fm, oc PLED STATE OF FLORIDA 9 yr: DEPARTMENT OF STATE 22 PH io: 4g DIVES aa ADMINISTRA ye DEPARTMENT OF STATE, HEARINGS | * DIVISION OF LICENSING, Petitioner, oon 4 v. CASE NO.: C20-00269 BB97-00035 DOTHAN SECURITY, INC., CD2000-0787 ALAN B. CLARK, PRESIDENT, Respondent. ADMINISTRATIVE COMPLAINT COMES NOW the Department of State, Division of Licensing, pursuant to Section 493.6121, Florida Statutes, and states that it is the licensing authority as defined therein, that it has statutory jurisdiction over the Respondent, and alleges: The name and last known address of the Respondent is: Dothan Security, Inc. Alan B. Clark, President 1109 West Tharpe Street, Suite C Tallahassee,-Florida 32303 Respondent holds a Class "BB" Security Agency Branch Office License, number BB97-00035, effective September 23, 1999. Also, Respondent holds a Class "A" Private Investigative Agency License, number A86-00102, effective February 23, 2000, a Class "B" Security Agency License, number B00-01502, effective August 3, 1999, a Class “DS” Security Officer School/Or Training Facility, effective March 23, 1999 anda Class "C" Private Investigator License, number C88-00706, effective October 9, 1998, issued to Dothan Security, Inc., Alan B. Clark, President. All licenses were issued pursuant to Chapter 493, Florida Statutes. As set forth below, an investigation of Respondent by Petitioner has revealed facts which justify action provided for in Section 493.61 18(2), Florida Statutes. Count | During the period August 4, 1999 to March 7, 2000, in Leon County, Florida, Respondent committed fraud, deceit, negligence or misconduct in the practice of regulated activities under Chapter 493, Florida Statutes, in that Respondent billed Greyhound Lines, Inc., the client, at an armed rate when unarmed security were provided. Respondent is in violation of Section 493.6118(1)(f), Florida Statutes. WHEREFORE, Petitioner intends to take disciplinary action pursuant to Section 493.61 18(2), Florida Statutes, including, but not limited to a reprimand, probation, administrative fines, suspension of licenses or revocation of licenses. NOTICE OF RIGHTS In accordance with Sections 120.569 and 120.57, Florida Statutes, you the Respondent may request a formal hearing or informal hearing, or may enter into a stipulation and settlement. In order to request a hearing, you must complete the enclosed Election of Rights form and file it with the Division of Licensing within twenty-one (21) days of receipt of this complaint. If you request a formal hearing, you must also send a statement of the material facts alleged in this complaint which you dispute. To enter into a stipulation and settlement, sign and return the attached Stipulation and Settlement which is an agreement to accept the suggested penalty without proceeding to a hearing. Failure to file the Election of Rights form with the Division of Licensing within twenty-one (21) days of receipt of this administrative complaint shall be considered a waiver of your right to a hearing and shall result in the issuance of a final order without the benefit of a hearing. The final order will notify you of the right to appeal the final order pursuant to Section 120.68, Florida Statutes. Dated this 19" day of July, 2000. John M. Russi, Director Division of Licensing CERTIFICATE OF SERVICE | HEREBY CERTIFY that a copy of the foregoing has been furnished by certified mail to Dothan Security, Inc., Alan B. Clark, President, 1109 West Tharpe Street, Suite C, Tallahassee, Florida 32303 and Dothan Security, Inc., Alan B. Clark, President, 441 Van Pelt Lane, Pensacola, Florida 32505, this 19" day of July, 2000. 2 lane UU, H. Wayne Mitchell Assistant General Counsel Department of State Division of Licensing The Capitol, M.S. #4 Tallahassee, Florida 32399-0250 Ikj - AKERMAN SENTERFITT ATTORNEYS aT Law 301 SouTH Bronoucn Street, Surrs 200 Post Orrice Box (0555 “TALLAHASSEE, FLORIDA 32302-2555 PHONE (850) 222-3471 © Fax (850) 222-9628 http://www.akerman.com Phyllis Dunaway E-mail: pdunaway@akerman.com August 2, 2000 VIA HAND DELIVERY Cynthia Borden, Agency Clerk Department of State/Division of Licensing 2520 N. Monroe Street Tallahassee, FL 32303 Re: Petitions for Formal Proceeding, Case No: C20-00269£8B97-00035; CD2000- 0787 and Case No: C20-00269, MB93-00125, CD2000-0788 i si ; Dear Ms. Borden: Please find enclosed two Amended Petitions for Formal Proceeding to be filed in the above- referenced cases. . : If you have any questions or concerns with the following requests, please do not hesitate to call. Ext. 8204 . : Sincerely, IRMAN, SENTERFITT & EIDSON, P. hylli way, for Bruce Culpepper Enclosure(s) ‘TLOLO956;!

Docket for Case No: 00-004744