l\/. f\t - Florida Attorney General

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
OFFICE OF THE ATTORNEY GENERAL,
DEPARTMENT OF LEGAL AFFAIRS,
STATE OF FLORIDA,
Plaintiff,
Case No.:
~l\/ .
vs
T & G MARKETING, INC. dba
CUSTOMLINE REMODELERS,
a Florida corporation; and
THOMAS R. CONRAD, GLORIA L.
CONRAD and RICHARD M. CONRAD,
Individually and as Officersffiirectors of
T & G Marketing, Inc.,
~Ol3(1\.(XY1~}."'3
f\t\
COPY
RECEIVED FOR FILING
APR 2 6 2013
Defendants.
SHARON R. BOCK
CLERK & COMPTROLLER
CIRCUIT CIVIL DIVISION
COMPLAINT
Plaintiff, OFFICE OF THE ATIORNEY GENERAL, DEPARTMENT OF LEGAL
AFFAIRS, STATE OF FLORIDA (hereinafter referred to as "Plaintiff'), sues Defendants T &
G MARKETING, INC dba CUSTOMLINE REMODELERS, a Florida for-profit corporation
(hereinafter referred to as "T&G MARKETING"); and THOMAS R. CONRAD, (hereinafter
referred to as "THOMAS CONRAD"); GLORIA L. CONRAD, (hereinafter referred to as
"GLORIA CONRAD") and RICHARD M. CONRAD, (hereinafter referred to as "RICHARD
CONRAD"), Individually and as Officers/Directors of T & G Marketing, Inc. and collectively
(hereinafter referred to as "Defendants") and alleges as follows:
JURISDICTION
1.
This is an action for damages and injunctive relief, brought pursuant to Florida's
Deceptive and Unfair Trade Practices Act ("FDUTPA"), Chapter 501, Part II, Florida Statutes.
2.
This Court has jurisdiction pursuant to the provisions of FDUTPA.
3.
Plaintiff is an enforcing authority of FDUTPA as defined in Chapter 501, Part II,
Florida Statutes, and is authorized to seek damages, injunctive and other statutory relief pursuant
to this part.
4.
The statutory violations alleged herein occurred in or affected more than one
judicial circuit in the State of Florida. Venue is proper in the Fifteenth Judicial Circuit as the
principal place of business of the Defendants is Palm Beach County, Florida.
5.
Defendants, at all times material hereto, provided goods or services as defined by
Florida Statutes Section 501.203(8).
6.
Defendants, at all times material hereto, solicited consumers as defined by Florida
Statutes Section 501.203(7).
7.
Defendants, at all times material hereto, were engaged in trade or commerce as
defined by Section 501.203(8).
8.
Plaintiff has conducted an investigation, and the head of the enforcing authority,
Attorney General Pamela Jo Bondi, has determined that an enforcement action serves the public
interest. A copy of said determination is attached and incorporated herein as Plaintiff's Exhibit
A.
DEFENDANTS
9.
Defendant T&G MARKETING is a Florida for-profit corporation, with a
principal address of 3599 South Congress Avenue, #741, Palm Springs, FL 33461.
2
10.
Defendant THOMAS CONRAD is an adult individual and President of T&G
MARKETING with a principal place of business at 6439 Crooked Stick Court, Lake Worth, FL
33463.
11.
Defendant GLORIA CONRAD is an adult individual, Vice-President and
Secretary of T&G MARKETING with a principal place of business at 6439 Crooked Stick
Court, Lake Worth, FL 33463.
12.
Defendant RICHARD CONRAD is an adult individual, Vice-President and
Treasurer of T&G MARKETING with a principal place of business at 12868 Ellison Wilson
Road, Juno Beach, FL 33408.
13.
Defendants THOMAS CONRAD, GLORIA CONRAD AND RICHARD
CONRAD, at all times material, knew of and controlled the activities of Defendant T &G
MARKETING.
Defendants THOMAS CONRAD, GLORIA CONRAD AND RICHARD
CONRAD had actual knowledge or knowledge fairly implied on the basis of objective
circumstances, that the acts of the employees, agents, and representatives of Defendant T&G
MARKETING as described below, were unfair or deceptive and/or prohibited by law.
BACKGROUND
14.
Defendants THOMAS
CONRAD, GLORIA CONRAD and RICHARD
CONRAD operate and own T&G MARKETING, a for profit corporation that engages in the
business of installing windows, hurricane shutters, room enclosures, texture coating, soffit, fascia
and siding.
15.
T&G MARKETING was incorporated on April 10, 1992 and currently remains an
active corporation with the Florida Department of State Division of Corporations.
PRIOR ASSURANCE OF VOLUNTARY COMPLIANCE
3
16.
Plaintiff previously investigated allegations including but not limited to that
Defendants were not fully compliant with Section 489.126 of Florida Statutes relating to
payment of advanced or deposited funds to contractors.
17.
As a result of Plaintiffs investigation, Defendants T&G MARKETING,
THOMAS CONRAD individually and as President ofT&G MARKETING, GLORIA CONRAD
individually and as Vice-President and Secretary of T&G MARKETING and RICHARD
CONRAD individually and as Vice-President and Treasurer ofT&G MARKETING entered into
an Assurance of Voluntary Compliance (hereinafter referred to as the "Assurance") on or about
May 4, 2006. A true and correct copy of the Assurance is attached and incorporated herein as
Exhibit B.
18.
Pursuant to the terms of the Assurance, Defendants T&G MARKETING,
THOMAS CONRAD, GLORIA CONRAD and RICHARD CONRAD agreed to the following
injunctive provisions:
a)
Respondents and their representatives, agents, employees or any other
person who act under, by, through, or on behalf of Respondents, directly or indirectly, or through
any corporate or other device, shall hereby comply with and have actual knowledge of Chapter
501, Part II, Florida Statutes ( 1997); 1
b)
Respondents shall make known to each employee or independent
contractor in a sales or marketing capacity, the terms and conditions of this agreement and obtain
a signed acknowledgment that the employee or independent contractor understands the terms of
this agreement and agrees to abide by it. The Office of the Attorney General will review and
1
Assurance, Pg. 2, Not Numbered (First Full Paragraph)
4
approve any document Respondent prepares to comply with this term. This term is continuing in
nature and applies to all current and future employees and independent contractors; 2
c)
Respondents shall not make any intentionally false or intentionally
misleading statements regarding the date of delivery and/or installation of its products or
services;3
d)
Respondents shall disclose the anticipated date or time frame of delivery
and/or installation of products clearly and conspicuously on any contract presented to an
individual consumer. Respondents shall not make any verbal representations to a consumer
which differ from the signed contract;4
e)
Subsequent to the execution of any contract, Respondents shall make a
full, prompt, accurate and complete disclosure of any period of delay it anticipates with respect
to delivery and/or installation of its products or services which differs from the executed
contract; 5
f)
Respondents agree, that in any case where they are unable to provide
delivery and/or installation of any products Respondents manufacture within the period specified
in the contract with an individual consumer, Respondents shall permit such consumer to
withdraw from the contract without penalty or further obligation and return any monies received
pursuant to the contract;
g)
6
Respondents shall comply fully with Section 489.126, Florida Statutes,
relating to the payment of advanced or deposited funds in connection with their contracts;
2
Assurance, Pg. 2, Par. 1
Assurance, Pg. 2, Par. 2
" Assurance, Pg. 2, Par. 3
s Assurance, Pg. 3, Par. 4
6
Assurance, Pg. 3, Par. 5
' Assurance, Pg. 3, Par. 6
3
5
7
h)
Respondents agree to cooperate fully with the Office of the Attorney
General in addressing any further complaints or inquiries received after the execution of this
Agreement. 8
i)
Respondents shall not affect any change in the form of doing business or
its organizational identity as a method of avoiding the terms and conditions set forth in this
Assurance. 9
j)
Future violations of the Assurance are by statute prima facie evidence of a
violation of Chapter 501, Part II, Florida Statutes, and will subject the Respondents to any and all
civil penalties and sanctions provided by law, as well as attorney's fees and costs. 10
POST ASSURANCE OF VOLUNTARY COMPLIANCE CONDUCT
19.
A majority of the contracts entered into by T&G MARKETING by and through
THOMAS CONRAD, GLORIA CONRAD and RICHARD CONRAD after the execution of the
Assurance did not include the anticipated date or timeframe of delivery and/or installation of
products at all. An example of such a contract is attached and incorporated herein as Exhibit C.
20.
Some consumers receive no response when they attempt to obtain a refund after
delivery and/or installation of the products was not completed in a timely manner.
21.
Defendants have continued charging and receiving consumers' down payments
for work that has never been completed. Specifically, consumers paid large deposits at the time
of contract ranging from $1,275.00 to $4,000.00. Defendants failed to install or provide the
shutters as contracted. Although Defendants rescheduled installations, they ultimately never
performed the installations. As of September 19, 2012, there were at least 50 open jobs in which
deposits were taken, but installation was not completed.
8
Assurance, Pg. 3, Par. 7
Assurance, Pg. 3, Not Numbered (Fifth Full Paragraph)
10
Assurance, Pg. 3, Not Numbered (Sixth Full Paragraph)
9
6
22.
Defendants T&G MARKETCNG by and through THOMAS CONRAD, GLORIA
CONRAD and RICHARD CONRAD failed to respond to multiple efforts by the Office of the
Attorney General to follow up regarding consumer complaints.
COUNT I
T&G MARKETING, THOMAS CONRAD, GLORIA CONRAD AND RICHARD
CONRAD'S VIOLATION OF THE FLORIDA UNFAIR Ai~ DECEPTIVE TRADE
PRACTICES ACT (FDUTPA) THROUGH VIOLATION OF PRIOR ASSURANCE OF
VOLUNTARY COMPLIANCE
23.
Plaintiff re-alleges paragraphs 1-22 and incorporates same by reference as if fully
set forth herein.
24.
Defendants T&G MARKETING by and through THOMAS CONRAD, GLORIA
CONRAD and RICHARD CONRAD violated the Assurance by entering into contracts that did
not include the anticipated date or timeframe of delivery and/or installation of products at all.
25.
Defendants T&G MARKETING by and through THOMAS CONRAD, GLORIA
CONRAD and RICHARD CONRAD also violated the Assurance by failing to disclose the
period of anticipated delay of performance.
26.
Defendants T&G MARKETING by and through THOMAS CONRAD, GLORIA
CONRAD and RICHARD CONRAD also violated the Assurance by not responding to
consumers when they attempt to receive refunds after delivery and/or installation of products
was not completed in a timely manner.
27.
Defendants T &G MARKETING by and through THOMAS CONRAD, GLORIA
CONRAD and RICHARD CONRAD violated the Assurance by continuing to charge and
receive consumers' down payments for work that has never been completed.
28.
Defendants T&G MARKETING by and through THOMAS CONRAD, GLORIA
CONRAD and RICHARD CONRAD violated the Assurance by not allowing consumers to
7
withdraw from contracts and failing to refund monies collected for work that was never
performed.
29.
Finally, Defendants T&G MARKETING by and through THOMAS CONRAD,
GLORIA CONRAD and RICHARD CONRAD violated the Assurance when they failed to
respond to multiple efforts by the Office of the Attorney General to follow up regarding
consumer complaints.
COUNT II
T&G MARKETING, THOMAS C01''RAD, GLORIA CONRAD AND RICHARD
CONRAD'S VIOLATION OF THE ASSURANCE OF VOLUNTARY COMPLIANCE
THROUGH VIOLATION OF FLORIDA STATUTES SECTION 489.126
30.
Plaintiff re-alleges paragraphs 1-29 and incorporates same by reference as if fully
set forth herein.
31.
Defendants T&G MARKETING by and through THOMAS CONRAD, GLORIA
CONRAD and RICHARD CONllAD violated the Assurance by not fully complying with
Florida Statutes Section 489.126, thereby violating Chapter 501, Part II, Florida Statutes.
32.
Defendants T &G MARKETING by and through THOMAS CONRAD, GLORIA
CONRAD and RICHARD CONRAD received money for repair, restoration, addition,
improvement, or construction of residential real property in excess of the value of work
performed. There was an implied intent to defraud consumers, as Defendants collected monies,
yet failed or refused to perform any of the work specified in the contract for at least a 90 day
period in violation of Florida Statutes Section 489.126.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff, State of Florida, Department of Legal Affairs, Office of the
Attorney General, respectfully requests that this Court:
8
1.
Grant a permanent injunction against Defendants, and their officers, agents,
servants, employees, attorneys and those persons in active concert or participation with them
who receive actual notice of this injunction, prohibiting such persons from violating the
provisions of Chapter 50 l, Part II, Florida Statutes, as specifically alleged above and granting
any further appropriate injunctive relief.
2.
Grant rescission of the contracts entered into by Florida consumers;
3.
Grant rescission of any releases executed by Florida consumers as a condition of
receiving any portion of a refund;
4.
Award restitution to consumers for the acts and practices of the Defendants in
accordance with§ 501.207(3), Florida Statutes;
5.
Award as disgorgement of all revenue, and all interest or proceeds derived there-
fmm by Defendants as. a result of transactions with Florida consumers, generated as a result of
the unconscionable, unfair and deceptive practices as set forth in this complaint, to the Attorney
General for deposit into the General Revenue Fund;
6.
Assess against Defendants civil penalties in the amount of Ten Thousand Dollars
($10,000.00), pursuant to §501.2075, Florida Statutes, or Fifteen Thousand Dollars ($15,000.00)
in cases involving senior citizens or handicapped persons, pursuant to §501.2077(2), Florida
Statutes, for each violation of Chapter 501, Part II, Florida Statutes;
7.
Award costs to Plaintiff for all expenses in bringing and maintaining this action,
including reasonable attorney's fees pursuant to §501.2105, Florida Statutes;
8.
Waive the posting of a bond by Plaintiff in this action;
9.
Grant such other and further relief as this Honorable Court deems just and proper,
9
including, but not limited to, all other relief allowable under § 501.207(3), Florida Statutes, said
relief to include but not be limited to dissolution of the Defendant entities and a permanent
injunction prohibiting Defendants from collecting advanced fees in connection with their
contracts unless fully compliant with Section 489.126 of Florida Statutes.
Respectfully submitted,
PAMELA JO BONDI
ATTORNEY GENERAL
[email protected]
OFFICE OF THE ATIORNEY GENERAL
1515 N. Flagler Dr., Suite 900
West Palm Beach, FL 33401
Ph.: 561-837-5000
Fax: 561-837-5109
10
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
OFFICE OF THE ATTORNEY GENERAL,
DEPARTMENT OF LEGAL AFFAIRS,
STATE OF FLORIDA,
Case No.:
Plaintiff,
vs
T & G MARKETING, INC. dba
CUSTOMLINE REMODELERS,
a Florida corporation; and
THOMAS R. CONRAD, GLORIA L.
CONRAD and RICHARD M. CONRAD,
Individually and as Officers/Directors of
T & G Marketing, Inc.,
Defendants.
DETERMINATION OF PUBLIC INTEREST
COMES NOW, PAMELA JO BONDI, ATTORNEY GENERAL, STATE OF
FLORIDA and states:
1. Pursuant to Section 20.11, Florida Statutes (1995 and 1997), I am the head of the
Department of Legal Affairs, State of Florida (hereinafter referred to as the "Department").
2. In this matter, the Department seeks actual civil penalties on behalf of one or more
consumers caused by an act or practice performed in violation of Chapter 501, Part II, Florida
Statutes.
Page l of2
PLAINTIFF'S
EXHIBIT
A
3. I have reviewed this matter and I have determined that an enforcement action serves
the public interest.
Dated:
~" ~ \ ~ol?:>
PAME A JO BONDI
ATTORNEY GENERAL
STATE OF FLORIDA
Page 2 of2
STATE OF FLORIDA
OFFICE OF THE ATTORNEY GENERAL,
DEPARTMENT OF LEGAL AFFAIRS
IN THE MATTER OF:
AG Case # LOS-3-1100
T & G MARKETING, INC. dba
CUSTOMLINE REMODELERS;
THOMAS R. CONRAD; GLORIA L.
CONRAD and RICHARD M. CONRAD
Respondents.
ASSURANCE OF VOLUNTARY COMPLIANCE
PURSUANT to the provisions of Chapter 501, Part II, Florida Statutes, Florida's
Deceptive and Unfair Trade Practices Act, the OFFICE OF THE ATTORNEY GENERAL,
DEPARTMENT OF LEGAL AFFAIRS, hereinafter referred to as the Attorney General,
caused an inquiry to be made into the business and advertising practices of T & G
Marketing, Inc., a Florida corporation doing business in Florida and doing business as
Customline Remodelers, whose business address is 2310 SE 2nd Street, Suite 5,
Boynton Beach, FL 33435, hereinafter referred to as Respondents.
IT APPEARS that Respondents are willing to enter into this Assurance of Voluntary
Compliance, hereinafter referred to as Assurance, without any admission that
Respondents have violated Florida's Deceptive and Unfair Trade Practices Act or any
other law and for the purpose of settlement in this matter only, and the Attorney General,
by and through its undersigned Assistant Attorney General being in agreement, does in this
PLAINTIFF'S
EXHIBIT .
5
matter accept this Assurance in termination of this inquiry pursuant to Section 501.207(6),
Florida Statutes (2001 ), and by virtue of the authority vested in the Attorney General by
said statute.
IT lS HEREBY AGREED by the parties that Respondents and their representatives,
agents, employees or any other person who act under, by, through or on behalf of
Respondents, directly or indirectly, or through any corporate or other device, shall hereby
comply with and have actual knowledge of Chapter 501, Part II, Florida Statutes (1997),
the Florida Deceptive and Unfair Trade Practices Act.
IT IS FURTHER AGREED by the parties that:
1) Respondents shall make known to each employee or independent contractor in a
sales or marketing capacity, the terms and conditions of this agreement and obtain a
signed acknowledgment that the employee or independent contractor understands the
terms of this agreement and agrees to abide by it. The Office of the Attorney General will
review and approve any document Respondent prepares
to comply with this term. This
term is continuing in nature and applies to all current and future employees and
independent contractors.
2) Respondents shall not make any intentionally false or intentionally misleading
statements regarding the date of delivery and/or installation of its products or services.
3) Respondents shall disclose the anticipated date or time frame of delivery and/or
installation of products clearly and conspicuously on any contract presented to an
individual consumer.
Respondents shall not make any verbal representations to a
consumer which differ from the signed contract.
4) .Subsequent to the execution of any contract, Respondents shall make a full,
prompt, accurate and complete disclosure of any period of delay it anticipates with respect
to delivery and/or installation of its products or services which differs from the executed
contract.
5) Respondents agree, that in any case where they are unable to provide delivery
and/or installation of any products Respondents manufacture within the period specified in
the contract with an individual consumer, Respondents shall permit such consumer to
withdraw from the contract without penalty or further obligation and return any monies
received pursuant to the contract.
6) Respondents shall comply fully with Section 489.126, Florida Statutes, relating to
the payment to advanced or deposited funds in connection with their contracts.
7) Respondents agree to cooperate fully with the Office of the Attorney General in
addressing any further complaints or inquiries received after the execution of this
Agreement.
IT IS FURTHER AGREED by the parties that the Respondents shall not effect any
change In the form of doing business or its organizational identity as a method of avoiding
the terms and conditions set forth in this Assurance.
IT IS FURTHER AGREED by the parties that future violations of this Assurance are
by statute prima facie evidence of a violation of Chapter 501, Part II, Florida Statutes, and
will subject the Respondents to any and ail civil penalties and sanctions provided by law, as
well as attorney's fees and costs.
IT IS FURTHER AGREED by the parties that Respondents shall pay to the State of
Florida, Office of the Attorney General, Department of Legal Affairs, the total sum of twenty
thousand dollars ($20,000.00), pursuant to Section 501.2105, Florida Statutes, said
payment to represent costs and investigative fees. Fifteen thousand dollars ($15,000.00)
due no later than April 28, 2006 and the balance of five thousand dollars ($5,000.00) due
no later than May 31, 2006. Payment shall be made by check made payable to Office of
the Attorney General, Legal Affairs Trust Fund and shall be sent, with this agreement,
by certified or overnight mail to Assistant Attorney General Lynn Etkins, Office of the
Attorney General, 11 O SE 6th Street, Ninth Floor, Fort Lauderdale, FL 33301.
IT IS FURTHER ACKNOWLEDGED that Respondents have returned over
$20,600.00 in deposit money to consumers during the course of this investigation.
Respondents have also remedied complaints and concerns of consumers either by
contract cancellation, discount, installation of ordered products or by other means at the
request of each complaining consumer.
IT IS FURTHER AGREED by the parties thatthis Assurance shall become effective
upon its execution by the parties. Acceptance by the Office of the Attorney General shall
be established by the signature of the Deputy Attorney General. The receipt or deposit by
the Office of the Attorney General of any monies pursuant to the Assurance does not
constitute acceptance by the Deputy Attorney General, and any monies received shall be
returned if this Assurance is not executed by the Deputy Attorney General.
IT IS FURTHER AGREED by the parties that Respondents and their
representatives, agents, employees or any other person who acts under, by, through, or on
behalf of Respondents, directly or indlrectly, or through any corporate or other device, shall
not represent or imply that any advertisement or business activity used or engaged in by
Respondents has been approved, in whole or in part, by the Office of the Attorney General.
IN WITNESS WHEREOF, the Respondents have caused this Assurance of
Voluntary Compliance to be executed by Thomas R. Conrad, Individually and as President
of T & G Markeling, Inc., Gloria L. Conrad, Individually and as Vice-President and
Secretary of T & G Marketing, Inc. and Richard M. Conrad, Individually and as VicePresident and Treasurer of T & G Marketing, Inc. as a true
B6yN roAI
13ch. Florida, this ;;_I
day of
11,ete.; I
I
act
and deed in
2006.
By my signature I hereby affirm that I am acting in my capacity and within my authority as
President of T & G Marketing, Inc. and that by my signature I am binding the corporation to
this Assurance.
T omas R Conrad, Individually and as
President of T & G Marketing, Inc.
STATE OF FLORIDA
COUNTY OF BROWARD
)
)
BEFORE ME, an officer duly authorized to take acknowledgments in the State of
Florida peaonally appeared, Thomas R. Conrad, Individually and as President of T & G
Marketing, Inc., and he acknowledged before me that he executed the foregoing
instrument for the purposes therein stated on the ;?I day of ,AU1L..
Swem and subscribed to before me this RI day of """'1AI L
, 2006.
, 2006.
/4o~'.is~~7u£i.~o~ci/
&r/!1t:..1A />eztKl A7_z~&.;e1JL~
(print, type, or stamp commissioned Notary Public)
Personally known ~ or Produced Identification _ ___(check one)
Type of Identification Produced:_ _ _ _ _ _ _ _ __
By my signature I hereby affirm that I am acting in my capacity and within my authority
as Vice-President and Secretary of T & G Marketing, Inc. and that by my signature I am
binding the corporation to this Assurance.
_tJ~i{~~t
Gloria L.Conrad, Individually and as
Vice-President and Secretary of
T & G Marketing, Inc.
STATE OF FLORIDA
COUNTY OF BROWARD
)
)
BEFORE ME, an officer duly authorized to take acknowledgments in the State of
Florida personally appeared, Gloria L.Conrad, Individually and as Vice- President and
Secretary ofT & G Marketing, Inc., and she acknowledged before me that he executed the
foregoing instrument for the purposes therein stated on the .dL_ day of AR~/L
•
,
2006.
Sworn and subscribed to before me this ,(?f
day of
•A e-'1et L
, 2006 .
&:~·..
IL
.. ~ ~?U.//
NOTARY
STATE oFFLDIOA
PUBLIC-
h-vfl't::./;t ./>B?fN
Ei r;;?t:rA~~L-L)
(print, type, or stamp commissioned Notary Public)
Personally known_L or Produced Identification _ _ _ _(check one)
Type of Identification Produced:_ _ _ _ _ _ _ __ _
~ ·~
~
...
PATRICIA DEAN Fll2GERALD
IAY COMMISSION I DD 09706S
..
"'t.,~
EXPmES:Mly24.2009
Son<lodTMIB"°""'~S.Mcn
By my signature I hereby a~rm that l am acting in my capacity and within my
authority as Vice President & Treasurer of T & G Marketing, Inc. and that by my signature I
am binding the corporation to this Assurance.
IV> ~
Ri~chnciividually
and as
Vice-President & Treasurer of
T & G Marketing, Inc.
STATE OF FLORIDA
COUNTY OF BROWARD
)
)
BEFORE ME, an officer duly authorized to take acknowledgments in the State of
Florida personally appeared, Richard M. Conrad, Individually and as Vice-President &
Treasurer of T & G Marketing, Inc., and he acknowledged before me that he executed the
foregoing instrument for the purposes therein stated on the
-t2.L day of A&r k
,
2006.
Sworn and subscribed to before me this ,///
'
day of
,,l-MJ L-
, 2006.
/~
jl..~~~/
NOTARY PUBLIC - STATE OF'FLO ~
f:t.r~1c.,tt /Je~d F"/ TA-~&ML-0
(print, type, or stamp commissioned Notary Public)
K
Personally known
or Produced Iden· c
(check one)
Type of Identification Produced:_~--r......-~~~----
("\- 'Lynn Etkins
·
Assistant Attorney General
Accepted this
~day of-===;!1i=~r---;~
L.IC. #C6CO 53029
CUSTOMLINE REMODELERS
·- - -- -·- ----·
·----=~7
Total
I.
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2.
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lltor. F1a11Jer, Iii' h ~:ll
~ "'~ Ill) <1<11-.i111 tcir :ltk Oitll'*lilil! ;Wll"Jl'Ji, inelloaing, bur not llnlieu 10. llllLre Ill rtnl~
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3~ 7-
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,
1!2 Oepoalt
e·t Slgnlng
t. perm. by lelagram, S11i1
:<1noe1 U!l1 ••1T•1w1, I~ s~tie :nay n:it lll;ep 111 or oar. or*"' caan aowr. ~avmert
!lt;YER
·Contract
114 Balance Duo
at, Start of Job
l ./
aJ/fl) i.
11J.o
-~00
ffa!'lnco Due •t
Completion
of Jc•b
~--<-
/. . .
-- ~
Cus1D1: •er mli" no:a 10% ot
Comp/s !lon Balance If Inspection
is R9qu1,9d.
I
I
--------c
--~~-.-~~~~-~~---
l j ___ _
D/11'1:
roau~----------·---------- -----OAT E"
}
PLAINTIFF'S
EXHIBIT
j
::Z:o,.-n-:._!f~·'~~-------fl"-PAESt:NTAT; tr!'
_______,
Api:imved UV cim~ -_