AFFIDAVIT OF LORENZO KILGORE
State of Georgia
Rockdale County
I, Lorenzo Kilgore of 2969 Stanton Rd SE, Conyers, GA 30094, do hereby swear under oath
that:
- I was referred to Certified Roofing and Gutters by Sidney Pirtle. I spoke with
Antonio Johnson sometime around late July 2021. - We agreed to meet and I gave him my address sometime around July 23, 2021. We
agreed to meet and he came out to do a roof inspection on July 24,2021. I did inform he that a
roof inspection had already been done by another roofing company, but he did a separate inspection
for his estimate. - After the inspection, I informed him that if he was going to install the new roof, I
needed a date and I needed to see the shingles that were going to be installed. He brought the
shingles by and I informed him that I wanted the architectural shingles. - Later on, I signed a contract with him and he gave me the date of August 13, 2021
to install the shingles. When I signed the contract, he did inform me that normally he receives the
payment that the insurance company sends as the deposit, which would have been $,4050.00. I
told him that when he starts working on the roof, I’ll release the deposit. On August 21, 2021, his
workers brought some shingles by and I did not inspect the shingles because we had agreed on
what shingles would be installed and I just expected the shingles he brought would be those exact
shingles. - On Friday August 13, 2021, his workers showed up to remove the existing shingles
and install the new roof. First the old shingles and felt were removed. Then the workers installed
the synthetic felt. When they opened the shingles that were delivered on August 12, 2021, they
were the wrong shingles and not the architectural shingles that we had agreed on. I called Antonio
Johnson and informed him that his guys brought the wrong shingles. Initially, he said, “No, they
brought the right shingles”, so I then let him speak to his foreman, Laurencio.; Laurencio informed
Antonio that those were indeed another type of shingle that was a level below what we had agreed
upon. - Antonio, spoke with me over the phone and told me that those shingles would work,
but I told him I did like how those shingles looked and that’s not what we agreed on. He then told
me that he couldn’t exchange the shingles because he had spent nearly $20,000.00 to supply other
jobs. He said that it would take 3 days for his money to be returned to his card, then, he could buy
the right shingles. By this time, my roof was exposed and at no time did he offer to secure the roof
from the outer elements and rain was forecasted for the next day. I told him that getting the right
shingles was his responsibility and that he needed to return the shingles and get the right shingles.
He told me to give him a few minutes and that he would call me back. While I was waiting for him
to call me back, I went to Lowes to confirm the difference between the shingles that he bought and
the architectural shingles we agreed on. When he did call me back, he said he would not be able
to return the shingles and purchase the ones that we agreed upon.
- I told him that the roof needed to be complete today. He told me that he could not
get the shingles that day. After he could not offer a solution to purchase the shingles, I told him
that I would by the shingles. I told him that I would go to Home Depot because they had enough
shingles in inventory to finish the installation. He told me that he would meet me there. I went
there and bought the shingles. See Receipt. The workers that were helping him delivered the
shingles and once they were on site, the crew began to install the shingles on the top of the roof. - I stepped outside to see how things were going and I noticed that an ice and water
shield barrier was on the ground. The ice and water shield barrier were supposed to be installed
over the patio roof on the back side of the house because of a seem between the gable and the
patio. - When I saw that the ice and water shield was not being installed, was still on the
ground, but shingles were being installed on the patio, I mentioned it to the foreman. I asked the
foreman can he go up on the roof and tell them that the ice and water shield need to be installed
on the patio roof. He said that he cannot go up on the roof because he just had appendix surgery.
I called Antonio Johnson and informed him that the ice and water shield was not being installed.
He told me that his foreman was going to take care of it. I told him that I just told the foreman and
that the foreman did not communicate the instructions to the workers. Then, I proceeded to go up
on the roof and stop them. One of the workers was able to interpret and let the installers know that
the ice and water shield needed to installed before the shingles. - They did remove some of the shingles and begin to install the ice and water shield
and I took a photo of the start of that process and told them to let me know when the ice and water
shield has been fully applied, but no one ever came to let me know. Nor did they take a photo to
show me that it was properly. - See Photo.
- Between 2 -3 pm that day, Antonio Johnson came to the site with his trailer and
loaded up the other shingles. I told him about the difficulty of the job and that this was supposed
to be a process whereby his guys would install the roof and I would have never had to get involved.
He asked me have I ever flew with Delta Airlines?? He said that there might be turbulence on the
ride, but Delta’s job was just to get you from one destination to another. I told him that if I knew
that the job was going to be like this, I would have chosen a different contractor and that he’s just
the kind of contractor that homeowner’s want to avoid. - By the end of the day, the roof was completed and was debris and nail all over the
lawn. The workers began to clean up, but it was getting late. When the roof was being removed,
the workers had tarps to catch a lot of the nails, but they removed the tarp and a large quantity of
nails fell from the tarp. Because the nails were blown from the roof with a leaf blower and on the
main part of the lawn, I removed a lot of those nails myself. As we began to lose daylight, I began
to help even more to restore my yard in the condition that it was in before these guys ever showed
up. - As we were cleaning up, Antonio walked over to me and said, “ Hey when you
make the check out to pay for the roof, make it out to Laurencio Jimenez-Juarez. I told him that I
contracted with him and that it was his job to pay him because our agreement was that $4,045.00
would be paid as a deposit and the rest would be paid upon completion and after the insurance
company releases payment. After this Laurencio ask to talk to me and told me that he needed to
get paid because Antonio owed him $7,000.00 from a previous job. Due to it being late in the day,
I told Laurencio that I would pay him with my own money on the next morning, which was
Saturday, August 14, 2021. I paid him $4,045.00. - After I paid him Antonio sent me an invoice via email on 8/24/2021 for $16,255.00.
then I told him that he needed to deduct the payment that was made to Laurencio. He deducted
the payment, but did not deduct the payment for the shingles that I bought. I reminded him that
he needed to deduct for the shingles. He then sent an invoice for the $8434.00. I paid him
$5,934.50 as Final Payment (See copy of Cashier’s Check). I told him that he was in breach of
contract and due to lack of performance based on our agreement and what I had to provide as well
a no proof of proper ice and water shield installation, the check was final payment.
shingles put on before ice and water shield
some shingles removed and ice and water shield applied
ice and water shield beginning installation
Roofers did assure me that they would apply ice and water shield all the way to the edge of roof,
but never informed me they completed the install of the ice and water shield.
Under penalty of perjury, I hereby declare and affirm that the above stated facts, to the best of my
knowledge and belief, are true and correct.
Dated this _ day of April, 2022.
Respectfully Submitted,
Lorenzo Kilgore
VERIFICATION
I, Lorenzo Kilgore, being duly sworn depose and say that I have read the foregoing Affidavit and
know the contents thereof. That the same is true of my own knowledge except as to those matters
and things stated upon information and belief, and as to those things, I believe them to be true.
(Sign in the presence of a Notary Public)
Sworn to and subscribed before me this _ day of ____________, 2022.
Notary Public
(Printed name of Notary Public)
My Commission Expires: ________
EXHIBIT 2
Page 1 of 1
Certified Roofing & Gutters
3301 Buckeye Rd Ste 205
Atlanta, GA 30341 US
Ejcertifiedroofing@gmail.com
INVOICE
BILL TO
Lorenzo Kilgore
2969 Stanton Road SE
Conyers, Georgia 30094
INVOICE 45
DATE 08/24/2021
TERMS Due on receipt
DUE DATE 08/24/2021
SERVICE DESCRIPTION QTY RATE AMOUNT
Roof Installation 49 Squares Charcoal HDz 1 16,255.00 16,255.00
Credit Memo Homeowner paid materials. Home Depot receipt ending in
44051.
1 -3,775.50 -3,775.50
PAYMENT 9,979.50
BALANCE DUE $2,500.00
EXHIBIT 3
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TANASHIER Z MTLLER@HOMEnEPOT.COM
0128 00003 44051
SALE CASHIER SHEA
08/13/21 09:38 AM
1005-067-402 TLHD CHAR ..:A>
GAF TIMBEPLINE HDZ CHARCOAL
150@32.50 4875.00
MAX REFUND VALUE $3510.00/150
— –�-10% off Militar·y Discount——–
3900.00 10% off Military Discou -390.00
MUST RE l”LIRN AU ITEMS FOR A FULL REFUND
———Instant Vol Savlngs———–
4875.00 Instant Vol Savings -975.00
MUSl RETURN ALL ITEMS FOR A FULL REFUND
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SALES TAX
TOTAL
3,510 00
245.70
$3,755.70
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USO$ 1,877.85
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USO$ 1,877.85
AUTH CODE 04560G/70337Cl1 TA
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AID A0000000031010 CHASE VT.SA
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0128 03 44051 08/13/2021 6925
RETURN POL.ICY DEFINITIONS
POLICY ID DAYS POL.ICY EXPIRES ON
A 1 90 11/11/2021
X�***
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