GALVESTON - Ambar Rangel claims Michael F. Padula and Tug and Deby Jackson inflicted approximately $40,000 in damages in connection to a roofing project in Galveston.

A lawsuit filed Nov. 22 in Galveston County Court at Law No. 2 says Padula, doing business as Palm Coast Structural, and the Jacksons, doing business as TD Group, allegedly lied to the plaintiff about performing work necessary toward obtaining a windstorm certificate.

Recent court documents show Rangel, doing business as Moon Roof & Remodeling, landed the assignment in January 2010 and subsequently hired TD Group to perform an inspection and approve the roof for compliance of specific Texas Department of Insurance requirements and Texas Windstorm Insurance Association requirements for the area.

TD Group represented themselves to be certified in the requirements, according to the original petition. One of its inspectors conducted an inspection and approved the roof while Padula signed an application for certificate of compliance.

Rangel claims to have later discovered "that the roof was not in compliance with TDI requirements as previously approved by the TD Group" and the proper documents were not filed.

"The plaintiff was caused to suffer multiple damages due to the defendants' negligence and breach of contract," the suit says.

It adds the complainant was forced to redo the entire roof to the tune of $41,611.

Attorney Javier Marcos Jr. of Houston is representing Rangel, and Galveston County Court at Law No. 2 Judge Barbara Roberts is presiding over the case.

Cause No. 66,411

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