Knarles and Barkley are father and son respectively. Barkley is seventeen years old. They operate a facilities maintenance company that regularly does business in the District of Columbia, Maryland and Virginia. The company is based in Maryland. They have a number of contracts with building owners where they have agreed to provide building maintenance to both residential and commercial buildings within the three jurisdictions already mentioned. They receive a monthly payment of $2,000 to $4,000 depending upon the size of the building.
They bill the owners for any equipment of a substantial nature that has to be replaced. Because of Knarles' long-term relationships with building owners, these contracts that were once in writing are generally renewed without a new written agreement. Often Knarles and Barkley will replace outdated and broken equipment such as water heaters and boilers that are part of a building's heating system. Further, as part of maintenance they regularly wash windows, remove snow and do touch-up painting as required.