that -- that all inspections up to and including
4 the final inspection for the roofing permit under
5 Abe Shultz Construction at the address of
6 4032 Greenwood Drive, is to be obtained within
7 three months of this Board's date or a fine not to
8 exceed $10,000 would be imposed.
9 So what I'm asking is, you acknowledge that
10 you -- if he was to complete and get a final
11 inspection from the County, that you would pay the
12 rest of that contract, the rest of that proposal,
13 which is obviously a contract because people are
14 paying money on it. You took it as a contract.
15 They're -- they're saying it's a proposal.
16 So are you saying that if he was to come in,
17 redo your roof, get it where it's not leaking
18 anymore, fix the flashing, not counting the -- the
19 rotten wood that is where -- is in my opinion where
20 I think it's leaking. I haven't even been --
21 THE WITNESS: It's not leaking from the -- the
22 -- if you're talking about on the side.
23 MR. DIFRANCESCO: Right.
24 THE WITNESS: Yeah, it's not leaking there.
25 That's not where the leak is from.
Page 349
1 MR. DIFRANCESCO: If he was to come in there
2 and fix what's -- and make your roof right, you
3 would pay him that $3,000?
4 THE WITNESS: Would he still do the -- the
5 remaining --
6 MR. DIFRANCESCO: No, no, and I'll tell you
7 why. Because you got $14,000 from the insurance
8 company --
9 THE WITNESS: Correct.
10 MR. DIFRANCESCO: -- to do that. So why
11 wouldn't he use that $14,000 of that insurance
12 company's money to do that? I don't think --
13 THE WITNESS: Yeah, reason being, the reason
14 being --
15 MR. DIFRANCESCO: -- it's coming from both
16 ends here.
17 THE WITNESS: Correct. If we pay him the
18 remaining for the damages that he caused, pay him
19 the $3,000, we still have to pay $3,000 to fix that
20 damage that he caused inside.
21 MR. DIFRANCESCO: Where is that $14,654 go to?
22 THE WITNESS: The -- the screening, the
23 drywalls, the pool -- the pool solar water heater.
24 It's 12 panels, and I think it came up to 8 or 9
25 thousand or somewhere around that -- that range for
Page 350
1 the -- to install them, to get them and to install
2 them, and do the plumbing of the -- the unit, the
3 plumbing that runs to the -- the house on the side.
4 MR. DIFRANCESCO: Did the insurance company --
5 but you signed off on it with the insurance
6 company.
7 THE WITNESS: Correct.
8 MR. DIFRANCESCO: I know your wife said you
9 had a list of what the $14,000 would cover.
10 THE WITNESS: Correct. It's in there. It's
11 in the paper that you guys --
12 MR. CHAIRMAN: I -- I did not allow that
13 into --
14 THE WITNESS: Correct.
15 MR. CHAIRMAN: -- it's on that one.
16 MR. DIFRANCESCO: Okay. So --
17 THE WITNESS: I have a breakdown of what it's
18 for.
19 MR. DIFRANCESCO: But -- but you and your
20 wife, or your wife, whoever, signed off on that to
21 hold him harmless after -- after that.
22 THE WITNESS: Yeah. This was --
23 MR. DIFRANCESCO: How do you expect him to
24 come back and -- and pay you more money now,
25 anything above that proposal contract, contract?
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1 THE WITNESS: Yeah. So that's -- that's the
2 thing. It would be either or. If we pay him the
3 $3,000, he would have to fix that damage, the
4 damage that they caused in the garage, the damaged
5 that they caused in the rooms, in the bedrooms, he
6 would have to fix that. And then we could pay the
7 3,000. If we don't -- if he just fix and we don't
8 pay him the $3,000, we still have to pay for that.
9 So it's still going to cost us to pay for it
10 because the painting and the -- the painting and
11 the ceiling, it came up to 6,000 something dollars.
12 MR. DIFRANCESCO: Okay.
13 THE WITNESS: Because it's the front, the
14 front of the house, the -- inside the house, the
15 nanny's suite, inside the bedroom, in the garage.
16 There's different leaks that happened in the
17 garage, not just the hole that you see.
18 MR. DIFRANCESCO: And the insurance company
19 came and did their assessment?
20 THE WITNESS: Uh-huh.
21 MR. DIFRANCESCO: And that came out to
22 $14,654, they didn't call that damage done?
23 THE WITNESS: They gave us less than the quote
24 that we end up getting for everything. They gave
25 us a few cents on the dollar for whatever it is.
Page 352
1 MR. DIFRANCESCO: But it was -- what you're
2 saying -- I know we weren't allowed to see --
3 THE WITNESS: Correct.
4 MR. DIFRANCESCO: -- that paperwork, but what
5 you're telling me is that that $14,654 was supposed
6 to come to -- but they held back. They -- they --
7 in other words, you paid a little bit more out of
8 your pocket.
9 THE WITNESS: Well, it still hasn't been
10 fixed. It haven't been fixed yet.
11 MR. DIFRANCESCO: Well, I wouldn't fix it
12 until you get the roof in.
13 THE WITNESS: Sure. That's what -- that's the
14 problem we're having.
15 MR. DIFRANCESCO: So you got $14,654 to do
16 that work --
17 THE WITNESS: Correct.
18 MR. DIFRANCESCO: -- to fix all that stuff.
19 THE WITNESS: And 80 percent of that or 60
20 percent of that is just to put the solar water
21 heater on the roof because it's over 8,000
22 something dollars.
23 MR. DIFRANCESCO: It seems -- it sounds like a
24 brand new water heater.
25 THE WITNESS: Well, it's the -- it's the
Page 353
1 12-panel water heater.
2 MR. DIFRANCESCO: So you have to buy all new
3 panels?
4 THE WITNESS: Yeah, because they're -- they've
5 been sitting there and they're brittle. They've
6 been sitting and stacked on top of each other for
7 over two years.
8 MR. DIFRANCESCO: But the insurance company
9 didn't -- didn't assess that?
10 THE WITNESS: They did. They came out and did
11 it. It's in the paperwork that if you had -- was
12 submitted, you guys would have seen it. They came
13 out and --
14 MR. DIFRANCESCO: So they paid you $14,654?
15 THE WITNESS: Correct, but the damage that was
16 caused is over 18 or $20,000, because they pay us
17 cents on the dollar, because there were a few
18 things they claim they can't cover.
19 MR. DIFRANCESCO: Why did you accept it?
20 THE WITNESS: We had no choice.
21 MR. DIFRANCESCO: You're a pretty smart guy.
22 THE WITNESS: Yeah, but we had no choice.
23 MR. DIFRANCESCO: You're not an accountant,
24 but you are an accounting, but you're not an
25 accountant, but it seems like Mr. Brown is actually
Page 354
1 smarter than the both of you because it seems like
2 he got both of you. It went off with both your
3 money. But I think you're smart enough to realize
4 that you didn't have to take that money.
5 THE WITNESS: Yeah.
6 MR. DIFRANCESCO: You could have waited and --
7 THE WITNESS: We tried -- we tried --
8 MR. DIFRANCESCO: -- and tell the insurance
9 company I want to -- I want to -- we want to get
10 our own people in here to look at that.
11 THE WITNESS: Yeah. The reasons why we -- one
12 of the reason why we took it as well, because we
13 try -- we were going to get the damage fixed with
14 it, but the reason was because he kept lying to his
15 insurance company saying he didn't know us, and we
16 wanted to show that -- the insurance company
17 actually cut a check because he was on our roof,
18 because he kept lying to them and telling them
19 because we -- telling them that he don't know us,
20 he never been on our roof, but then he pulled the
21 permit. And they were like send us the permit so
22 we can see it.
23 MR. DIFRANCESCO: When you had the mold
24 remediation people come out --
25 THE WITNESS: Yes, ma'am -- yes, sir.
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1 MR. DIFRANCESCO: And you did have them come
2 out?
3 THE WITNESS: Uh-huh.
4 MR. DIFRANCESCO: And I know this because
5 that's what my neighbor does. Whenever he goes --
6 you get called out. The first thing he does is
7 contact the insurance company to -- in -- in the
8 middle and make sure that you get everything that
9 you deserve.
10 THE WITNESS: The insurance company, his
11 insurance company doesn't cover it. It doesn't
12 cover mold. No. It's a lot of things that we're
13 still on our own that we still have to pay for.
14 MR. DIFRANCESCO: I understand. Okay.
15 MR. CHAIRMAN: Mr. DiFrancesco, are you --
16 MR. DIFRANCESCO: Yes, I'm done.
17 MR. CHAIRMAN: Mr. Roberts, I'm going to
18 expound on what Mr. DiFrancesco was trying to say.
19 Is -- is there a way -- should we come to an
20 agreement that you would allow Mr. Campbell back on
21 your roof and not pay the additional $3,000?
22 THE WITNESS: Yes, I would. If we pay him, he
23 have to fix those damages because we have to pay
24 for that.
25 MR. CHAIRMAN: So if we ask him to go back on
Page 356
1 your roof and complete the contract proposal,
2 whatever documentation, County wants him to rip
3 everything off, he rips everything off, they get
4 the nail inspection, they get the sheathing
5 inspection, they get the underlayment, they get all
6 that, and we pass inspection, and your roof is
7 exactly what you paid for, would you pay him the
8 additional $3,000?
9 THE WITNESS: Just for the roof?
10 MR. CHAIRMAN: Uh-huh.
11 THE WITNESS: Can I speak with my wife just
12 for a second before I answer that question?
13 MR. CHAIRMAN: I have no problem with that,
14 yeah.
15 MR. MATHEWS: And Mr. Leonard, I would -- I
16 would say under that scenario, if -- if we can --
17 what I would suggest is that if you guys go in
18 caucus, the lawyers have an opportunity to talk for
19 -- see if we can craft something that works that we
20 can propose to you, that would be satisfactory.
21 But one of the things that I would like, that I
22 think would give comfort to the parties, is if the
23 $3,000 is placed in Deana's trust account, and it
24 sits there, and there's some sort of a settlement
25 agreement that reflects when -- when the roof
Page 357
1 passes inspection that within 48 hours or
2 something, the money is then tendered to my -- to
3 my trust account.
4 MR. CHAIRMAN: Absolutely.
5 MR. MATHEWS: I think that -- that's -- that's
6 fair. We'd be -- we'd be willing to do that.
7 MR. CHAIRMAN: Okay. Mrs. Barbieri, do you
8 want to -- how does this work? Can we, like, go
9 chitchat for a little bit or --
10 MS. BARBIERI: Assistant County Attorney
11 Katherine Barbieri, the Board cannot talk, because
12 of the Sunshine Law, in anything but in the open.
13 So you -- and you're here to make a decision on the
14 disciplinary hearing only, whether or not they're
15 in violation; and if they're in violation, your
16 remedies are outlined in the code. If you want to
17 take a ten-minute break and let them see if they
18 have a resolution, and you feel that would come --
19 because when you make your decision, you consider
20 the gravity of the violation, the actions taken to
21 remedy the violation, but if you want to give them
22 five minutes to talk, that's fine, but the Board
23 can only talk in the open.
24 MR. CHAIRMAN: Thank you for that
25 clarification. I wanted to make sure on that.
Page 358
1 Mr. Roberts?
2 THE WITNESS: Yes. My wife is telling me that
3 those holes that they ripped down, it wasn't
4 covered under the policy, under his policy because
5 they stated that it was work that was started, not
6 damages that happened afterwards. So it wasn't
7 covered.
8 So moving forward, if we have them come out
9 and do it, if he can't -- it will be nice for him
10 to just do the -- the ceiling, the damages they
11 caused, I have no problem paying them the $3,000.
12 MS. FALCE: If -- if I could just chime in for
13 a moment --
14 MR. CHAIRMAN: Yes, please.
15 MS. FALCE: While your proposal for the escrow
16 account and all of -- all of that is -- seems
17 practical to me, I am not the lawyer for the
18 homeowners. I'm the lawyer for --
19 MR. CHAIRMAN: The County.
20 MS. FALCE: -- the County staff, and so I
21 cannot advise them one way or another. I don't
22 have an attorney/client relationship. And so to
23 the extent that it's helpful for the County staff
24 to weigh in on what's necessary to bring it to code
25 and to finish those things, we -- we are happy to
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1 have that conversation. But as far as accepting
2 any -- any funds into my firm's escrow, they --
3 they are not my client and I -- I -- I don't
4 feel -- you know, that wouldn't work, but --
5 MR. CHAIRMAN: Okay. Well, the County has
6 attorneys and I would imagine they have a trust
7 account.
8 MS. BARBIERI: This is Assistant County
9 Attorney Katherine Barbieri, again, we would --
10 that is not the County's position.
11 We do not -- it's a civil matter on the actual
12 money and the repairs. Again, we're here for the
13 disciplinary action on -- for the disciplinary
14 action. The County would not hold the trust
15 account.
16 MR. CHAIRMAN: Thank you, Mrs. Barbieri.
17 Anybody else on the Board have any questions
18 for Mr. Roberts?
19 MR. MATHEWS: I have a couple short ones.
20 MR. CHAIRMAN: Okay.
21 MR. MATHEWS: Thanks.
22 RECROSS EXAMINATION
23 BY MR. MATHEWS:
24 Q. Mr. Roberts, do you have a mortgage on the
25 property?
Page 360
1 A. Under -- under my name?
2 Q. Yes.
3 A. There's a mortgage on the property but not
4 under my name, if that's what you're asking.
5 Q. Okay. And so generally mortgage companies
6 require that you have insurance, correct?
7 A. We can't one because it can't pass inspection.
8 Q. But it was -- the -- the insurance was
9 canceled prior to?
10 A. Somewhere around there.
11 Q. Okay. So did -- as a homeowner or somebody
12 had an interest in that property, were you paying taxes
13 and insurance on your own?
14 A. No. The mortgage company stepped in and we
15 are paying extra because they are using their insurance.
16 Q. So there was an escrow fund; you were
17 escrowing fees on a monthly basis to then satisfy
18 insurance and taxes?
19 A. I'm not sure how they do it -- did it, but we
20 paid them our same mortgage payment and it went through
21 the same way. Whatever amount that they added on,
22 that's what we paid.
23 Q. Generally --
24 A. Before -- the insurance we had before was
25 still being paid through the mortgage. It was added
Page 361
1 into the mortgage.
2 Q. Okay. I don't understand how there was a
3 lapse. Generally mortgage companies insist upon there
4 being insurance to protect themselves, right? I just
5 don't understand how there was a lapse in coverage.
6 A. Well, that's how it -- it's going. I'm not
7 sure.
8 Q. You referenced that -- one of the things I
9 think you've been hung up on is the -- the damage to the
10 drywall. Mr. Campbell didn't cause that damage, did he?
11 A. Abe Shultz did.
12 Q. Mr. Campbell didn't, did he?
13 A. Abe Shultz did. The company Abe Shultz,
14 because that's who came. The company and the crew for
15 Abe Shultz.
16 Q. Well, isn't it Brown and his crew?
17 A. The same guys, give or take a few of them, one
18 or two of them, didn't come back, but it was the same
19 crew. The same exact people that showed up with
20 Mr. Brown, they showed up with Mr. Campbell as well.
21 Q. Could you go after Mr. Brown and get that
22 money back from him?
23 A. We tried but Mr. Campbell made -- reassured us
24 that, you know, he would talk to Mr. Campbell --
25 Mr. Brown and he would get everything done. So we end
Page 362
1 up going -- because like I said, Mr. Campbell, he played
2 the nice role. You know, he picked up our phone calls,
3 he listened, we vent to him thinking that he was just
4 the assistant and he was going to talk to Mr. Brown.
5 Q. But you wrote -- you already said you wrote
6 checks -- gave money to -- to Brown, right?
7 A. Yes.
8 Q. So you have a legal cause against Brown?
9 A. Not at the moment.
10 Q. Okay.
11 A. Because Mr. Campbell came on our roof and did
12 roof work, and he assured us that he would not allow
13 Mr. Brown to ruin his company. This was in December
14 when we find out this man is the owner that was telling
15 us he's the secretary the entire time.
16 MR. CHAIRMAN: Mr. Roberts, Mr. Mathews has
17 asked that question multiple times. You've
18 answered it multiple times. Thank you.
19 MR. MATHEWS: No additional questions.
20 MR. CHAIRMAN: Does anybody on the Board have
21 any questions for Mr. Roberts?
22 (No response.)
23 Thank you, Mr. Roberts.
24 THE WITNESS: Thank you, guys.
25 MR. MATHEWS: For our next witness we'll call
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1 Milton Brown a/k/a Andrew Brown.
2 Deana, did you subpoena him to come today?
3 MS. FALCE: Did I subpoena him?
4 MR. MATHEWS: Yeah.
5 MS. FALCE: I did, but he's not here.
6 MR. MATHEWS: I'm sorry?
7 MS. FALCE: I did, but he is not here.
8 MR. MATHEWS: Was he served?
9 MS. FALCE: Yes and we released -- we released
10 him from the subpoena after he was served, after
11 speaking. That was our subpoena.
12 MR. MATHEWS: You released him from the
13 subpoena?
14 MS. FALCE: He lives in Miami-Dade County,
15 which is more than 100 miles away from this
16 commission and --
17 MR. MATHEWS: Okay. I guess we won't be
18 hearing from him.
19 MS. FALCE: Did you serve your own subpoena?
20 MR. MATHEWS: I'm not going to be
21 cross-examined, but thank you.
22 At this point, the Respondents rest. We would
23 like to do closing arguments, but how -- how can
24 we -- Ms. Barbieri, how can we facilitate an
25 opportunity for the lawyers and the homeowners to
Page 364
1 have a discussion?
2 MS. BARBIERI: I guess it's up to the Chair
3 whether they want to give you five minutes to do
4 that or not or whether they want to go straight to
5 closing arguments and issue a decision or they --
6 you could do closing arguments. The Board can't
7 issue a decision. It's not like a judge, they can
8 go back into chambers and -- and withhold their
9 decision, you know, until later. They have to do
10 everything in the Sunshine. So they have to meet
11 to issue a decision.
12 MR. CHAIRMAN: So Mrs. Barbieri, it -- it --
13 can we have a discussion as the Board members how
14 they feel or is it my decision solely?
15 MS. BARBIERI: No. You can definitely --
16 definitely take input from the other Board members
17 on how they want to -- to proceed. I mean, you
18 could take closing and then withhold -- if -- like
19 I said, give them five minutes or you could
20 withhold -- decide not to issue a decision, but if
21 there's no decision issued, there will be --
22 everything just remains status quo at that point,
23 and then, you know, and then ask for input from
24 everybody at the next meeting or something like
25 that. It's basically a kind of a continuance, I
Page 365
1 guess.
2 MR. CHAIRMAN: And the -- because I'm
3 struggling with we have a disciplinary case in
4 front of us, is what we're here to vote on.
5 MS. BARBIERI: That's it.
6 MR. CHAIRMAN: We're also trying to figure out
7 how to help --
8 MS. BARBIERI: Yeah, and that -- and I
9 appreciate that, but the Board is here for
10 disciplinary only.
11 MR. CHAIRMAN: Okay. Thank you.
12 MS. BARBIERI: The -- the help is -- is -- you
13 know, if you want to give them time -- you could do
14 closing. Close it, that way, there will be no more
15 witnesses or anything presented and then just
16 continue the decision making to the next Board
17 meeting. That way you have closed the thing so
18 that if they don't resolve it at the next board
19 meeting, when you make a decision, staff can -- or
20 they -- you know, it will be based on the record.
21 That I guess staff will have to get you the
22 minutes.
23 MR. CHAIRMAN: I would like to hear closing
24 arguments.
25 MS. FALCE: Okay.
Page 366
1 MR. CHAIRMAN: Yes, please.
2 MS. FALCE: Thank you. Well, we've all spent
3 a lot of time together today and I very much thank
4 everyone on this Board for volunteering their time
5 to listen to staff's presentation of their case and
6 also Mr. Campbell's case. We -- we appreciate the
7 time that you spent to do that.
8 There's been a lot of testimony and evidence
9 presented to you today, not all of it relevant to
10 the inquiry that is before you all. And part of
11 your power as the Contractor Licensing Board -- as
12 the Examining Board, you have the power to revoke
13 or suspend Mr. Campbell's Certificate of Competency
14 if one of the following -- if you find that one of
15 the following has occurred. And the three
16 violations that the notice to Mr. Campbell
17 contained were the following:
18 Disregards and violates an applicable state or
19 local building code, regulation or law. You heard
20 extensive testimony today from Mr. Cicio as well as
21 the two building inspectors, Mr. Johnson and
22 Mr. Heffelfinger related to the violations of the
23 building code that are applicable to this home, and
24 those are specifically Sections 110.5, which
25 requires inspections through out the project of the
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1 Florida Building Code, Section A-110.6 which
2 requires approval, and then finally, Section
3 706.7.1.2 of the Florida Building Code for existing
4 buildings, which particularly deals with the -- the
5 distance between the nails when the sheathing is
6 nailed in.
7 There were pictures showing that that was
8 insufficiently done when this roof -- at least in
9 the 8x8 portion that Mr. Heffelfinger watched them
10 take up and reveal during his inspection on
11 April 13th. So there's clear evidence that there
12 is a building code violation for this roof.
13 The next is, That performs any act which
14 assists a person or business in engaging in the
15 unlicensed business of contracting as defined
16 herein, if the certificate holder knows or has
17 reasonable grounds to know that the person or
18 business is unlicensed. And when you look at the
19 definition of what the business of contracting,
20 what a contractor means in the code, it's a person
21 who is qualified for and shall only be responsible
22 for the entire project contracted for, and means
23 the person who, for compensation, undertakes to
24 submit a bid to or do himself or by others
25 construct, repair, alter, remodel, add to, subtract
Page 368
1 from or improve any building or structure.
2 And we heard testimony today from Mr. Campbell
3 that he provided the bid form, the proposal form
4 for his company to Mr. Brown to submit to property
5 owners for projects. Whether Mr. Brown intended to
6 perform those projects or hand them off to
7 Mr. Campbell, but he submitted those bids.
8 There's also evidence in the record from
9 Mr. Cicio, during his investigation, he spoke with
10 Mr. Brown and he -- where he stated that Mr. Brown
11 considered Mr. Campbell and Abe Shultz Constructing
12 (sic) his qualifying agent. And that was
13 discovered during his investigation.
14 Finally, the last section is: Commits fraud
15 or deceit or other misconduct in the practice of
16 contracting. And so when the bids were given,
17 Mr. Brown represented that he was part of
18 Abe Shultz Construction, LLC, according to the
19 testimony of the homeowners, as well as Mr. Cicio
20 and his investigation. And when they contacted
21 Mr. Campbell to ask about it, they were under the
22 impression that he was the secretary/assistant, and
23 not the owner of the company, and were told things
24 that were untrue, according to their testimony, as
25 well as Mr. Cicio's investigation of those -- of
Page 369
1 those actions.
2 And so there is ample evidence, competent
3 substantial evidence from people here before you
4 today that satisfies all three of the violations
5 that the County staff has noticed Mr. Campbell in
6 violation of the Contractor Licensing Board
7 requirements.
8 And finally, given all of that evidence here
9 before you, the staff is recommending that the
10 Board, one, suspend the permitting privileges for
11 Lindolph Campbell, Abe Shultz Construction, LLC for
12 a period not to exceed 365 days; two, require that
13 a written request be made to the Board to reinstate
14 Abe Shultz Construction, LLC, Lindolph Campbell,
15 permitting privileges after the one-year
16 suspension; three, require that all inspections up
17 to and including the final inspection for the
18 roofing permit under Abe Shultz Construction, LLC
19 for the address of 4032 Greenwood Drive,
20 Fort Pierce, Florida shall be obtained within three
21 months of this Board's order date, or a fine not to
22 exceed $10,000 shall be imposed; and four, require
23 that all inspections be performed by a licensed
24 St. Lucie County building inspector.
25 Finally, staff also recommends that the Board
Page 370
1 forward a copy of the Board's order to the
2 Florida Department of Business and Professional
3 Regulations and the surrounding municipalities.
4 We thank you for your time and rest.
5 MR. CHAIRMAN: Thank you, Ms. Falce. Thank
6 you, very much, appreciate that. Mr. Mathews?
7 MR. MATHEWS: Board, thank you for your time
8 today. I know it's been a long day and a fair
9 amount of exhibits. It's been messy back and
10 forth. Part of this is compounded by the fact that
11 there are not depositions, so I have to ask
12 questions blindly, figure out from the record
13 what's going on, what may have happened, what
14 didn't happen, cross-examine witnesses at the same
15 time. So I appreciate your patience. It's a
16 little bit messy. It's kind of like making
17 sausage, but at the end, you know, you kind of get
18 the flavor of it.
19 There is no doubt that this was a messy
20 transaction with -- with the Crooks and Roberts.
21 Nobody would want to plan it out this way. No
22 contractor, no professional would -- would want to
23 have a -- a situation go from bad to worse, but
24 this kind of happened. And it's -- it was a mixed
25 bag in terms of who knew what and who was doing
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1 what, but I think we figured out a few things
2 today. And I think that there are some substantial
3 reasons to deviate from the recommendation of the
4 attorneys from the -- from the County and to not
5 provide such a harsh result to a guy who's a
6 one-man shop who's trying to put food on the table.
7 He's a hard working guy. Unfortunately, I didn't
8 elicit to testimony, the guy's been working with
9 his hands since he's 12-years old. Four hundred
10 clients, four or five hundred roofs, A Plus rating
11 from Triple B, and everybody knows if you -- if you
12 complain to the Better Business Bureau, they will
13 tag you. You will have problems. That's not the
14 case with this company.
15 This seems like it was a tremendous anomaly.
16 A number of things, like I said, went -- went
17 wrong. Andrew Brown, I would have liked to have
18 heard from the man. He wasn't here. He had a
19 substantial impact on what happened in this thing,
20 and it's been the testimony from my client that he
21 wasn't aware of the proposal. Was it not good
22 business practice to provide him with a proposal
23 sheet? I think we could agree probably so, but it
24 wasn't like this was a routine practice of them
25 coming and going and doing all this business. It
Page 372
1 was a couple instances. You had a guy,
2 Andrew Brown, who was a handyman. AB Handyman. He
3 did certain jobs. When he got a lead that was
4 above his -- his -- his pay grade, above what he
5 could do, he would call in for assistance and he
6 was getting some money on the side, not big money,
7 a finder's fee. Hey, here's a job that you can do
8 and -- and Lindolph was hungry. He's trying --
9 trying to get by. He's a competitive builder --
10 bidder. He probably underbid this -- or this job
11 was probably drastically underbid, but I think it's
12 important to know that there are certain material
13 gaps in what happened in this relationship.
14 The video, what would that video have said?
15 Hey, I'm just walking off the area. We're trying
16 to -- to get a repair. We got a couple things we
17 want to get done here. I -- I don't know. It
18 wasn't produced. If it was produced, I gotta think
19 it was going to help me in some way. I gotta think
20 it was something in there or it would have been
21 produced.
22 We heard from Mr. Roberts. Initially he
23 called, one little leak. It was a nail head, and
24 now he's going to change out an entire roof that's
25 in a "C" shape. I thought it was an "L" shape.
Page 373
1 That's a big job. You don't get a couple of quotes
2 from that. You get one quote from a guy who's
3 going to put rubber sealer on it for $11,000. You
4 get another quote from a guy who says he can do it
5 for seven grand, but you saw, as best we could,
6 because we didn't have the original
7 eight-and-a-half by eleven piece of paper that had
8 the proposal on it, that it was going to be a
9 repair.
10 Now, when the homeowners got up there and they
11 looked at it, they go, "Well, geez, this isn't what
12 we wanted," but that must have been some part of
13 the relationship or else why would they agree to
14 pay the man another $4,000 above that. You're
15 going from a $7,000 proposal to an $11,000
16 proposal. Something happened then. It wasn't just
17 some drywall. It was a material change in the
18 product -- project.
19 My guess is that the AB Handyman came in there
20 and said, look, I can -- I can do a patch job here.
21 We can do this area, but we're not doing the whole
22 thing. And then when they saw what was going on,
23 they weren't happy with it and they wanted to -- to
24 renegotiate. But what's interesting about the
25 August proposal and the September proposal is that
Page 374
1 they were unknown to Lindhurst -- Lindolph. He was
2 in the dark on this. So he had a rogue guy with
3 some proposal slips who sent this one out. And
4 Lindolph finds out about it later. What does he
5 decide to do? This is bad. He's like -- he looked
6 at it and he said in the -- in the one portion,
7 I'll do the work above here, but I'm not doing the
8 bottom work. Eleven thousand dollars, I'm going to
9 honor that proposal. It's not something I want to
10 do, but I'm going to do it because I want to
11 protect my reputation. I want to protect my
12 company. And I think he wanted to do what was
13 right by -- by the homeowner.
14 He's trying to figure out what happened. He
15 realized that Brown took a lot of money. He thinks
16 he can get the money back from Brown in some
17 capacity, out of gentlemanliness, I don't know,
18 business relationship, community relations. That
19 didn't happen. So -- but you heard testimony at
20 the end of the day he didn't receive $8,000. He
21 hasn't received any money for this job. He laid
22 out money for materials, laid out money for -- for
23 guys being in a hotel room, had the impression that
24 he was going to get $3,000 at the end of the job to
25 try to scrape together something to pay his guys.
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1 He never got that.
2 And you know, I think we saw it in -- if there
3 was a situation that was appropriate for Mr. Brown
4 to go out and provide estimates, the mechanism
5 should have been, You know what, Mr. Brown, you go
6 out and get a proposal, bring it back to me, let me
7 see it, let me counter-sign it, and then go out and
8 deal with it. That process didn't happen.
9 So Mr. DiFrancesco, when you said, Hey, it
10 looked like there was performance under the
11 contract, it was because Abe Shultz was honoring a
12 contract that he didn't know about, but he felt
13 that he could because he was going to cobble
14 together what he thought was the honor of Brown in
15 bringing some money back to him because he knows
16 that he screwed him, or he screwed the homeowner,
17 and the remaining money under -- under the
18 contract. That didn't happen. But what did happen
19 in December is that Lindolph went and got -- got
20 the permit. He was trying -- trying to do the
21 thing, trying to get it done.
22 January 1 he goes there, figures out the scope
23 of the project, says, Ah, the drywall, the solar,
24 that's not me. Somebody else made that deal,
25 sorry, can't do it, but I will do the other. And
Page 376
1 then I think the material work was done on the 13th
2 and the 14th, guy worked hard. Then he -- he felt
3 like he satisfied his end of -- end of the bargain.
4 He wanted the money. Homeowner said forget it,
5 we're not paying you.
6 So he's frustrated. You got Lindolph who's
7 saying I just busted myself up here. I'm now out
8 money. I can't get this done. It was messy. He
9 went back -- he had several conversations with
10 Mike. He had conversations with others. Hey, I
11 want to go -- I -- I'll -- I'll try to figure this
12 out. I gotta save some money to get -- get the --
13 to get the materials because they're not cheap, and
14 I gotta take a crew up there, but he was prepared
15 to do so. You heard testimony that a crew was
16 going up there to take care of it. The -- the plug
17 was pulled on that. That didn't happen. And that
18 was -- that was unfortunate, but as we -- we -- the
19 other thing that's a question mark is the
20 insurance. I still don't understand that.
21 The homeowner's insurance, I don't understand
22 how that happened, and that's -- that's
23 unfortunately a problem because maybe that would
24 solve some -- some of the issues here.
25 But the other issue is that there was a claim
Page 377
1 made on Abe Shultz's insurance, and that was paid.
2 And in theory, that sort of satisfied a lot of the
3 damages that we're talking about, including the
4 sheetrock. It's not Abe Shultz's fault if the
5 homeowner didn't consult with counsel, get their
6 own -- their own investigator in there, get their
7 own property appraiser and say, Hey, guys, it's not
8 $14,000, it's $18,000.
9 And by the way, this solar thing, I -- I have
10 no evidence that the thing ever worked. I mean,
11 we're talking about damages for equipment that --
12 that we've never seen operated. And it says here
13 install water brackets. It doesn't say remove it
14 and reinstall it, so -- and that's what Nicki
15 wrote. If Nicki wanted to be detailed about what
16 was happening, for all we know, those -- that water
17 heater stuff was on the -- could have been in the
18 dirt for months. So I don't know where that comes
19 from.
20 I think the -- the crux of this job comes down
21 to a couple components. It's the Brown component,
22 which I think we flushed out. It's a period of
23 time when this gentleman didn't know what was going
24 on there. He was rogue. Maybe it was bad that he
25 trusted him in some capacity. Maybe -- but he was
Page 378
1 not acting with -- with actual authority. He
2 didn't have a business -- business card. He had a
3 proposal sheet. Anybody could come up with a
4 proposal sheet off the -- off the Internet. It
5 happens to be there was some sort of a very loose
6 relationship, but it wasn't like these guys were
7 doing business all the time together.
8 Then we come down to the flat roof.
9 Abe Shultz agreed to do the flat roof. They
10 thought they did a job that was consistent and
11 would have passed, would have gotten passed
12 inspection. Some pictures were taken, yep, better
13 pictures could have been taken. And I suppose if
14 he were a lawyer he would have said who he spoke to
15 at the County commissions office who said you don't
16 have to have somebody physically appear. Do it in
17 writing. Oh, I spoke to this person on this date.
18 That's unfortunately not the way this -- this
19 operated, but he did have a good faith basis that
20 he could take the pictures and get it resolved at
21 the end -- at the end.
22 There were some pictures there. I think that
23 they reflect workman-like work. There were some
24 nails that are missing and we -- we've gone past
25 that. We've said, you know what, he'll agree to
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1 take the old roofing off, renail it, get it
2 permitted, have it pass inspection, every -- every
3 step of the way. He's agreed to do that.
4 So we're -- we're left with a couple of
5 things. Was this intentional that he didn't -- he
6 didn't nail the boards down properly. I don't
7 think so. I mean he didn't say, Hey, I'm trying to
8 save money on nails, guys. Looks like -- somebody
9 in the -- in the quality control department didn't
10 -- didn't do it. It was -- it was rusty nails. My
11 guess is that they didn't look at the area that was
12 already done. They were more focused on the area
13 with the fresh plywood. And we saw the pictures
14 and one of the guys from the County said, Yep,
15 here's a picture of some fresh plywood and I'm
16 seeing a lot of nails in it. So I think that that
17 was -- it's not fraud. It's not -- it's not
18 intentional misconduct to try to mess up or -- or
19 cut a corner. These are guys who made a mistake on
20 a contracting job, and they've already said --
21 we've said in -- in the opening I said, he'll go,
22 he'll do it. He'll rip it off, he'll redo it
23 again, at his own cost and money. Why is he doing
24 it? Because he's a guy who's a contractor. He's
25 trying -- he's been in business for years. He's
Page 380
1 trying to get by. He doesn't want problems. He
2 wants solutions. Why would Lindolph not go and do
3 the work? Because he was getting hamstrung by the
4 homeowners. We want you to do this drywall work.
5 We want you to put in the -- the solar stuff. I
6 don't know, there's drip trays or something. Stuff
7 beyond what Lindolph thought he could bear out of
8 -- out of this proposal, that he never saw, that he
9 didn't -- that he didn't present.
10 So I think he acted honorably. You heard from
11 him multiple times, he did not authorize or -- or
12 say, you know what, Brown, you go out and you get
13 jobs. I'm going to fill them, and that's the deal,
14 and you get 25 percent of it. The guy made at most
15 750 on one project and maybe 300 on another. He
16 did a smash and grab with these homeowners.
17 Lindolph has a claim against him. He's
18 ruining his reputation. He's -- he's -- he's
19 portraying himself as a member of an organization.
20 He can't prevent that from happening. I get it, if
21 -- if Lindolph was here and -- and you go, Well,
22 this is the fifth time he did it. Then it's on
23 him. This is the first instance he knew about
24 this. Otherwise, they were small jobs that he was
25 bringing to him. So he didn't think much of it at
Page 381
1 the time, but later, this thing snowballs and all
2 of a sudden he's responsible for a pretty -- a big
3 piece of work. His reputation is getting
4 tarnished. He's now subject to potentially not
5 ever being able to do business in this County
6 again, which -- and I get it. You guys, this is
7 your County, it's your sandbox, you get -- if you
8 don't think people are doing it right in your
9 County, you have the ability to exclude them. But
10 365 days, maybe that's fair. That's up for you
11 guys to decide. I don't think it should be
12 lifetime. If he has to reapply, he has to reapply,
13 but a referral to the State for one job, a couple
14 of nails in an 8x8, and he's already said he'd redo
15 the whole thing. He'll do it. You guys will
16 inspect it I'm sure. All these guys will come out
17 and they're going to look -- you know, measure
18 every one, which is great. I want it -- if he's
19 going to do it, it's gotta be done right. But you
20 can't take away the man's career. You refer him to
21 the State, then he's got to appear before the
22 State. This could look really bad for him.
23 One -- you know, all of a sudden, some nails
24 and a messy timeline is coming back to him and it
25 all started from this guy Brown, who's nowhere to
Page 382
1 be found. I can't even examine him in this thing.
2 Can't get any documents from him.
3 So this is an important case. You guys have a
4 lot of power, a lot of responsibility. You're
5 gatekeepers in the community. Abe Shultz does not
6 normally do work in this -- in this neck of the
7 woods, and maybe this will prevent him from wanting
8 to ever do so again, but I don't want it to wreck
9 his career. I don't want it to -- to tarnish his
10 reputation such that it tears down over a decade
11 of -- of doing -- of doing work.
12 One other -- I want to touch on a couple other
13 things. I think the homeowners have a -- have a
14 very good beef with Brown. Brown misled them. He
15 took their money. He took their money in a
16 personal capacity. If they want some justice in
17 this, go after Brown. Go get the money back from
18 him.
19 I'm concerned about the reliability of the
20 homeowners. There was some things that I asked
21 them questions about that I didn't get -- get very
22 good responses on, the production of documents, the
23 video, the photographs, the couple different
24 versions of the -- the contract. I don't know if a
25 diligent effort was made to locate those documents;
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1 and if they weren't produced, perhaps there was
2 something in there that was going to tilt the
3 scales in favor of -- of the Respondent in this
4 case.
5 The other thing that I -- that I found highly
6 suspicious is that you've got two years, two years
7 of agonizing pain with the roof, and leaks and
8 people not showing up. And there's not one text
9 message between a husband and wife who've been
10 involved in every communication, every substantive
11 matter concerning this event, they've both been
12 together at the same time. It defies credibility.
13 It's -- it's not possible. They don't -- they
14 don't text each other about it. Nothing --
15 WhatsApp, nothing? So why? There was something in
16 those communications that maybe was going to tilt
17 the scale in favor of -- of the Respondent in this
18 case.
19 I'd like to be able to resolve this. This
20 isn't your traditional case where the parties can
21 just go out in the hallway and say, Well, let's --
22 let's figure this out. Let's -- let's shake hands,
23 let's try to figure a way -- and -- and I do
24 appreciate perhaps the Board taking some time in
25 abeyance and deliberating on this at a future time,
Page 384
1 so we do have an opportunity to talk. I'd be more
2 than happy to -- to speak with County, happy to
3 speak with the homeowners, see if we can fash --
4 fashion some sort of a remedy, but the -- the thing
5 that's -- the ball that's in your court is the
6 disciplinary action concerning this gentleman and
7 his company. And that's very significant. And
8 that's the thing that I would urge you to be very
9 deliberate about in terms of what actually was the
10 misconduct. Was it intentional? And I think I've
11 pointed out a variety of reasons why it wasn't
12 intentional. And he wasn't trying to take a short
13 cut. He was duped by somebody else.
14 So I think that those are all -- all factors,
15 and the fact that the man's willing to come back
16 here and -- and say, you know what, I'll -- I'll
17 fix it. I want to make it right because that's who
18 he is. That's -- that's what he did in December
19 when he found out about that bogus proposal. He
20 goes, I'm going to honor it. I'm going to make
21 due. Got -- got the permit, and January he -- he
22 was gangbusters in there for three days to knock it
23 out, because he wanted it off his plate, wanted the
24 homeowner satisfied, wanted to move on with -- with
25 business, realizing that it was a loss for him.
Page 385
1 Whether he got the money from -- from Brown and the
2 homeowners on the $3,000, he was still going to
3 probably break even at best.
4 So I urge you to exercise discretion and --
5 and not punish the company and this individual in
6 such a -- an overly harsh way. What I would
7 recommend is that Abe Shultz Construction and/or
8 Lindolph Campbell be provided with a reprimand, but
9 -- and -- and I don't know how it works. If you
10 guys were to go further than that and yank his
11 ability to do business in the County, then he's not
12 able to perform the work on -- on their roof, which
13 he wants to. And he can't afford probably to pay
14 somebody else to do it. I think that that might
15 bankrupt him.
16 So then that doesn't help the homeowner and it
17 doesn't help the County. The County I think wants
18 to protect its residents. So if you were to bar
19 him, I guess I would say -- is there an exclusion
20 for -- for one property? I don't know. That's
21 something for -- for you guys to -- to -- to think
22 about.
23 I'll look -- I just want to check my notes for
24 a moment here.
25 The homeowners spoke a little bit about
Page 386
1 continuing leaks in the property. I -- I don't
2 know if I have -- I haven't not seen competent
3 evidence regarding that. If there were leaks in my
4 -- in my property, my roof on a particular date,
5 I'd have a video of it raining down. I'd have
6 pictures saying, Look at the drips, look at this.
7 I'd have it timestamped down, especially the way
8 these guys are. These guys are on the roof,
9 walking around, taking pictures. So I don't know
10 if there is continual damage, but it also defies
11 logic that you would accept a check and enter into
12 a release with an insurance company without knowing
13 the full extent of your damages. I mean, the
14 document -- the release was signed February 1, I
15 think, three weeks ago. If -- if they signed the
16 release knowing that there was continuing damages,
17 and that they could get more from the insurance
18 company, that's -- shame on the homeowners. I
19 mean, they -- they went to his -- his insurance
20 company. They could -- they could have squeezed
21 that -- that lemon pretty hard. I don't know if
22 they did. I don't know if they -- it doesn't sound
23 like they tried to, but that shouldn't be on these
24 Respondents to have to deal with a fault in the --
25 in the process.
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1 So again, it was messy. We're trying to make
2 it right. I'd like the opportunity to make it
3 right, and that's it. Thank you.
4 MR. CHAIRMAN: Thank you, Mr. Mathews.
5 And with respect to one of your comments at
6 the end, we would be suspending his permitting
7 privileges. He would still have the opportunity to
8 close out the existing permit. So for -- for your
9 reference and your knowledge, if we did, the Board
10 did decide to suspend his license, he would have
11 the opportunity still through the County and to be
12 able to close out that existing LB permit.
13 MR. MATHEWS: I appreciate that, and if that
14 were a part of -- part of your findings or order,
15 if you could carve that out in there just so it's
16 clear from an administrative standpoint.
17 MR. CHAIRMAN: I first and foremost want to
18 also say thank you to staff, thank you to everyone
19 being here today. Sorry we did not get a lunch
20 break. That's on me. I apologize. But thank you
21 guys for being here all day. There's a lot of
22 information, a lot of testimony, a lot of -- a lot
23 of muddy things that I think came out through this
24 as -- as closing statements said on both -- on both
25 points, but we are here to look at the violations
Page 388
1 that are in front of us and to see if Mr. Campbell,
2 in fact, did this. And you know, staff has
3 recommendations and we are simply looking at his
4 state certification for his license for roofing,
5 not for general construction, I believe; and, also,
6 the County Certificate No. 31981, which is the
7 number that was on top of that proposal, as the
8 County's certificate number, and that's on it as
9 well. So a little clarification on that.
10 MR. MATHEWS: When does the Board meet again?
11 MS. JOHNSON: March 16th.
12 MR. MATHEWS: I'm sorry, I didn't hear you.
13 MS. JOHNSON: March 16th.
14 MR. CHAIRMAN: We -- we meet again in three
15 weeks.
16 MR. MATHEWS: Okay.
17 MS. BARBIERI: So Mr. Chairman, Assistant
18 County Attorney Katherine Barbieri, the Board has
19 heard closings. You may decide to deliberate and
20 issue an order today, if you wish on the three
21 violations brought forward by County staff. If
22 that's what you wish, I'll read you the -- the law
23 to refresh your memory on that and so you
24 understand what you're looking at, or the Board may
25 decide if they want that they can -- you can have a
Page 389
1 motion to continue and hold your decision making in
2 abeyance until the next meeting to let the parties
3 talk and then take that into consideration as part
4 of your -- the corrective action. And I believe
5 right now those are the two decisions before the
6 Board.
7 MR. CHAIRMAN: Mrs. Barbieri, I would actually
8 like to hear the law, please. Thank you.
9 MS. BARBIERI: What?
10 MR. CHAIRMAN: I'd like to hear the -- the law
11 of the first one.
12 MS. BARBIERI: The first one would be -- I'll
13 read the law then.
14 MR. CHAIRMAN: Thank you.
15 MR. MATHEWS: One final housekeeping matter, I
16 think this would be valuable if the Board were to
17 have this as -- as an exhibit, a live exhibit.
18 They can get it back at the end of it, but it is an
19 original, but it's -- I think it's part of the
20 record.
21 MS. FALCE: So if I -- I guess my -- my only
22 objection would be, we're taking away the original
23 contract from the party whose possession -- it --
24 it's their property. I'm not sure how the -- the
25 Board clerk handles exhibits like that, that we
Page 390
1 can't just make a copy and -- and provide it. It's
2 -- it's the original and it's the only one.
3 MR. MATHEWS: It's a piece of evidence though.
4 I mean that --
5 MS. JOHNSON: We can make a copy of it and --
6 MR. MATHEWS: -- this is evidence related to
7 the case. It doesn't matter whether it's original
8 or not. If you accept --
9 MR. CHAIRMAN: I believe everyone on the Board
10 has seen that. That's the one with the green
11 writing on top --
12 MR. MATHEWS: I don't know whether you guys
13 want to inspect it further or not.
14 MS. BARBIERI: We could make color copies.
15 The Board has accepted copies in the past. It's
16 the -- you know, it's the Board's decision, as long
17 as we have a -- an accurate complete copy of it and
18 we can make it in color.
19 MR. CHAIRMAN: Yeah. It was provided in the
20 packet of information we were providing and then
21 original document was then passed around to
22 everybody. We've all had an opportunity to see the
23 -- the green writing. So I -- I would say no.
24 We've all seen it on the Board. Does anybody need
25 to see it again? Anybody need a copy of it again?
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1 MR. SAMPSON: No.
2 MR. CHAIRMAN: Okay.
3 MS. BARBIERI: Are you ready?
4 MR. CHAIRMAN: Yes, ma'am.
5 MS. BARBIERI: Yes, sir. So under
6 section ten sixty-seven, revocation or suspension
7 of Certificates of -- of Competency, if it's
8 determined that the contractor or the business for
9 which the certificate holder is a qualified agent,
10 has committed any of the following acts, and staff
11 has listed the three acts that you see in your
12 packet. I will read them again. So if -- if
13 they've committed -- disregards and violates an
14 applicable state or local building code, regulation
15 or law, performs any act which assists a person or
16 business in engaging in the unlicensed business of
17 contracting as defined herein, if the certificate
18 holder knows or has reasonable grounds to know that
19 the person or business is unlicensed, or -- and
20 these are ors, you don't have to find all three of
21 these in violation, you could find just one of
22 them -- commits fraud or deceit or other misconduct
23 in the practice of contracting. If you find one of
24 those, then under the dis -- disciplinary hearing
25 procedures, if after the hearing the Contractor's
Page 392
1 Licensing Board finds that there has been
2 misconduct by a contractor, said Board may, but
3 shall not be required to impose any of the
4 following enumerated sanctions alone or in
5 combination: Revocation of their St. Lucie County
6 Certificate of Competency, suspension of St. Lucie
7 County Certificate of Competency, denial of issue
8 or renewal of St. Lucie County Certificate of
9 Competency. The last one is a period of probation
10 of reasonable length, not to exceed two years,
11 during which the contractor's contracting
12 activities shall be under the supervision of the
13 Contractor's Licensing Board and/or participation
14 in duly accredited program of continuing education.
15 Any period of probation or continuing education
16 program ordered by the Contractor's Licensing Board
17 may be revoked for cause by said Board at a hearing
18 noticed to consider said purpose, a fine not to
19 exceed $10,000, a public reprimand. And again,
20 each of these are an or, reexamination requirement
21 or denial of the issuance of St. Lucie County
22 building permits or requiring the issuance of
23 permits with specific conditions; and, also, you
24 could order reasonable investigative and legal
25 costs for the prosecution of the violation.
Page 393
1 When imposing any disciplinary sanction on a
2 contractor, a person holding a Certificate of
3 Competency or a state certified contractor who's
4 been found to have violated this article, the
5 Contractor's Licensing Board shall consider all the
6 evidence presented at the hearing, as well as the
7 gravity of the violation, the impact of the
8 violation on the public health, welfare or safety,
9 any actions taken by the violator to correct the
10 violation, any previous violations committed by the
11 violator, and then any other evidence presented at
12 the hearing by the parties relevant as to the
13 sanction which is appropriate for case given the
14 nature of the violation and the violator.
15 MR. CHAIRMAN: Thank you, very much,
16 Mrs. Barbieri. Now we have an open discussion
17 or --
18 MS. BARBIERI: Yes, you may.
19 MR. CHAIRMAN: Mr. Pride, Mr. Jerger,
20 Ms. Taylor, Mr. DiFran, Mr. Langel?
21 MR. DIFRANCESCO: Yes, sir. Well, there's no
22 doubt in my eyes that I believe Mr. Campbell is
23 guilty of one, if not all three of the violations,
24 definitely the second violation of aiding and
25 abetting an unlicensed contractor. He said that
Page 394
1 himself in his own testimony here. I'm not buying
2 the thing that he doesn't -- he's running out of
3 money, you know, and he doesn't have the money to
4 fix the roof because in today's market, he said he
5 did 400 roofs. I'm sure he got paid. I'm not
6 buying that he's going to go bankrupt or not have
7 any money. I do have a problem with one of staff's
8 recommendations, which is forward it to the --
9 MR. CHAIRMAN: DBPR.
10 MR. DIFRANCESCO: The Board's order to -- how
11 do you say it?
12 MR. CHAIRMAN: DBPR.
13 MR. DIFRANCESCO: Yeah, that. But I would
14 like to make a motion, unless anybody wants to talk
15 about it.
16 MR. CHAIRMAN: I'd just like to make a comment
17 real quick and -- you know, we went over in the
18 last couple years on this Board the civil penalties
19 for fee comparison, and, you know, first time
20 violation, second time violation, third time
21 violation, so on, so forth. You know, first time
22 violation up here in the County, first time coming
23 to this County might be his last. We'll never
24 know, time will tell. So I would just ask that the
25 Board would take that into consideration.
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1 Mr. Langel?
2 MR. LANGEL: I'm for a motion.
3 MR. CHAIRMAN: Ms. Sheila, do you have
4 anything?
5 MS. TAYLOR: Well, yeah, actually, I do have a
6 couple things I'd like to throw out here.
7 MR. CHAIRMAN: Please.
8 MS. TAYLOR: After an entire day of listening
9 to all of this, there was an awful lot of the -- he
10 didn't know, they didn't know. Well, as far as I'm
11 concerned, ignorance of the law is no excuse.
12 I mean, if you're a contractor, you're
13 supposed to know what you're -- what you're
14 required to do and what you're -- what the
15 requirements are for roofing. And -- and if you
16 don't do it, you need to go back and do it. And
17 I'm sure that the inspectors would gig you, and if
18 you don't fix the gig, shame on you.
19 And I don't understand why you wouldn't want
20 to go out there and fix it, unless of course you
21 didn't know, but if you didn't know, why didn't you
22 know? It was your proposal. Who in their right
23 mind gives their company's paperwork to somebody to
24 go out and do whatever with. That's just nuts.
25 And if you do it, then you kind of are responsible.
Page 396
1 And I just think that if you gave a proposal sheet
2 to somebody that went out and got a proposal, you
3 should be demanding an answer from that person that
4 you gave that proposal sheet to. Like what went
5 on, what happened, how much are we doing, what are
6 we doing, and if you just ignore the fact that you
7 gave it to the guy and let the guy do whatever,
8 then you're responsible.
9 MR. SAMPSON: I think documentation is kind of
10 the thing as is -- the proposal just came across as
11 very -- very broad, document, I mean it's -- it's
12 just -- it's -- it's -- it's just lacking in -- in,
13 you know, the specifics, and there is some concern,
14 you know, without having Mr. Brown here, and I do
15 have a problem when I look at this proposal with
16 the additional parts in it, but, you know, at the
17 end of the day, I guess that really doesn't matter
18 because it's more so about the actions that -- that
19 were taken, and Mr. Campbell had people working for
20 him that he cannot document as either being
21 directly employed for Abe Shultz Construction or as
22 any sort of documentation for a subcontractor as
23 well.
24 So you know, in my mind, I -- I -- I do think
25 the second violation does definitely need to stay
Page 397
1 in there.
2 MR. CHAIRMAN: You know, one of the things
3 that I remember hearing, and I jotted it down as
4 very important to me, was Mr. Campbell was on that
5 roof personally. Mr. Campbell stated that he
6 worked on that roof for two days. Mr. Campbell was
7 there with his crew doing that. And I also firmly
8 believe that if Mr. Heffelfinger, when he went out
9 there and had those three places removed, if those
10 nails were done correctly, we wouldn't be here,
11 because I think he has the right intentions. I
12 think he actually wanted to do the right thing to
13 that homeowner, and then just got caught when he
14 ran out of money.
15 I don't think he's a bad guy. I think he
16 cares. I think he cares about the product. I
17 think he cares about the people, I think he cares
18 about doing the right thing.
19 MR. DIFRANCESCO: Mr. Chairman, I got to -- I,
20 too, have an issue with the proposal where
21 Ms. Crooks wrote in about the water heater and
22 brackets. It wasn't on the original proposal. She
23 wrote this one in here. Mr. -- we're not here to
24 question Mr. Brown because he's not here. I don't
25 know if they know that Mr. Campbell here came to
Page 398
1 fix everything and they decided they had something
2 else on or not. You can't tell if it was on the
3 roof or who took it off the roof or if it was
4 working.
5 I know that staff is recommending that the
6 Board, on No. 3, where the job gets completed. How
7 do we fix staff's recommendation on getting the job
8 completed if it's a he say, she say thing on who's
9 going to put that water heater back on the roof?
10 Unless they come to an agreement before we make a
11 motion? I don't -- I mean, I'm ready to make a
12 motion.
13 MR. CHAIRMAN: Mr. Di --
14 MR. DIFRANCESCO: I can see where it's going
15 to get sticky in -- in between those two after
16 we're done. And I know that's not our --
17 MR. CHAIRMAN: No.
18 MR. SAMPSON: An I ask a quick question, with
19 that, should we just focus on not so much the
20 proposal but the scope of work in the permit?
21 MR. PRIDE: That's what I was going to say. I
22 think we need to go by the scope of work and the
23 permit.
24 MR. CHAIRMAN: I feel the same way, the scope
25 of work and the permit.
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1 MR. SAMPSON: So technically the water heater
2 brackets and the drywall would not be part of his
3 roofing permit, and then that would have to be
4 settled --
5 MR. CHAIRMAN: Civilly.
6 MR. SAMPSON: -- outside and civil.
7 MR. DIFRANCESCO: Civil matter.
8 MR. CHAIRMAN: Yep.
9 MR. SAMPSON: Which they already received
10 funds for from the insurance company.
11 MS. TAYLOR: Yeah. But, see, that's not up to
12 us.
13 MR. SAMPSON: It's not, yeah. That's what I'm
14 saying is --
15 MR. CHAIRMAN: Any further discussion?
16 MS. TAYLOR: It's definitely not up to us.
17 MR. SAMPSON: -- it's more so about the
18 completion of the permitted work.
19 MS. TAYLOR: That's not even up to us either.
20 It's whether he went according to --
21 MR. SAMPSON: Or not. They want him to
22 complete it, but I don't think there's enough
23 definition here.
24 MS. TAYLOR: Well, that's true.
25 MR. CHAIRMAN: Sheila, I can barely hear you.
Page 400
1 MS. TAYLOR: It's supposed to be an open
2 discussion, right?
3 MR. CHAIRMAN: It is. I can barely hear you
4 though.
5 MR. SAMPSON: No, I -- I -- I just going back
6 to the -- I -- I -- I like the idea of the
7 homeowners being made whole and having their
8 project finished, even though it's, you know,
9 longer than any of us would like to see.
10 MR. CHAIRMAN: We all do, but, unfortunately,
11 that's not in front of us right now.
12 MR. SAMPSON: But -- but we still want to see
13 the houses in our communities completed and up to
14 code.
15 So, you know, if we could, you know, have that
16 be a part of it. But there are some stipulations.
17 I don't know, you know, if we would have control
18 over one, would be the homeowners allowing
19 Mr. Campbell back onto the property. You know, I
20 don't -- I don't know if, like, we can make that
21 part of ours or -- but also, you know, as far as --
22 as you know, as long as it's specifically stated
23 that the permit is for the -- or excuse me, the
24 work completed is for the permit, then that makes
25 -- that makes a little bit more sense to me.
Page 401
1 MS. BARBIERI: Mr. Chairman, I would request
2 when a motion is made they -- the motion maker tell
3 us what subsections, if any, they're finding in
4 violation and why, and then we -- again, these are
5 just recommendations from staff. You can take one,
6 or none of them, or all of them, or you can make
7 your own based on the rules that I read. And then,
8 obviously, if it's seconded, then you can open it
9 up for more -- further discussion from the Board
10 also.
11 MR. CHAIRMAN: Thank you, Mrs. Barbieri. I'd
12 be willing to entertain a motion.
13 MR. DIFRANCESCO: Mr. Chairman, I'll make a
14 motion.
15 MR. CHAIRMAN: Yes, Mr. DiFrancesco.
16 MR. DIFRANCESCO: I'll make a motion that we
17 find Mr. Campbell in violation of Subsection 4,
18 performs any act which assists a person in
19 business -- a person or business in engaging in the
20 unlicensed business of contracting.
21 He stated himself that he does do business
22 with Mr. Brown and he does pay him to -- give him
23 money to -- to help him. Like I said, I feel
24 that -- actually, you know, his own words in -- in
25 my eyes violates it.
Page 402
1 I'd like to make a motion to revoke
2 Mr. Campbell's roofing license in St. Lucie County
3 for 365 days. I also -- if he wants to come back
4 here and work, he should have a written request
5 made to the Board to reinstate him, his permitted
6 privilege after one year.
7 Number 3, I'd like him to fin -- to go over
8 there and make the -- and finish the job. I do
9 understand that that's going to depend on the
10 homeowner allowing him to step foot back on the
11 property. If they're not willing to let him work
12 on the property anymore, then I don't think that
13 No. 3 would be -- would come into effect.
14 MS. TAYLOR: That's true.
15 MR. SAMPSON: Would he be required to have a
16 hold harmless?
17 MR. DIFRANCESCO: I'm sorry?
18 MR. SAMPSON: Would he be required to go for a
19 hold harmless, to be removed from the permit?
20 MR. DIFRANCESCO: Yes. I don't agree with
21 recommending a -- to forward a copy of the Board's
22 order to the Florida Department of Business and
23 Professional Regulation.
24 MR. CHAIRMAN: So your motion is to revoke for
25 365 days, after -- he must come in front of the
103 (Pages 403 to 405)
14a1ee71-ec15-49a3-8e03-9c913fa632d6Electronically signed by Karen M. Bellemare (301-293-169-3900)
Page 403
1 Board after a year, and to finish the permit --
2 MR. DIFRANCESCO: Yes.
3 MR. CHAIRMAN: -- pending owner's approval
4 allowing him on the property?
5 MR. DIFRANCESCO: Right.
6 MR. CHAIRMAN: We have a motion on the floor.
7 MR. PRIDE: I'd second it.
8 MR. CHAIRMAN: We have a second by Mr. Pride.
9 Open for discussion. So no fees, no penalties, no
10 monetary --
11 MR. SAMPSON: I did like the idea of the
12 continuing education. I think some -- some
13 construction --
14 MR. DIFRANCESCO: I believe it was my
15 understanding that he was fined.
16 MR. SAMPSON: Mr. Brown was fined.
17 MR. CHAIRMAN: Mr. Brown was fined.
18 MR. DIFRANCESCO: Mr. Brown was fined.
19 MR. SAMPSON: Yeah.
20 MR. CHAIRMAN: Mr. Campbell was never fined.
21 MR. DIFRANCESCO: This is his first offense?
22 MR. CHAIRMAN: This is his first offense.
23 MR. DIFRANCESCO: I would like to --
24 MR. CHAIRMAN: Keep that in mind.
25 MR. DIFRANCESCO: I would like to amend my
Page 404
1 motion to include a first offense fine of $500.
2 MR. SAMPSON: But you still don't want the --
3 the going before the DBPR?
4 MR. DIFRANCESCO: No.
5 MR. CHAIRMAN: So we have an amended motion to
6 include a fine of $500 for first offense?
7 MR. DIFRANCESCO: Yes, sir.
8 MR. CHAIRMAN: Thank you, Mr. DiFrancesco.
9 We have a motion, Mr. Pride, amended motion.
10 Do you second --
11 MR. PRIDE: I'll second.
12 MR. CHAIRMAN: -- that amended motion. You
13 second that amended motion?
14 MR. PRIDE: Yes.
15 MR. CHAIRMAN: Any further discussion?
16 (No response.)
17 Madam Secretary, would you please call a
18 vote -- a voice vote, please?
19 MS. JOHNSON: Mrs. Taylor?
20 MS. TAYLOR: Yes, ma'am.
21 MS. JOHNSON: Mr. DiFrancesco?
22 MR. DIFRANCESCO: Yes, ma'am.
23 MS. JOHNSON: Mr. Jerger?
24 MR. JERGER: Yes, ma'am.
25 MS. JOHNSON: Mr. Leonard?
Page 405
1 MR. CHAIRMAN: No, ma'am.
2 MS. JOHNSON: Mr. Pride?
3 MR. PRIDE: Yes, ma'am.
4 MS. JOHNSON: Mr. Langel?
5 MR. LANGEL: Yes, ma'am.
6 MS. JOHNSON: Mr. Sampson?
7 MR. SAMPSON: Yes, ma'am.
8 MS. JOHNSON: It passed.
9 MR. CHAIRMAN: Thank you. Thank you again,
10 staff. May I have a motion to adjourn? Or, no, we
11 have to -- what's next on the agenda? I apologize.
12 MS. BARBIERI: No. I believe that's it.
13 MR. JERGER: No more business.
14 MR. CHAIRMAN: No more business. Disciplinary
15 case. Old business. Any old business? No old
16 business? No new business? Can I have a motion to
17 adjourn?
18 MR. LANGEL: Motion to adjourn.
19 MR. CHAIRMAN: Motion to adjourn by
20 Mr. Langel.
21 (Concluded at 5:25 P.M.)
22
23
24
25
14a1ee71-ec15-49a3-8e03-9c913fa632d6Electronically signed by Karen M. Bellemare (301-293-169-3900)
Page 406
1 STATE OF FLORIDA )
:SS
2 COUNTY OF ST. LUCIE )
3
4 CERTIFICATE
5 I, KAREN M. BELLEMARE, FPR, a Shorthand
6 Reporter, certify that the foregoing transcript,
7 Pages 1 through 405 inclusive, was transcribed from
8 an audio recording that was provided by
9 St. Lucie County. The transcript is a true and
10 accurate transcription to the best of my ability.
11 I certify further I am neither attorney nor
12 counsel for, nor related to, nor employed by any of
13 the parties to the action, and further, that I am
14 not a relative or an employee of any party in this
15 action, nor am I financially interested in the
16 outcome of this action.
17 Dated this 12th day of May, 2022.
18
19 _________________________
20 Karen M. Bellemare, FPR
21
22
23
24
25
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A
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175:15 179:20
180:11,16,17
182:19 184:15,16
184:16 199:14,15
203:20 204:3,5
207:10 217:7
226:7 227:10
230:7,10,12 231:9
233:12 234:18
236:3,14 250:4
251:10 253:23,24
254:10,14 274:14
275:4,6 279:17
280:21,23 290:5
291:14 292:21
294:2 295:3,15
317:5 326:25
327:25 328:7,12
329:15 330:21
332:14 333:20
334:6 336:2,24
345:13 350:24
352:6 355:20,25
361:18,22 364:8
370:9 374:16
375:6,15 376:9
381:24 382:17
384:15 389:18
395:16 398:9
400:5,19 402:3,10
backed 76:8
background 126:5
126:7 342:8
bad 192:2 326:19
331:6 370:23
374:5 377:24
381:22 397:15
badly 209:15
bag 370:25
balance 93:15
174:14 182:22
234:18 334:1
ball 384:5
bank 70:18 131:21
165:7,23
bankrupt 385:15
394:6
bar 385:18
Barbieri 7:6,8,9,16
32:22 33:17,18
66:16,19,24 67:2
67:5 110:1,12,20
111:19,22 112:3
129:16,17 281:19
282:2,8 298:7,10
298:14 299:11,16
299:21 300:1
303:15,17 306:21
306:23 308:1
357:7,10,11 359:8
359:9,16 363:24
364:2,12,15 365:5
365:8,12 388:17
388:18 389:7,9,12
390:14 391:3,5
393:16,18 401:1
401:11 405:12
bare 12:20 22:1
39:23 40:7,9
barely 23:18 32:7
162:12 183:19
399:25 400:3
bargain 376:3
base 12:21 39:23
285:6
based 15:15 20:15
22:7 33:12 37:14
47:8 55:5 56:14
61:4 78:12 103:1
Page 410
138:9 159:4 178:2
181:19 214:11,16
227:3 238:5
255:14 259:3
271:8,20 365:20
401:7
bases 5:16
basic 65:17,21
basically 29:9 39:4
39:5 52:3 223:2
282:16 364:25
basis 218:2 360:17
378:19
Bass 1:17 5:1
Bates 44:5
bathroom 97:15
339:20
Beach 13:15 19:24
bear 7:16 184:12
296:13 380:7
bedroom 54:4
116:1 351:15
bedrooms 351:5
beef 382:14
beer 116:3,13
341:16
began 15:20 16:12
70:25 79:22 80:2
149:22 160:20
beginning 67:22
78:20 88:8 98:21
101:1 112:10
148:16 159:22
198:16
begins 148:19
behalf 8:6 21:14
312:24
believe 26:20 29:2
29:18 32:2,18
33:18,20 37:23
38:24 41:3 46:14
46:15,25 49:11
50:1 51:14 56:22
60:11,16 61:13
62:6 74:19 77:25
78:5 81:4 83:2
84:7 85:4 95:24
96:2,25 99:7,7,18
99:22 100:11
102:1 109:22
114:1 115:7
116:24 118:2
123:16,19 125:13
125:16 127:25
138:2 139:6
146:12 151:15
155:7 161:22
166:22 167:7,19
173:7,24 176:21
178:17 179:7
184:2 194:6
195:17,17,23
196:6,21,21 197:6
197:9 201:4 227:8
251:16 270:6
271:18 273:15
275:11 302:5
303:21 309:3
328:25 347:9
388:5 389:4 390:9
393:22 397:8
403:14 405:12
Bellemare 406:5,20
belonging 93:12
beneath 134:22
benefit 106:2
best 9:8 67:25
145:3 183:19
373:5 385:3
406:10
better 133:9 135:16
137:19 145:10
147:24,25 151:24
152:3,25 163:6
168:12 257:24
283:3 322:8
329:16 371:12
378:12
bewildered 236:9
beyond 9:5 245:10
257:12 380:7
bid 367:24 368:3
bidder 372:10
bids 368:7,16
big 230:25 292:14
330:1 339:19
372:6 373:1 381:2
bigger 24:18
161:13 220:13
billing 44:3
bit 29:7 73:3,10
74:2 81:25 94:6
98:10 114:23
127:22 154:15
160:7 161:24
164:3 179:4
190:12,21 214:2,8
226:15 258:6
308:24,24 329:15
335:23 352:7
357:9 370:16
385:25 400:25
black 161:21
blame 270:13
blank 134:5,13
208:8 209:2
284:15
blindly 370:12
blocked 331:4
blow 41:12 343:10
blue 114:6
blurry 40:12
board 1:4,11 2:6,10
2:11,15,19,21,23
3:4 4:25 10:14
11:6 22:8,12,24
27:17,25 28:4,10
29:10 30:20 33:18
40:18 56:21,24
61:2 66:5,13 67:1
67:3,5 98:10
101:1 109:19
110:11,15 112:7
118:10 119:8,8
125:12 144:5
156:15 171:17
172:2 185:8 192:3
192:18 194:13
218:22 227:14
259:24 275:10,11
275:19 277:13
279:19 282:12
288:16 298:9,12
298:15,22 307:18
312:2,7 323:17
343:20 357:11,22
359:17 362:20
364:6,13,16 365:9
365:16,18 366:4
366:11,12 369:6
369:10,13,25
370:7 383:24
387:9 388:10,18
388:24 389:6,16
389:25 390:9,15
390:24 392:1,2,13
392:16,17 393:5
394:18,25 398:6
401:9 402:5 403:1
Board's 22:20,25
348:7 369:21
370:1 390:16
394:10 402:21
boards 23:18 379:6
boat 254:17,22
body 27:2,6 51:11
259:9
bogus 384:19
bold 243:24
bombarded 86:13
book 35:23 37:3
43:20 53:3 132:13
132:19 144:9
164:20 203:16,19
230:17,18,19
313:3,5
borrow 141:18
boss 68:24
bottle 116:3
bottom 23:24,24
41:6,19 42:5
45:10,11,11 72:17
101:5 106:25
136:2 156:22
199:9 243:16
374:8
bought 344:21,23
345:21
bounce 214:7
bow 214:2
box 42:5,13,17
45:11 47:24
bracket 321:6,18
brackets 48:9,11
49:4 72:8,9 149:6
154:24 255:5
293:3 300:15
377:13 397:22
399:2
brand 352:24
break 66:6 87:17
109:1,2,10 192:16
193:3 242:3 304:4
304:7 357:17
385:3 387:20
breakdown 350:17
brief 6:21 66:9 73:6
109:11 151:9
192:24 193:5
197:9 304:8
briefly 194:16
216:22
bring 27:14 92:6
109:23 236:3
256:25 294:5
296:11 298:21
358:24 375:6
bringing 245:14
272:17 273:13
375:15 380:25
brittle 353:5
broad 103:18
396:11
broke 56:12
brother 68:14,20
88:22 129:15
142:19 145:22
284:1 311:20
brother's 111:6
344:2
brother-in-law
88:15 129:6
brother-in-law's
129:8
brothers 142:20
brought 8:17 54:3
94:25 105:12,21
109:23 110:9
118:3 161:18
198:11 298:23
302:7 330:14
339:7 388:21
Broward 89:4,5
Brown 9:18 11:7
11:15,18,22 14:11
Page 411
14:15 15:9,15
16:1,6 18:13,20
18:21,23 19:5,17
19:19 20:1,7,7,16
21:9,15,18 24:12
24:15 30:6,10,12
32:11,15 36:25
37:4,16,16,19
38:1,7,20,22,23
39:1,2 41:4,7 53:7
53:7 68:2 69:2,16
69:22 70:12 71:12
73:4,20 74:5,9,13
76:10 77:6,14,17
77:21 78:1,5,13
79:3,12 80:11,14
80:16,17,21,23
81:1 84:15 88:9
88:18 89:14,21,24
90:3,22,25 91:4
92:15 93:13,25
94:1,15 96:12,16
97:2 100:7,12
107:2 121:20,21
122:8 124:6,9
128:23 130:23,25
131:3,20 133:10
133:13,14,20
135:14 138:10,14
138:14,25 139:8
139:12,12,15,19
139:21 142:5
143:16,16,17,21
145:9 146:6
147:16,20 150:15
152:15 153:5,20
154:19 155:7,10
155:13 156:23,25
157:2 158:8
159:11,23 160:5,8
161:6 162:7 163:8
163:25 164:13
165:5,10 166:3,6
166:15 167:1
173:13 175:12,13
184:13,14,17
186:10,13,17,20
186:23 188:13,13
230:1 232:17,24
235:4,5,7,8,10,12
235:13,18,22
237:4 242:12,17
244:10 245:8
246:1,23 247:1,10
247:19,23,24
249:14,21 250:13
252:18,19,20
253:16 255:15,19
255:22 261:2
262:8,11,18,25
263:6,7,7 264:6
264:16 265:19
267:7,8,24 269:3
270:18 271:19
272:7 273:1 274:6
276:11,21 277:3
277:17 283:14,17
283:21 284:4,20
285:16,22,24
286:8 287:19
289:9,14 290:5
297:7 300:19
301:9,10,20
310:14 313:15,25
315:6 317:1
318:21 322:4,24
323:4 324:6
325:19 326:21,22
330:23 331:6,7,24
332:18 333:4,11
333:23 334:18
336:21,23 337:1
341:4,10,21 342:2
342:4 353:25
361:16,20,21,25
362:4,6,8,13
363:1,1 368:4,5
368:10,10,17
371:17 372:2
374:15,16 375:3,5
375:14 377:21
380:12 381:25
382:14,14,17
385:1 396:14
397:24 401:22
403:16,17,18
Brown's 8:13 20:10
94:20 136:5
165:23 185:15
188:6 265:18
buckets 330:11,13
330:15
buckle 211:11
build 291:10
builder 372:9
building 5:21 6:8
6:11 9:17 11:24
13:4,8 14:3,5,18
14:23,23 15:24
16:11,23 17:10,15
17:23,24,25 18:5
18:15 21:22,23
22:23 31:6,11
39:7,15 40:4,5,25
46:19 49:17,19
55:13 58:25 60:14
62:14,15,24,25
63:2 104:23
106:12,12,15
169:9,10,15 171:3
172:6 175:24
192:15,25 193:7,8
193:17,19,23,24
196:2 197:4,25
198:5 200:9
207:17 213:3
214:4,15 217:18
221:18 222:8
225:23 251:8
257:8 281:7,8
297:3 366:19,21
366:23 367:1,3,12
368:1 369:24
391:14 392:22
buildings 212:10
367:4
built 214:11
bunch 208:3
224:11 269:23
270:3
burden 296:12,13
Bureau 13:15
19:23 283:3
371:12
burned 102:14
burns 117:5
business 5:23 9:18
18:8,9,12,14,22
18:25 19:4,7 20:9
20:17 23:1 69:11
78:18 80:20 100:7
121:25 124:8
138:21,25 140:22
140:24 141:6
153:12 158:22
165:14 185:18
187:1 190:8
192:19 241:14
242:18 243:4
271:22 272:23
275:12,13,15
283:3 285:25
293:5 305:9,10
307:15,21 308:12
308:17 325:13,14
325:16 326:1
327:6 338:24
339:6 340:20
367:14,15,18,19
370:2 371:12,22
371:25 374:18
378:2,2,7 379:25
381:5 384:25
385:11 391:8,16
391:16,19 401:19
401:19,20,21
402:22 405:13,14
405:15,15,16,16
businessman
324:16
busted 376:7
busy 73:7,15
buy 240:7 353:2
buying 394:1,6
Byrd 277:25
C
C 3:1 372:25
call 3:4,6 6:21
60:24 62:14 66:11
68:23 72:23 73:7
77:21 82:1 85:8
89:13 93:21
116:19 138:7
146:1,6 171:14
175:12 184:6
190:18 192:14
193:7 195:18
204:11,17 217:8
217:22 218:4
219:3 237:4,5
240:8,23,24
245:11 246:1
247:16 257:5
292:7,8,8 298:24
298:25 299:8,22
304:1,10 311:19
311:21,22 316:3,4
317:21,22,24
326:20 331:7,11
331:12 333:23
343:3,10 351:22
362:25 372:5
404:17
called 29:8 30:24
49:23 75:23 76:16
77:14,15 83:8
89:1 94:18 99:10
99:12,14 116:10
122:14 139:16
145:10 189:24
191:23 196:9
197:7 207:12,21
212:15,22 215:11
215:14,16 216:2,9
216:10 222:5
233:22,24 234:6
237:6 240:11
254:4,13 261:5,6
262:25 263:8
288:12 291:23,25
292:5 305:12
317:9,10 331:4,17
331:17 333:9
335:8 336:1,11,12
342:4 347:15
355:6 372:23
calling 6:6 53:19
68:12 77:24 94:25
236:6,21 237:4
246:8,11 254:1
343:25
calls 73:6,20 80:14
209:6 218:1
225:23 362:2
Page 412
camera 111:19
Campbell 2:18
5:10,18 8:7,9,12
9:9 10:16 12:5
14:2,15 16:17,25
17:8,13 18:18
19:2,3,6,10,14,18
20:8,12,16,23
21:6,16,20,25
22:2,9,13,18
28:25 29:4,8 30:5
30:8,11 32:4 39:6
49:24,25 54:24
55:12,14 56:5,14
58:6,17 60:11
64:1 68:2 72:23
73:22 74:6,11,11
74:14,17,25 75:14
75:19,20 76:14,25
77:6,15 78:8,11
78:15,23 79:2,6
79:11 80:6,14,21
80:23 81:1,2,7,9
81:12,16,17 82:13
82:23 83:24 84:8
84:15 85:5,9 86:4
86:18 93:20,24
94:2,2,8,23 95:11
96:1,10,21 97:1
99:20,25 106:11
116:10 122:1
123:20 124:5,17
124:19 128:23
137:25 138:2
155:25 156:3
159:14 160:5,8
166:13,19,21
167:2,8,11,16
168:8 170:4,13,23
173:5,23 174:6,8
174:12,21 175:15
175:20 178:21
179:18 181:12,24
183:6 184:18
185:11 186:4,11
186:18,21,22
187:15 195:18,21
195:24 196:20,22
207:12,21 212:22
220:8 222:21
223:6 228:13,15
228:19,19,22,24
241:9,23 244:11
260:21 261:2
271:2 272:15
274:2 277:9,14
279:20 280:8
282:13,20 297:2
298:1,11,13 302:6
302:8 310:14
315:7 316:5
317:10,14,18
318:22 323:18
324:6,8,9 326:18
326:20,21 331:5,7
331:9,21 332:8,17
333:2,5,8,14,16
333:24 334:8,20
334:24 335:17
337:7 339:14
340:10 341:21
342:10,12,22,25
343:2,6 347:15
355:20 361:10,12
361:20,23,24
362:1,11 366:16
368:2,7,11,21
369:5,11,14 385:8
388:1 393:22
396:19 397:4,5,6
397:25 400:19
401:17 403:20
Campbell's 17:16
21:5,10 138:6
366:6,13 402:2
cancel 83:18,23
canceled 16:22
30:24 31:1,2
32:23 33:1,12
45:15,17,21
244:13 344:25
345:2,6,7 360:9
cap 51:4
capacity 309:15
374:17 377:25
382:16
captured 57:1
carbon 11:20 132:1
166:2
card 12:16 124:11
124:18 138:22,25
153:12 190:8
198:18 201:11
285:25 327:6
338:24 339:6
340:21 378:2
care 68:25 72:7
73:18 74:15 77:19
80:11 93:4 122:13
228:18 312:11
332:9 376:16
career 381:20
382:9
cares 397:16,16,17
397:17
carpenter 34:15
cars 98:13 327:11
327:12
carve 387:15
case 4:20,23 5:4,7,8
10:14,15 14:11
21:21 22:7 57:7
57:13,13 62:16
64:7,8 65:19
99:24 117:21
184:7 194:13
212:20 213:24
220:4 249:2
271:17 275:20
283:22 285:21
288:18 298:18
299:2 303:22,24
305:6 365:3 366:5
366:6 371:14
382:3 383:4,18,20
390:7 393:13
405:15
cases 116:13,14
cash 277:11 324:24
325:17
cashier's 11:16
15:18 70:11,17
71:25 93:11
165:22
casual 41:10
190:14
catch 329:13
330:11
categories 63:24
category 64:4
caucus 356:18
caught 272:19
397:13
cause 117:2 179:16
361:10 362:8
392:17
caused 37:23 100:9
179:9,13 213:13
321:12 339:17
349:18,20 351:4,5
353:16 358:11
cave 114:4
caving 87:1
CBC1258575 18:16
CCC1331723
18:17
ceiling 53:24 68:8
68:10 79:22,25
80:3 82:11,15,17
86:22 87:1,2 97:8
98:7,10 102:3,5
111:8,8 112:18
113:24 114:4
115:5 154:2,3,25
157:20 163:12
170:15 175:10
182:7,15,20,25
293:13 339:18,20
351:11 358:10
ceilings 191:10
center 200:11
201:20 202:18
205:24 220:16
221:19 225:24
cents 351:25
353:17
certain 7:21 25:8
58:23 117:24
149:23 150:4
179:22 239:3
243:10 278:12
285:4 289:14
372:3,12
certainly 23:8
certificate 18:10
123:23 229:19
366:13 367:16
388:6,8 391:9,17
392:6,7,8 393:2
406:4
certificates 279:21
391:7
certification 61:20
61:22 62:1,3
388:4
certifications
193:20 276:15
certified 10:12 14:2
14:3 18:15,16
46:19 49:18,19
57:12 62:23,24
64:9,10 65:18,20
279:10 307:21
393:3
certify 406:6,11
cetera 176:12
CEUs 62:2
Chair 1:11,12
308:2 364:2
Chairman 3:3,21
4:1,13,24 6:23 7:6
7:15,25 10:4 23:3
23:16 24:23 25:1
25:3,11,15 27:21
28:3 30:4,16 31:8
31:14,17,22 32:13
33:11,15,22 41:14
46:22 47:2,4,7
51:19,24 52:5,14
53:2,12 59:22,25
60:5,8 61:1 63:17
66:3,5,10,16,20
67:2,9,24 68:15
68:18 87:5,7,11
87:13 91:15,18,24
103:5,19,24
106:17,25 107:4,7
107:10,16,18,19
108:1,4,10,11,13
108:18,23,25
109:2,6,8,10,12
109:25 110:21
111:1,13,20 112:5
112:8,12,15,23
113:1,9 114:5,16
Page 413
114:21 118:4,11
118:14 119:3,6,21
119:25 120:2,8,13
120:15,17 121:17
124:23 125:5,8,11
125:16 126:2,8
127:4 128:10,12
128:15,18 129:16
141:20,22 142:22
143:1 144:9,16
159:6 164:19
171:20 184:8,11
188:20,23 189:10
190:13 192:3,7,9
192:12,17 193:1,2
193:4,9 198:11
200:22,24 202:4,9
202:11,13,18,21
202:23 203:14,19
203:22 204:6
205:3,5 209:9,17
210:2 211:25
212:3,5 217:21,25
218:5,9,11,14,17
218:20,25 219:5,7
223:22 226:5,14
226:17,24 227:6
227:13,15,17,24
228:2,7,15,21
229:4 230:21,24
241:9 260:16,20
260:24 261:21
269:7 271:2,11
272:13 274:2
275:2,2,23,25
276:5 277:9,12
278:22 279:8,19
281:19,24 282:7
282:10,16 297:20
298:9,12 299:3,5
299:10,15,20,23
300:3,6,8 303:12
303:16,20,25
304:6,9,12 305:17
306:21 307:6,19
307:22 308:6
309:5,20 310:4,7
313:4,6,9,12
319:12 324:12
338:12,16 343:16
343:19 350:12,15
355:15,17,25
356:10,13 357:4,7
357:24 358:14,19
359:5,16,20
362:16,20 364:12
365:2,6,11,23
366:1 370:5 387:4
387:17 388:14,17
389:7,10,14 390:9
390:19 391:2,4
393:15,19 394:9
394:12,16 395:3,7
397:2,19 398:13
398:17,24 399:5,8
399:15,25 400:3
400:10 401:1,11
401:13,15 402:24
403:3,6,8,17,20
403:22,24 404:5,8
404:12,15 405:1,9
405:14,19
challenge 80:8
175:11
chambers 1:8
364:8
change 11:6 23:17
40:18 70:1,4 90:9
96:9 135:17
147:19 255:2
372:24 373:17
changed 91:14
161:5 162:16
227:7
changes 91:7
changing 235:11
channel 312:11
316:19
Chapter 18:5 33:8
47:16 216:17
characteristics
153:11
characterization
103:13
charge 95:7 186:8
246:5,6 292:7
charged 79:14
175:4,14 185:24
charging 203:22
Chase 70:18 131:22
165:20,23
cheap 376:13
check 11:16,17,20
11:20 15:18 16:5
70:11,17 71:25
72:1 93:11,14
100:17,20 103:8
103:10 121:20,23
122:1 123:12
131:25 132:2
163:14 164:18
165:4,11,23 166:1
166:3,4 247:5
258:2 279:1 303:5
325:1,5,19 354:17
385:23 386:11
checkbook 166:2
checked 123:3
checking 200:16,17
checks 19:9 32:14
32:20 122:7
244:14 362:6
Chief 13:4 21:22
193:8,17,19 222:5
chime 358:12
chitchat 357:9
choice 186:7 266:3
353:20,22
choose 258:1
287:15 288:17
Chris 1:13
Christmas 329:21
chronological
45:12
Ciccio 2:4,5
Cicilo 316:20
Cicio 4:9,9 6:6,17
7:1 10:5,6,7 23:3
25:18,19,22 26:2
26:6,15 27:8 28:1
28:2,5,11,12,20
29:14,17,20,23
30:1,4,7,21 31:4
32:1 33:20,25
34:5 45:1 46:25
47:3,6 53:21
55:23 60:13,16
61:4,7 63:21,21
64:20 66:4 84:7
85:4 99:8 114:1
114:22 119:19,22
142:4 144:18
184:2,22 185:2,4
194:10 198:9
220:3,23 235:11
240:6 279:8,9
281:15,16 292:5
316:20 329:9
366:20 368:9,19
Cicio's 195:12
368:25
circle 206:14,17
circumstances 99:6
212:8,19
citation 36:25 37:4
37:20 38:23
City 72:24 74:19
civil 38:9,10 178:20
271:15,16 359:11
394:18 399:6,7
Civilly 399:5
claim 20:11 21:3,7
21:8,9 99:1,17
100:1,12 101:19
103:7 118:18
177:5,11,24,25
178:10 248:1,4,7
248:8,11,18 249:1
249:10,18 257:21
353:18 376:25
380:17
claimed 18:21,23
19:3 20:7 72:2
77:17 143:20,22
186:22 336:7
claiming 20:24
83:3 100:5
claims 118:18
178:7
clarification 36:6
67:3 110:3 134:7
172:9 357:25
388:9
clarified 121:1
135:14
clarify 26:23 27:22
47:1 110:1 181:23
clarifying 172:21
clear 9:16 28:13
37:18 66:23 74:1
108:1 119:15
120:1 136:9
139:18 178:7
236:18 237:13
292:9 367:11
387:16
clearer 67:1
clearly 103:9 107:5
108:19 284:22
315:10
clerk 389:25
click 24:18
client 59:24 284:23
325:5,8 359:3
371:20
clients 241:16
324:21 371:10
close 4:19 9:11 76:9
181:25 208:5
290:11 346:10
365:14 387:8,12
closed 14:11 80:1
365:17
closer 41:12 47:11
closing 6:22 363:23
364:5,6,18 365:14
365:23 387:24
closings 388:19
cloth 114:3,8
clothes 341:16
clothing 141:5
286:4 306:8
clue 189:9
Clyde 2:16 4:8 6:12
14:5 16:24 21:24
26:16 46:2,21
55:6 62:17 143:3
195:23 196:1,2,5
196:7 197:6
204:13 213:21
216:14 219:9,16
Clyde's 196:21
co-borrower 132:9
co-owner 142:12
Coast 11:16 164:18
Page 414
coat 321:14 322:1
coating 151:19
321:16,24,25
cobble 375:13
code 5:21 6:2 9:17
10:12 14:18,23
16:9,11 17:10,15
17:23 18:5,7
20:13 44:3,3
48:16 61:22 62:24
63:3 104:23
157:12 197:25
198:5 200:9
201:18 209:25
211:2 213:3,5,7,8
214:4,11,15,16
220:4 221:18
225:23 226:6
227:10 256:25
264:14 291:11
294:5 296:11
297:3 339:15
357:16 358:24
366:19,23 367:1,3
367:12,20 391:14
400:14
cognizant 191:2
cohesiveness
250:18
coincides 113:23
collect 236:25
250:23 254:19
272:8,10 330:16
collected 235:22
collection 53:10
58:16 310:25
collects 272:11
color 117:9,15
167:23 390:14,18
combination
164:17 392:5
combined 165:1
come4:17 8:1 22:2
54:5,8 58:11
69:25 71:15,18
82:16 84:9,20,25
85:1 86:1,8 89:3
91:5,12 96:12
97:17 100:21
102:5 113:25
115:3 116:11
117:22 135:15
139:11 143:15
147:18 152:19
161:11 162:7,15
166:10 173:24
175:15 176:9
178:23 179:19,19
180:17 189:2,11
190:25 193:25
207:20 217:7
219:20 234:24
237:21 238:13
240:3,4 241:5
245:9 248:23
251:9 255:22
262:14 263:16
265:12 285:7
286:14 287:2,18
288:17 290:11
293:18 299:6
304:13 320:8
321:14 332:21
333:22 334:25
338:22 346:14
348:16 349:1
350:24 352:6
354:24 355:1,19
357:18 358:8
361:18 363:2
378:3,8 381:16
384:15 398:10
402:3,13,25
comes 24:21 81:13
82:13 85:21
105:11 157:3,4
258:13 272:3
377:18,20
comfort 356:22
coming 68:9 113:22
113:22 114:2
115:11 116:22
175:21 176:7
190:22 191:10
202:24 215:18
240:10 300:8
329:13 335:13
336:18 349:15
371:25 381:24
394:22
Commencement
12:8 43:21 73:23
73:25 74:10 75:18
107:8,9,14 137:23
172:25
commend 273:13
comment 4:16,19
47:13 192:18
270:18 394:16
comments 45:20
387:5
commission 1:8
363:16
Commissioners
144:5 312:2,8
323:17
commissions
378:15
commits 20:13
368:14 391:22
committed 20:19
391:10,13 393:10
committing 5:24
communicate
255:23,25 315:17
communication
55:14 65:10 84:15
132:7,10 137:9
246:25 383:10
communications
64:13,23,24 65:3
65:8 246:22 315:5
315:12,14,19,22
316:24 318:9,15
319:1 383:16
communities
400:13
community 250:12
374:18 382:5
Comp 19:24 124:1
276:13,14
companies 189:18
276:14 326:16
345:10 360:5
361:3
company 8:10
13:21 19:15 20:2
20:8 21:5,10,11
22:4 38:12 39:6
74:8 79:4 81:11
88:24 95:6,6
99:11 100:10,15
103:2,8 105:5
122:15 126:22,23
130:15 142:1,2
145:5,25 150:11
151:16 152:8,10
165:12 170:14,15
177:6 180:15
243:1 244:13
248:4,17 251:20
254:5 257:21
280:9 306:4,8
308:15 321:13
323:10 324:17
325:5,24 326:2
331:14 332:12,16
332:19,19 333:8
333:18,21 334:7
334:25 335:18,22
346:17,18,19,24
347:12 349:8
350:4,6 351:18
353:8 354:9,15,16
355:7,10,11
360:14 361:13,14
362:13 368:4,23
371:14 374:12
384:7 385:5
386:12,18,20
399:10
company's 180:23
288:24 349:12
395:23
compare 43:6
comparison 394:19
compassion 272:16
274:25
compensated 178:5
181:18
compensation 9:24
13:16 19:10,12,16
19:20 20:4 177:12
178:2 181:11
186:13 367:23
competency 123:23
124:10,18 125:2
229:19 366:13
391:7 392:6,7,9
393:3
competent 369:2
386:2
competitive 372:9
complain 371:12
Complainant 24:4
35:19,20 52:24
53:6 120:5
complained 9:7
complaint 5:11,13
9:1 10:23 13:11
15:2 28:17 30:2
35:16 36:14 38:2
49:18 84:1,5
128:25 130:7,16
131:4 140:4 144:4
144:22 160:10
174:4 184:23
186:3 194:14
259:14 312:1,6
323:16,20,24
332:7
complete 8:19 9:5
9:13,20 73:22
81:18 82:24 84:9
84:12 93:16,17
104:7 113:15
114:14 115:25
116:17 137:22
149:4 175:4
183:22 194:25
198:22 208:13
283:12 292:21
305:14,25 306:18
335:11 337:20
339:25 340:4,8
348:10 356:1
390:17 399:22
completed 8:25
11:14 17:4,13
20:22 32:12 33:4
46:4 63:2 75:18
80:5 83:10 98:1
104:18 117:14,16
159:24 173:15,18
174:19,23 180:14
Page 415
182:10,23 194:18
216:12 220:5,7
268:2 271:4,14
337:8 340:7 398:6
398:8 400:13,24
completely 108:2
189:3 230:5
completing 166:6
completion 399:18
Compliance 10:10
13:15 19:23
compliant 339:15
component 377:21
components 377:21
composite 39:11
169:8 208:1
compound 292:2
compounded
370:10
compromised
115:6
computer 19:9
199:15
concern 396:13
concerned 76:6
213:8 214:9
275:19 382:19
395:11
concerning 38:16
39:8,12 52:3 57:9
58:12 64:1 130:14
130:23 313:15
315:5,12,14,23
318:9,15,16
323:17 383:11
384:6
conclude 105:10
Concluded 405:21
condition 224:16
conditions 392:23
conduct 326:1
conducted 13:10
149:15 197:3
confirm 20:10
76:16 223:14
confirmation 76:15
confirmed 19:21
33:11 70:9
confused 181:16
263:3,4 266:13
confusion 71:18
103:23 266:14
conjunction 6:8
connected 341:19
connection 274:8,9
283:24
consider 340:8
357:19 392:18
393:5
consideration
389:3 394:25
considered 277:3
368:11
consist 288:3
consistent 48:24
60:18,21 171:25
172:7,23 211:2,3
285:11,15 309:1
378:10
consoling 334:3
construct 327:8
367:25
Constructing
340:14 368:11
construction 5:9,13
5:17,18 8:6,8,10
10:16 11:2,10
12:2,6,10 13:22
14:12,25 15:4,7
15:11,24 16:3,9
16:12,14,16 17:8
17:18 18:15,25
19:7 20:12 21:13
21:14 22:10,13,17
30:17 31:12 34:11
37:15 42:24 58:12
59:18 64:2 68:24
78:25 88:9 92:16
93:7 94:24 95:15
96:10 99:3,15
100:4 104:7,10
123:3,14 124:7
128:24 129:4
130:15 135:10
137:9 139:3,8
188:10 227:7
231:15,25 232:3
233:17 242:8
244:10 248:2
250:1 251:21
297:2 310:15
315:8 316:25
327:9 338:23,24
339:11 340:16,23
341:1,7,11 348:5
368:18 369:11,14
369:18 385:7
388:5 396:21
403:13
consult 346:20
377:5
consumed 116:4
contact 69:5,5
76:22 88:19,20
89:11,15 96:15,20
99:19,23 124:4
128:21 130:2,4,17
145:9 146:5
178:19 180:19
184:13 248:17,19
310:13 311:18
355:7
contacted 29:4,25
69:22 88:18
130:19,21 180:10
184:14,22 186:4
215:23,25 229:25
232:18 233:1
368:20
contacting 80:10
180:12 242:6
contacts 71:12
contained 103:17
366:17
contemplate
321:20 322:9
contemplated
285:12
contemplating
152:16
contemporaneou...
158:12
contents 116:8
contingency 323:4
continual 386:10
continuance
364:25
continue 77:9 78:2
127:5 186:25
246:1 365:16
389:1
continuing 62:4
78:7 386:1,16
392:14,15 403:12
contract 11:1,4,9
11:12 16:2,13
20:17 21:12 23:6
32:3,3,5,8,19
37:14 79:6,13
81:19,23 82:7,8
92:18 95:7 97:18
130:6,9,11 131:1
135:10 158:7
160:22 162:3,3,5
162:8,20 163:23
164:5,7,10 170:21
171:19,22 174:9
174:13,18 182:7
185:11,15 186:10
187:20,25 188:5,6
188:7 237:10,13
248:21 261:17,20
262:15,16,17,18
262:19 265:13,15
265:18,19,22
266:2 268:14,25
269:5 285:1
292:12 294:24
295:11,22 303:5
311:25 312:5
332:23,23 334:16
336:7 339:10
348:12,13,14
350:25,25 356:1
375:11,12,18
382:24 389:23
contracted 11:3,11
15:4 204:16
367:22
contracting 5:23,25
9:20 10:7 18:9
20:15 367:15,19
368:16 379:20
391:17,23 392:11
401:20
contractor 10:13
12:4,10 14:2,3,10
16:15,25 18:15,17
18:24 31:3 45:24
54:21 55:9 61:11
61:16 62:8 95:13
107:21,24 108:7,8
108:16 150:3
185:3 189:5,6,11
190:6 194:13
197:8 206:5,18,20
207:7 212:12,15
216:21 218:1
220:8 229:8
264:21 265:4
274:21 279:10
280:3 281:2,2,4,9
282:3 293:15
346:13 366:11
367:20 369:6
370:22 379:24
391:8 392:2 393:2
393:3,25 395:12
contractor's 3:4
33:19 35:8 61:15
82:9 184:23
202:24 229:12,16
281:7 347:11
391:25 392:11,13
392:16 393:5
contractor/custo...
45:16
contractors 1:4
44:19 45:2,4
206:8 207:3
217:24 232:9,13
245:23 275:14,15
279:7
contracts 18:14
21:18 25:4,5
158:18,20 159:1
244:12
contradict 279:16
control 79:4 185:20
379:9 400:17
conversate 78:7
conversation 28:24
30:5,9,11,13
38:25,25 56:19
68:19 78:4 81:2
Page 416
81:14,14 82:23
95:10 97:3 123:19
130:20 139:16
147:15 152:18
156:5 157:16,18
170:13 187:22,24
190:14,14 195:18
196:22 247:14
292:10 317:11,12
318:12 322:8
336:17 337:24
342:11 343:7
359:1
conversations
30:15 56:15 68:3
73:9 75:10 94:3
124:15 139:18
174:5 196:7,20
222:20 223:5
247:9 376:9,10
cooperate 257:19
copies 32:13 87:23
87:24 110:8,8
118:8 128:6,8
130:6 302:17
309:16 311:24
312:5,19 315:16
390:14,15
copious 28:6
copy 10:23,25 11:8
11:20,24 12:7,14
13:1 14:14,17,24
22:25 23:7,14
24:13 26:11,20,25
35:25 36:14 37:3
40:12 41:24 42:11
45:6 50:9 52:10
57:5 63:21 65:22
105:23 110:10
128:2,13 130:22
131:2,12,18,25
132:1,18 133:23
134:5 136:9,10
137:13,14 152:5
158:14 165:3
166:2 168:7,24
171:21 198:8
199:4 223:15
234:10 236:1
252:1 284:24
302:13,19,24
311:10 312:20,20
313:6,14,24
316:10 370:1
390:1,5,17,25
402:21
corner 220:14
222:2 329:1
379:19
corporate 308:10
corporation 8:11
141:3,4
corporations 14:1
19:25 307:10
correct 29:14,17,20
35:7 36:4 37:7
38:5,9,11,21 42:2
42:7,13,18 43:13
43:15 45:7 46:7
47:3,6,18,21,22
49:5,9,10,13,14
50:18 51:16 54:25
55:1,7,17,18 56:2
57:7,24 58:1,2
61:11,12,14 62:5
62:19,20 63:4,6
63:22 64:3 65:3
65:17 75:4 88:10
88:16 89:22 91:2
91:8,21 92:20,22
92:23 93:1,17
95:14,16 99:4
101:20,21 102:8
103:2 104:5,11
108:4 123:5
125:14 127:14,15
127:21 129:7
132:1 133:2
134:10 135:7,11
138:12 139:25
140:1 142:13,14
142:17 143:11
144:7 145:1 147:3
149:10 150:6
153:2,3 157:7
158:9,13 166:9,14
174:5 177:7,16,18
177:20,21 180:4,5
183:8,13 186:16
195:2 200:16
201:10 203:11
206:9,13 210:20
214:25 215:12
216:7 218:13,16
222:14,15 223:17
227:12 232:18
239:1,19 256:11
262:17 265:14
270:23 272:4
285:4 292:25
294:6 300:24
302:12 303:1
305:1,4 306:9
309:25 310:16
311:1 312:16,19
318:22 320:3,16
320:24 321:4,13
324:18 325:7
327:1 330:4 337:1
337:2,4,6 338:25
339:11,12 340:9
340:11 341:12,23
342:5,21 344:24
345:24 349:9,17
350:7,10,14 352:3
352:17 353:15
360:6 393:9
corrected 199:21
correcting 91:23
correction 50:12
corrections 206:11
corrective 389:4
correctly 25:21
55:11 196:15,16
218:15 222:19,24
228:4 315:21
397:10
correspond 267:22
correspondence
68:2 130:7,13
311:25 312:6
cost 12:2 22:3
31:24 76:9 234:20
249:3 263:22
291:6,7 351:9
379:23
costs 70:8 190:13
290:2,12 296:14
392:25
counsel 5:3 6:20
14:16 23:13 28:1
63:8 66:18,18
105:24 213:1
307:1 309:10,11
377:5 406:12
counsel's 259:23
counselor 64:17
counter 168:2
counter-sign 375:7
countersign 159:10
159:17
countersigned
158:15
counting 348:18
countless 333:19
county 6:2,9 7:9
8:21,25 10:8,10
10:24 14:4,16
16:9 18:7 20:13
22:23 30:18 31:13
34:7 35:16 36:24
39:12 45:7 52:2
62:11 68:12 72:25
73:2 74:23 89:4
96:17 108:21
118:25 119:11,16
123:9,15,21,22
124:10,11,18
132:24 142:12
144:5 171:13,15
171:22 187:6,9
189:6 193:6,18
196:3 198:15
206:20 207:22
209:4,23 210:10
212:9 219:3,17
223:12 228:12
229:19 233:11,24
234:7 243:13,15
255:9,20 258:24
259:7 271:15
275:4 297:6
298:20 305:4
310:13 312:2,7,7
323:17 330:24,25
348:11 356:2
357:10 358:19,20
358:23 359:5,8,14
363:14 369:5,24
371:4 378:15
379:14 381:5,7,9
384:2 385:11,17
385:17 387:11
388:6,18,21 392:5
392:7,8,21 394:22
394:23 402:2
406:2,9
county's 40:11
41:23 203:13,15
203:18 303:21
359:10 388:8
couple 23:4 44:2
77:2 96:6 126:6
140:17 165:24
176:19 194:20
196:10 209:2,3
222:10 223:24
236:20 246:12
277:5,6 319:20
320:5 329:11
359:19 372:1,16
373:1 377:21
379:4 381:13
382:12,23 394:18
395:6
course 91:17
283:11 343:22
395:20
court 1:23 228:22
347:2 384:5
cover 104:16 123:1
212:12 217:8
290:2 328:13,18
350:9 353:18
355:11,12
coverage 19:12,20
20:4 361:5
covered 104:10
122:20,21 215:17
215:24 328:15
358:4,7
covering 98:6
239:15 290:11
328:10
coverings 294:3
Page 417
328:21
covers 330:1
coverup 160:21
CPA 305:19
crack 54:8 112:21
craft 356:19
crazy 234:4 238:12
create 140:21
created 65:13
311:9
credibility 383:12
Credit 11:16
164:18
crew 15:19 70:7,14
70:19 71:17 72:20
77:1,4,19,20 78:2
78:13 79:19 81:8
81:8 82:13 85:10
86:5,6 89:17,18
90:12 94:16 95:18
95:25 96:4,6 97:7
115:21 120:25
121:2,3,6 143:13
161:6 165:15
175:22 226:1
288:8 361:14,16
361:19 376:14,15
397:7
crews 77:8 292:3
criminal 332:7
Crooks 2:9,9,20
5:12 10:24 11:1,9
12:4,11 15:3,8,13
15:14,17 16:5
20:18,20,23 21:13
24:7,10,21 35:21
50:17 67:9,12,14
67:14,19,21 68:17
68:19 87:5,8,10
87:12,15 88:2
102:20 105:14,19
106:6,8,20 107:2
107:6,9,12,17
109:4,18,20,22
110:18 111:4,16
112:9,12,14,17,25
113:4,11 114:7,9
114:12,19,23
118:4,5,12,17
120:14,15,19
121:3,7,9,13,18
121:21,24 122:2,5
122:9,14,20,23,25
123:5,7,11,16,19
123:25 124:6,12
124:15 125:12,20
126:9 127:8
128:20 129:18,20
132:22 140:5,10
144:18 156:21
184:11 185:9,10
185:12,16,18
186:16 187:7,10
187:12,16,21
188:8,24,25 189:8
189:13 190:15
191:4,9,23 192:4
192:9,11 253:5
277:16 287:5
297:24 298:6
299:6,12,14 300:9
300:12,17,21,24
301:1,7,10,19,23
302:1,4,8,12,16
302:19,23 303:1,8
303:11,12 310:10
312:23 315:5,12
315:14,23 323:22
370:20 397:21
Crooks'283:15
285:2,21
cross 2:11,13,17,23
125:18 200:25
223:25 262:20
275:21 281:21
338:17
cross-examination
66:25
cross-examine
370:14
cross-examined
363:21
crux 276:16 377:20
cup 168:3
current 176:3
197:24
currently 54:1
104:12 193:21
276:12
cussing 335:9
customer 42:9,10
347:11
customers 186:21
cut 17:4 33:4 46:5
54:22 103:8 154:2
187:15,17 188:15
213:21 220:9,13
220:17 222:14
224:25 225:1
249:7 261:8
354:17 379:19
384:13
cutout 176:16
182:8
D
D 3:1
damage 13:20
23:17 54:2,10,11
100:5 102:3,6
104:24 106:22
123:1 177:19
178:2 179:9,10
180:6,7,25 181:8
191:5 339:18
349:20 351:3,4,22
353:15 354:13
361:9,10 386:10
damaged 11:6 21:3
40:18 48:15 53:23
86:25 153:25
154:24,24 157:10
182:19,20 194:19
194:19 213:13
252:11 293:6,7
351:4
damages 13:22
21:6,11 99:17
100:9 102:17
113:18,18 118:20
177:12 178:6,10
179:16 181:22
206:10 248:13
327:17 339:17
349:18 355:23
358:6,10 377:3,11
386:13,16
Danielle 4:6 279:4
dark 114:24 374:2
darned 271:23
data 28:7
date 13:3,9 21:16
22:5,20 23:20
25:2 36:21 37:12
37:13,24,25 38:2
38:3,4 41:8,9,18
43:22,24 48:6
50:13,13 56:21
58:7 60:7,9 79:7
85:3 137:17 155:2
156:24 158:2,7
160:15 165:20
166:18 167:16
169:10,13 174:3
194:5 195:1,4
199:10,11,13,14
199:15,18 201:8
217:4 240:14,14
258:11 314:20
348:7 369:21
378:17 386:4
dated 11:17,21,25
13:17,20 54:15
55:16 57:23 65:14
65:15 72:14 133:1
134:8 149:10
158:2,3 177:15
255:3 286:18
406:17
dating 326:25
Dave 4:7 6:12 13:5
13:8 21:23 26:16
28:23 49:17 50:8
50:9 56:15 62:17
193:7 200:24
205:3
David 2:12 193:10
193:17 222:5
Dawn 178:17
day 44:1 73:13
75:19 81:13 82:19
104:16 115:22,24
127:3 160:14
163:19 166:12
173:17 179:19
223:7 234:5
238:20 239:3,5,8
244:12 253:17
259:12,14,15
309:4 332:23
335:16 342:18
370:8 374:20
387:21 395:8
396:17 406:17
days 22:11 76:8
78:10 212:13
237:22,23 290:20
317:24 369:12
381:10 384:22
397:6 402:3,25
daytime 342:16
DBPR 219:18
394:9,12 404:3
dead 259:9
deal 158:17 186:10
230:25 259:19
262:4 326:16
375:8,24 380:13
386:24
dealing 29:9 58:1
167:1 265:9
dealings 284:3
deals 126:5 367:4
dealt 226:3 259:21
Deana 1:17 4:25
52:9 66:22 118:5
125:13 192:5
200:22 209:9
212:1 363:2
Deana's 356:23
dear 250:25 251:7
debris 48:17
157:13
decade 382:10
deceit 5:24 20:14
20:19 368:15
391:22
deceived 20:23
December 10:21
12:12,15 16:17
29:16,19 44:1
57:23 76:14,20
77:1 78:6 81:5
95:1,3,12,25
96:19 113:15
Page 418
117:10 121:10
169:3 172:7,12,19
173:1,2 246:7
267:20,21 268:1
328:8,12 331:14
332:13,14 334:22
334:22 343:11
362:13 375:19
384:18
decent 151:2
decide 270:23
273:2,5,7 274:13
274:20,24 275:1
364:20 374:5
381:11 387:10
388:19,25
decided 50:1
250:17 398:1
decipher 23:21
decision 192:22
273:9 275:13,14
275:16 276:1
307:2 357:13,19
364:5,7,9,11,14
364:20,21 365:16
365:19 389:1
390:16
decisions 185:21
214:10 275:19
389:5
deck 12:20 39:23
40:7,9 48:15,16
157:11,12 207:8
208:22 252:11
decking 22:1 34:9
34:16 197:17
214:19
declaration 276:9
declined 77:13
81:21 186:1
decorum 7:21
Deduct 268:6
deed 305:5
deeds 186:21
deep 9:4,15
defense 25:10
60:25
defer 28:3 31:5
40:3 55:13
deficiencies 9:9
deficiency 225:25
226:1
defies 383:12
386:10
defined 18:9
367:15 391:17
definitely 183:24
197:16 231:18
255:10 364:15,16
393:24 396:25
399:16
definition 367:19
399:23
degree 305:23
delay 292:24
delegated 312:23
deleted 131:8 314:5
314:6
deliberate 384:9
388:19
deliberating
383:25
delivered 57:12
76:21 81:4
demand 176:11
demanded 71:15
247:17,17
demanding 188:6
396:3
demands 9:12
174:21 177:2
292:18
demonstrate
131:19
demonstrating
5:16
denial 392:7,21
deny 103:15 347:3
347:3,4,5
department 19:22
20:9 23:1 75:23
76:2 160:7 197:5
207:14 217:18
370:2 379:9
402:22
depend 402:9
depending 214:2
depends 229:9,11
depict 58:22
depicting 132:4
depicts 329:5
deployed 180:16
deposit 70:5 90:13
131:22 165:19,22
deposited 70:17
93:12
depositions 370:11
Depot 1:23
describe 40:1 44:7
44:10 55:19 111:3
194:16
described 40:20
102:23 128:24
131:4 162:4
163:22 315:6
describing 111:14
description 39:19
39:20 40:15,24
47:23 48:3,5,18
48:23,25 55:2
148:15,17 157:9
160:19 162:14
169:11,21 170:10
170:19,25 182:23
252:10 301:4
Descriptions 301:5
deserve 355:9
detail 39:20 134:2
135:17 141:10,25
detailed 48:25 49:7
71:23 93:3 101:20
135:16 162:8,10
162:16 169:21
377:15
details 23:22 24:2
130:14 162:5,6
163:11
determination
46:20
determinations
214:14
determine 38:22
241:6 321:11
determined 37:13
45:16 63:1 391:8
deviate 371:3
Di 398:13
died 344:2
difference 163:6
225:12 337:5
different 24:19
40:20 75:5 108:1
108:19 121:9
156:10,11,12
164:25 167:7
168:1 170:24
171:23 201:7
205:11 257:7
266:2 268:20
288:22 308:24
312:15 317:15,17
344:12 351:16
382:23
difficult 24:3 78:21
180:17 270:17
DiFran 393:20
DiFrancesco 1:12
3:10,11 28:12,20
29:12,15,18,21,24
30:3 32:2,7,16
44:15,18,21,25
45:2 60:13,20
107:18,19,20
108:2,5,20,24
114:9,14,17
120:16,17,19
121:5,8,11,14,19
121:22,25 122:3,6
122:10,19,21,24
123:2,6,8,13,17
123:23 124:3,9,14
124:16,21,23
125:6,10 185:10
185:13,17 186:3
187:5,8,11,14,18
188:4,19,21
191:16 202:8,10
215:8,13 216:1,8
216:15,25 217:3,6
217:12,17,20
221:7 227:15,18
227:25 257:6
260:22,24,25
261:5,11,13,16,19
261:25 262:6,13
262:24 263:4,16
263:21,24 264:4,8
264:11,15,19,23
264:25 265:2,7,12
265:18,23 266:5,9
266:11,17,19,22
266:24 267:4,6,8
267:11,15,18,20
268:4,6,10,13,16
268:19,23,25
269:3,9,11,14,17
269:20,22,25
270:2,9,16 277:14
277:20,22 278:4,7
278:9,14,17,20
279:2 280:8,14,18
280:21 281:1,8,11
281:14,17 282:9
282:14 294:25
295:5,10,13,17,21
295:24 296:2,5,12
296:16,19,23
297:23 298:5
300:9,13,18,22,25
301:3,8,14,22,24
302:3,6,10,14,18
302:21,24 303:4
303:10 343:22,25
344:10,14,20,25
345:8,18,20,25
346:4,7,12,20,23
347:8,10 348:1,23
349:1,6,10,15,21
350:4,8,16,19,23
351:12,18,21
352:1,4,11,15,18
352:23 353:2,8,14
353:19,21,23
354:6,8,23 355:1
355:4,14,15,16,18
375:9 393:21
394:10,13 397:19
398:14 399:7
401:13,15,16
402:17,20 403:2,5
403:14,18,21,23
403:25 404:4,7,8
404:21,22
dig 83:2
digging 99:7
Page 419
digitally 26:17
diligence 279:25
diligent 280:5
382:25
dime 256:13 337:18
direct 2:10,13,16
2:18,22 64:13
88:5 193:13
219:12 229:5
304:23
directed 220:9,12
306:24
direction 225:15
directly 100:9
301:19 325:19
396:21
dirt 377:18
dis 391:24
disagree 80:8
119:18
disagreement
81:24
disapprove 223:1
disapproved 216:4
222:18
disciplinary 4:20
4:23 357:14
359:13,13 365:3
365:10 384:6
391:24 393:1
405:14
disconnect 271:3
272:3
discount 9:4,15
discovered 9:8
220:15 327:14
368:13
discovering 222:3
discrepancies
160:7
discrepancy 182:17
discretion 385:4
discuss 50:23
204:17 346:12
discussed 72:24
162:6 164:14
174:12 294:11
discusses 75:14
discussing 70:7
127:21 223:17
258:5 300:11
discussion 55:9
96:25 170:4 171:5
287:5 293:10
364:1,13 393:16
399:15 400:2
401:9 403:9
404:15
discussions 56:5
153:19
dishonest 78:17,19
dishonesty 79:18
display 110:4
disputed 45:18
disregard 9:16
297:3
disregarding 5:20
152:18
disregards 16:10
366:18 391:13
disrespect 241:12
distance 201:15
367:5
Division 13:15,25
19:23,25
document 12:11
23:8,10 24:1,18
27:16 28:7 36:2,4
37:6 38:16 43:19
43:22 44:10 52:1
52:19 54:17 56:2
64:9 99:9 102:19
103:6,22 108:12
108:17 119:12
128:20 131:24
132:22 133:23
136:14,15,23
137:4,5,7,8,11,13
137:14,15,20,24
138:7 144:24
154:22 156:8,12
156:15 164:23
166:25 168:3
169:18 171:3,4
244:3 251:19
253:24 309:24
310:24 311:11
312:8 386:14
390:21 396:11,20
documentation
25:5 232:12
271:21 356:2
396:9,22
documented
186:14
documents 10:18
24:9 27:9,14 36:7
39:11 52:3,21
53:10 59:2 63:25
63:25 64:16 71:7
72:20 76:17 100:1
100:2 103:20
105:21 106:3
127:11 128:21
129:1,2 130:6,8
130:22,24 131:19
139:20 144:19
164:17 171:8
243:11 244:6,8
246:16 247:25
248:6 304:4 305:3
308:21 309:1
310:6,12,15,17,19
310:25 311:3,25
312:3,5,9 313:2
313:14,17,22
315:8 318:25
330:17 382:2,22
382:25
doing 69:11,13
71:13 73:14 75:9
80:24 82:10 89:10
94:4,6 96:22
150:3 182:24
184:24,24 186:17
226:7 229:20
238:17 257:3,4,5
257:5,5,17 258:1
270:20 289:23
292:13 307:10
325:4 331:12,13
336:8 344:18
345:10 370:25
371:25 373:21
374:7 378:7
379:23 381:8
382:11,11 396:5,6
397:7,18
dollar 351:25
353:17
dollars 76:10 163:3
245:4 277:7 320:6
351:11 352:22
374:8
door 87:1 113:25
115:16
doors 189:21
dot 140:1
doubt 370:19
393:22
Doug 222:9
dozen 60:3 202:3
237:4
draft 50:7 199:10
drafted 199:13,16
253:14
dragged 179:17,23
184:1
drastically 372:11
draw 35:22 37:2
40:10 47:19 54:14
58:15
drifting 321:8
drinking 341:16
drip 12:22 39:24
59:6,10 208:23,25
380:6
dripping 321:8
drips 386:6
Drive 1:23 12:1,9
13:23 14:13 15:5
22:18 35:14 67:15
194:1 198:24
212:20 219:21
229:25 246:24
248:3 304:17
313:16 348:6
369:19
driver's 73:21 74:4
137:22 138:4
driving 138:17
327:13 336:2
dropped 343:9,11
dropping 345:11
drove 86:5,5
317:18 335:25
dry 12:18 17:12
dry-in 35:2 51:3
278:2
drywall 48:21
53:24 54:2,5,8,9
102:3 118:21
122:12 154:25
170:1,15,16
182:19 194:19,20
293:13,14 337:21
361:10 373:17
375:23 380:4
399:2
drywalls 349:23
Duces 243:20,23
due 7:11,13 9:2
11:12,13 17:16
103:5 174:9 202:4
256:15 279:25
334:9 339:24,24
384:21
duly 392:14
dumpster 71:3
76:20,24 81:4
85:22 116:8,14
118:1 343:3,5,8
343:12
duped 272:12
384:13
dwelling 193:22
E
E 3:1,1 133:15
earlier 60:2 106:9
114:2 118:7,17
195:13 248:10
258:6 263:11
302:19 304:13
321:15 331:5
338:7
earliest 138:9
early 18:3 47:14
95:3 174:2 216:16
328:25 329:2
earn 290:5 292:24
easier 322:4
easily 78:8
edge 12:22 39:24
59:10 191:20
Page 420
208:23,25
education 62:4
126:4 392:14,15
403:12
effect 139:9 402:13
effort 237:18
241:15 382:25
eight 202:19,21
220:14,14 221:24
221:24
eight-and-a-half
373:7
either 9:14 34:13
48:6 58:17 77:7
77:16 80:5 83:12
123:1 145:17
149:7 192:19
207:6 235:17
262:12 263:5
351:2 396:20
399:19
eleven 373:7 374:8
elicit 306:24 371:8
eliciting 307:3
email 13:13 19:21
24:20 52:11 53:11
65:3 75:1,1 76:22
81:5 85:20 101:25
102:20 103:1
106:10 118:7,20
139:5,7,23 140:13
142:4,6 168:15,16
203:5,11,24 204:7
309:14 311:25
312:6 315:25
316:19 317:4
318:7
emailed 52:9
emails 127:15
empathetic 190:3
employ 232:9,11,14
232:15 234:24
employed 6:8
396:21 406:12
employee 19:17
406:14
employees 19:15
52:2 232:7 306:13
employment 244:9
244:12 246:21
empty 116:13
enclosure 102:12
117:8 146:25
ended 152:17
322:21
endorsement
193:22,23,24
219:19
ends 349:16
Enforcement 10:12
61:22
engage 9:19 64:13
engaging 18:8
367:14 391:16
401:19
enter 87:21,24
105:15 106:4
386:11
entered 27:8,10
entertain 401:12
entire 8:3 17:3 28:7
33:3 46:4 69:9
110:8,16,22,24
150:5 152:1 180:1
225:16,20 226:9
227:11 271:7
275:20 314:12
322:3 331:10
332:25 333:18
336:23 339:20
362:15 367:22
372:24 395:8
entitled 82:5
178:10
enumerated 392:4
equipment 377:11
erased 344:13
Ervin 50:17,19
132:7,8,9 142:9
315:7
escrow 358:15
359:2 360:16
escrowing 360:17
especially 86:17
274:16 386:7
Esq 1:17,19
establish 126:6
128:21 142:24
310:13
estimate 34:17
69:18 122:16
148:6 189:12
285:7
estimates 90:7
150:15 151:7
375:4
estimating 284:16
et 176:12
evening 173:18,21
237:8
event 318:8 383:11
events 78:12 79:17
157:2 250:10
eventually 311:22
everybody 89:4
112:8 192:18
260:18 344:3
364:24 371:11
390:22
everybody's 172:1
evidence 6:4 7:10
7:20 8:11,23
10:18 24:2 27:3,6
27:7 51:11 87:25
105:16 110:3,13
110:17 119:5,10
120:9 209:24
224:2,8 366:8
367:11 368:8
369:2,3,8 377:10
386:3 390:3,6
393:6,11
evidencing 244:9
exact 23:11 167:19
317:15 361:19
exactly 35:3 115:12
129:3 134:4
136:11,11 151:24
152:3 155:21
169:5 187:16
191:12 197:13
209:8,17 213:5
223:7,8 296:7
309:23 334:5
356:7
Examination 2:6,7
2:7,8,10,11,13,13
2:14,14,16,17,18
2:19,22,23,24
34:3 61:5 63:19
88:5 125:18
193:13 200:25
212:6 215:3
219:12 223:25
229:5 282:18
304:23 338:17
359:22
examine 23:22
275:21 382:1
examiner 193:24
Examining 1:4 3:4
366:12
example 52:18
232:15 294:18
exceed 22:11,20
225:24 348:8
369:12,22 392:10
392:19
exchange 77:25
186:13 203:25
exclude 381:9
exclusion 385:19
excuse 7:3 46:22
66:5 86:24 91:15
111:11,11 114:9
124:23 126:2
144:9 151:20
215:8 274:2
276:10 313:4
395:11 400:23
executed 309:12,16
309:17
execution 42:12,14
exempt 276:13
exemption 19:11
19:13,20 20:4
exercise 385:4
exhausting 86:15
exhibit 36:17 38:7
38:7 39:10,10,11
40:11,21 43:19
48:24 53:22 54:15
55:16,16 57:22,22
58:15,16 118:24
128:17 132:13,18
133:22 138:9
140:15 141:9
144:7,8 148:15
153:1 154:21
160:11 164:16,16
164:19 169:8,8
172:5,5 203:10
204:1 208:1
286:20 293:2
315:6 326:5
389:17,17
exhibits 41:23
177:9 370:9
389:25
existing 14:23
17:24 48:14,16
71:11 157:10,12
161:15 206:9
210:25 227:2,4
252:10,12 327:21
328:2 367:3 387:8
387:12
expect 159:16
179:7 236:2
238:13,22 322:6
350:23
expectancy 322:6
expected 91:10
154:15 164:4
253:23
expecting 144:13
178:1 237:23
250:22,23 253:23
268:1,3,8,10
expense 154:12
expensive 72:3
76:13 154:11,19
163:14 292:16
319:22,23,24
experience 61:8
151:6 171:18
207:11 293:14
experienced 238:13
316:2 317:13,25
318:6 321:4
323:25
experiencing
316:16 317:8
321:2
expert 58:24
Page 421
expiration 104:4
expire 84:22
expired 84:18,21
85:15 86:11 105:2
175:23,25 176:2
explain 51:22 74:2
74:12 89:2 99:5
133:9 138:3
151:24 152:3
199:11 221:15
261:16,19 292:6
explained 129:2
145:10,22 186:5
190:2 222:22
294:23 346:25
explaining 80:4
expletive 77:23
expose 15:23
exposed 46:13 47:5
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Multiservices
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226:8,8 227:9,19
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number 12:9 20:17
22:8 27:13 39:23
52:1,11 65:20
93:24 99:9 131:19
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25:16 26:19 59:17
64:19 156:18
159:3 209:6 210:1
300:2,3,5,7
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obtained 8:18
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348:6 369:20
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69:21 90:18 198:4
199:20 211:10
249:2 262:16
300:2 348:13
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104:2 124:20
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313:8,20 314:23
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36:10,10 37:2,6,9
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38:12 39:2,14,18
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42:21,22 43:7,9
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plans 193:23
Plantation 228:23
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play 129:22 314:4
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Page 438
practicing 7:22
pre-arranged
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preparation 125:24
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proceed 87:6
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Page 439
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Page 440
quote 15:9,12,15
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read 17:2 18:3 23:8
23:16,18,20 24:1
24:2 25:1 32:7,18
39:21 40:16 41:8
41:9 47:10 48:11
50:14 52:20 87:22
92:5,25 150:2,7
203:24 204:10
233:11 310:4
326:5 388:22
389:13 391:12
401:7
reading 103:6
reads 37:23
ready 33:19 82:21
82:22 304:9 391:3
398:11
real 91:15 112:23
274:19 336:8,9
394:17
realize 167:22
181:7 257:4,12
354:3
realized 291:24
347:21 374:15
realizes 91:11
realizing 384:25
really 3:21 8:15
89:13 137:3
144:13 148:7
179:5 190:3
191:13 210:3
224:22 247:5
254:2,2 259:18
272:16,17 274:25
275:3 278:13
280:18 330:3
336:17 339:19
381:22 396:17
Realtor 125:21
158:17,22,24
159:5,6
reapply 381:12,12
reasking 142:7
reason 105:22
197:10 212:23
237:17 257:13
266:5 274:5
293:20 314:3
321:5,17 322:20
324:5 330:6 333:1
343:2 349:13,13
354:12,14
reasonable 9:22
18:11 183:21
288:13 367:17
391:18 392:10,24
reasons 6:2 76:11
118:24 120:20
154:13 200:4
354:11 371:3
384:11
reassured 361:23
rebuild 15:9
rebuttal 6:19
recall 56:7,8 61:7
63:9,12 98:15
130:19 152:9
153:13 167:13,14
169:1,2 173:4
194:5 204:21
214:6 219:25
220:1 224:18
226:22 240:14
248:9 258:10
298:24 299:18
316:14,14 317:4
317:17 318:4,5,13
320:7 339:2
342:13,23 345:7
recalled 184:2
receipt 76:15
165:25 172:13
receive 35:16 75:24
83:14 85:8 120:4
177:12 185:11
217:13 244:3
258:15 264:5,6
279:21 284:24
308:18 332:2
339:4,8 374:20
received 5:11 13:14
23:7,12 36:21
38:2,23 39:12
41:15,17 51:16
63:21 64:10,12
69:20 84:5 88:14
89:24 90:2 92:2
92:25 103:2
118:15 130:23
132:23 175:18
177:17 181:20
289:14,16 301:19
303:9 313:15
332:5 338:24
374:21 399:9
receives 80:25
receiving 119:2
recess 66:7,9
109:11 193:5
304:8
recipient 119:18
recognize 167:22
recollection 166:20
167:12 172:8
204:19
recommend 127:5
241:16 385:7
recommendation
371:3 398:7
recommendations
70:23 348:2 388:3
394:8 401:5
recommending
22:8,24 369:9
398:5 402:21
recommends
369:25
record 4:4 7:8
10:17,18 23:11
26:12 27:8 32:21
39:21 43:2 53:16
67:13 87:22,25
105:16,22 107:13
107:20 108:18
110:7 118:9
119:11,13,15,24
120:1,12 185:4
193:16 212:14
219:15 220:24
228:17 238:8
247:5,21 307:17
307:20 308:25
314:9,12,15 315:1
365:20 368:8
370:12 389:20
recorded 314:13
recording 406:8
records 142:11
Recross 2:14 215:3
359:22
rectified 179:10
181:21
rectify 186:6 292:8
red 85:15 117:3
redacted 134:22
redirect 2:14,19,24
212:6 281:22
282:18
redo 240:4 346:15
348:17 379:22
381:14
redone 223:10
reexamination
392:20
refer 44:13,24
119:14 124:13
207:16 254:14
331:16 381:20
reference 23:5,9
25:24 48:19,21
53:3 113:19 171:7
387:9
referenced 95:17
101:16 105:12
118:7 143:9 361:8
references 52:11,16
referencing 91:18
253:2
referral 145:15
381:13
referred 54:10
74:11,22 75:4,6
94:1 128:23 145:6
145:16,17 284:7
293:8 310:14
333:7
referring 36:7
42:15 43:3 59:8
107:14 111:12
112:2 133:4 235:9
refers 69:2 74:6
refill 81:10 335:19
reflect 58:19 60:10
137:8 147:13
156:2 209:13
378:23
reflecting 131:21
318:25 329:24
reflects 356:25
refresh 166:20
204:18 388:23
refund 9:3,14
73:11 75:11 331:1
refuse 80:19 308:3
refused 9:1 79:16
refusing 81:24
regarding 14:5
36:25 50:22
131:22 246:23
257:9 311:3 316:9
319:1 343:4,7
386:3
regardless 213:17
regards 82:18
83:15 132:10
register 131:25
Page 441
regular 235:24
263:15 341:15
regularly 158:17
regulation 16:11
366:19 391:14
402:23
Regulations 20:10
23:1 370:3
rehash 303:19
reinspected 16:23
reinspection 18:1,3
47:14 216:15
reinstall 377:14
reinstate 22:12
369:13 402:5
rejected 206:2,5
relate 155:22
related 5:13 63:8
104:24 142:8
171:13 194:12
196:7,20 198:23
198:23 212:20
214:4,15 229:25
232:18 235:19
246:21 247:1
248:6,10,18
261:23 366:22
390:6 406:12
relates 177:19
relating 178:2
181:8 195:16
244:9 248:1
relations 374:18
relationship 30:6
142:25 244:9
283:21 358:22
372:13 373:13
374:18 378:6
relative 406:14
relayed 188:12,13
release 13:20
100:18 101:15
103:15,17 106:22
177:11 178:5
180:3 181:7
248:10 386:12,14
386:16
released 65:23
363:9,9,12
relevance 307:16
relevant 126:3,4
142:22 305:16
306:19,19,24
307:4,18 310:5
366:9 393:12
reliability 382:19
relied 180:22
rely 52:20 129:25
200:5 207:1
remaining 320:23
339:22 349:5,18
375:17
remains 22:6
364:22
remediate 122:17
remediated 122:11
remediation 354:24
remedies 357:16
remedy 287:20,22
357:21 384:4
remember 138:23
139:4,22 147:23
148:1 150:1
153:17 155:21
168:11,14 212:19
223:7 237:1
240:16 254:11
256:12 278:24
330:21 335:22
345:6 397:3
remind 231:20
remodel 367:25
removal 278:23
remove 48:17
157:12 176:23
178:24 278:1
279:5,7 294:3
377:13
removed 162:22
176:12 227:1
397:9 402:19
renail 48:16 157:11
178:24 227:11
294:3 379:1
renailed 196:24
222:25
renegotiate 373:24
renew 85:16,18
105:3,4
renewal 85:20
392:8
renewed 86:12
176:8 179:21
345:4,5 347:17,18
renotice 58:5
repair 8:13 11:5
23:17 40:17,19
102:11 118:21
135:13,20,22
147:9,9 149:15
150:23 162:4
175:16 283:8
288:6 319:22,23
321:25 367:25
372:16 373:9
repaired 34:14
130:16 135:23
146:16 149:24
282:21 295:14
296:17
repairing 210:15
321:20
repairs 35:6 181:25
359:12
repaper 179:1
repeat 164:9
201:23
repetitive 153:11
rephrase 209:15,16
replace 48:15 90:12
118:22 135:22
150:18 151:12
153:25,25 154:1,2
154:4,24,25
157:10 162:22,25
163:1 177:3
252:11 288:6
293:6,13 295:24
322:3,5
replaced 135:24,25
146:20,22 149:7
149:25 162:23
182:8 210:19
215:6 225:16,18
replacement 34:6,8
50:23 102:2
147:10,11,14
225:7
replacing 211:3
replied 175:23
176:3
reply 288:11,14
292:14
report 50:4,5 53:23
54:15,20 100:23
141:25 176:20
180:14 199:5
203:13 213:9
223:15
reported 201:13
Reporter 406:6
REPORTERS 1:23
reports 21:17
represent 178:12
242:18
representative
309:17
representatives
15:10 58:17
represented 78:18
124:6 159:11,12
188:9 271:20
368:17
representing 79:1
271:25 311:22
represents 74:5
184:20
reprimand 385:8
392:19
reputation 8:9
374:11 380:18
381:3 382:10
request 18:3 22:12
47:14 83:18
128:21 132:3
159:9 162:10
176:23 192:13
210:6 212:16
216:16 291:20
297:5 309:24
310:12,16,18,19
310:25 311:2,24
313:14,19 369:13
401:1 402:4
requested 22:2
32:25 45:20 52:2
52:23 70:12 71:24
72:13 73:11 81:20
84:24 137:21
233:21 301:2
requesting 244:6
requests 14:21
17:14 73:21
309:18 310:9
require 22:11,15
22:21 152:12
171:21 360:6
369:12,16,22
required 8:21
12:17 14:20,22
17:11,15,17 20:5
48:16 61:21,25
70:11 71:6 105:6
157:11 164:7
218:7,9,10 252:11
392:3 395:14
402:15,18
requirement
201:18 206:21
209:5,14,24 215:5
225:22 226:20,21
392:20
requirements
17:22 369:7
395:15
requires 200:9
221:18 226:6
366:25 367:2
requiring 392:22
reread 40:15
315:11
reroof 5:21 11:25
12:20 15:5 39:22
40:8 200:9
reroofed 285:13
reroofing 5:14 12:8
61:8
reseal 162:24
research 38:12,16
99:13 190:9,11
279:17
researched 150:2
reserve 6:17 184:6
200:20 260:14
281:22 298:22
Page 442
resheathing 338:1
residence 15:11,19
16:1
residents 385:18
resolution 82:16
357:18
resolve 56:9 365:18
383:19
resolved 175:8
179:14 378:20
respect 7:23 25:7
43:11 103:6
178:13 202:5
387:5
respectfully 42:21
43:12
respectively 28:23
30:8
respond 8:7 74:20
77:15,16
responded 172:2
Respondent 383:3
383:17
respondent's 35:23
37:3 43:20 132:13
Respondents
363:22 386:24
response 13:13
27:13 236:4
304:10 312:24
362:22 404:16
responses 24:15
382:22
responsibilities
312:23
responsibility
20:25 186:8
217:22 271:13
296:10 382:4
responsible 21:7
100:4 272:25
367:21 381:2
395:25 396:8
responsive 24:9
52:8 64:5 127:11
129:1 308:22
310:16,19,25
315:8,15 330:19
rest 95:23 117:16
185:1 196:17
222:15 288:17,18
293:23 301:4
303:24 348:12,12
363:22 370:4
rested 298:19
resting 299:12
result 20:25 21:6
49:17,24 104:21
171:6 178:9 180:7
180:8 371:5
resulted 101:19
resulting 104:24
resumed 117:13
return 72:21
236:14 309:12
325:8,10
returned 9:9
113:14 231:9
returning 81:3
returns 305:25
306:17 307:10,12
reveal 367:10
revealed 17:7,20
19:9 20:1
reverse 45:12
review 39:7 50:7,10
reviewed 50:5
reviewing 28:6
revised 58:4,5
199:11,18
revocation 391:6
392:5
revoke 5:17 6:3
366:12 402:1,24
revoked 392:17
ridiculous 80:13
right 5:7 8:7 24:8
24:15,17 27:23,23
29:22 41:7 43:12
43:14 44:23 45:9
45:13,17,24 46:2
46:6 47:17 48:3,7
50:23 51:1,4,12
55:4 64:2 65:1,16
67:16 70:16 74:21
83:24 105:4
113:10 115:17
116:21 127:18
132:3 133:24
134:25 135:2,6
143:10 144:2
148:13 154:7
156:17 157:6,13
157:14 158:18,24
160:24 161:9,10
162:4 163:5 164:8
165:2 169:16
173:12 176:17,22
177:6,15 180:10
181:5 184:6 186:6
189:20 191:8
192:22,22 200:20
201:15 206:11
208:3 210:17,19
211:11 214:12,23
221:10 223:13
224:9 225:4,5,11
225:15,17,18,19
230:14 231:4
235:6,20 238:21
244:1 247:18
249:24 252:7
256:15,20 257:1
260:12,13,14
261:8,22 263:3
265:5 270:12,16
274:15,19 275:6
275:12 281:20,22
284:3,10 289:14
289:19 291:9
292:6 296:19
298:23 299:1
302:18 303:14
305:6 310:3
312:15,18 316:1
318:10,16,21
319:5 320:12,19
321:3 324:16,17
329:10 331:25
332:3,6 333:11
335:22 337:3
339:8 344:2,4,4
348:23 349:2
361:4 362:6
374:13 381:8,19
384:17 387:2,3
389:5 395:22
397:11,12,18
400:2,11 403:5
right-hand 146:24
ring 200:10 202:22
rip 79:22 356:2
379:22
ripped 79:24 98:17
111:7 112:19
175:9 337:21
339:17,19,20
358:3
ripping 336:18,20
rips 356:3
Roberts 2:22
129:19 140:8,10
140:12 151:19
299:8 304:11,12
304:15,16,18,25
309:19 319:17
324:13,16 343:21
355:17 358:1
359:18,24 362:16
362:21,23 370:20
372:22
Roberts'313:19,20
rock 254:17,22
Roger 1:8
rogue 374:2 377:24
role 362:2
roll 3:6
rolls 56:19,22
161:18,19
roof 11:5 12:18,18
12:18 13:2 15:9
15:21,22 16:20,22
17:3,11,11,12,12
17:19,20,21 21:1
21:21,25 23:17
29:1 33:3 34:8,8
34:16 40:17 46:4
48:14 49:22 50:1
50:22 51:2,7
53:25 54:12 56:22
58:13 69:8,9,15
69:18 71:11,22
72:11 79:11,16
80:9,25 81:18
83:10,16,21 85:6
86:19,23 90:11
91:12 94:20 102:8
102:13 104:7,10
104:12 111:17
115:10,25 116:4,6
117:25 130:16
131:3 132:4,4,4
132:11 133:1,9
134:20 135:20,24
146:8,16,17,22,23
147:12 148:22
149:4,21,24 150:4
150:5,9,18 151:3
151:13 152:1
153:8,14,25
154:14 157:4,10
159:24 160:21
161:12,14,15
164:3 170:19
173:6 174:23
175:2,17,21 176:1
176:10,12 178:9
179:1,15 180:8
181:21,25 182:4,5
182:12,17,25
183:5,11,22,22
186:19 189:1,2,17
189:19,21,22
190:4,23 191:1
194:18,20,21,25
195:5,19,25
196:14,17,20
197:14,17,21,21
197:22 198:2
199:24 200:14
201:7 203:3 207:8
208:14,17 210:15
210:16,25 212:12
213:2,8,11,11,16
213:19 214:11,12
214:15,19,19
215:10,17,19,20
215:24 216:3,10
216:11,12,13
217:1,4,8,8,9
220:5,6,7 222:15
224:16,16,19,20
224:20,24 225:16
226:7,9 227:11
229:20 230:10
Page 443
237:9 239:4,13
240:3,5 252:10
256:1,24 257:3,11
263:8,15 278:22
279:7 285:16
287:24 288:1,5,6
288:21 289:23
290:19 291:10
294:6,7,14,14,20
295:17 313:24
314:11,11,12,13
314:14 320:15,18
320:22,23,25
321:5,14,16,24,25
322:1,3,5,6,7,7,10
327:22,22 328:2
328:17,17 334:11
334:13,14,21,23
334:25 336:8
338:2,8 339:15
340:5,6,8 341:15
344:18,19 345:9
345:10,12,23
346:2,9,15,15
347:3,16,19,24
348:17 349:2
352:12,21 354:17
354:20 355:21
356:1,6,9,25
362:11,12 367:8
367:12 372:24
378:8,9 383:7
385:12 386:4,8
394:4 397:5,6
398:3,3,9
roofer 68:13 278:5
278:13
roofing 14:2 16:14
18:16,23 22:16
31:13 35:11 54:21
68:22,25 79:23
85:16 88:24,24
89:9 94:16 99:15
113:13 132:8
143:14,21,23
145:25 150:10
151:6 159:12,13
162:20,21 178:3,8
229:15 279:7,10
279:11 281:2,3,12
284:7 315:6,13,15
315:23 316:12,25
318:16 319:2
320:4 325:21,22
348:4 369:18
379:1 388:4
395:15 399:3
402:2
roofs 34:6,13,19,20
34:23 145:24
210:24 278:18
282:20,24 371:10
394:5
rooftop 11:6 40:18
room 111:6 114:24
291:3 322:22,24
326:21 374:23
rooms 337:22
340:5 351:5
rotted 191:19
rotten 210:19 295:2
295:8,24 296:17
348:19
rough 24:1
roughly 326:23
route 326:4
routine 371:24
rows 117:11
Roxann 112:3
rubber 150:19
151:25 373:3
rubberized 151:17
Ruberoid 12:23
39:24
ruin 79:3 95:6
332:18 362:13
ruined 185:19
ruining 380:18
ruler 205:20
rules 7:10,20 401:7
run 81:9
runaround 324:6
running 291:24
294:19,21 306:6
331:14 394:2
runs 350:3
rushing 236:13
rusty 225:10,13
321:7 379:10
S
S 3:1
safe 34:17 228:3
safety 393:8
sag 214:2
sales 158:19 271:19
salesman 322:18
Sampson 1:14 3:18
3:19 30:22 31:19
31:23 32:5 276:6
276:20,23 277:1
279:21,25 280:2
391:1 396:9
398:18 399:1,6,9
399:13,17,21
400:5,12 402:15
402:18 403:11,16
403:19 404:2
405:6,7
sanction 393:1,13
sanctions 392:4
sandbags 191:11
328:16 329:12
sandbox 381:7
sat 317:23 318:12
satisfactory 222:11
238:24 356:20
satisfied 179:3
210:7 376:3 377:2
384:24
satisfies 369:4
satisfy 206:21
209:4,23 360:17
saturate 112:19
saturated 68:8 72:7
79:21 112:21
Saturday 15:19
52:9 53:14
sausage 370:17
save 150:22,24
315:3 376:12
379:8
saved 314:7,23,24
344:1
saw 6:14 48:25
92:8 96:1 98:6
121:11,14 131:22
138:18 142:3
147:8 171:7 220:2
220:11 224:2
237:16 257:22
313:9 321:10
326:8 328:24,24
334:10 373:5,22
375:2 379:13
380:8
saying 27:4 74:20
80:18 84:11,16
86:2 91:11 114:10
170:5 175:20
179:18 181:10
182:11,17 184:3
229:11 235:15
237:12 249:5,20
251:4,5,15 252:9
257:16 261:11
262:1,13 263:14
265:14 266:18
270:6,8,15 272:9
273:10,11,21
289:22 296:4,9
312:22 327:22
331:5,12 333:13
336:18 348:1,15
348:16 352:2
354:15 376:7
386:6 399:14
says 32:24 33:2
36:22 39:22 40:8
42:6,17,20 45:15
45:21 47:25 48:2
48:14 50:22 51:2
51:5,6 53:6,23
54:21 55:8 71:12
75:16 108:6
111:17 133:12,12
134:15 135:13
145:6 154:23
155:5,8,11,14,24
155:24 157:5
158:6,10 160:19
166:18 169:9
170:10 199:10,23
216:15 231:14
243:20,23 253:5
256:2 293:2,6,12
301:4 310:12
315:4 339:10
373:4 375:23
377:12
scale 383:17
scales 383:3
scenario 356:16
schedule 17:10,16
83:8,9 213:14
256:3
scheduled 16:21
79:6 82:19,22
83:19 175:1
school 202:24,25
scope 9:6,21 40:14
153:20 375:22
398:20,22,24
scrape 374:25
screen 41:13
102:12,13,14
114:2 117:6
118:21 132:14
314:1,1 316:17
317:3 318:6
screening 349:22
screwed 257:14,16
257:17 375:16,16
screws 257:14
se 1:20 305:2
seal 151:25 154:25
293:13 296:2
sealed 113:21
sealer 373:3
sealing 152:10
seam 54:9
season 190:22
191:1 274:17
second 32:3,8 33:1
44:12 49:23 50:25
53:22 54:20 58:22
72:12,15 163:18
169:14 200:3
227:18 256:4
260:25 288:10
356:12 393:24
394:20 396:25
403:7,8 404:10,11
404:13
seconded 401:8
Page 444
secondly 190:7
secretary 1:12 3:5
4:13 18:22 19:4
20:24 72:19 73:18
74:7 79:1 94:1,4
94:23 109:25
110:6 119:7
228:17 242:7,20
243:3 331:9
333:13 334:2
362:15 404:17
secretary/assistant
368:22
section 5:21 6:1
14:18,19,20,21,22
17:20,23 42:19
43:12 54:22 158:6
197:22 201:13
213:4,5,6 227:17
227:18 260:7
269:6 367:1,2
368:14 391:6
sections 14:17 17:9
17:13,18 176:16
239:3 366:24
see 5:6 18:4 23:18
24:10,14 25:24
26:24 33:8 36:2
36:17 37:19 39:19
41:25 42:5 43:22
44:13,21 47:15,24
54:16,22 59:4,4,7
68:13 72:12 88:25
90:3 98:13 101:8
110:15,24 111:9
111:16,21 112:7,8
112:20,24 116:2,9
116:13 117:5,14
119:8,17 124:17
134:1,16,25
136:11,12 138:5
138:19 139:7,20
145:2 148:2,17,20
157:1 158:14
162:13 163:20,23
164:23 169:12,18
169:19,21 172:15
177:9 178:11
181:5 191:9,17
195:20 196:18
197:18 200:1
208:1,24 210:13
210:14 212:23
213:4,5,7,19
214:22 215:9,21
216:1,17 217:9,14
224:13 225:1,9,10
225:11 227:1,15
227:19,23 236:3
237:20 243:21
251:24 252:5
255:1,6,10 258:8
265:1,2 270:9
271:2 274:16
280:21 295:6,10
295:13,21 322:16
322:22 326:7
327:8 339:6
351:17 352:2
354:22 356:19
357:17 375:7
384:3 388:1
390:22,25 391:11
398:14 399:11
400:9,12
seeing 4:19 91:20
110:22 212:25
329:7 330:2
379:16
seek 186:7 331:1
seeking 68:11
seen 23:8,10 51:10
52:18,23 119:5
138:24 140:4
171:4 176:19
196:14 205:22
206:24 217:16
222:23 250:25
251:6 254:9
304:12 319:20
338:22 353:12
377:12 386:2
390:10,24
sees 71:9,10
selected 224:24
sell 271:25
send 29:10 56:24
65:18 70:7 73:23
75:2 90:12 234:3
237:13 259:11
268:16 269:14
272:24 273:2,7
274:20 288:8
313:2 315:2 317:3
318:7 328:23
333:12 335:24,24
343:4 347:19
354:21
sending 314:14
317:2 318:5
sends 82:3
Senior 10:10
sense 111:23
289:21 400:25
sent 14:25 24:11,14
27:11 57:12 69:14
69:19 74:18,19
75:2,21,22 76:15
83:12 84:11,16
85:19,20 100:18
102:20 106:10
118:6 119:20
122:15 131:3,7,17
133:5,10,18,20
134:6 136:6 137:1
137:21,24 138:5,5
142:4 148:4,22
162:11 175:20
177:11 231:7,13
250:1 268:15,22
268:23,24 269:16
269:22 271:9
272:12,19,21
273:17 309:2,23
312:15,17,18
313:25 314:16
315:16 316:18
318:7 335:3 343:5
344:18 347:20
374:3
sentence 55:8
148:19
sentences 204:10
separate 19:15
166:23 167:5,16
167:17,20 334:17
separately 178:20
317:25
September 11:3,10
11:13,17,21 15:8
15:18,20 16:1,13
29:13 37:13 70:10
70:19 71:21 72:22
77:3 79:20 90:16
90:17 91:3 93:7
93:10,19,21 95:9
96:4 97:12 98:20
111:9 113:6,12,13
120:24 121:8,10
124:4 125:7,9
134:9,15 135:2,8
135:21 136:14,18
136:21 138:15
153:6 157:3
158:12 159:25
160:3,12,13,19
163:3,20 165:6,21
166:16 170:5
249:21 286:18
291:15 301:20
326:24 327:2,2,4
327:5,19,20 328:5
332:13 333:1
342:19,20,25
373:25
sequence 157:2
250:10
series 52:7 116:15
seriously 93:5
serve 363:19
served 14:14,15
127:8 243:6,9
363:8,10
service 309:13
332:3,4,5
Services 19:23
set 26:1 86:6
119:15 232:15
317:17
sets 105:24
settle 259:12
settled 249:4 399:4
settlement 356:24
seven 10:11 122:16
373:5
shady 165:10,13
270:3,7 326:16,17
shake 238:19
383:22
shame 386:18
395:18
shanks 200:11
202:22
shape 372:25,25
shaped 327:23
share 128:1,7
129:11
sheath 104:14
sheathing 8:22
12:18 13:2 14:6
15:23 16:20,22
17:11,20,21 34:23
51:2,7,8 58:23
59:1 83:6,7
104:14 176:17
178:25 195:5
199:24,25 200:8
205:12,12,14
206:4,22 207:13
209:5,13,25
210:17 211:14
213:11,12,16,20
215:6 216:3,10,11
217:9 218:12
220:6,11 225:7
226:2 233:20
294:4 327:21
356:4 367:5
shed 31:7
sheet 51:4 210:12
211:3 214:7
371:23 378:3,4
396:1,4
sheetrock 377:4
sheets 208:3 225:17
257:11 288:19
Sheila 1:14 395:3
399:25
shift 329:15
shifted 329:12
shingle 11:6 23:17
40:18 90:12 154:1
163:1 197:21
278:2
shingled 69:10
Page 445
162:25
shingles 135:24
147:1 151:13
154:24 208:22
224:14,17 293:6
322:10,12,15
shirt 95:24 139:2
153:12 340:25
shock 237:25
shocked 237:12
shop 371:6
short 184:15 205:7
237:8 359:19
384:12
shortcoming 226:2
shorter 205:23
Shorthand 406:5
shortly 139:14
166:15,15
shot 314:1
shots 316:17 317:3
318:6
shouting 335:9
show 8:12 44:17
75:19 86:3 96:5
101:25 106:1,21
112:13 114:1
115:19,23 116:12
116:12,17 138:1
152:21 156:7
238:8,9,25 246:17
257:2 354:16
showcase 210:4
showed 3:22 16:20
72:6 79:10 86:8
86:10 89:19 90:15
90:17 95:25 96:2
146:2 157:19
160:17 179:13
194:17,24 237:9
239:18 277:15
290:18 317:20
334:11,12 341:10
361:19,20
showing 5:15 12:2
12:16 13:2 207:7
235:16 249:19
367:7 383:8
shown 202:7
shows 11:12 111:6
113:7,12,17,18
114:24 115:15,20
117:9,22 153:7
179:20 227:22
327:3 328:19
shrugged 187:1
Shubin 1:17 5:1
Shultz 5:9,18 8:6,8
8:10,12 9:12,16
9:20 10:15 11:2
11:10 12:6,10
13:22 14:25 15:3
15:7,11 16:3,9,14
16:16 17:8 18:14
18:25 19:7 20:12
21:13,14 22:10,13
22:17 28:13 30:16
31:11 37:15 42:9
42:24 58:11 64:2
68:24,25 74:6
78:25 85:16 88:9
89:8 92:15 93:7
94:24 95:15 96:10
99:3,15,15 100:4
104:7,10 120:21
122:4 123:3 124:7
128:24 129:4
130:15 134:3
135:10 137:9
138:17,21,25
139:2,8 143:14,21
143:23,25 145:16
153:11 158:15
159:10,12,13
167:1 171:8 173:5
176:23 178:8,21
178:23 181:11,24
183:9 188:10
204:11 226:1
231:15,24 242:7
244:10 248:2
249:25 251:21
258:2 285:25
286:9 297:2
310:15 311:16,23
315:7 316:25
319:21 323:3,18
327:9 332:16
333:8,10,10
338:23,24 339:10
340:14,23 341:1,7
341:10 348:5
361:11,13,13,15
368:11,18 369:11
369:14,18 375:11
378:9 382:5 385:7
396:21
Shultz's 120:25
377:1,4
shut 282:14
Shutlz 232:2
sic 36:22 52:4
73:12 78:7 83:23
178:24 183:6
204:16 221:19
238:18 246:24
316:20 319:18
368:12
side 54:4 69:10,10
82:9,9 90:12
112:21 113:20
115:10,15,18
116:8,18 133:19
133:24 146:24,25
154:1 173:22
179:13 292:11
294:19 295:8
301:2 316:4,4,5,6
327:9 338:23
348:22 350:3
372:6
sides 270:3,10
siding 292:12 295:8
295:25 296:16
sight 160:22
sign 106:15,24
107:22 108:5,16
136:7 159:19
231:11,12 234:11
236:2 249:9
253:25 261:20
262:15 269:25
284:25 287:12,15
309:5 323:23
signature 42:15
43:14,17 48:6
72:16 106:18,19
106:20,21 107:4,7
107:17,24,24
108:6,7,14,16
136:2,4,5 156:21
159:18 177:13
287:9 309:2
signatures 23:23,25
108:19
signed 11:2,10 12:3
12:11 16:4 21:13
36:18 37:6,16
41:2,4 42:8,23
43:4,25 50:8 56:2
72:16 76:24
100:19 106:13,23
106:25 107:2
159:2,20 173:1
180:3 181:7
190:22 191:2
253:23,24 254:10
268:25 269:1,3,5
269:18,21 309:3
323:20 350:5,20
386:14,15
significant 54:5
384:7
signing 303:5,5,6,7
signs 138:19
silent 255:22
similar 49:6 137:13
186:21 310:8
simple 249:17
simply 271:17
388:3
single 20:22
sir 26:3,6 38:9
40:22 41:1 46:18
49:3 58:10 59:9
60:16 121:13,18
122:2 125:23
151:20 181:13,15
182:3 201:17
203:4 205:16,18
208:4,7,12,15,18
210:12 211:15
219:5 224:7
227:13 228:7,14
228:21 229:4,7
230:21 260:17
273:4,21 274:2
277:21,24 284:11
284:17 285:5
288:7 289:2
290:20 291:1,4
292:22 293:1,5
297:4,8,11,14,17
323:13,15 332:1
338:3,9 354:25
391:5 393:21
404:7
sister 99:11
site 9:10 12:24
15:25 18:4,21
33:7 46:21 47:15
49:12,25 194:9,12
199:5 205:17
214:23 225:20
234:5 238:20
273:7 291:14,22
sits 356:24
sitting 27:23 28:9
149:6 171:16
192:18 296:24
299:17 353:5,6
situated 181:21
190:18
situation 8:4 76:3
80:12 185:20
237:17 251:12
257:13 287:20,22
292:6 370:23
375:3
situations 275:17
six 82:24 83:4,25
122:16 174:25
179:24 180:1
184:2 200:11
201:20 202:18,21
205:23 210:11
216:10 220:15
221:19,23 225:18
225:24 226:10
227:21,21 273:6
317:20 320:22,22
321:22 346:5
six-inch 225:21
226:21
sixty-seven 391:6
Page 446
size 222:13
sketchy 184:25
slips 374:3
slope 257:4 294:18
sloped 69:10
sloppy 117:1
slow 238:18
small 8:10 52:19
69:7 141:13 146:9
146:13 149:2
210:3 233:7 245:9
263:17 328:15
329:25 330:3
339:19 380:24
smaller 32:6
smart 353:21 354:3
smarter 354:1
smash 380:16
smoking 341:16
snowballs 381:1
soft 194:21
software 308:16
solar 48:8,10 49:4
72:10 102:2
117:18,22 118:22
118:22 149:3,5,9
149:12 154:4,4,23
161:20,20 182:18
255:5 293:3
300:15,15 321:6
321:18,18 349:23
352:20 375:23
377:9 380:5
sold 322:18
sole 78:24 95:5
232:5
solely 364:14
solutions 380:2
solve 376:24
somebody 42:9,23
141:1,20 145:20
159:18 206:25
207:13,22 244:21
272:24 273:2,7
291:12 337:24
360:11 375:24
378:16 379:8
384:13 385:14
395:23 396:2
somebody's 326:17
soon 70:5 83:1
165:18 174:7
183:25 189:16,17
334:13
sooner 90:13,14
sophistication
307:8,12
sorry 3:24 36:6
61:20 68:14,15,17
75:15 87:12
101:13 102:11
103:22 123:7
128:17 131:15
132:13,16 136:20
140:3 141:12
153:10 161:1
163:5 164:9
169:13 173:1,5
174:15,16 175:18
183:9,9 187:7
195:10 206:3
228:8 230:17
239:10,10 241:21
257:15 265:23
269:11 272:16
298:5 299:13
300:9 304:16
312:4 315:10
363:6 375:25
387:19 388:12
402:17
sort 8:2 55:19
67:22 90:6 137:8
151:17 187:3
234:3 276:8,14
284:4 356:24
377:2 378:5 384:4
396:22
sorted 190:6
sought 8:19
sound 386:22
sounded 312:22
sounds 183:4
352:23
space 11:16 160:3
164:18 210:4
318:13
spaced 201:19
spacement 221:18
spaces 195:25
226:25 227:2
228:4
spacing 239:18
speak 4:17 50:19
52:25 66:12,17
68:5 74:11 85:22
86:9 97:1 145:8
186:20 214:18,20
217:11 333:14
356:11 384:2,3
speaker 175:12
317:10,11 336:13
341:19
speakerphone
77:22
speaking 30:9 84:7
147:25 188:11
231:5 311:20
324:11 342:1,12
363:11
speaks 66:15 75:17
78:11
spec 240:16
special 3:22 278:15
278:17 279:4,14
specialize 170:16
specialties 62:10
specialty 307:11
specific 229:21
278:11 392:23
specifically 366:24
400:22
specifics 396:13
speculation 209:7
spell 301:5
spelled 133:14
speller 72:11
spelling 155:1
157:23 300:21,22
spend 90:19
spent 28:6 237:22
290:20 320:5
366:2,7
spite 179:24
spoke 19:1 41:3
69:6 72:5 94:8,19
97:7 139:18
147:11,17 149:1
161:25 173:5,23
189:25 195:22
216:20,21 223:9
317:22 324:4,8
326:9,20,21
331:20 334:23
335:2 336:25
337:10,11 343:6
368:9 378:14,17
385:25
spongy 211:21
214:6
spot 68:8 154:3
159:18
spots 104:17
115:12 194:20
196:10,15 213:22
spurs 98:13
square 234:16,16
285:4,12,19
289:23,23 327:24
squares 267:3
squeezed 386:20
SS 406:1
St 6:2,9 8:20,25
10:8 14:16 16:9
18:7 20:13 22:22
30:18 31:13 34:7
35:16 36:24 39:12
40:11 41:23 45:7
52:2 68:12 73:2
74:23 89:4 96:17
118:25 119:11
123:9,15,21
124:10,11,18
142:12 144:5
171:22 174:4
177:8 187:6,9
189:6 193:18
196:3 198:15
206:20 207:22
209:4,23 210:9
223:12 229:19
233:11 253:18
255:20 297:6
312:1,7 323:17
369:24 392:5,6,8
392:21 402:2
406:2,9
stacked 353:6
staff 4:2,12,14,22
5:2,4,10 21:17,19
22:7,24 23:14
30:16,19 31:17
101:2 119:16
123:17 124:16,24
128:13 193:6
219:3 228:12
273:12 277:12
281:14 298:20
358:20,23 365:19
365:21 369:5,9,25
387:18 388:2,21
391:10 398:5
401:5 405:10
staff's 275:4 348:2
366:5 394:7 398:7
staffing 244:12
stamped 65:15
stand 6:13 228:13
standard 193:21,23
210:21 219:18
standpoint 387:16
stands 102:19
stapled 114:3
star 167:17,18
170:12 252:3,3
start 6:5 55:10
67:22 70:1,24
160:25 162:2
164:8 165:16
190:18 203:22
223:3 235:21,21
236:6,17,21 237:7
246:8,8,12 250:24
251:11,14 255:23
281:22 288:10
342:3
started 20:21 29:13
70:6,16 76:2
90:21,23,25 98:13
99:17 112:19,21
115:2 120:22,23
123:14 124:3,22
125:6,8 141:5
159:25 161:2,6,17
161:20 165:16,17
Page 447
182:9,14,16,20
191:9 261:13
267:12,13 271:11
279:1 335:16
337:25 358:5
381:25
starts 48:12 116:17
state 4:3 10:11
13:16 16:11 20:3
20:5 30:11 46:20
67:11 99:24
123:10,11,20
135:15 140:22,23
160:11 171:24
187:21 193:15
197:24 219:14
228:16 271:13
278:22,25 279:10
304:13 366:18
381:13,21,22
388:4 391:14
393:3 406:1
stated 27:8 30:7
32:3,4 38:24 41:4
55:9 56:23,25
69:16 73:21 74:14
76:10 79:12 80:17
82:24 88:14 93:20
108:5 117:20
120:23 121:19
170:7,21 171:11
174:24 175:3
182:7 186:7,9
188:3 237:13
246:13 259:4
320:18 325:24
326:3 332:21
334:13,13 337:22
340:10 341:18
346:11 347:2
358:5 368:10
397:5 400:22
401:21
statement 2:4,9 6:6
6:11,17,22 7:5,12
13:4 14:4 39:5
51:2 55:5,6 65:11
66:13 87:20
100:23 105:18
154:20 186:12
188:17 195:12
199:22 249:8
statements 2:2
99:25 100:2
131:21 154:10
242:17 387:24
states 32:8 75:21
118:20 187:25
stating 39:4 85:9
103:8 119:24
209:8 276:5 338:6
status 59:13,17
343:1 364:22
stay 70:21 291:2
315:13 396:25
Stayton 178:17
step 233:2 270:23
379:3 402:10
step-brother
142:18
step-dad 142:10
step-father 142:16
stepped 360:14
steps 327:17
sternly 80:15
stick 127:2
sticky 398:15
stipend 245:11
stipulations 400:16
stop 183:20 226:6
295:14 296:9
stopped 15:22
117:11 160:23
189:22
stops 71:12
story 184:14 237:8
347:22
straight 234:21
237:24 328:11
364:4
straighten 273:14
Street 1:18,20 5:1
strike 89:23 159:7
string 24:5 52:15
52:22 53:5 133:12
133:16 134:20
171:7 314:18
318:20
strip 48:15 252:11
stripe 157:11
stripped 15:23
21:25
strongly 77:13
structure 198:3
368:1
structured 262:21
struggling 365:3
stubs 244:13
stuff 48:7 64:10
71:9 98:13 124:2
151:17 170:11
185:1 190:6
262:22 269:23
270:3,7 287:15
328:16 343:8
352:18 377:17
380:5,6
sub-contractor
19:18
subcontractor
232:14 237:21
261:2 276:8
278:10 396:22
subcontractors
232:10,16 250:14
250:14,19 276:10
276:11,20,24
277:19,20,23
279:23 288:1
subject 381:4
submit 8:24 105:19
177:23,25 206:20
207:15,23 236:19
249:19 251:7,8
253:22 257:21
258:23 259:7,14
367:24 368:4
submittals 75:1
submitted 15:12
43:12 161:22
177:5 180:15
197:19 209:3
217:17 220:23
251:2 255:6,11
284:21 314:2
318:19 353:12
368:7
submitting 10:17
10:23 11:24 12:7
12:14 13:13,19,25
14:10 107:21
subpoena 24:7
27:13 52:1 57:6
63:22 127:8 128:2
144:15 243:6,9,20
243:23 304:3
308:19 309:1,11
313:19,20 330:19
363:2,3,10,11,13
363:19
subpoenaed 323:6
subpoenas 14:14
52:8 118:25
119:16 312:15
Subsection 401:17
subsections 401:3
subsequent 196:19
substantial 173:9
369:3 371:2,19
substantive 383:10
subtract 367:25
sudden 381:2,23
suddenly 257:22
sue 80:18
sufficient 176:5
260:5
sufficiently 51:9
200:1 214:16
suggest 356:17
suggests 81:11
suite 79:24 97:14
98:12,14 102:4
111:17 351:15
summary 199:7
Sun-Biz 19:25
Sunbiz 140:16,20
143:24
Sunday 70:24
90:21
Sunshine 357:12
364:10
super 326:11
supervise 306:15
supervision 392:12
supervisor 13:14
19:22
supplemental
200:12 225:23
226:8,8
supporting 12:24
suppose 207:19
378:13
supposed 84:23
137:25 138:3
173:20 182:8
236:9 247:14
259:2,3 293:11
306:23 319:10
328:4 337:20,22
342:3 343:8,9
345:3,5 346:9
352:5 395:13
400:1
sure 39:22 40:17
44:6,18,25 47:7
64:6 65:25 66:8
66:16 80:16 85:17
86:12 100:18
108:15 109:2
112:3 116:19
120:25 121:5
124:12 127:19
128:10 130:21
134:6,12 139:6,10
139:17 148:12
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18,000.00 240:5
184 2:11
18th 11:17 15:18
90:16 93:11
116:16 117:17
136:20,21 163:17
165:6,21
19 13:4 15:20 45:1
160:20 198:14
249:21
193 2:13
19th 16:13 29:13
70:10,19 77:3
79:20 90:17 97:12
120:24 121:8
124:4 125:7,9
160:12,13,16,25
161:3 249:21
1st 1:18 5:1 13:21
79:9 96:2 173:4
180:3 181:2
186:19 266:15
288:25 334:12,12
335:1,1,14
2
2 44:4,25 55:16,16
145:4,4 311:24
2,000 257:22
280:25
2,750 164:8,11
2/10 199:19
20 13:12 25:3 34:17
161:23 199:1
203:21 292:4
346:9
20-something
332:13 334:22
20,000 353:16
201 2:13
2011-0365 12:9,15
16:20
2015 36:22
2018 344:2
2019 10:9 320:1,2
2020 8:14,16 11:11
11:13,17,22,25
12:12,16 15:8,18
15:20 16:2,13,15
16:18 28:8 29:13
29:19 37:13 44:1
70:10 75:15 78:6
88:8,10 93:10,21
95:9,12 97:12
98:20 105:2
117:10 120:24
124:20,20 130:14
131:7 133:1
138:11 142:2
146:7 148:10,20
149:10,14 153:6
155:14,22 160:20
166:19 167:6,12
167:17 169:11
172:7 173:2 230:8
252:3 323:9
2021 10:25 11:3
14:7 16:21,24
17:7 21:23 32:25
33:10 36:19 45:13
46:2 47:14 54:16
55:16 56:4 57:23
79:9 85:8 86:4
99:19 104:2
115:21 173:4
175:16 180:9,11
194:7,8 196:6
199:5,21 219:23
223:16 238:25
239:9 240:17
258:18,19 259:25
288:25 320:11
337:8
2022 1:5 10:22
13:17,21 14:24
20:7 28:9 75:16
177:15 199:20
406:17
20th 16:21 32:25
45:13 77:3 79:20
79:20 82:18 83:9
85:4 90:21 97:12
111:8 113:14
125:9 159:25
160:3,17 161:2,7
162:2 173:1
175:25 228:22
328:5
21 10:20,21,21 13:7
13:17 15:2 18:1
21:24 37:13 157:3
240:18 286:18
212 2:14
215 2:14,15
219 2:16
21st 11:10,13,21
16:2 71:21 91:3
93:10,13,18,19
138:15 153:6
158:12 166:3
301:21 328:6
22 13:18 57:23 60:7
234:16 271:22
224 2:17
229 2:18
22nd 10:21 12:12
43:25 77:1 78:10
78:13 95:25 96:19
113:15 117:10
173:2 177:23
23 13:24 100:25
Page 456
101:6 102:19
177:8
2300 1:8
23rd 78:6,10
24 13:24 62:2
100:25 101:8,9
102:19 177:8
24982 246:24
24th 343:5
25 2:6 13:7 14:3
163:23,23 164:8
164:10,15 237:13
237:14,15 256:3,4
256:4,5 264:2
268:2,6,9,10,12
380:14
25th 60:7 72:22
93:21 95:9 326:23
343:6
26 12:22 39:24
261 2:19
26th 131:4 133:1
138:11 148:20
184:13
28 1:5 2:6 14:3
282 2:19
28th 3:4 14:24
185:6
29 14:9 223:11
29th 113:12
2nd 79:9 96:2
3
3 1:18 57:22,22
130:13 148:16
398:6 402:7,13
3,000 9:2 11:13
32:11 82:10 163:3
174:14 182:18,23
183:12 187:15,19
187:25 188:2
234:18 237:19,24
259:13 266:11
270:25 289:22
290:8,9 334:9
336:3,6 337:9,19
339:15 340:2
349:3,19,19 351:3
351:7,8 355:21
356:8,23 358:11
374:24 385:2
3,000.00 82:5 337:5
337:11
3/4-inch 215:6
30 14:14 127:18
300 2:21 380:15
304 2:22
3042 178:24 319:18
31981 155:15,16
167:6,17 252:3
388:6
33130 5:2
33130-1610 1:18
33316-1377 1:21
33323 228:23
338 2:23
34 2:7
343 2:23
34950 1:24
34982 1:9 67:15
304:17
359 2:24
365 22:11 369:12
381:10 402:3,25
380422 11:17
39 14:14
3rd 20:7
3x3 17:4 33:4 39:24
46:4 47:1 55:2
4
4 55:16 56:4 130:22
148:16 164:16,16
164:19 313:14,19
401:17
4,000 11:12,12,18
11:21 15:17 16:6
32:9,14 71:25
72:2 93:8,9,14
155:5 158:6,10,11
163:4,6,17,18,21
163:21 164:1,18
165:5,20 166:4
290:7 303:5 335:3
373:14
4/13 50:1
4/30/2021 33:2
4/6 204:25
4/6/21 204:13
40 14:17 229:13
243:16,17
400 282:22,23
285:19 307:13
394:5
400,000 308:13,14
308:15
4032 8:14 12:1,9
13:23 14:13 15:5
22:18 35:14 36:25
39:8,13 49:12
58:13,18,20 59:13
59:15 64:14 67:14
142:12 146:8
194:1 198:24
201:2 212:20
219:21 229:25
246:24 248:3
253:7 297:6
304:16 305:1
313:16 348:6
369:19
405 406:7
43 14:17 304:16
432 52:4
44 14:23
46 1:18 5:1
48 357:1
49 14:24
5
5 2:3 37:3 131:2
155:22 167:12
5,000 79:15 80:17
80:25 175:4,13
185:23,24 234:19
235:2,19 240:2
247:14 264:16
273:6 289:19
290:4 334:14
335:5,11,15
337:11,14
5:25 1:7 405:21
5:33 52:6
50 15:1
500 245:3,13
325:10 404:1,6
507.50 38:10
53 15:1
575 277:6
5th 73:20 124:20
137:18 155:14
166:19 167:6,17
248:21 249:23
252:3
6
6 11:8 23:6,12
32:18 38:7 40:11
40:11,24 41:25
42:12 43:4,8,16
47:20,20 48:24
131:12 153:1
154:21 169:16
230:14,16 249:24
249:25 251:19,19
286:13,17,25
293:2 326:5
6,000 131:12
351:11
60 251:1 352:19
61 2:7
63 2:8
68 2:9
6x6 201:22
7
7 11:15 32:18,19
39:10,10 40:21
41:23 42:16 43:4
43:6,11,19 48:25
131:19 169:8,17
169:18 172:5,5,10
172:11 329:9
7,000 11:4 15:10
23:18 32:3,5
40:18 69:20 89:25
92:3 131:14,15
134:11,18 135:6
135:10 152:14
154:7 161:9 162:3
162:18 163:9
319:21 373:15
70 251:1 308:5
700 245:4,14
706.7.1.2 14:22
17:23 367:3
73 166:8
75 12:21 39:23
750 380:15
772-464-2664 1:25
8
8 2:3 11:20 32:20
132:3 172:7
201:25 240:10,11
329:4,7 349:24
8,000 32:11 158:7
159:23 237:12
249:21 251:4
264:8 289:9,16,25
303:7 331:24
332:2 335:4
336:19,21 337:1
352:21 374:20
8:35 1:7 3:3
80 257:11 288:19
308:5 352:19
88 2:10
8D 200:10 202:22
8th 12:15 16:17
29:19 76:14
172:19 246:7
8x8 17:5,20 33:5
46:6 47:2,3
201:13,22 216:6
367:9 381:14
9
9 11:23 18:4,5
32:20 33:8 39:23
47:15,16 50:4
53:22 216:16,17
240:11 349:24
9-inch 12:21
9,000 234:20 240:3
240:4
9/21/20 156:24
9:51 175:20
90 218:3