FILE D

APRO 2019

Docketod by

CHIEF FINANCIAL OFFICER

JIMMY PATRONIS

STATE OF FLORIDA

DEPARTMENT OF FINANCIAL SERVICES, DIVISION OF INSURANCE AGENT AND AGENCY SERVICES,

DOAH CASE NO.: 17-3188PL

Petitioner, DFS CASE NO.: 202437-17-AG

V.

PAMELA WILLIAMS DENSON,

Respondent.

FINAL ORDER

THIS CAUSE came on for consideration of and for final agency action on a Recommended Order. After reviewing the record, including all testimony and admitted exhibits, considering applicable law, and otherwise being fully apprised in all material premises, the Recommended Order is hereby adopted, except as modified below.

1. Conclusions of Law paragraph 16 is clarified by the following. Paragraph 16 states that, with respect to Respondent's violation of section 648.44(1)(m), Florida Statutes (2017), "the evidence fails to support Petitioner's assertion that the violation was willful, and thus, fails to support the aggravated penalty." The Department recognizes that this finding by the Administrative Law Judge ("ALJ") is based upon competent, substantial evidence in the record, and, therefore, does not disturb the same. The Department also recognizes that the findings of fact relating to Respondent' s "non- culpability" with respect to Lumbermens' failure to pay or secure the forfeiture judgment (see third and fourth sentences of Conclusions of Law paragraph 19) may not have been intended by the ALJ to have any bearing on the "willfulness" determination set forth in

   
   

   Filed April 5, 2019 9:55 AM Division of Administrative Hearings

   
   

   paragraph 16, and may have been included solely because of the substantive due process opinions raised by the ALJ in paragraphs 19-20. However, for clarity, the Department disavows the implication, if any, that the ALJ's non-culpability findings in paragraphs 19-20 are relevant to the issue of whether Respondent did or did not willfully violate section 648.44(1)(m), Florida Statutes (2017), in the manner alleged by the Department in this matter; viz., that Respondent executed bonds while a judgment on a bond previously executed by Respondent for a surety principal remained unpaid or unsecured. While Respondent may or may not have been culpable with respect to the unpaid and unsecured judgment, that issue did not form any part of the basis of the Administrative Complaint in this matter.

2. Conclusions of Law paragraphs 19 and 20 are modified by rejecting the first sentence of paragraph 19 and the last sentence of paragraph 20. The rejected language raises the issue of substantive due process in the context of the Department's proposal that satisfaction of the judgment be made a condition of reinstatement. Because the Department adopts the ALJ's recommendation of a three-month suspension, without the proposed reinstatement condition, the rejected language is irrelevant to this matter.

   The rejected language does not appear to set forth any conclusions of law, but, rather, appears simply to make suggestions to the Department. However, to the extent that a statement of reasonableness is necessary, paragraphs 19 and 20 as modified are as or more reasonable than paragraphs 19 and 20 without modification.

3. The Recommendation is modified to correct the statutory citation by replacing "448.441(1)(m)" with "648.441(1)(m)".

Accordingly, Respondent's limited surety agent license is suspended for three (3)

months, effective as of the date of this Order.

DONE and ORDERED t h i s d a y o f

NOTICE OF RIGHT TO APPEAL

A party adversely affected by this final order may seek judicial review as provided in section 120.68, Florida Statutes, and Florida Rule of Appellate Procedure

9.190. Judicial review is initiated by filing a notice of appeal with the Agency Clerk, and a copy of the notice of appeal, accompanied by the filing fee, with the appropriate district court of appeal. The notice of appeal must conform to the requirements of Florida Rule of Appellate Procedure 9.110(d), and must be filed (i.e., received by the Agency Clerk) within thirty days of rendition of this final order.

Filing with the Department's Agency Clerk may be accomplished via U.S. Mail, express overnight delivery, hand delivery, facsimile transmission, or electronic mail. The address for overnight delivery or hand delivery is Julie Jones, DFS Agency Clerk, Department of Financial Services, 612 Larson Building, 200 East Gaines Street, Tallahassee, Florida 32399-0390. The facsimile number is (850) 488-0697. The email address is Julie.Jonesia mv floridacfo.com.

Copies furnished to:

Frank Eduardo Gil, Esq.

The Law Office of Frank E. Gil, P.A. 10689 North Kendall Drive, Suite 208

Miami, Florida 33176 Attorney for Respondent

Chase Den Beste Senior Attorney

Department of Financial Services 200 East Gaines Street Tallahassee, Florida 32399-0333

Robert E. Meale Administrative Law Judge

Division of Administrative Hearings 1230 Apalachee Parkway Tallahassee, Florida 32399-3060

STATE OF FLORIDA

DIVISION OF ADMINI STRATIVE HEARINGS

DEPARTMENT OF FINANCIAL SERVICES,

Petitioner,

vs.

PAMELA WILLIAMS DENSON,

Respondent.

Case No. 17-3188PL

RECOMM ENDED ORDER

On Septe mber 29 , 2017 , Robert E. Meal e, Admi nistrat ive Law Judge of the Division o f Administr ative Heari ngs ( DOAH), conducted the fin al hearin g by vid eoconfere nce in M iami and Tallahassee, Florida.

APPEAR ANCES

For Petitioner: Matthew R . Daley, Esquire

Department of Financia l Services Office o f the G eneral Counsel 200 East Ga ines Street Tallaha ssee, F lorida 32399

For Respondent: Frank Eduardo Gil, Esquire

The Law Office of Frank E. Gil, P. A. 10689 North Kendal l Drive, Suite 208

Miami, Florida 33176 STATEM ENT OF THE I SSUES

The iss ues are whethe r, in violati on of s ection 648 . 45 ( 3 )( c), Fl orida St atutes, Responde nt execu ted a bo nd after a judgme nt had b een ente red on a bail bo nd that she had executed

and the judgment had remained unpaid or unsecured for at least

35 days; and, if so, what penalty should be imposed.

PRELIMINARY STATEMENT

An Admini strative Complain t dated F ebruary 2 4 , 2017 , alleges that Re sponden t is cu rrently license d as a limited surety ( ba il bond) agent, hol ding lice nse number A 097887 . At all mat erial t imes, R esponde nt all egedly was the primar y bail bond agent , owner, and sole managing member of V. I. P. B ailbonds, LLC, l ocated at 20 401 N orthwe st Sec ond Av enue, Suite 216 , Miami Gardens, Florida. At all mater ial times, V. I. P. Bail bonds, LLC, was alle gedly a n agent for Lu mbermen s Mutua l Insur ance, a surety company l icensed t o do bus iness in Florida.

The Adminis trative Com plaint alle ges that, o n August 3 , 2007 , in criminal case numb er 071363 1 CF 10 A, R espondent executed a bond fo r Richard Banton in the am ount of $ 75 , 000 , on which Lumberme ns Mutu al Insu rance w as the surety. On July 17 , 2009 , the Clerk o f Circuit Court in a nd for Brow ard County , Florida, allegedly entered a judgment o rdering th e forfeitu re of bond power nu mber US 1 00781910 and ord ering Lu mbermens Mutual Insurance to pay $ 75 , 000 by August 2 1 , 2009 . On August 21 , 2009 , the Clerk of Circuit C ourt alle gedly ent ered a Ce rtificate of Uns atisfi ed Jud gment. At the hearing, the Administrative Law Judge gra nted Peti tioner' s oral moti on to tak e officia l notice

of the c ivil ac tion re sulting in the $ 75 , 00 0 judgm ent, wh ich may be found online at htt ps:// ww w. browa rdclerk . org/ We b 2 / Case Search/ Details/? ca seid= Nzgl O TY 3 - 176 xu N Tk M 88 o 3 d& c ase Num= CAC E 09039681 & category= CV.

On Dece mber 2 8 , 2010 , Peti tioner allege dly in formed

Responde nt that she was prohib ited fro m execu ting bai l bonds until t he judg ment o f July 17 , 20 09 , was paid. Respondent has allegedly failed to pay the judgment.

The Adm inistra tive Co mplaint allege s that Respond ent has violated section 648 . 44 ( 1 )( m) b y execut ing bai l bonds after a judgment had bee n entere d on a bail bon d that s he had e xecuted and, wit hin 35 d ays of i ts entry , the ju dgment h ad not b een paid or payme nt of th e judgme nt had n ot been secured by bond; section 648 . 45 ( 2 )( f), by dem onstrating a lack of reasonabl y adequate knowledge an d competence to engage i n the licens ed business; section 64 8 . 45 ( 2 )( j) , by willf ully faili ng to comp ly with or willfull y violat ing any proper rule or order o f Petiti oner or willfull y violat ing any provisio n of cha pter 648 or the Florida Insurance Code; an d section 648 . 45 ( 3 )( c), by failing t o comply with any la w relating to the bus iness of b ail bond in surance or violatin g any pr ovision of the Florida Insuranc e Code.

Responden t timely requeste d a form al admini strative

hearing.

At the heari ng, Pe tition er cal led tw o witn esses and of fered into evi dence s even ex hibits: Petition er Exhib its 1 - 7 .

Respon dent c alled no wi tness es, bu t offe red o ne exh ibit: Respond ent Exh ibit 1 . All exh ibits w ere ad mitted except Petitio ner Exh ibit 4 , which was pro ffered.

The court reporter filed th e transcr ipt on Oc tober 19 , 2017 . The pa rties filed propos ed rec ommend ed ord ers by November 20 , 2017 .

FINDINGS OF FACT

1. . At all ma terial t imes, Res pondent has been licensed as a l imite d sure ty ( b ail b ond) a gent, holdi ng li cense number A 097887 . She ha s not been p revio usly d iscipl ined.

2. . From Mar ch 2004 throug h August 2010 , Respond ent was appoin ted a s a b ail b ond a gent to rep resen t Ind iana Lumbe rmens Mutual I nsurance Compan y ( Lumbe rmens). On August 3 , 2007 , Respon dent, as a b ail bo nd age nt, i ssued a bond on be half o f her princip al, Lum bermens , in th e amou nt of $ 75 , 000 for def endant Richard Benton.

3. . Almost two years later , Mr. Bento n failed to appear at a mandat ory cou rt appe arance on May 15 , 200 9 , in B roward Circuit Court Case 07 - 1 3631 C F 10 A. On May 15 , 2009 , a circuit judge entered an Or der Es treati ng Bon d, whi ch ord ered L umberm ens to pay $ 7 5 , 000 to th e Brow ard C ounty Clerk of Co urts.

   
   

   
   

4. . On July 17 , 200 9 , the B roward County C lerk of Courts entere d a ju dgmen t in t he amo unt o f $ 75 , 000 ag ainst Lumbe rmens based o n the O rder E streati ng Bon d ( Judg ment). After " Ordered and Adj udged," the Ju dgment reads: " Judgment in the a mount of

   $ 75 , 00 0 be a nd the same is he reby e ntere d agai nst In diana Lumber mens M utual Ins as suret y" plu s inte rest. On July 17 , 2009 , t he Cle rk' s o ffice served a cop y of t he Jud gment to the bail bo nd age ncy at which Respon dent w orked.

5. . By Cler k' s Ce rtifica te of Unsatis fied J udgment dated August 21 , 20 09 , th e Brow ard Co unty C lerk o f Cour ts cer tified that th e $ 75 , 000 Ju dgment had no t been satisf ied as of th e date of the cer tificate. The ce rtific ate, w hich, on it s face , was not se rved on Re spond ent o r her bail bond agen cy, s tates errone ously that the Judgm ent w as ag ainst Lumb ermen s and Resp onde nt. This fla wed cer tificat e does n ot esta blish b y clear and conv incing evidenc e that the Jud gment w as unpa id, nor do the confus ing d ocket remar ks th at the civi l acti on ag ainst Lumber mens was " Dispos ed by Othe r," a s indi cated unde r the column marke d " St atisti cal C losure ( s)." Howev er, P etiti oner introdu ced int o evide nce Pet itioner Exhibi t 7 , wh ich is another Clerk' s cert ificat e cert ifying that the J udgmen t rema ined u npaid as of S eptemb er 28 , 2017 . This estab lishes by clear and convinc ing ev idence that t he Judg ment r emains outsta nding.

   
   

6. . After t he expi ration of 35 days fo llowing the en try of the Ju dgmen t, Re spond ent co ntinu ed to exec ute su rety bonds as a bail bond agent f or one o r more s urety co mpanies. In 2 015 , an investi gator employ ed by P etitio ner ca lled Re sponde nt and informed he r about th e Judgment against L umbermens. The investi gator t old Res pondent that t he Judg ment wa s outst anding and " c ould affec t her lice nse."

   CONCL USIO NS OF LAW

   
   

7. DOAH has jurisdiction of the subject matter.

   
   

   §§ 120.569 and 120.57(1), Fla. Stat. (2015).

   
   

8. . Petition er bear s the b urden of provin g the m aterial allegatio ns by cle ar and co nvincing evidence. § 120 . 57 ( 1 )( j).

9. . A " bail bond a gent" i s eith er a " l imited surety agent" or a " profes sional bail bond a gent." § 648 . 25 ( 2 ). Respo ndent is a ba il bond agent who is a limi ted sur ety age nt and may be referre d to b y eith er sta tutory term.

10. . A crimi nal sur ety bai l bond encomp asses a n under taking by the bail b ond age nt who endor sed the bond to " ens ure th at the defenda nt appe ars at all cr iminal procee dings for whi ch the surety bond is posted." § 903 . 045 . The unde rtaking by the surety c ompany arises under t he condi tions a nd term of the surety bond. Assumin g liabi lity un der the surety bond, if the defenda nt fail s to ap pear as requir ed, the court shall d eclare the bon d forfe ited, a nd the clerk of cour t shall , withi n five

    
    

    days, transmit notice of the forfeiture to the surety agent and the surety company. § 903.26(2)(a).

11. . If the fo rfeiture is not paid or d ischarge d by the court withi n 60 days, the c lerk of th e cou rt ent ers j udgme nt on the forfe iture " ag ainst the surety." § 903 . 27 ( 1 ). Wit hi n t en days, t he cle rk shal l furn ish Pet itione r and t he Off ice of Insuran ce Reg ulatio n a ce rtifie d copy of the " judg ment d ocket" and the " sure ty com pany" a copy of the judgm ent, i ncludi ng the power of att orney numbe r and the na me of the " execut ing ag ent." Id. If the judgm ent is not p aid wi thin 3 5 days , the clerk shall

    furnish copies of the judgment	and	a certifi cate of
    nonsatis faction to Petit ioner,	the	Offi ce of In surance
    Regula tion, and the s heriff of	t he	co unty in whi ch th e	bon d was

    
    

    executed. Id.

    
    

12. . Section 903 . 27 ( 3 ) pro vides:

    
    

    Surety bail bo nds may not be execut ed by a bail bond agent agai nst whom a judgment has been entered which has remaine d unpaid for 35 days an d may n ot be e xecuted for a compan y agai nst wh om a judgme nt has been entered which h as remai ned unp aid for

    50 days. No she riff or ot her of ficia l who is empow ered to accept o r approv e surety bail bo nds sha ll acce pt or a pprove such a bond exec uted by such a ba il bond agent or execute d for such a compan y unti l such judgment has been paid.

    
    

13. . The pre condit ion to the no naccept ance o f a bai l bond

    
    

    from a bail bond agent or a surety is the entry of a judgment

    
    

    
    

    against t he party. Thus, in this cas e, w here the judg ment was not e ntere d aga inst Respo ndent , pu blic offic ials could lawf ully conti nue t o acc ept bail bonds tha t she had exec uted as a bail bond a gent, alth ough the b ail b ond ag ent h ersel f is prohi bited from e xecuti ng bai l bond s by s ection 648 . 4 4 ( 1 )( m ), whi ch is trigge red by an u npaid " judg ment [ that] has b een e ntered on a bond exe cuted b y a bail bond a gent," rather t han a j udgment against a bai l bond agent.

14. . It is the duty of Pe titio ner t o pro ve th e Jud gment and that the J udgment r emained o utstandin g at the time that Respon dent e xecute d addi tional bail bonds. See, e. g. , St at e v. Roba rge , 450 So. 2 d 855 ( Fla. 1984 ) ( state must prove both elemen ts of crim e of " posse ssion of a firea rm wi thout a lic ense" becaus e " wit hout a licen se" is with in the enact ing cl ause o f the statute, not a subseque nt clause). Petiti oner has p roved both elements in thi s case.

15. . Respond ent ra ises th e defe nse of equita ble est oppel, which requi res P etiti oner to re presen t a m ateri al fa ct th at is contr ary t o a l ater- asser ted p ositi on, R espon dent to re ly on the repre senta tion, and Respo ndent to s uffer a de trime ntal chang e in positio n in r elianc e on t he rep resent ation. See , e. g. , Ha mi lt on Downs Ho rsetrac k, LLC v . State , 226 So. 3 d 1046 ( Fl a. 1 st DCA 2017 ) ( equitable estoppel wh ere an inve stigator wi tnessed an invalid race due to commo n owne rship o f both horse s, but , in a

    
    

    
    

    post- r ace me eting when the ra ce, if unoff icial , coul d have been rerun, a ssured t he opera tor that the rac e was of ficial). The above- des cribed co mments b y Petitio ner' s in vestigato r do not rise to a represe ntation of anythi ng, exce pt the f act that Respond ent' s licens e could be af fected by the outst anding Judgment agains t Lumbe rmens-- an asse rtion t hat Pet itioner continues t o make in this case. Nor i s Re spond ent able to p rove detrime ntal re liance. Respondent s eems to imp ly that the investi gator' s commen t lulle d Respo ndent i nto a f alse se nse of securi ty, so that she di d not inves tigate wheth er Lum bermen s had paid the 20 09 Judgmen t in 2015 . Regard less o f whet her an investigat ion in 201 5 would ha ve uncover ed anythin g that an investi gation in 2017 failed to un cover, Respond ent is really invitin g the A dminist rative Law Jud ge to s peculat e, agai nst the clear and convincin g evidenc e of the Clerk' s s econd cer tificate, that the Judgme nt was actuall y paid. But the fa ct is the Judgmen t was n ever p aid, so any re liance by Res pondent could never be de trime ntal.

16. . Florida Ad ministrati ve Code R ule 69 B- 24 1 . 080 ( 13 ) provides that t he pena lty ran ge for a viola tion of

    section 6 48 . 44 ( 1 ) ( m) is s uspension for not more th an three months fo r the in itial vi olation. In its pr oposed re commended order, P etition er requ ests a six mon ths' su spensio n based on the willfulnes s of Resp ondent' s v iolation. However, the evidence

    
    

    
    

    fails to sup port Petiti oner' s asse rtion that t he vi olatio n was willful and, t hus, f ails to suppo rt the aggrav ated pe nalty.

17. . In its propos ed rec ommend ed orde r, Pet itione r also request s that post- suspen sion r einsta tement be co nditio ned on Respondent ' s paymen t of the Judgment. Petit ioner ' s re quest does not cite any au thority, but se ction 6 48 . 49 ( 1 ) provid es that P e t i t i o n e r " m a y n o t g r a n t . . . r e i n s t a t e m e n t i f i t f i n d s t h a t t h e c i r c u m s t a n c e s f o r w h i c h t h e l i c e n s e . . . w a s s u s p e n d e d still exi st or are likely t o recur." The Admin istrative Complai nt sou ght re vocati on, so Petit ioner has pr ovided Respon dent n otice of th e pos sibili ty th at the pena lty in this proceedi ng coul d effect ively d eprive her perm anently of her license as a bail bo nd agent.

18. . In her propo sed re commen ded or der, R espond ent co ntends that di sciplin e in th is case would violat e her p rocedur al due proce ss r ights , ci ting Mathews v. Eldridge , 424 U. S. 319 ( 1976 ). The argu ment ap pears t o suppl ement h er equi table- e stoppel argumen t by fo cusing on the long d elay of Petiti oner in bring this case. Perhap s, the argum ent is that her pr ocedur al due process rights are vio lated b y a lack of an adminis trative statut e of l imitat ions. Neither the gover nment nor private interest is para mount, s o the f ocus tur ns to th e risk o f error of the la ck of st atute of limitati ons in th e contex t of the ample pr ocedural safegua rds that attach in a cha pter 120

    
    

    
    

    adminis trativ e proce eding. See Rivera v. Minnich , 483 U. S. 574 ( 1987 ); Addin gton v. T exas , 441 U. S. 418 ( 1979 ); Santosky v.

    Kr am er , 455 U. S. 745 ( 1982 ) ( Rehnquist, J. , dissenting). The flaw in this argume nt is t hat no thing suggest s that the o utcome of this prose cution would have b een any diffe rent if it ha d been filed one da y afte r Res ponden t had execut ed th e firs t bail bond after th e time had run for Lu mbermens to pay the Ju dgment.

    Thus, a court's addition of a limitations period, on the ground of procedural due process, would not alter the outcome of this case.

19. . This is not to im ply that Res pondent may not have a substantive due process argument -- a prospect that Peti tioner may wish to c onsider in assess ing the penalty. The facts of this case establ ish a clea r violation based on the bail bo nd agent' s strict l iability for endorsing su rety bonds after the failure of the surety company that she represent s to pay a Judgmen t arising out of a surety bo nd that t he agent has endo rsed on b ehalf of her principal . The facts o f this cas e fail to e stablish a single act or omis sion on Respondent ' s part in connection with this br each o f cont ract b y Lumb ermens . Neither the allegations nor the evid ence suggest s that Petit ioner someho w knew that Lumberm ens mig ht not pay the surety bond a t issue in thi s case or that s he endors ed bail b onds on behalf of Lumberme ns after the fo rfeitu re ord er ent ered b y the Clerk.

    
    

    
    

20. Petitioner may not deprive Respondent of her license, which is a property interest, without due process:

Substa ntive due pr ocess refers to ce rtain action s that the g overnm ent ma y not engage in, no matter how m any pro cedura l safe guards it employs." Blaylo ck v. Schw inden , 862 F. 2 d 1352 , 1354 ( 9 th Cir. 1988 ).

Substantive due process "protects a liberty or property interest in pursuing the 'common occupations or professions of life.'" Benigni v. City of Hemet, 868 F.2d 307, 312 (9th Cir. 1988) (quoting Schware v. Board of Bar Examiners, 353 U.S. 232, 238-39,

1 L. Ed. 2 d 7 96 , 77 S. Ct. 752 ( 1957 )); see

also Cha lmers v . City of Los Angeles , 762 F. 2 d 753 , 757 ( 9 th Cir. 1985 ). In ord er to prove a subst antive due pr ocess claim, appella nts mu st ple ad tha t the govern ment' s action was " cl early arbitra ry and unrea sonab le, h aving no s ubsta ntial rela tion to the public health , safet y, mora ls, or genera l welf are." Village of Euclid v.

Ambler Re alty Co. , 272 U. S. 365 , 395 , 71 L.

Ed. 303 , 47 S. Ct. 114 ( 1926 ). Betsey

Lebbo s' s alleg atio ns t hat a ppel lees' act ions deprived her of th e abilit y to prac tice law thus sta tes a s ubstant ive due process claim.

Lebbos v. Ju dges o f Supe rior C ourt, 883 F. 2 d 810 , 818 ( 9 th Cir. 1989 ). If, on the pre sent facts, Pe titioner can d etermine that suspend ing Re sponde nt' s l icense until she pa ys a $ 75 , 000 Judgment bears a substa ntial r elation to the public health, safety, morals , or g eneral welfare , it m ay impo se the relief sought in its propo sed rec ommend ed ord er; oth erwise , Peti tioner may pr efer to co nfine itse lf to the p enalt y rec ommen ded i n its ru le .

RECO MME NDAT ION

It is

RECOM MENDE D th at Pe titi oner enter a f inal orde r fin ding Respo nden t gu ilty of v iola ting sect ion 448 . 44 ( 1 ) ( m), Flo rida Statut es; s uspen ding her l imited sure ty li cense for three month s; an d rei nstat ing the l icens e at the end o f thr ee mo nths withou t rega rd to whethe r the Judgme nt rem ains o utstan ding.

DONE A ND EN TERED this 22 nd day o f Nov ember , 201 7 , in Tallaha ssee, L eon Cou nty, Fl orida.

ROBER T E. MEALE

Administ rative L aw Judge

Divisio n of Ad ministr ative H earings The De Soto Building

1230 Apa lachee Parkway

Tallahassee, Florida 32399 - 3060

( 8 5 0 ) 4 8 8 - 9 6 7 5

Fax Fil ing ( 8 50 ) 92 1 - 6847 www. doah. s tate. fl. us

Filed w ith the Clerk of the Divisi on of Admini strati ve Hea rings this 2 2 nd d ay of Novem ber, 2017 .

COPIES FU RNISHED:

Matthew R . Daley, Esquire Depar tment of Finan cial Serv ices Offic e of the G enera l Cou nsel 200 East Ga ines Street Tallaha ssee, F lorida 32399 ( e Served)

Frank Eduardo Gil, Esquire

The Law O ffice of Frank E. Gil, P. A. 10689 Nor th Kendal l Drive, Suite 208

Miami, Florida 33176

(eServed)

Julie Jones, CP, FRP, A gency Clerk Division of Legal Services Department of Financia l Services 200 East Gaines Street Tallahasse e, Florida 32399 - 0390 ( e Served)

NOTICE O F RIGHT TO SUB MIT EXC EPTIONS

All part ies have the rig ht to s ubmit. wr itten ex ceptions within 15 days from the date of this Re commended Order. Any exc eptions to this R ecommende d Order s hould be filed wit h the age ncy that will iss ue the F inal Ord er in th is case.

Docket for Case No: 17-003188PL

Orders for Case No: 17-003188PL