Isaiah Blancas Construction

Complaint: [redacted] I am rejecting this response because: I.B.Ccrew members were irresponsible in leaving the debry (Old felt, shingles, their work broom, flashing that was removed and other items) When the flashing was removed, and all of the other items that were left did not allow the water to run off of the house Water had no place to go therefore creating the leak , that turned into a downpour on the flat side of the roof and the kitchen area of our home Mr [redacted] showed no interest in our loss but rather what he could gain from this unfortunate incident When I spoke to Mr [redacted] on April 13, 2015, informing him that due to the fact that his crew had left these items on the roof, causing bad leaks into our home, he said he would send the crew over to remove the things that were left on roof and have them stop the leak, which he did But the damage was already done Due to crews negligence, the ceiling collapsed, furniture and carpet were ruined and the electical supply to ceiling fan in kitchen has been ruined, it does not work anymore On April 14, the crew finished the roof I again spoke to Me [redacted] concerning the damage He told me it would be taken care of if we gave him $ I could not believe he was trying to scam us for $ When it was his crew's negligence that created the problem The photos that I sent to you show the extent of their negligence If they had put the items that they left on the roof into the trailer like they should have this never would have happened Please look at photo of roof closely It will show that where the flashing was removed is where the problem began Mr [redacted] supposed to be licensed, bonded and insured, I feel that his insurance should take care of this issue Regards, [redacted] [To assist us in bringing this matt

According to MrB [redacted] , he has spoken to the Consumer and they have resolved all issues regarding this Complaint If the information youi have is different, please advise Otherwise, he will proceed accordingly as agreed with the Consumer.Thanks again for your consideration.Regards,Eric D [redacted] Attorney for the Business

Revdex.com Serving New Mexico and Southwest Colorado Jefferson St., NE, Suite A Albuquerque, NM 87109- ATTN: Ms [redacted] Investigations and Dispute Resolution Center [redacted] , COMPLAINANT, vs ISAIAH BLANCAS CONSTRUCTION, RESPONDENT REPLY OF RESPONDENT ISAIAH BLANCAS CONSTRUCTION’S RESPONSE TO REBUTTAL FILED BY [redacted] Dear Ms [redacted] , By and on behalf of the Isaiah Blancas Construction (“IB Construction”or “Respondent”), the following response is being submitted to the above referenced Complaint (“Response”or “Matter”) and pursuant to the filing of this its Reply to the Rebuttal provided by the Complainant(s) regarding the work performed and the materials provided by IB Construction to the Complainantsat [redacted] (“Job” or “Job Site”), states as follows: COMPANY PROFILE AND HISTORY IB Construction is a general contractor that primarily does roofing work that involves everything from minor repairs to complete replacement of a roofThe repairs made and the work performed by IB Construction is regularly required in response to damage arising from extraordinary events such as extreme storms or other events that have created or caused damage to the roof of a residential or commercial propertyBecause of and due to the nature of their work, IB Construction’s work is customarily performed pursuant to insurance claims and the associated insurance loss provisions that apply to the damage and, potentially, the payment for the necessary repairs and replacement of an entire roof as well as any and all associated structures or supporting structures or edifices related to the roof IB Construction performs the necessary work in accordance with its own standards for quality workmanship and in accordance the construction standards and requirements established by and enforced by the State of New MexicoIB Construction also attempts to satisfy and perform in accordance with the demands and requirements of the Homeowner or Owner as well as any interested third parties, such as mortgage holders or an insurance representative or claims adjuster It is essential that IB Construction performs work for its customers and on the jobs in accordance with the foregoing as in as strict compliance with all of the foregoing requirements as possible RESPONSE AFFIRMATIVE DEFENSES The Defendant hereby asserts the following affirmative defenses to the claims of the Complainant, as applicable and if applicable and to the extent applicable, under the circumstances and as stated in the Complaint and they are as follows: Due to the foregoing factors as stated in the Company Profile and History, because neither the Property Owner nor IB Construction has control, and certainly not exclusive control, over the schedule, scheduling factors and criteria, including the timing for payment and, accordingly, the required work schedule, many, if not all, scheduling issues are beyond the control or either the Property Owner or IB Construction and are, almost exclusively, within the dominion and control of the insurer/insurance company or the mortgage or note holder on the property IB Construction guarantees its work and provides the manufacturer’s warranty to the property owner as is applicableOnce the guarantee expires and no claims have been timely submitted regarding either the workmanship or the materials, the guarantees and warranties cannot be revived and no longer apply OBJECTIONS TO COMPLAINT The following statements as made and asserted in the Complaint are and intended to purposefully and intentionally falsely prejudice the Investigator and the Investigation, with said misstatements being as follows: The Complainants did not give the Respondent a down payment of eighty percent (80%) as stated in the Complainant Final payment was not provided to the Respondent by the Complainant The Job was completed per the agreement and agreed scope of work as well as the agreed specifications and requirements, including materials The Job was completed per the agreement and agreed scope of work as well as the understanding of potential, latent defects and the preexisting damage to the roof at the Job Site At the time the Job was completed, the Complainants had no problems with either the quality of the work or the workmanship and the Respondent was never contacted nor any attempted contact made by the Complainants with the Respondent, including the absence of any phone calls or phone messages from the Complainant REPLY TO OBJECTIONS REBUTTAL The following statements as made and asserted in the Complaint are and intended to purposefully and intentionally prejudice the Investigator and the Investigation, with said misstatements being as follows: that the Complainants were never satisfied; that the Complainants “lost contact” with the Respondent, IB Construction; that the Respondents “blew up” the Complainants’ telephone; that the Respondents did a “sloppy, subpar job on our roof”; that Isaiah Blancas would act like he did not know the Complainants and hang up on the Complainants; that Isaiah Blancas returned the “stolen items” or any “stolen items”; and, that Isaiah Blancas ever said the “job” was a “bad” job The foregoing alleged agreements, statements and events were never made nor did they ever occur as stated SPECIFIC RESPONSE As is customary with any and all jobs performed by IB Construction no time frame was committed to or presented to the Complainants because of the various factors stated previously herein as well as weather factors, which must be planned for and precautions taken to protect the job site and the Property, just as IB Construction did in this case and on this Job IB Construction always accepts jobs subject to latent or hidden defects or damages that are unseen or unforeseeable but are pre-existing, whether to the roof, the sub-roof, or the structure, and these hidden and undiscoverable conditions may actually dictate or limit the scope and quality of the final work performed and delivered, just as IB Construction did in this case and on this Job because of the preexisting damages to the roof with said disclosure and qualifying terms being stated to and the Complainants being notified as such, also, as was done in this case IB Construction always uses materials in accordance with the insurers’ standards and requirements, which are stipulated prior to the project being initiated, just as IB Construction did in this case and on this Job, with the corresponding cost of materials to be determined, again, just as IB Construction did in this case and on this Job IB Construction always provides adequate and sufficient tools for its workers and it only uses its own tools, just as IB Construction did in this case and on this Job Many of the allegations and accusations asserted against IB Construction do not even warrant an acknowledgment much less a response because any such allegations as stated in the Complaint have no relevance or bearing on either the quality of the work that was performed or the timing for completing the work or the bid price to complete the job or the final cost to complete the Job; therefore, no such acknowledge or response is included nor is any forthcoming in this or any subsequent Response Upon completion of the Job, the Complainants were satisfied with the work performed and only made reference to a few relatively minor, problems that were immaterial based upon the total scope of work performed REPLY TO SPECIFIC RESPONSE REBUTTAL The following statements as made and asserted in the Rebuttal are false, with said misstatements being as follows: that the Complainants were given a time and agreed on a March completion date; that the job and work was so unprofessional and “sloppy” that inspectors state it is “the worst job they have ever seen”; the Complainants did not receive a new roof with new materials; the Complainants’ garage doors were damaged; the job was not “finished on time, within scope, with the correct materials, with any [display of skilled] workmanship”; and, the Complainants did not ever contact Isaiah Blancas without either reaching him or him responding, whether it was a few times or many times The foregoing events never occurred nor did the project proceed or conclude as stated in the foregoing statements GENERAL RESPONSE Unless any allegations is directly, specifically and expressly admitted to herein, any allegations or statements made by the Complaining Party are hereby denied for all purposes relevant to these proceedings REPLY TO GENERAL RESPONSE REBUTTAL No Reply to the Libel and Slander Claims asserted by the Respondent is required because a rebuttal was not provided by the Complainant ARGUMENT AND AUTHORITY Complainants were satisfied with the Job when it was completed, the Complainants did not decide to complain until more than one year after the work and the Job was completed Therefore, the position taken by the Respondent is that the Complainants’ claims are contrived and suspicious because of the delay in presenting the claims as well as being Unless any allegations is directly, specifically and expressly admitted to herein, any allegations or statements made by the Complaining Party are hereby denied for all purposes relevant to these proceedings REPLY TO ARGUMENT AND AUTHORITY REBUTTAL The following statements as made and asserted in the Rebuttal are false, with said misstatements being as follows: that the Complainants complained; and, that the Respondent did not return their phone calls The foregoing agreement was never made nor was a commitment made for the foregoing RESPONDENT’S CLAIMS Because of and due to the inflammatory nature of the claims and their lack of merit, the Respondent intends, to the fullest extent possible and as it becomes necessary, to pursue any and all claims that they have or may have regarding the actions and conduct of the Complainantsas stated as follows: DEFAMATION Respondent intends to pursue any and all claims for any and all damages sustained and resulting from any and all defamatory statements made by the Complainantsregarding IB Construction and its business practices REPLY TO DEFAMATION REBUTTAL The following statements as made and asserted in the Rebuttal are false, with said misstatements being as follows: that the Respondent “defamed his own name by the quality of the work” The referenced work was performed in accordance with the Agreement and was in compliance with all applicable building codes being complied with and, accordingly, maintaining the good name and reputation of the Respondent LIBEL AND SLANDER Respondent intends to pursue any and all claims for any and all damages sustained and resulting from any and all libelous and slanderous statements made by the Complainantsregarding IB Construction and its business practices REPLY TO LIBEL AND SLANDER COMPLAINTS REBUTTAL No Reply to the Libel and Slander Claims asserted by the Respondent is required because a rebuttal was not provided by the Complainant RELIEF REQUESTED IB Construction requests that any and all relief requested by the Complainants be denied in its entirety and for all purposes regarding the claims made therein as well as the relief sought and requested by the Complainants and that the Respondent, be awarded its costs and such other and further relief to which it may show itself to be justly entitled RESERVATION OF RIGHT TO AMEND OR SUPPLEMENT REPLY TO REBUTTAL AS IT BECOMES NECESSARY IB Construction specifically and expressly reserves the right to amend or supplement this Reply to the Complainant’s Rebuttal as it becomes necessaryand is required to either respond to new or different allegation s or accusations or to clarify the statements made herein based upon new or different or, even, contrary information that may become available and that the Respondent may be made aware of that he is not aware of or infinitely familiar with at this time regarding any matters or issues discussed herein or any other matters or issues that may arise later during the pendency of this Complaint Respectfully submitted, [redacted] * [redacted] Phone: [redacted] Fax: [redacted] By: /s/ [redacted] * [redacted] * [redacted] Attorney for Respondent IB Construction

Guarantee has expired ibc only gives a yr guarantee thanks for your cooperation on this matter

The leaks the [redacted] had were from the flat roof area their ins. Co. Did not pay for I just got back into town as I had a family emergency I did let the [redacted] know we would fix issue that their ins. Co. Did not pay for as soon as ib construction was paid balance of 500dollar deductible was... paid for total contract price includes the 500dollar deductible as soon as ib construction receives monies owed we will fix issue for free as I told them we would ib construction will send contract and scope of loss break down sheet from ins. Co. Only shingle roof was paid for by ins. Co. Not flat roof that's why we did not tear off flat roof nor replace it this complaint is invalid and ib construction will have to take legal action through court if payment is not received thank you ib constructionUpdate via Fax 04/30/15:To whom it may concern here are the documents from I.B. Construction & [redacted] Ins. Co. as you can see no flat roof was paid for, nor did I.B. Construction agree on contract to perform any work on any flat roof for the [redacted] only shingle shingle roof was agreed too, also [redacted] already had leaks in numerous areas to their home Ins. Co. did not pay for the leak damage to interior as it was considered wear & tear over time I.B.C. also thought Deductible was 500.00 it’s actually 1,000 plus & extra 757.24 for Non-Recoverable Depreciation as stated on contract balance due to I.B. Construction is 1,000 plus 757.24 total due 1,757.24 then & only then will I.B.C. Re-Roof Flat Roof for free If not I.B.C. will take [redacted] to court for balance or maybe BBB can arbitrate matter complain is totally invalid Please Do not Put it on my BBB File. Thank you Isaiah B [redacted] # [redacted]

I have read response from the [redacted] the leaks shown on pictures is from flat roof and any time any co. works on a roof their is always trash until job is complete as stated before flat roof is not in contract to be repaired and ins. co. did not pay for flat roof to be replaced ib construction did not tear any flashing off on flat roof as it was not worked on I believe ib construction is being more than fair by agreeing to replace flat roof at no cost by being paid balance of monies owed to IBC flat roof will continue to leak as it was not replaced or worked on thank you ib construction

Shingle roof was never spoken of only flat which needs to be replaced with new wood decking my laywer Mr D [redacted] will be handling case from here on out thanks

Complaint: ***
I am rejecting this response because:My rebuttal is the documents I have provided has clearly supported my claims. I deny the allegations made in the attorney’s response and the claims are clearly false, even fraudulent IB Construction is liable for every bit of the damage to my interior and exterior dwelling, it’s damaged contents, as well as a brand new roof with brand new supplies at no further cost to us as it has already cost us time and money to weather this mess As for the video, I will try to resend it or even a link for you to see it. Rain in September 2014 It is just to show you the amount of rain fall that came down so you can just imagine the damage to the house.
See attached
Regards,
*** *** [To assist us in bringing this matter to a close, the consumer must give a reason why they are rejecting the responseIf the consumer does not provide a reason if he complaint will be closed Administratively Resolved]

Victor C*** had made a mistake on second contract for flat roof I had cancelled second contract but Mr *** wanted IBC to keep monies and at least patch for flat I let Mr *** know there was a month guarantee which has past this is a brief summary for complaint if Mr *** does want IBC to
completely remove decking and replace roof with a new one it will cost more Thanks IBC

To Revdex.comRe: ID# *** Isaah Blancas ConstructionThis is a rebuttal to their responseI was not aware the contract had been cancelledThe job was left unfinishedI also had a year warranty and I have tried to contract Isaah B*** multiple times and he would not answer his phone or return my callsI have sent photo’s and a copy of the warrantyMy shingle roof and flat roof are leaking and the flat roof is not finishedI did not pay for a patch.*** ***10-28-

Complaint: ***
I am rejecting this response because: We signed a contract for roof work to be done November The work was never performed until June It took IB construction
months before they came and completed the work and only after we threatened to call the Revdex.com back then after failure to respond or the numerous excusesHow does a warranty on a product begin before I ever received the product? To the best of my knowledge a warranty begins when I have that product in my possessionWhy should my warranty time start counting down before I even own the product? So according to IB way of thinking I only get a months warrantyIs this why IB took so long to do the roofing job? It's a way for IB construction to circumvent their obligations to their customers by not having to honor any of the warranties on the unprofessional jobs they performAlso the materials are supposed to be under warranty for yearsIs the cracking and gaps in my roof from bad or materials or by the untrained workers hired by IB construction? Many people from the New Mexico area are just finding out now how bad a job IB Construction did on their houses
Regards,
*** *** [To assist us in bringing this matter to a close, the consumer must give a reason why they are rejecting the responseIf the consumer does not provide a reason the complaint will be closed Answered]

Revdex.comServing New Mexico and Southwest ColoradoJefferson St., NE, Suite AAlbuquerque, NM 87109-0110ATTN: Ms*** ***Investigations and Dispute Resolution Center*** ***, COMPLAINANT,vsISAIAH
BLANCAS CONSTRUCTION, RESPONDENT.RESPONDENT ISAIAH BLANCAS CONSTRUCTION’S RESPONSETOCOMPLAINT FILED BY *** ***Dear Ms***,By and on behalf of the Isaiah Blancas Construction (“IB Construction”or “Respondent”), the following response is being submitted to the above referenced Complaint (“Response”or (Matter”) and pursuant to the filing of this Response regarding the work performed and the materials provided by IB Construction to the Complainant at *** *** *** *** *** ** *** (“Job” or “Job Site”), states as follows: COMPANY PROFILE AND HISTORYIB Construction is a general contractor that primarily does roofing work that involves everything from minor repairs to complete replacement of a roofThe repairs made and the work performed by IB Construction is regularly required in response to damage arising from extraordinary events such as extreme storms or other events that have created or caused damage to the roof of a residential or commercial propertyBecause of and due to the nature of their work, IB Construction’s work is customarily performed pursuant to insurance claims and the associated insurance loss provisions that apply to the damage and, potentially, the payment for the necessary repairs and replacement of an entire roof as well as any and all associated structures or supporting structures or edifices related to the roof.IB Construction performs the necessary work in accordance with its own standards for quality workmanship and in accordance the construction standards and requirements established by and enforced by the State of New MexicoIB Construction also attempts to satisfy and perform in accordance with the demands and requirements of the Homeowner or Owner as well as any interested third parties, such as mortgage holders or an insurance representative or claims adjuster.It is essential that IB Construction performs work for its customers and on the jobs in accordance with the foregoing as in as strict compliance with all of the foregoing requirements as possible.RESPONSEAFFIRMATIVE DEFENSESThe Defendant hereby asserts the following affirmative defenses to the claims of the Complainant, as applicable and if applicable and to the extent applicable, under the circumstances and as stated in the Complaint and they are as follows:Due to the foregoing factors as stated in the Company Profile and History, because neither the Property Owner nor IB Construction has control, and certainly not exclusive control, over the schedule, scheduling factors and criteria, including the timing for payment and, accordingly, the required work schedule, many, if not all, scheduling issues are beyond the control or either the Property Owner or IB Construction and are, almost exclusively, within the dominion and control of the insurer/insurance company or the mortgage or note holder on the propertyIB Construction guarantees its work and provides the manufacturer’s warranty to the property owner as is applicableOnce the guarantee expires and no claims have been timely submitted regarding either the workmanship or the materials, the guarantees and warranties cannot be revived and no longer applyOBJECTIONS TO COMPLAINTThe following statements as made and asserted in the Complaint are and intended to purposefully and intentionally the Investigator, with said misstatements being as follows:The Complainant did not give the Respondent a down payment of eighty percent (80%) as stated in the ComplainantFinal payment was not provided to the Respondent by the ComplainantThe Job was completed per the agreement and agreed scope of work as well as the agreed specifications and requirements, including materials.The Job was completed per the agreement and agreed scope of work as well as the understanding of potential, latent defects and the preexisting damage to the roof at the Job Site.At the time the Job was completed, the Complainant had no problems with either the quality of the work or the workmanship and the Respondent was never contacted nor was any attempted contact made by the Complainant with the Respondent, including the absence of any phone calls or phone messages from the ComplainantSPECIFIC RESPONSEAs is customary with any and all jobs performed by IB Construction no time frame was committed to or presented to the Complainant because of the various factors stated previously herein as well as weather factors, which must be planned for and precautions taken to protect the job site and the Property, just as IB Construction did in this case and on this Job.IB Construction always accepts jobs subject to latent or hidden defects or damages that are unseen or unforeseeable but are pre-existing, whether to the roof, the sub-roof, or the structure, and these hidden and undiscoverable conditions may actually dictate or limit the scope and quality of the final work performed and delivered, just as IB Construction did in this case and on this Job because of the preexisting damages to the roof with said disclosure and qualifying terms being stated to and the Complainant being notified as such, also, as was done in this caseIB Construction always uses materials in accordance with the insurers’ standards and requirements, which are stipulated prior to the project being initiated, just as IB Construction did in this case and on this Job, with the corresponding cost of materials to be determined, again, just as IB Construction did in this case and on this Job..IB Construction always provides adequate and sufficient tools for its workers and it only uses its own tools, just as IB Construction did in this case and on this JobIB Construction incidental and immaterial allegations and accusations do not even warrant an acknowledgment, much less a response because any such allegations as stated in the Complaint have no relevance or bearing on either the quality of the work that was performed or the timing for completing the work or the bid price to complete the job or the final cost to complete the Job; therefore, no such acknowledge or response is included nor is any forthcoming in this or any subsequent Response..Upon completion of the Job, the Complainant was satisfied with the work performed and only made reference to a few relatively minor, problems that were immaterial based upon the total scope of work performed.GENERAL RESPONSEUnless any allegations is directly, specifically and expressly admitted to herein, any allegations or statements made by the Complaining Party are hereby denied for all purposes relevant to these proceedingsARGUMENT AND AUTHORITYComplainant was satisfied with the Job when it was completed, the Complainant did not decide to complain until more than one year after the work and the Job was completed Therefore, the position taken by the Respondent is that the Complainant’s claims are contrived and suspicious because of the delay in presenting the claims as well as being Unless any allegations is directly, specifically and expressly admitted to herein, any allegations or statements made by the Complaining Party are hereby denied for all purposes relevant to these proceedings RESPONDENT’S CLAIMS Because of and due to the inflammatory nature of the claims and their lack of merit, the Respondent intends, to the fullest extent possible and as it becomes necessary, to pursue any and all claims that they have or may have regarding the actions and conduct of the Complainant as stated as follows:DEFAMATIONRespondent intends to pursue any and all claims for any and all damages sustained and resulting from any and all defamatory statements made by the Complainant regarding IB Construction and its business practices.LIBEL AND SLANDERRespondent intends to pursue any and all claims for any and all damages sustained and resulting from any and all libelous and slanderous statements made by the Complainant regarding IB Construction and its business practices.RELIEF REQUESTEDIB Construction requests that any and all relief requested by the Complainant be denied in its entirety and for all purposes regarding the claims made therein as well as the relief sought and requested by the Complainant and that the Respondent, be awarded its costs and such other and further relief to which it may show itself to be justly entitled.RESERVATION OF RIGHT TO AMEND OR SUPPLEMENT RESPONSE AS IT BECOMES NECESSARYIB Construction specifically and expressly reserves the right to amend or supplement this Response as it becomes necessary and is required to either respond to new or different allegation s or accusations or to clarify the statements made herein based upon new or different or, even, contrary information that may become available and that the Respondent may be made aware of that he is not aware of or infinitely familiar with at this time regarding any matters or issues discussed herein or any other matters or issues that may arise later during the pendency of this ComplaintRespectfully submitted,*** *** *** ** *** ** *** *** *** *** *** ***Phone: ***Fax: ***By: /s/ *** *** *** ***Attorney for Respondent

###-###-####RE: ID# ***RebuttalMrB*** has never been to my houseHis employees did not feel the plywood needed to be replacedMy shingle roof is also leakingIf MrB*** wants to spend time and money litigating this matter then so be itThe office of attorney general said I have a very strong case, so that’s the way I will go if no response.*** ***11-7-

Complaint: ***
I am rejecting this response because:
Mr*** refuses to accept responsibility for damages caused by his crew, they represent his companyI don't know if Mr*** realize that we have presented pictures of the flat part of roofThe picture not only show that the flashing was removed. The flashing is among the other trash and items that were left. Mr*** stated that we had numerous leaks in are home; this is not true. We had a leak in the Master Bedroom and over a year ago on the flat part of roof that is in debate here. I repaired the leak on the flat part of roof over a year ago, and did not have any leaks until his crew left the debri on that part. I repaired the leak in the bedroom and have not had any problems. This is only two leaks not numerous leaksWe do not owe Mr*** anything, he was paid for the repairs to the roof. He stated in his own words that we would not owe him anything but what was paid to himI wish Mr*** was a man of integrity and own up to this mistake,. I contacted the Consumer Protection Agency, and spoke with someone with the Construction Industry Division, because of this situation and the lack of cooperation of IBC, I wanted to make sure this company was really licensed, bonded and insured. If matters cannot be resolved through Revdex.com, I will have no other recourse and will have to file my complaint with the Consumer Protection Agency. I hope things will be resolved soon.
Regards,
*** *** [To assist us in bringing this matter to a close, the consumer must give a reason why they are rejecting the responseIf the consumer does not provide a reason if he complaint will be closed Administratively Resolved]

We will check to see if customer still has a guarantee if so ibc will make sure guarantee is kept

A inspection was performed by a inspector from the city of las cruces roof passed inspection 100percent per nm state codes already explained this to customer and our co. Was never paid in full, Thank you and God bls

Guarantee has expired ibc only gives a 1 yr guarantee thanks for your cooperation on this matter

Revdex.com
Serving New Mexico and Southwest Colorado
7007 Jefferson St., NE, Suite A
Albuquerque, NM 87109-0110
ATTN: Ms. [redacted]
Investigations and Dispute Resolution Center
[redacted],
COMPLAINANT,
vs.
ISAIAH BLANCAS CONSTRUCTION,
RESPONDENT.
REPLY OF RESPONDENT ISAIAH BLANCAS CONSTRUCTION’S RESPONSE
TO
REBUTTAL FILED BY [redacted]
Dear Ms. [redacted],
By and on behalf of the Isaiah Blancas Construction (“IB Construction”or “Respondent”), the following response is being submitted to the above referenced Complaint (“Response”or “Matter”) and pursuant to the filing of this its Reply to the Rebuttal provided by the Complainant(s) regarding the work performed and the materials provided by IB Construction to the Complainantsat [redacted] (“Job” or “Job Site”), states as follows:
COMPANY PROFILE AND HISTORY
IB Construction is a general contractor that primarily does roofing work that involves everything from minor repairs to complete replacement of a roof. The repairs made and the work performed by IB Construction is regularly required in response to damage arising from extraordinary events such as extreme storms or other events that have created or caused damage to the roof of a residential or commercial property. Because of and due to the nature of their work, IB Construction’s work is customarily performed pursuant to insurance claims and the associated insurance loss provisions that apply to the damage and, potentially, the payment for the necessary repairs and replacement of an entire roof as well as any and all associated structures or supporting structures or edifices related to the roof.
IB Construction performs the necessary work in accordance with its own standards for quality workmanship and in accordance the construction standards and requirements established by and enforced by the State of New Mexico. IB Construction also attempts to satisfy and perform in accordance with the demands and requirements of the Homeowner or Owner as well as any interested third parties, such as mortgage holders or an insurance representative or claims adjuster.
It is essential that IB Construction performs work for its customers and on the jobs in accordance with the foregoing as in as strict compliance with all of the foregoing requirements as possible.
RESPONSE
AFFIRMATIVE DEFENSES
The Defendant hereby asserts the following affirmative defenses to the claims of the Complainant, as applicable and if applicable and to the extent applicable, under the circumstances and as stated in the Complaint and they are as follows:
Due to the foregoing factors as stated in the Company Profile and History, because neither the Property Owner nor IB Construction has control, and certainly not exclusive control, over the schedule, scheduling factors and criteria, including the timing for payment and, accordingly, the required work schedule, many, if not all, scheduling issues are beyond the control or either the Property Owner or IB Construction and are, almost exclusively, within the dominion and control of the insurer/insurance company or the mortgage or note holder on the property.
IB Construction guarantees its work and provides the manufacturer’s warranty to the property owner as is applicable. Once the guarantee expires and no claims have been timely submitted regarding either the workmanship or the materials, the guarantees and warranties cannot be revived and no longer apply.  
OBJECTIONS TO COMPLAINT
The following statements as made and asserted in the Complaint are false and intended to purposefully and intentionally falsely prejudice the Investigator and the Investigation, with said  misstatements being as follows:
The Complainants did not give the Respondent a down payment of eighty percent (80%) as stated in the Complainant.
Final payment was not provided to the Respondent by the Complainant.
The Job was completed per the agreement and agreed scope of work as well as the agreed specifications and requirements, including materials.
The Job was completed per the agreement and agreed scope of work as well as the understanding of potential, latent defects and the preexisting damage to the roof at the Job Site.
At the time the Job was completed, the Complainants had no problems with either the quality of the work or the workmanship and the Respondent was never contacted nor any attempted contact made by the Complainants with the Respondent, including the absence of any phone calls or phone messages from the Complainant.
REPLY TO OBJECTIONS REBUTTAL
The following statements as made and asserted in the Complaint are false and intended to purposefully and intentionally prejudice the Investigator and the Investigation, with said misstatements being as follows:
6. that the Complainants were never satisfied;
7. that the Complainants “lost contact” with the Respondent, IB Construction;
8. that the Respondents “blew up” the Complainants’ telephone;
9. that the Respondents did a “sloppy, subpar job on our roof”;
10. that Isaiah Blancas would act like he did not know the Complainants and hang up on the Complainants;   
11. that Isaiah Blancas returned the “stolen items” or any “stolen items”; and,
12. that Isaiah Blancas ever said the “job” was a “bad” job.
The foregoing alleged agreements, statements and events were never made nor did they ever occur as stated.
SPECIFIC RESPONSE
As is customary with any and all jobs performed by IB Construction no time frame was committed to or presented to the Complainants because of the various factors stated previously herein as well as weather factors, which must be planned for and precautions taken to protect the job site and the Property, just as IB Construction did in this case and on this Job.
IB Construction always accepts jobs subject to latent or hidden defects or damages that are unseen or unforeseeable but are pre-existing, whether to the roof, the sub-roof, or the structure, and these hidden and undiscoverable conditions may actually dictate or limit the scope and quality of the final work performed and delivered, just as IB Construction did in this case and on this Job because of the preexisting damages to the roof with said disclosure and qualifying terms being stated to and the Complainants being notified as such, also, as was done in this case..
IB Construction always uses materials in accordance with the insurers’ standards and requirements, which are stipulated prior to the project being initiated, just as IB Construction did in this case and on this Job, with the corresponding cost of materials to be determined, again, just as IB Construction did in this case and on this Job..
IB Construction always provides adequate and sufficient tools for its workers and it only uses its own tools, just as IB Construction did in this case and on this Job.
Many of the allegations and accusations asserted against IB Construction do not even warrant an acknowledgment much less a response because any such allegations as stated in the Complaint have no relevance or bearing on either the quality of the work that was performed or the timing for completing the work or the bid price to complete the job or the final cost to complete the Job; therefore, no such acknowledge or response is included nor is any forthcoming in this or any subsequent Response..
Upon completion of the Job, the Complainants were satisfied with the work performed and only made reference to a few relatively minor, problems that were immaterial based upon the total scope of work performed.
REPLY TO SPECIFIC RESPONSE REBUTTAL
    The following statements as made and asserted in the Rebuttal are false, with said misstatements being as follows:
that the Complainants were given a time and agreed on a March 2014 completion date;
that the job and work was so unprofessional and “sloppy” that inspectors state it is “the worst job they have ever seen”;
the Complainants did not receive a new roof with new materials;
the Complainants’ garage doors were damaged;
the job was not “finished on time, within scope, with the correct materials, with any [display of skilled] workmanship”; and,
the Complainants did not ever contact Isaiah Blancas without either reaching him or him responding, whether it was a few times or many times.
The foregoing events never occurred nor did the project proceed or conclude as stated in the foregoing statements.  
GENERAL RESPONSE
Unless any allegations is directly, specifically and expressly admitted to herein, any allegations or statements made by the Complaining Party are hereby denied for all purposes relevant to these proceedings.  
REPLY TO GENERAL RESPONSE REBUTTAL
No Reply to the Libel and Slander Claims asserted by the Respondent is required because a rebuttal was not provided by the Complainant.
ARGUMENT AND AUTHORITY
Complainants were satisfied with the Job when it was completed, the Complainants did not decide to complain until more than one year after the work and the Job was completed.  Therefore, the position taken by the Respondent is that the Complainants’ claims are contrived and suspicious because of the delay in presenting the claims as well as being Unless any allegations is directly, specifically and expressly admitted to herein, any allegations or statements made by the Complaining Party are hereby denied for all purposes relevant to these proceedings.
REPLY TO ARGUMENT AND AUTHORITY REBUTTAL
The following statements as made and asserted in the Rebuttal are false, with said misstatements being as follows:
that the Complainants complained; and,
that the Respondent did not return their phone calls.
The foregoing agreement was never made nor was a commitment made for the foregoing.
RESPONDENT’S CLAIMS
Because of and due to the inflammatory nature of the claims and their lack of merit, the Respondent intends, to the fullest extent possible and as it becomes necessary, to pursue any and all claims that they have or may have regarding the actions and conduct of the Complainantsas stated as follows:.
DEFAMATION
Respondent intends to pursue any and all claims for any and all damages sustained and resulting from any and all defamatory statements made by the Complainantsregarding IB Construction and its business practices.
REPLY TO DEFAMATION REBUTTAL
The following statements as made and asserted in the Rebuttal are false, with said misstatements being as follows:
that the Respondent “defamed his own name by the quality of the work”.
The referenced work was performed in accordance with the Agreement and was in compliance with all applicable building codes being complied with and, accordingly, maintaining the good name and reputation of the Respondent.
LIBEL AND SLANDER
Respondent intends to pursue any and all claims for any and all damages sustained and resulting from any and all libelous and slanderous statements made by the Complainantsregarding IB Construction and its business practices.
REPLY TO LIBEL AND SLANDER COMPLAINTS REBUTTAL
No Reply to the Libel and Slander Claims asserted by the Respondent is required because a rebuttal was not provided by the Complainant.
RELIEF REQUESTED
IB Construction requests that any and all relief requested by the Complainants be denied in its entirety and for all purposes regarding the claims made therein as well as the relief sought and requested by the Complainants and that the Respondent, be awarded its costs and such other and further relief to which it may show itself to be justly entitled.
RESERVATION OF RIGHT TO AMEND OR SUPPLEMENT
REPLY TO REBUTTAL
AS IT BECOMES NECESSARY
IB Construction specifically and expressly reserves the right to amend or supplement this Reply to the Complainant’s Rebuttal as it becomes necessaryand is required to either respond to new or different allegation s or accusations or to clarify the statements made herein based upon new or different or, even, contrary information that may become available and that the Respondent may be made aware of that he is not aware of or infinitely familiar with at this time regarding any matters or issues discussed herein or any other matters or issues that may arise later during the pendency of this Complaint.
Respectfully submitted,
[redacted]
Phone: [redacted]
Fax: [redacted]
By: /s/ [redacted]
[redacted]
Attorney for Respondent
IB Construction

Complaint: [redacted]
I am rejecting this response because:
I.B.C. crew members were irresponsible in leaving the debry (Old felt, shingles, their work broom, flashing that was removed and other items).  When the flashing was removed, and all of the other items that were left did not allow the water to run off of the house.  Water had no place to go therefore creating the leak , that turned into a downpour on the flat side of the roof and the kitchen area of our home.  Mr. [redacted] showed no interest in our loss but rather what he could gain from this unfortunate incident.  When I spoke to Mr. [redacted] on April 13, 2015, informing him that due to the fact that his crew had left these items on the roof, causing bad leaks into our home, he said he would send the crew over to remove the things that were left on roof and have them stop the leak, which he did.  But the damage was already done.  Due to crews negligence, the ceiling collapsed, furniture and carpet were ruined and the electical supply to ceiling fan in kitchen has been ruined, it does not work anymore.  On April 14, 2015 the crew finished the roof.  I again spoke to Me. [redacted] concerning the damage.  He told me it would be taken care of if we gave him $500.00.  I could not believe he was trying to scam us for $500.00.  When it was his crew's negligence that created the problem.  The photos that I sent to you show the extent of their negligence.  If they had put the items that they left on the roof into the trailer like they should have this never would have happened.  Please look at photo of roof closely.  It will show that where the flashing was removed is where the problem began.  Mr. [redacted] supposed to be licensed, bonded and insured, I feel that his insurance should take care of this issue.
Regards,
[redacted] [To assist us in bringing this matt

According to Mr. B[redacted], he has spoken to the Consumer and they have resolved all issues regarding this Complaint.  If the information youi have is different, please advise.  Otherwise, he will proceed accordingly as agreed with the Consumer.Thanks again for your...

consideration.Regards,Eric D[redacted]Attorney for the Business