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Exhibit S-3: Electrical Scope Deviation & Permit Misrepresentation (2008 Case CE08-03180)

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Subject: Evidence that a 2008 electrical permit citation referencing “entire development” was executed only in Phase 3, suggesting potential permit misrepresentation, false closure, or systemic inspection failure.

📈 Citation Overview

  • Citation Number: CE08-03180
  • Date: October 1, 2008
  • Agency: City of Plantation – Building Enforcement
  • Description: “ELECTRICAL WORK W/O PERMIT – SITE LIGHTING FOR ENTIRE DEVELOPMENT – LIGHT POSTS & REWIRING”
  • Status: Closed

Initial Findings

  • Permit language required work across the entire Omega Villas development.
  • Contractor Vincent Pagan was engaged for the cited work.
  • Historical and resident accounts confirm that only Phase 3 received new light poles and rewiring.
  • No records show work in Phases 1, 2, or 4.

⚠ Discrepancy Summary

Despite the citation covering all phases:

  • Work was limited to Phase 3.
  • The City closed the citation as if the entire property was compliant.

This suggests:

  • False representation of scope,
  • Lack of city inspection beyond Phase 3, or
  • Ignored/misfiled inspection findings.

Broader Implications

  • Phases 1, 2, and 4 may have remained out of electrical compliance, creating long-term safety risks.
  • Phase 2 owners may have been financially penalized later without ever receiving the upgrades cited in 2008.
  • This reflects a pattern of selective contractor execution, unequal infrastructure spending, and false permit closures.

2006-2008 Vincent Pagan Invoices

Review of invoices from 2007–2008 obtained through the Association’s accountant, Juda Eskew & Associates, shows multiple payments for electrical-related repairs (light-pole work, circuit checks, and fixture replacements) billed under the general “maintenance” line item during the same period as City of Plantation Case # CE08-03180.
Several of these invoices list near-identical descriptions and dates, suggesting either duplicate billing or unverified expenditures for work allegedly tied to electrical-code compliance.

Despite these charges, City records confirm that the CE08-03180 citation remained unresolved, and no approved electrical permit was ever filed under the contractor name referenced in the invoices. This points to a breakdown in financial verification and contractor oversight.

These accounting entries provide the first documented financial trail linking unpermitted electrical work, unverified billing, and subsequent City fines—a pattern consistent with the broader oversight failures later seen in the 2023–2025 construction cycle.

  • 📄 Supporting File: Copies of Juda Eskew Invoices.pdf – Historical invoices showing duplicate or unverified electrical-repair billing coinciding with City of Plantation Case CE08-03180.

Supporting File: Vincent Pagan DBPR Enforcement Letter – March 16 2009 (Case No. 2008-024074)

The Florida Department of Business and Professional Regulation reviewed a complaint filed by Shawn Martin and determined that Vincent Pagan engaged in unlicensed contracting activity at Omega Villas during the 2008 construction period.
DBPR’s investigation concluded that “the activities in question do constitute unlicensed practice as alleged,” and a Notice to Cease and Desist was issued.

This record directly corroborates City of Plantation Case CE08-03180, which cited electrical-code violations and unpermitted work. When read alongside the Copies of Juda Eskew Invoices.pdf file, the letter provides state-level confirmation that the electrical work billed through Association funds was performed by an unlicensed individual, validating the pattern of permitting misrepresentation and financial negligence already documented.

2007-2008 Annual Report of Officers (From Sunbiz Records)

Purpose: Provide a snapshot of the Association’s corporate filings for the year in question.
This establishes who held authority when relevant permits, contracts, or enforcement actions occurred.
All data should be taken directly from the Florida Division of Corporations (Sunbiz.org) filings for that calendar year.

2007 Omega Villas Officer Report – SunbizDownload
2008 Omega Villas Officer Report – SunbizDownload

Note:
Officer listings and minutes are provided for context and corporate transparency.

All information is derived from publicly available filings and records obtained through the Association or Sunbiz.org.

This section is for documentation purposes only and should not be construed as an allegation of misconduct.

Board Minutes on Record (Same Period)

Purpose: Establish the decision-making context by referencing meeting minutes from the same period as the cited violations, contracts, or complaints.

This demonstrates whether the Board was informed of or acted on the issue reflected in the annual report or exhibit.

07.16.07 Board meetingDownload
08.20.07 Board meetingDownload
09.17.07 Board meeting (Vince – Vincent Pagan)Download

Notable Excerpt from the 9.17.2007 Board Minutes

Contractor Reference in 2007 Minutes (“Vince”)

Meeting minutes dated September 17, 2007 record multiple directives to “follow up with Vince on status of work,” reference “Vince Invoices,” and note that “Vince will be working on Phase 3 & 4 this upcoming Saturday.” The same page also lists “Pending Vince work” under electrical and lighting maintenance items.

This document demonstrates that a contractor identified only as “Vince” was performing light-pole and electrical-system work throughout Omega Villas during late 2007 — the same scope and timeframe later cited in City of Plantation Case CE08-03180 (Electrical Work Without Permit) and investigated under DBPR Case No. 2008-024074.

Cross-referencing the minutes with DBPR records indicates that “Vince” and “Vincent Pagan” likely refer to the same individual, as Pagan was the subject of the 2008 DBPR Cease-and-Desist Order for unlicensed electrical contracting at Omega Villas. This alignment connects internal association records, municipal citations, and state enforcement actions within a single 2007–2008 timeline.

All identifications are based on matching names, dates, and work descriptions appearing in official records. Determinations of liability or intent rest exclusively with the appropriate regulatory authorities.

Supporting Evidence:

  • Excerpt Above – Board Meeting Minutes, September 17 2007 (“Vince Work” references)
  • Links Below – Board Meeting Minutes for Calendar Years 2006-2007 (“Vincent” or “Vince” work references)

  • 📣🚨🛑Links to Evidence Attachments:
    • City of Plantation Citation CE08-03180 (Oct 1 2008)
    • DBPR Cease-and-Desist Letter – Vincent Pagan (March 16 2009, Case No. 2008-024074)
    • 🚨🚨Examples of Phase 2 Gould Roofing Repairs (2007–2009) Showing Defects: 2007-09 Gould Roofing Phase 2 Shoddy Repairs
    • 🚨More Examples of 2007-2024-25 Living Conditions from My Personal Story: https://hoajusticenow.com/home/160-2/
    • 🚨2008 Broward Complaint PDF
    • 🚨🚨2008 DBPR email stating they were deferring this complaint to City of Plantation Building Department: 2008 Gould Roofing DBPR Complaint
    • 🚨🚨2008 City Chief Building Inspector Adam Attah email on upcoming Citations/Fines
    • 🚨🚨City of Plantation Stop Work Notice Placed on Phase 2 Properties
    • 📣🚨🛑Vincent Pagan Citations: 2008 City of Plantation Citations Issued for Phase 3 Only, when same date(s) and type(s) of citations scope/summary can be seen in Phases 1, 2, & 4’s citation history on the City of Plantation’s Code Enforcement website???
    • 📣🚨🛑Both Gould Roofing & Pagan Contractor Examples: The selective issuance of citations exclusively to Phase 2 — despite identical violations appearing across Phases 1, 3, and 4 — suggests arbitrary and capricious enforcement practices by the City of Plantation during the 2008 review period.
      • 📣🚨🛑Such non-uniform application of identical standards raises substantial questions about procedural fairness and equal treatment under the City’s code-enforcement framework.
      • 📣🚨🛑The record indicates a lack of due diligence in the inspection and citation process, as violations recorded in other Phases were neither cited nor documented despite being visible in the City’s own records.
      • 📣🚨🛑The pattern suggests a failure to exercise prudent oversight consistent with municipal code-enforcement obligations.
      • 📣🚨🛑The disparity reflects a potential pattern of selective enforcement that materially distorted the financial and legal impact on Phase 2 owners.
      • 📣🚨🛑If validated, such selective enforcement may constitute grounds for equitable relief, including reassessment or reallocation of legacy fines tied to the 2008 citations.
      • 📣🚨🛑The selective targeting of Phase 2 may have caused compensable harm to affected owners by distorting the distribution of fines and inflating long-term financial burdens.
    • 🚨🚨Gould Roofing Example: 2007 Juda Eskew paid invoices for Gould Roofing Co., Inc. 2007-09 Gould Roofing Phase 2 Shoddy Repairs
    • 🚨🚨More Examples of 2007-2024-25 Living Conditions from My Personal Story: https://hoajusticenow.com/home/160-2/
    • 🚨Gould Roofing Example: 2008 Broward Complaint PDF
    • 🚨🚨Gould Roofing Example: 2008 DBPR email stating they were deferring this complaint to City of Plantation Building Department: 2008 Gould Roofing DBPR Complaint
    • 🚨🚨Both Gould Roofing & Pagan Work Involved: City of Plantation Chief Building Inspector Emails on Citations: Adam Attah email 8.5.08 & 2008 City Chief Building Inspector Adam Attah email on upcoming Citations/Fines
    • 🚨🚨Both Gould Roofing & Pagan Work Involved: City of Plantation Stop Work Notice Placed on Phase 2 Properties
    • 📣🚨🛑Both Gould Roofing & Pagan Work Involved: 2008 City of Plantation Citations Issued for Phase 2 Only, when same date(s) and type(s) of citations scope/summary can be seen in Phases 1, 3, & 4’s citation history on the City of Plantation’s Code Enforcement website???
      1. 📣🚨🛑2008 Phase 2 City Code Violation Citations Issued for Gould Roofing & Pagan Work: 2008 City Citations for Phase 2
      2. 📣🚨🛑The selective issuance of citations exclusively to Phase 2 — despite identical violations appearing across Phases 1, 3, and 4 — suggests arbitrary and capricious enforcement practices by the City of Plantation during the 2008 review period.
      3. 📣🚨🛑Such non-uniform application of identical standards raises substantial questions about procedural fairness and equal treatment under the City’s code-enforcement framework.
      4. 📣🚨🛑The record indicates a lack of due diligence in the inspection and citation process, as violations recorded in other Phases were neither cited nor documented despite being visible in the City’s own records.
      5. 📣🚨🛑The pattern suggests a failure to exercise prudent oversight consistent with municipal code-enforcement obligations.
      6. 📣🚨🛑The disparity reflects a potential pattern of selective enforcement that materially distorted the financial and legal impact on Phase 2 owners.
      7. 📣🚨🛑If validated, such selective enforcement may constitute grounds for equitable relief, including reassessment or reallocation of legacy fines tied to the 2008 citations.
      8. 📣🚨🛑The selective targeting of Phase 2 may have caused compensable harm to affected owners by distorting the distribution of fines and inflating long-term financial burdens.
    • 🚨🚨Gould Roofing Example: 2007 Juda Eskew paid invoices for Gould Roofing Co., Inc.

📹 Video Recordings Relevant to S-3 (Click-Through Timeline)

  1. 🚨🚨May 2024 BOD Meeting – Confrontation with Former President Ken Aker where discussion is connected to 2006-08 Gould Roofing repairs and historical roof repairs. https://youtu.be/TiX9PT3reIg
  2. 🚨🚨February 2024 BOD Meeting – Austro’s “Levy” Discusses Unlicensed/Unpermitted Roofing in Phase 4 Demonstrates the repetition of historical patterns. https://youtu.be/qeeW6etMmQI?si=91xBnrZwz4xpuTkc
  3. 🚨🚨October 2023 BOD Meeting – Whistleblower Challenges Board About $1M+ City Fines Identifying that fines likely stem from the 2008 citations tied to Gould Roofing / Pagan. https://youtu.be/4_YOf41x21s
  4. 🚨🚨2008 Citations Discussed on Record Historic discussion tying Gould’s work to the original City citations. https://youtu.be/E3z60KLjtV8?si=CfN_PKIS4L3MAMBV

Strategic Conclusion

This case demonstrates that the City of Plantation may have been complicit in approving or overlooking a materially deceptive execution of a cited electrical safety violation.

It raises critical questions about:

  • Contractor oversight,
  • Phase-based discrimination in capital improvements,
  • Whether city records were closed despite incomplete work.

Result: A false sense of compliance and hidden safety risks for residents.

📌 RICO Connection

The Racketeer Influenced and Corrupt Organizations Act (RICO) applies when a pattern of racketeering activity (fraud, obstruction, retaliation, etc.) is used to advance a scheme.

This exhibit shows:

  • Possible Fraudulent misrepresentation of permit scope.
  • City possible complicity or negligence in closing the violation.
  • Pattern evidence that potentially supports a broader racketeering narrative.

For reference:

Prepared by:
Shawn Martin, MBA
Omega Villas Unit Owner & Whistleblower
Exhibit Series: Infrastructure & Vendor Oversight (Exhibit S-3)