XAVIER BECERRA THOMAS RINALDIbar.ca.gov/pdf/accusations/ard285333_2017_09_26_acc.pdf · XAVIER...
Transcript of XAVIER BECERRA THOMAS RINALDIbar.ca.gov/pdf/accusations/ard285333_2017_09_26_acc.pdf · XAVIER...
XAVIER BECERRA Attorney General of California
2 THOMAS L. RINALDI Supervising Deputy Attorney General
3 VIVIAN CHO Deputy Attorney General
4 State Bar No. 293773 300 So. Spring Street, Suite 1702
5 Los Angeles, CA 900 13 Telephone: (213) 897-2043
6 Facsimile: (213) 897-2804 E-mail: [email protected]
7 Attorneys for Complainant
8 BEFORETHE DEPARTMENT OF CONSUMER AFFAIRS
9 FOR THE BUREAU OF AUTOMOTIVE REPAIR
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STATE OF CALIFORNIA
In the Matter of the Accusation Against:
DENNIS D. GATLIN dba JOHNNYS SMOG CENTER 4611 W. Imperial Hwy. Inglewood, CA 90304
Automotive Repair Dealer Registration No. ARD 285333 Smog Check Station License No. TC 285333
and
YUNIS AHMAD OMARI 12400 Eucalyptus Ave. # 1 Hawthorne, CA 90250
Smog Check Inspector License No. EO 639849
Respondents.
ACCUSATION
25 Complainant alleges:
26 PARTIES
27 1. Patrick Dorais (Complainant) brings this Accusation solely in his official capacity as
28 the Chief of the Bureau of Automotive Repair, Department of Consumer Affairs.
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1 Automotive Repair Dealer Registration
2 2. On or about November 15, 2016, the Bureau of Automotive Repair issued
3 Automotive Repair Dealer Registration Number ARD 285333 to Dennis D. Gatlin DBA Johnnys
4 Smog Center ("Respondent Gatlin"). The Automotive Repair Dealer Registration was in full
5 force and effect at all times relevant to the charges brought herein and will expire on November
6 30, 2017, unless renewed.
7 Smog Check Station License
8 3. On or about December 29, 2016, the Bureau of Automotive Repair issued Smog
9 Check Station License Number TC 285333 to Respondent Gatlin. The Smog Check Station
10 License was in full force and effect at all times relevant to the charges brought herein and will
11 expire on November 30, 2017, unless renewed.
12 STAR Certification
13 4. On or about February 8, 2017, the Bureau certified Respondent Gatlin as a STAR
14 station. That certification was in full force and effect at all times relevant to the charges brought
15 herein and will remain active unless the Automotive Repair Dealer Registration and/or Smog
16 Check Station License issued to Respondent Gatlin is revoked, canceled, or the licenses become
17 delinquent or certification is invalidated.
18 Smog Check Inspector License
19 5. On or about October 28, 2016, the Bureau of Automotive Repair issued Smog Check
20 Inspector License Number EO 639849 to Yunis Ahmad Omari ("Respondent Omari").1 The
21 Smog Check Inspector License was in full force and effect at all times relevant to the charges
22 brought herein and will expire on November 30, 2018, unless renewed.
23 JURISDICTION
24 6. This Accusation is brought before the Director of the Department of Consumer
25 Affairs (Director) for the Bureau of Automotive Repair, under the authority of the following laws.
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1 Respondent Gatlin and Respondent Omari are hereinafter collectively referred to as "Respondents."
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1 7. Business and Professions Code section 9884.7 provides that the Director may revoke
2 an Automotive Repair Dealer Registration.
3 8. Business and Professions Code section 9884.13 of the Code provides, in pertinent
4 part, that the expiration of a valid registration shall not deprive the Director or chief of
5 jurisdiction to proceed with a disciplinary proceeding against an automotive repair dealer or to
6 render a decision invalidating a registration temporarily or permanently.
7 9. Section 44002 of the Health and Safety Code provides, in pertinent part, that the
8 Director has all the powers and authority granted under the Automotive Repair Act for enforcing
9 the Motor Vehicle Inspection Program.
10 10. Section 44072.6 of the Health and Safety Code provides, in pertinent part, that the
11 expiration or suspension of a license by operation oflaw, or by order or decision of the Director
12 of Consumer Affairs, or a court oflaw, or the voluntary surrender of the license shall not deprive
13 the Director of jurisdiction to proceed with any investigation of, or action or disciplinary
14 proceedings against the licensee, or to render a decision suspending or revoking the license.
15 11. Section 44072.8 of the Health and Safety Code states:
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When a license has been revoked or suspended following a hearing under this article, any additional license issued under this chapter in the name of the licensee may be likewise revoked or suspended by the director.
STATUTORY PROVISIONS
19 12. Section 477 of the Business and Professions Code provides, in pertinent part, that
20 '"Board" includes "bureau," "comn1ission," "committee," "department," "division," "exa1nining
21 committee," "program," and "agency." "License" includes certificate, registration or other means
22 to engage in a business or profession regulated by the Business and Professions Code.
23 13. Business and Professions Code section 9884.7 states, in pertinent part:
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(a) The director, where the automotive repair dealer cannot show there was a bona fide error, may refuse to validate, or may invalidate temporarily or permanently, the registration of an automotive repair dealer for any of the following acts or omissions related to the conduct of the business of the automotive repair dealer, which are done by the automotive repair dealer or any automotive technician, employee, partner, officer, or member of the automotive repair dealer.
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(1) Making or authorizing in any manner or by any means whatever any statement written or oral which is untrue or misleading, and which is known, or which by the exercise of reasonable care should be known, to be untrue or misleading.
( 4) Any other conduct that constitutes fraud.
(6) Failure in any material respect to comply with the provisions of this chapter or regulations adopted pursuant to it.
(c) Notwithstanding subdivision (b), the director may suspend, revoke, or place on probation the registration for all places ofbusiness operated in this state by an automotive repair dealer upon a finding that the automotive repair dealer has, or is, engaged in a course of repeated and willful violations of this chapter, or regulations adopted pursuant to it.
10 14. Section 44012 of the Health and Safety Code provides, in pertinent part, that tests at
11 smog check stations shall be performed in accordance with procedures prescribed by the
12 department.
13 15. Section 44015, subdivision (b), of the Health and Safety Code provides that a
14 certificate of compliance shall be issued if a vehicle meets the requirements of Health and Safety
15 Code section 40012.
16 16. Health and Safety Code section 44072.2 states, in pertinent part:
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The director may suspend, revoke, or take other disciplinary action against a license as provided in this article if the licensee, or any partner, officer, or director thereof, does any of the following:
(a) Violates any section of this chapter [the Motor Vehicle Inspection Program (Health and Safety Code§ 44000, et seq.)] and the regulations adopted pursuant to it, which related to the licensed activities.
(c) Violates any of the regulations adopted by the director pursuant to this chapter.
(d) Commits any act involving dishonesty, fraud, or deceit whereby another is injured ...
17. Health and Safety Code section 44072.10 states, in pertinent part:
(c) The department shall revoke the license of any smog check technician or station licensee who fraudulently certifies vehicles or participates in the fraudulent inspection of vehicles. A fraudulent inspection includes, but is not limited to, all of the following:
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(I) Clean piping, as defined by the department
(4) Intentional or willful violation of this chapter or any regulation, standard, or procedure of the department implementing this chapter ....
REGULATORY PROVISIONS
6 18. California Code of Regulations, title 16, section 3340.24, subdivision (c), states:
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The bureau may suspend or revoke the license of or pursue other legal action against a licensee, if the licensee falsely or fraudulently issues or obtains a certificate of compliance or a certificate of noncompliance.
10 19. California Code of Regulations, title 16, section 3340.30, subdivision (a), states:
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A smog check technician shall comply with the following requirements at all times while licensed.
(a) A licensed technician shall inspect, test and repair vehicles in accordance with section 44012 of the Health and Safety Code, section 44035 of the Health and Safety Code, and section 3340.42 of this article ....
20. California Code of Regulations, title 16, section 3340.35, subdivision (c), states:
(c) A licensed station shall issue a certificate of compliance or noncompliance to the owner or operator of any vehicle that has been inspected in accordance with the procedures specified in section 3340.42 of this article and has all the required emission control equipment and devices installed and functioning correctly ....
21. California Code of Regulations, title 16, section 3340.41, subdivision (c), states:
... [n ]o person shall enter into the emissions inspection system any vehicle identification information or emission control system identification data for any vehicle other than the one being tested. Nor shall any person knowingly enter into the emissions inspection system any false information about the vehicle being tested.
22. California Code of Regulations, title 16, section 3340.42, sets forth specific emissions
test methods and procedures which apply to all vehicles inspected in the State of California.
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1 COST RECOVERY
2 23. Business and Professions Code section 125.3 provides, in pertinent part, that the
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Board may request the administrative law judge to direct a licentiate found to have committed a
violation or violations of the licensing act to pay a sum not to exceed the reasonable costs of the
investigation and enforcement of the case, with failure of the licentiate to comply subjecting the
license to not being renewed or reinstated. If a case settles, recovery of investigation and
enforcement costs may be included in a stipulated settlement.
VID DATA REVIEW
24. Beginning March 9, 2015, California's Smog Check Program was updated to require
the use of an On-Board Diagnostic Inspection System ("OIS") during smog checks. OIS is the
Smog Check equipment required in all areas of the State when inspecting most model-year 2000
and newer gasoline and hybrid vehicles and most 1998 and newer diesel vehicles. Data retrieved
and recorded during an OIS smog check includes: the eVIN, which is the digitally stored VIN
programmed into the vehicle's Powertrain Control Module ("PCM"); the communication
protocol, which is the manufacturer/vehicle specific language the PCM uses to relay information;
and the number of Parameter Identifications ("PIDs"), which is the number of specific data values
each PCM uses related to emissions controls.
25. On or about February 22, 2017, Bureau representative Mauricio Cabeza initiated
an investigation in which he reviewed OIS test data for Johnnys Smog Center. The OIS Bureau
Test Data lists differences in Vehicle Identification Numbers (VIN) for vehicles that have
received smog inspections, in addition to communication protocol (the language used to
communicate) and Parameter ID (PID) differences with vehicles that have been certified correctly
that are the same make and model vehicles. Representative Cabeza's investigation revealed that
the data related to certain vehicles certified by Johnnys Smog Center contained discrepancies
between the information transmitted during the inspections and documented information known
about the subject vehicles. Specifically, representative Cabeza compared the data received from
the certified vehicles to data from vehicles of the same year, make, and model and determined
that the data from at least ten (I 0) of the certified vehicles contained the following discrepancies:
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1 (1) missing eVIN; (2) incorrect vehicle communication protocols; and (3) incorrect PID counts.
2 These documented discrepancies confirm that the vehicles receiving smog certificates from
3 Johnnys Smog Center were fraudulently tested during the smog inspection using the "clean
4 plugging" method.2 Table 1 illustrates the documented clean plugging activities of Respondents
5 between February 20, 2017 to February 23, 2017.
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Test Date Vehicle Certified Certificate Technician OIS Test Data Details &VINNo. No. License No.
2/20/2017 2005 Mercedes Benz ZN220536C EO 639849 Comm. Protocol: !914 C230K Sport Sedan (Respondent (expected: KWPF)
WDBRF40J35F685135 Omari) PID Count: 2
(expected: 17 or 20)
e VIN missing
2/20/2017 2007 Mercedes Benz ZN220537C EO 639849 Comm. Protocol: !914 E350 (Respondent (expected: ICANll bt5)
WDBUF56X37B037414 Omari) PID Count: 2 (expected: 44)
e VIN missing
2/20/2017 2003 Ford Expedition ZN220538C EO 639849 Comm. Protocol: !914 Eddie Bauer (Respondent (expected: JPWM)
1FMRU17W53LA72404 Omari) PID Count: 2 (expected: 22)
e VIN missing
2/20/2017 2006 Ford F150 ZN220539C EO 639849 Comm. Protocol: !914 Supercrew (Respondent (expected: I CAN II bt5)
1FTPW12576KB30706 Omari) PID Count: 2 (expected: 44)
e YIN missing
2 "Clean plugging" refers to the use of another vehicle's properly functioning On Board Diagnostic, generation II, (OBD II) system, or another source, to generate passing diagnostic readings for the purpose of issuing fraudulent smog Certificates of Compliance to vehicles that are not in smog compliance and/or not present for testing.
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Test Date
2121/2017
212112017
212112017
212212017
212212017
212312017
Ill
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Vehicle Certified Certificate Technician OIS Test Data Details &VINNo. No. License No.
2007 Ford Taurus SEL ZN220548C EO 639849 Comm. Protocol: 1914 1FAFP56U07Al77784 (Respondent (expected: 1CAN11 bt5)
Omari) PID Count: 2 (expected: 40)
e V1N not expected
2002 Buick ZN220549C EO 639849 Comm. Protocol: 1914 Rendezvous CX (Respondent (expected: JVPW)
3G5DA03E62S537979 Omari) PID Count: 2
(expected: 19 or 20)
e V1N not expected
2000 Ford Ranger ZP846504C EO 639849 Comm. Protocol: 1914 lFTYRl OC5YPA68449 (Respondent (expected: JPWM)
Omari) PID Count: 2 (expected: 16)
e V1N not expected
2004 Mazda RX8 ZP846506C EO 639849 Comm. Protocol: 1914 JM1FE173940110715 (Respondent (expected: ICAN11 bt5)
Omari) PID Count: 2 (expected: 3 7)
e YIN not expected
2007 Dodge Charger SE ZP846511C EO 639849 Comm. Protocol: 1914 2B3KA43G87H707120 (Respondent (expected: ICANll bt5)
Omari) PID Count: 2
(expected: 41 or 43112 or 43112115)
e YIN not expected
2004 Cadillac Deville ZP846521C EO 639849 Comm. Protocol: 1914 1G6KD54YX4U194340 (Respondent (expected: JYPW)
Omari) PID Count: 2 (expected: 23)
e YIN not expected
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1 26. The data analysis conducted on Johnnys Smog Center between February 20, 2017 and
2 February 23,2017 shows that Respondents participated in a scheme to perform at least ten (10)
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4 fraudulent Smog Check inspections resulting in the issuance often (10) fraudulent electronic
5 Smog Check Certificates of Compliance.
6 FIRST CAUSE FOR DISCIPLINE
7 (Untrue of Misleading Statements -Respondent Gatlin)
8 27. Respondent Gatlin's Automotive Repair Dealer Registration is subject to disciplinary
9 action pursuant to Business and Professions Code section 9884.7, subdivision (a)(!), in that
10 between February 20,2017 and February 23, 2017, Respondent Gatlin made or authorized
11 statements which he knew or in the exercise of reasonable care should have known to be untrue
12 or misleading, as follows: Respondent Gatlin certified that the vehicles set forth above in Table 1
13 had passed inspection and were in compliance with applicable laws and regulations. In fact,
14 Respondent Gatlin used the clean plugging method in order to issue smog certificates of
15 compliance, and did not test or inspect the vehicles as required by Health and Safety Code section
16 44012. Complainant refers to, and by this reference incorporates, the allegations set forth above
17 in paragraphs 24 through 26, inclusive, as though set forth fully herein.
18 SECOND CAUSE FOR DISCIPLINE
19 (Fraud- Respondent Gatlin)
20 28. Respondent Gatlin's Automotive Repair Dealer Registration is subject to disciplinary
21 action pursuant to Business and Professions Code section 9884.7, subdivision (a)(4), in that
22 between February 20, 2017 and February 23, 2017, Respondent Gatlin committed acts which
23 constitute fraud by issuing electronic certificates of compliance for the vehicles set forth above in
24 Table 1 without performing bona fide inspections ofthe emission control devices and systems on
25 those vehicles, thereby depriving the People of the State of California of the protection afforded
26 by the Motor Vehicle Inspection Program. Complainant refers to, and by this reference
27 incorporates, the allegations set forth above in paragraphs 24 through 26, inclusive, as though set
28 forth fully herein.
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THIRD CAUSE FOR DISCIPLINE
(Material Violation of Antomotive Repair Act- Respondent Gatlin)
4 29. Respondent Gatlin's Automotive Repair Dealer Registration is subject to disciplinary
5 action pursuant to Business and Professions Code section 9884.7, subdivision (a)(6), in that he
6 failed in a material respect to comply with the provisions of this chapter or regulations adopted
7 pursuant to it when he issued electronic certificates of compliance for the 1 0 vehicles identified in
8 Table 1 above without performing bona fide inspections of the emission control devices and
9 systems on those vehicles, thereby depriving the People of the State of California of the
10 protection afforded by the Motor Vehicle Inspection Program. Complainant refers to, and by this
11 reference incorporates, the allegations contained in paragraphs 24 through 26, above, as though
12 set forth fully herein.
13 FOURTH CAUSE FOR DISCIPLINE
14 (Violations of the Motor Vehicle Inspection Program- Respondent Gatlin)
15 30. Respondent Gatlin's Smog Check Station License is subject to disciplinary action
16 pursuant to Health and Safety Code section 44072.2, subdivision (a), in that between February
17 20, 2017 and February 23, 2017, regarding the vehicles set forth above in Table 1, Respondent
18 Gatlin failed to comply with the following sections of the Health and Safety Code:
19 a. Section 44012: Respondent Gatlin failed to ensure that the emission control
20 tests were performed on the vehicles in accordance with procedures prescribed by the department.
21 b. Section 44015: Respondent Gatlin issued electronic certificates of compliance
22 for the vehicles, without ensuring that the vehicles were properly tested and inspected to
23 determine if they were in compliance with Health and Safety Code section 44012.
24 Complainant refers to, and by this reference incorporates, the allegations set forth above in
25 paragraphs 24 through 26, inclusive, as though set forth fully herein.
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2 FIFTH CAUSE FOR DISCIPLINE
3 (Failure to Comply with Regulations Pursuant to the Motor Vehicle Inspection Program-
4 Respondent Gatlin)
5 31. Respondent Gatlin's Smog Check Station License is subject to disciplinary action
6 pursuant to Health and Safety Code section 44072.2, subdivision (c), in that between February
7 20, 2017 and February 23, 2017, regarding the vehicles set forth above in Table I, Respondent
8 Gatlin failed to comply with the following provisions of California Code of Regulations, title 16,
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10 a. Section 3340.24, subdivision (c): Respondent Gatlin falsely or fraudulently
II issued electronic smog certificates of compliance for the I 0 vehicles identified in Table I above.
12 b. Section 3340.35, subdivision (c): Respondent Gatlin issued electronic smog
13 certificates of compliance for the I 0 vehicles identified in Table I above, even though the
14 vehicles had not been inspected in accordance with section 3340.42.
15 c. Section 3340.41, subdivision (c): Respondent Gatlin lmowingly entered false
16 infonnation into the emissions inspection system for the I 0 vehicles identified in Table 1 above.
17 d. Section 3340.42: Respondent Gatlin failed to ensure that the required smog
18 tests were conducted on the I 0 vehicles identified in Table I above, in accordance with the
19 Bureau's specifications.
20 Complainant refers to, and by this reference incorporates, the allegations set forth above in
21 paragraphs 24 through 26, inclusive, as though set forth fully herein.
22 SIXTH CAUSE FOR DISCIPLINE
23 (Dishonesty, Fraud or Deceit- Respondent Gatlin)
24 32. Respondent Gatlin's Smog Check Station License is subject to disciplinary action
25 pursuant to Health and Safety Code section 44072.2, subdivision (d), in that from February 20,
26 2017 and February 23, 2017, regarding the vehicles set forth above in Table I, Respondent Gatlin
27 committed acts involving dishonesty, fraud or deceit whereby another was injured by issuing
28 electronic certificates of compliance for those vehicles without performing bona fide inspections
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1 of the emission control devices and systems on the vehicles, thereby depriving the People of the
2 State of California of the protection afforded by the Motor Vehicle Inspection Program.
3 Complainant refers to, and by this reference incorporates, the allegations set forth above in
4 paragraphs 24 through 26, inclusive, as though set forth fully herein.
5 SEVENTH CAUSE FOR DISCIPLINE
6 (Violations of the Motor Vehicle Inspection Program -Respondent Omari)
7 33. Respondent Omari's Smog Check Inspector License is subject to discipline pursuant
8 to Health and Safety Code section 44072.2, subdivision (a), in that between February 20, 2017
9 and February 23, 2017, regarding the vehicles set forth above in Table I, Respondent Omari
10 failed to comply with section 44012 of the Health and Safety Code in a material respect, as
II follows: Respondent Omari failed to perform the emission control tests on those vehicles in
12 accordance with procedures prescribed by the department. Complainant refers to, and by this
13 reference incorporates, the allegations set forth above in paragraphs 24 through 26, inclusive, as
14 though set forth fully herein.
15 EIGHTH CAUSE FOR DISCIPLINE
16 (Failure to Comply with Regulations Pursuant to the Motor Vehicle Inspection Program -
17 Respondent Omari)
18 34. Respondent Omari's Smog Check Inspector License is subject to discipline pursuant
19 to Health and Safety Code section 44072.2, subdivision (c), in that between February 20, 2017
20 and February 23,2017, regarding the vehicles set forth above in Table I, he failed to comply with
21 provisions of California Code of Regulations, title 16, as follows:
22 a. Section 3340.24, subdivision (c): Respondent Omari falsely or fraudulently
23 issued electronic smog certificates of compliance for the I 0 vehicles identified in Table I above.
24 b. Section 3340.30, subdivision (a): Respondent Omari failed to inspect and test
25 the I 0 vehicles identified in Table I above, in accordance with Health and Safety Code sections
26 44012 and 44035, and California Code of Regulations, title 16, section 3340.42.
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1 c. Section 3340.41, subdivision (c): Respondent Omari knowingly entered false
2 information into the emissions inspection system for the 10 vehicles identified in Table 1 above.
3 Ill
4 d. Section 3340.42: Respondent Omari failed to conduct the required smog tests
5 on the 10 vehicles identified in Table 1 above, in accordance with the Bureau's specifications.
6 Complainant refers to, and by this reference incorporates, the allegations contained in
7 paragraphs 24 through 26, above, as though set forth fully herein.
8 NINTH CAUSE FOR DISCIPLINE
9 (Dishonesty, Fraud or Deceit- Respondent Omari)
10 35. Respondent Omari's Smog Check Inspector License is subject to disciplinary action
11 pursuant to Health and Safety Code section 44072.2, subdivision (d), in that he committed
12 dishonest, fraudulent, or deceitful acts whereby another was injured by issuing electronic smog
13 certificates of compliance for the l 0 vehicles identified in Table 1 above, without performing
14 bona fide inspections of the emission control devices and systems on the vehicles, thereby
15 depriving the People of the State of California of the protection afforded by the Motor Vehicle
16 Inspection Program. Complainant refers to, and by this reference incorporates, the allegations
17 contained in paragraphs 24 through 26, above, as though set forth fully herein.
18 OTHER MATTERS
19 36. Pursuant to Business and Professions Code section 9884.7, subdivision (c), the
20 Director may suspend, revoke, or place on probation the registration for all places of business
21 operated in this state by Respondent Gatlin, upon a finding that he has, or is, engaged in a course
22 of repeated and willful violations of the laws and regulations pertaining to an automotive repair
23 dealer.
24 37. Pursuant to Health and Safety Code section 44072.8, if Smog Check Station License
25 No. TC 285333, issued to Respondent Gatlin, is revoked or suspended, any additional license
26 issued under Chapter 5 of Part 5 of Division 26 of the Health and Safety Code in the name of said
27 licensee may be likewise revoked or suspended by the Director.
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38. Pursuant to Health and Safety Code section 44072.8, if Smog Check Inspector
2 License No. EO 639849, issued to Respondent Omari, is revoked or suspended, any additional
3 license issued under Chapter 5 of Part 5 of Division 26 of the Health and Safety Code in the name
4 of said licensee may be likewise revoked or suspended by the Director.
5 PRAYER
6 WHEREFORE, Complainant requests that a hearing be held on the matters herein alleged,
7 and that fo llowing the hearing, the Director of Consumer Affairs issue a decision:
8 1. Revoking or suspending Automotive Repair Dealer Registration No. ARD 285333,
9 issued to Dennis D. Gatlin DBA Johnnys Smog Center;
10 2. Revoking or suspending any other automotive repair dealer registration issued to
11 Dennis D. Gatlin;
12 3. Revoking or suspending Smog Check Station No. TC 285333, issued to Dennis D.
13 Gatlin DBA Johnnys Smog Center;
14 4. Revoking or suspending any additional license issued under Chapter 5 of Part 5 of
15 Division 26 of the Health and Safety Code in the name of Respondent Gatlin;
16 5. Revoking or suspending Smog Check Inspector License No. EO 639849, issued to
17 Respondent Omari ;
18 6. Revoking or suspending any add itional license issued under Chapter 5 of Part 5 of
19 Division 26 of the Health and Safety Code in the name of Respondent Omari;
20 7. Ordering Respondent Gatlin and Respondent Omari to pay the Bureau of Automotive
21 Repair the reasonable costs of the investigation and enforcement of this case, pursuant to
22 Business and Professions Code section 125.3; and,
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8. Taking such other and further action as deemed necessary and proper.
Chief
LA20 17604602
Bureau of Automotive Repair Department of Consumer Affairs State of California
28 52545742.doc Complainant
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