AB lll il ee ~ WV 16 1999 TREASURER 3~D THERE IDA INSURANCE Cf ER On ot Aline OF TRSUERCE Docketed by: BILL NELSON F . IN THE MATTER OF: “10-00 CASE NO.: 29978-99-AG BLAIRFOSTER) ——— ADMINISTRATIVE COMPLAINT TO: BLAIR FOSTER 2351 Wainut Court Pembroke Pine, Florida 33026-1502 BLAIR FOSTER 2200 Martin Luther King Blvd. Fort Myers, Florida 33901 You, BLAIR FOSTER, are hereby notified that the Insurance Commissioner of the State of Florida has caused to be made an investigation of your activities while licensed as an insurance agent in this state, as a result of which it is alleged: GENERAL ALLEGATIONS pter 648, Florida Statutes, you, BLAIR FOSTER, are uant to Chapter 648, Florida Statutes, the Florida Department of Insurance has jurisdiction over your insurance license and appointments. 4. You, BLAIR FOSTER, have been appointed by American Banker's Insurance Company to write limited surety bonds and/or bail bonds on its behalf. va ela ae oat COUNT | 5. The above general allegations are hereby realleged and fully incorporated * herein by reference. 6. . Atall times relevant to the allegations in this Administrative Complaint, you, BLAIR FOSTER, have been doing business as, or on n behalf of, a bail bonds agency known as SA All Out Bail Bonds, Inc., and/or A All Out Bail Bonds (hereinafter referred to as “A All Out Bail Bonds”), and located at 2200 Martin Luther King Blvd. Fort Myers, Lee County, Florida. 7. You, BLAIR FOSTER, ‘did place or ‘caused to be placed an advertisement in the May 1998 Sprint Lee County Area Yellow Pages for A All Out Bail Bonds that was false, deceptive, and misleading. (A copy of the advertisement is contained in the ~ attached Exhibit A). 8. You, BLAIR FOSTER, advertised, or caused to be advertised, the - statement: “Instant Release”, thereby implying that A A\l Out Bail Bonds can effectuate the instant release of incarcerated persons or effectuate an accelerated release from incarceration. This is a misleading, deceptive, or false advertisement because you and/or A All Out Bail Bonds cannot effectuate the instant or accelerated release of incarcerated persons. 9 The advertisement that you, BLAIR FOSTER, placed, or caused to be . Paced, in the May 1998 Sprint Lee County Area Yellow Pages for A All Out Bail Bonds . wasa ‘misleading, deceptive, or false advertisement. IT IS THEREFORE CHARGED that you, BLAIR FOSTER, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of ee Se er rn — ws . the Department of Insurance which constitute grounds for the suspension or revocation of your licenses and appointments: (a) Any misleading 0 or false advertisement or deceptive trade practice is prohibited as provided in part Xx of of chapter é 626. [Section 648. 44(6)(b), Florida Statutes}; (b) Demonstrated lack of fitness or trustworthiness to engage in the bail bond business. [Section 648.45(2) (e), Florida Statutes]: | (c) Fraudulent or dishonest practices in the conduct of business under the license or appointment. [Section 648.45(2) (g), Florida Statutes]; . (d) Willful failure to comply with, or willful violation of, any proper order or rule of the department o or willful Violation of any provision of this code. [Section 648.45(2)(j), Florida Statutes], (e) Violation of fany law relating to the business of bail bond insurance or violation of any | provision of the i insurance 2 code. “[Section 648. 45(3)60, Florida — Statutes}: A) Knowingly makin publishing, disseminating circulating, or placing before the publ, or causi tly c ire Ye me oublishe disseminated, oster, 3. Over any radio or television station, or 4. In any other way, an advertisement, announcement, or t with respect to the © business of i insurance, which is untrue, » deceptive, or “misleading. [Section 626. 9841(1)(b), ‘Florida Statutes se we u “(g) Knowingly: a. filing with any supervisory or other public official, b. making, publishing, disseminating, circulating, c. delivering to any person, d. Placing before the public, e. causing, directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the public, any false material statement. [Section 626.9541(1){e), Florida Statutes]. . COUNT II 10. The above general allegations are hereby realleged and fully incorporated herein by reference. 11. At all times relevant to the allegations in this Administrative Complaint, you, BLAIR FOSTER, have been doing business as, or on behalf of, a bail bonds agency known as Release Center, Inc., and/or the Release Center (hereinafter referred to as “Release Center’), located at 2200 Martin Luther King Bivd., Fort Myers, Lee County, Florida. 12. You, BLAIR FOSTER, did place or cauise to be placed an advertisement for the Release Center in the May 1999 Sprint Lee County Area Yellow Pages. (A copy of the advertisement is contained in the attached Exhibit A). 13. The advertisement contained the following statements: “Before you call a bondsman... ” , “See if you qualify for free release program”, “Lee County's On Premises Release Center’, “Release Negotiators available 24 Hours”, “Domestic Violence Specialists’, and “First Time Offenders Program’. 14. You, BLAIR FOSTER, advertised, or caused to be advertised, the statement: “Before you call a s bondsman. " thereby implying that the Release Center is not a bondsman or bail bond agent. This is a misleading, deceptive, or false 4 > w . rw) advertisement because you aré actively engaged in the business of a bail bond agent or bondsman at the Release Centers and because the telephone number provided in the advertisement is to a bail bond agent’s place of business. 15. You, BLAIR FOSTER, advertised, or caused to be advertised, that the Release Center was a “Domestic Violence Specialist,” thereby implying that such a specialty exists pertaining to bail bonds. This is a misleading, deceptive, or false advertisement because there is no domestic violence specialty as pertains to bail bonds. | 16. You, BLAIR FOSTER, advertised, or caused to be advertised, that the Release Center offered a “First Time Offenders Program,” thereby implying that such a program or exists pertaining to bail bonds. This was a misleading, deceptive, or false advertisement because there is no first time offenders program as pertains to bail bonds. 17. You, BLAIR FOSTER, advertised, or caused to be advertised, that the ‘Release Center offered a “Free Release Program,” thereby implying that such a program exists pertaining to bail bonds. This i isa misleading, deceptive, or false advertisement because there i is no free release program as pertains to bail bonds. See eiehgacee 18. 7 You, BLAIR ‘FOSTER, advertised, or caused to be advertised for the Release Center the statement “Release Negotiators available 24 Hours”, thereby implying that you could Negotiate releases from criminal detentions or incarcerations. This was a misleading, deceptive, or r false advertisement because as a limited surety agent or bail bond agent you do not have the authority to negotiate releases from criminal detentions or incarcerations. A a ee Department. we s) 19. You, BLAIR FOSTER, advertised, or caused to be advertised, that the Release Center was “Lee County's On Premises Release Center”, thereby implying that -. the business is on the same property as the Lee County Jail and thus affiliated with said ~ public facility. This is a misleading, deceptive, or false advertisement because the Release Center is not t located on any | Lee County location or premise, nor is it affiliated with Lee County. 20. _ The advertisement that you, BLAIR: FOSTER, placed, or caused to be placed, for the Release Center in the May 1998 8 Sprint Lee County Area Yellow Pages . isa misleading or false advertisement. 21. The ‘adveriisémient that you, BLAIR FOSTER, ‘placed, or caused to be placed, for the Release Center in the May 1998 Sprint Lee County Area Yellow Pages constitutes a deceptive trade Practice because it contains faise, deceptive, and misleading statements. a 22. The advertisement that you, BLAIR FOSTER, placed, or caused to be placed, for the Release Center in the May 1998 Sprint Lee County Area Yellow Pages failed to include a bal bond agent's sor agency’ s address of record filed with the “AT IS THEREFORE CHARGED that you, BLAIR FOSTER, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Insurance which constitute grounds for the suspension or revocation of your licenses and appointments: Ww U (a) Any misleading or false advertisement or deceptive trade practice is prohibited as provided in part X of chapter 626. [Section 648.44(6)(b), Florida Statutes]; (b) Any permissible advertising by a bail bond agent or agency must include the address of record filed with the department. {Section 648. 44(7), Florida Statutes]; (c) Demonstrated lack kof fi iness or ‘rustworthiness to engage in the bail bond business. [Section 648.45(2) (e), Florida Statutes]; (d) Fraudulent or dishonest practices in the conduct of business under the license or appointment. [Section 648.45(2) (g), Florida Statutes]; (e) Willful failure to comply with, or willful violation of, any proper order or rule of the department or willful violation of any provision of this code. [Section 648.45(2)(j), Florida Statutes]; (f) Violation of any law relating to the business of bail bond i insurance or violation _of any provision of the insurance code. [Section 648.45(3)(c), Florida Statutes]; (g) Knowingly making, publishing, disseminating, circulating, or placing before the public, or causing, directly or indirectly, to be made, published, disseminated, circulated, or placed before the public: 1. In a newspaper, magazine, or other publication, 2. In the form ofa notice, circular, pamphlet, letter, or poster, 3. Over any radio or tele jon sation’ or 4. In 1 any other way, an advertisement, ‘announcement, or ; statement Containing any assertion, representation or statement with respect to the business of inst ' nee, \ wich is untrue, deceptive, or r misleading. [Section 626.9544 (1)(b), Florida Statutes]: se ae ln a ills Siena oe ee Wd VU (h) Knowingly: a. filing with any supervisory or other public official, b. making, publishing, disseminating, circulating, c. delivering to any person, d. Placing before the _ public, e. causing, directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the publi any false material statement. [Section 626. 9541 (Ve), Florida Statutes), COUNT Ill | 23. | The ting are ‘hereby vealloged and fully incorporated herein by reference. 24. Ataill times relevant to the allegations i in this Administrative Complaint, you, BLAIR FOSTER, have been doing business as, or on behalf of, a bail bond agency known as Latinos Bail Bonds Corporation and/or Latinos Bail Bonds (hereinafter referred to as “Latinos Bail Bonds"), and located at 2200 Martin | Luther King Blvd. Fort Myers, Lee County, Florida 25. You, BLAIR FOSTER, id i place, c or cause to placed, an advertisement for Latinos Bail Bonds in the May 1998 Sprint Lee County Area Yellow Pages. (A copy of the advertisement is contained in the attached Exhibit A). . . 7 26. The advertisement contained the following statement in Spanish: “Salida : Instantanea’, ‘which translated into English means “Instant Release’. 27. . ‘You, BLAIR FOSTER, advertised, or caused to be advertised, a statement implying that the Latinos Bail Bonds can effectuate the instant release of incarcerated persons or effectuate an acosiersted release from incarceration. This is a misleading, deceptive, or false advertisement because you and/or the Latinos Bail Bonds cannot effectuate the instant or accelerated release of incarcerated persons. 28. The advertisement that you, BLAIR FOSTER, placed, or caused to be placed, for Latinos Bail Bonds in the May 1998 Sprint Lee County Area Yellow Pages that was a misleading, deceptive, or false advertisement. 29. The advertisement that you, BLAIR FOSTER, placed, or caused to be placed, for Latinos Bail Bonds in the May 1998 Sprint Lee County Area Yellow Pages that constitute a deceptive trade practice because it contained a false, deceptive, and misleading statement. 30. The advertisement that you, BLAIR FOSTER, placed, or caused to be placed, for Latinos Bail Bonds in the May 1998 Sprint Lee County Area Yellow Pages failed to include a bail bond agent's or agency’s address of record filed with the Department. IT 1S THEREFORE CHARGED that you, BLAIR FOSTER, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Insurance which constitute grounds for the suspension or revocation of your licenses and appointments: a (a) Any misleading or false advertisement or deceptive trade practice is _ prohibited as | 6)(b), Florida Statutes} (b) . Demonstrated lack of fitness or trustworthiness to engage in the bail bond _ business. [Section 648.45(2) (e), Florida Statutes]; (c) ‘Any permissible advertising by a bail bond agent or agency must include the address of record filed with the department. [Section 648.44(7), Florida Statutes]; tema Bele MBS MR 8 9 ae Maw fle Ka finan ae. ee nthe oe eh Alle nn Mein mn nes sain a Mee ti Be AB secnnsenra ier : pubsing, ed WV (d) Fraudulent or dishonest practices in the conduct of business under the license or appointment. [Section 648.45(2) (g), Florida Statutes]; (e) Willful failure to comply with, or willful violation of, any Proper order or rule of the department or willful violation of any provision of this code. [Section 648. 45(2)(j), Florida Statutes]; My Violation of any law ‘felating to the business of bail bond insurance or violation of any provision of the i insurance code. [Section 648. 45(9)0), Florida Statutes]: Q) Knowingly making, publishing, disseminating, circulating, or placing before - the public, or causing, directly or indirectly, to be made, published, disseminated, circulated, or placed before the public: 1.Ina newspaper, magazine, or other publication, 2. In the form of a notice, circular, pamphlet, letter, or poster, 3. Over any 7 radio or television station, or 4. In any other way, an advertisement, announcement, or statement containing any assertion, representation, or statement with respect to the business of insurance, which is untrue, deceptive, or misleading. [Section 626.9541(1)(b), Florida Statutes}; (h) Knowi filing with any supervisory or other public official, b. making, Pacing before the 34. . are hereby realleged and fully incorporated herein by reference. 10 an a oe le dle Wd WV 32. Atall times relevant to the allegations in this Administrative Complaint, you, BLAIR FOSTER, have been doing business as, or on behalf of, a bail bond agency known as A All Out Bail Bonds, Inc., and/or A All Out Bail Bonds (hereinafter referred to as “A All Out Bail Bonds”), and located at 2200 Martin Luther King Blvd. Fort Myers, Lee County, Florida. 33. You, BLAIR FOSTER, did place or caused to be placed an advertisement at a pay telephone located at the corner of Dr. Martin Luther King Boulevard and Cottage Street, which i is across the street from the Lee County Jail that was false ; deceptive and misieading, A copy of the advertisement i is contained i in ‘the attached Exhibit B). 34. The advertisement contained the following statement: “Instant Release”. 35. You, BLAIR FOSTER, advertised, or caused to be advertised, the statement: “Instant Release”, thereby implying that A All Out Bail Bonds can effectuate the instant release of incarcerated persons or effectuate an accelerated release from _ incarceration. This is a misleading, deceptive, or false advertisement because you and/or the Release Center cannot effectuate the instant or accelerated release of incarcerated persons. en 36. The advertisement that you, BLAIR FOSTER, placed or caused to be placed for A All Out Bail Bonds, on the pay telephone located at the corner of Dr. Martin Luther | g Boulevard and Cottage Street was a misleading, deceptive, or false FOSTER, placed, or caused to be -placed for A All Out Bail Bonds, on the pay telephone located at the corner of Dr. Martin 11 Sa nn eae ."e Ww Luther King Boulevard and Cottage Street constituted a deceptive trade practice because it contained false, deceptive, and misleading statements. IT IS THEREFORE CHARGED that you, BLAIR FOSTER, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Insurance which constitute grounds f for the Suspension or revocation of your licenses and appointments: (a) Any misleading or false advertisement or deceptive trade practice is prohibited as provided in part X of chapter 626. [Section 648.44(6)(b), Florida Statutes]; (d) Demonstrated lack of fitness or trustworthiness to engage in the bail bond business. [Section 648.45(2) (e), Florida Statutes}, (c) Fraudulent or dishonest practices in the conduct of business under the license. or appointment. [Section 648. 45(2) @, ‘Florida Statutes} . (d) Wilful failure to comply with, or wil violation of, any proper order or tule of the department or willful violation of any provision of this code. [Section 648.45(2)(), Florida Statutes]; . | (e) Violation of any law relating to the business of bail bond insurance or violation of any Provision of the insurance code. [Section 648.45(3)(c), Florida Statutes) . . Knowingly making, Publishing, disseminating, circulating, or placing before ‘the f public, or causing, directly or or indirectly, to be made, Published, disseminated, circulated, or placed before the publi 1. In a newspaper, magazine, or other “publication, 2. ‘Inthe form ofa notice, circular, pamphlet, letter, or poster, 3. Over any 12 i ‘7 Ww radio or television station, or 4. In any other way, an advertisement, announcement, or statement containing any assertion, representation, or statement with respect to the business of insurance, which is untrue, deceptive, or misleading. [Section 626.9541(1)(b), Florida Statutes]; (g) Knowingly: a. filing with any supervisory or other public Official, b. making, publishing, disseminating, circulating, c. delivering to any person, d. Placing before the public, e. causing, directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the public, any false material statement. [Section 626.9541(1)(e), Florida Statutes]. | _GOUNT Vv 38. The: above general allegations ar are © hereby realleged a and fully incorporated herein by reference. 39, At all times relevant to the allegations in this Administrative Complaint, you, BLAIR FOSTER, have been doing business as, or on behalf of, a bail bond agency known as Latinos Bail Bonds Corporation and/or Latinos Bail Bonds (hereinafter referred to as “Latinos Bail Bonds’), and located at 2200 Martin Luther King Bivd. Fort Myers, Lee County, Florida. | | wore Ene 40. fou, u, BLAIR FOSTER, did place, ¢ or cause to placed, z an advertisement for Latinos Bail Bonds ona pay telephone located at corner of Dr. Martin Luther King Boulevard and Cottage Street, which i is across 5 the street from the Lee County Jail. (A copy of the advertisement is contained in the attached Exhibit B). 41. The advertisement contained the following statement in Spanish: “Salida Instantanea’”, which translated into English means “Instant Release”. 13 eee i et ll ll Rn i MB hha a oe record filed with the Department. Ww we] 42. You, BLAIR FOSTER, advertised, or caused to be advertised, a statement implying that the Latinos Bail Bonds can effectuate the instant release of incarcerated persons or effectuate an accelerated release from incarceration. This is a misleading, deceptive, or false advertisement because you and/or the Latinos Bail Bonds cannot effectuate the instant or accelerated release of incarcerated persons. 43. The advertisement that you, BLAIR FOSTER, placed, or caused to be placed, for Latinos Bail Bonds on a pay telephone located at the corner of Dr. Martin Luther King Boulevard and Cottage Street that was a misleading, deceptive, or false advertisement. 44. The advertisement that you, BLAIR FOSTER, placed, or caused to be placed, for Latinos Bail Bonds on a pay telephone advertisement located at the corner : of Dr. Martin Luther King Boulevard and Cottage Street constitutes a deceptive trade practice because it contained false, deceptive, and misleading statement. 45. The advertisement that you, BLAIR FOSTER, placed, or caused to be placed, for Latinos Bail Bonds « ona 1 pay telephone advertisement located at the corner of Dr. Martin Luther King Boulevard and Cottage Street failed to include the address of hat you, BLAIR FOSTER, have violated or are 9 Provisions of the Fl ida Insurance Code and Rules of the Department of Insurance which constitute grounds for the suspension or r revocation : of your licenses and ‘Appointment’: 14 _ the pub (a) Any misleading or false advertisement or deceptive trade practice is prohibited as provided in part X of chapter 626. [Section 648.44(6)(b), Florida Statutes]; (b) Any permissible advertising by a bail bond agent or agency must include the address of record filed with the department. [Section 648.44(7), Florida Statutes]; (c) Demonstrated lack of fitness or trustworthiness to engage in the bail bond business. [Section 648.45(2) (e), Florida Statutes]; (d) Fraudulent or dishonest practices in the conduct of business under the license or appointment. [Section 648.45(2) (g), Florida Statutes]; (e) Willful failure to comply with, or willful violation of, any proper order or rule of the department or willful violation of any provision of this code. [Section 648.45(2)(j), Florida Statutes]; (f) Violation of any law relating to the business of bail bond insurance or violation of any provision of the insurance code. [Section 648.45(3)(c), Florida Statutes}; (g) Knowingly making, publishing, disseminating, circulating, or placing before rc directly or indirectly, to be made, published, disseminated, circulated, or placed before the public: 1. In a newspaper, magazine, or other publication, 2. In the form o ofa notice, circul pamphiet, Ie letter, or poster, 3. Over rany ~ 626.9541(1)(b), Florida Statutes): 15 Eth A ai ibe a aes coin bese ae wi oe Mena we lila fale Rta sinned A 2 wk eos wee a el li tll lA ak Florida Administ tiv e e Code F. A. C. de you uha Ww WwW (h) Knowingly: a. filing with any supervisory or other public official, b. making, publishing, disseminating, circulating, c. delivering to any person, d. Placing before the — public, e. causing, directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the public, any false material statement. [Section 626. 95440"), Florida Statutes} WHEREFORE, you, BLAIR FOSTER, are hereby notified that the Treasurer and Insurance Commissioner intends to enter an Order suspending or revoking your licenses and appointments as an insurance agent or to impose such penalties as may be provided under the provisions of Sections 648.44, 648.45, 648.49, 648.52, and 648.53, Florida Statutes, and under the other referenced sections of the Florida Statutes as set out in this Administrative Complaint. | NOTICE. OF RIGHTS Pursuant to Sections 120. 569 and 120. 87, Florida Statutes and Rule 28-1 06, a aright to request a proceeding to ; contest this action by the Department. Your may elect a proceeding by completing the attached Elect n of Rights form 0 or fi in a Pe on. “Your Petition or E Election ofa . proceeding must be writing and | must be filed with the General Counsel acting as ‘the Agency Clerk, Department of Insurance. If served by U.S. Mail the Petition o or Election Petition or Election should be delivered to 612 Larson Building, 200 East Gaines Street, Tallahassee, Florida 32399-0300. The Petition or Election must be received by, and ag ww Wd filed in the Department within twenty-one (21) days of the date of your receipt of this notice. YOUR FAILURE TO RESPOND TO THIS ; ADMINISTRATIVE COMPLAINT WITHIN TWENTY-ONE (21) DAYS WILL CONSTITUTE A WAIVER OF YOUR ‘RIGHT TO REQUEST A PROCEEDING ON THE MATTERS ALLEGED HEREIN AND AN ORDER OF REVOCATION WILL BE ENTERED AGAINST YOU. If a proceeding is requested and there is no dispute of fact the provisions of Section 120.57(2), Florida Statutes would apply. In this regard you may submit oral or written evidence in opposition to the action taken by this agency or a written statement challenging the grounds upon which the agency y has relied. While a hearing i is normally not required in the absence of a dispute of fact, if you feel that a hearing is necessary one will be conducted in Tallahassee, Florida or by telephonic conference call upon your request. | If you dispute material facts which are the basis for this agency's action you may request a formal adversarial proceeding pursuant to Sections 120.569 and 120.57(1), Florida Statutes. if you request this type of proceeding, the request must comply with all of f the requirements of Rule 28- 106, F. A. Cc. and contain a) A statement identifying with particularity t the allegations of the . oS ment which you ‘dispute and the nature of the dispute: b) An explanation of what relief you are seeking and believe you are ~ ‘entitled to; - c) ' Any other information which you contend is material. 417 These proceedings are held before a State administrative law judge of the Division of _ Administrative Hearings. Unless the majority of witnesses are located elsewhere the - Department will request that the hearing be conducted in Tallahassee. If a hearing is requested, you have the right to be represented by counsel, or other qualified representative, to take testimony, to call and to cross-examine witnesses, and to have subpoena and subpoena duces tecum issued on your behalf. Pursuant to Section 120.573, Florida Statutes, you are hereby notified that mediation is not available. Failure to follow the procedure outlined with regard to your response to this notice may result i in the request being denied. All prior correspondence | in this matter shall be considered freeform agency action, and no such correspondence shall operate as a valid request f¢ for an n administrative proceeding, Any request for administrative proceeding received prior to the date of this notice shall be deemed abandoned unless timely renewed i in compliance with the guidelines « as set out above. NELSON Treasurer and Insurance Commissioner 18 ew vy "CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing ADMINISTRATIVE COMPLAINT and ELECTION OF RIGHTS has been furnished to: BLAIR FOSTER, : 2351 Walnut Court, Pembroke Pine, Florida 33026-1502; and BLAIR FOSTER, 2200 Martin Luther King Bivd., Fort Myers, Florida 33901by Certified Mail this MOF say of 1999. MIGUEL OXAMENDI Senior Attorney Division of Legal Services 612 Larson Building Tallahassee, Florida 32399-033 (850) 413-4130 19 hs ‘td iw STATE OF FLORIDA DEPARTMENT OF INSURANCE IN THE MATTER OF: BLAIR FOSTER. Case No: 29978-99-AG ELECTION OF RIGHTS | have received and have read the Administrative Complaint filed against me including the Notice of Rights contained therein and | understand my options. | am requesting disposition of this matter as indicated be below. / (Choose one) 1. [] | do not desire a proceeding. The Department may enter a final order revoking my license(s). 2. | do not dispute any of the Department's factual allegations and | hereby elect an informal proceeding to be conducted in accordance with section 120.57(2), Florida _. Statutes. In this regard | desire to (Choose one): Submit a written statementand documentary evidence: {] attend an informal hearing to be held in Tallahassee; or [] attend an informal hearing by way of a telephone conference call. 3. [ ] 1 do dispute the Department's factual allegations. | have attached to this form a statement - indicating the specific issues of fact which are disputed and other required information indicated in the Notice of Rights. | hereby request a formal adversarial proceeding pursuant to Sections 120.569 and 120.57(1), Florida Statutes to be held ~* before the Division of Administrative Hearings. DATE: ood Signature of Petitioner “To PRESERVE YOUR RIGHT To A Name: PROCEEDING, You MUST RETURN | | Address: — “DEPARTMENT OF INSURANCE AT THE ADDRESS INDICATED IN © THE NOTICE OF RIGHTS. Phone: 20 337-7717 PAN 2200 MLK Blvd, Ft. Myers ¢ ONE BLOCK FROM THE JAIL efore, you call a bondsman... See if you oualify For Release PROGRAM Lee County’s RELEASE On Premise CENTER Release Center Release TTT ene 24 hours DOMESTIC VIOLENCE SPECIALISTS First Time Offenders Program Bail Bonds 3237-76 Servicios rapides confiables:y hones # Silviendo a la comunidad h en Naples y en.Fort My Abierto. las 24 he 337- Tt 208 cise tO GOUT ND a6 eee hy 8 OG aK rd ] VA . sore ° { ‘ | meanmee * peal CALL US FIST! ‘ome mary sas OPEN 24 HOURS ; eet Po ose so 1. She cateterst. ° a 7-7600 ae o@ BEEBE nlteee heeled Abierve ia 1A bores SALILIA avrerets « to comnanetent hingpeme. Re. grec. IM STAMTANEA on Magine y on fart Mhyare - qiat *S fer o PRSR CALL ewe we — ptLIGATOR a RECOvERny

Docket for Case No: 00-000704