Petitioner: DEPARTMENT OF AGRICULTURE AND CONSUMER SERVICES, DIVISION OF LICENSING
Respondent: PORT SERVICES INTERNATIONAL, INC., EDWARD EBMEIER, PRESIDENT
Judges: CLAUDE B. ARRINGTON
Agency: Department of Agriculture and Consumer Services
Locations: Fort Lauderdale, Florida
Filed: Apr. 30, 2003
Status: Closed
Settled and/or Dismissed prior to entry of RO/FO on Friday, September 5, 2003.
Latest Update: Nov. 14, 2024
STATE OF FLORIDA
DEPARTMENT OFAGRICULTURE AND CONSUMER SERVICES
DEPARTMENT OF AGRICULTURE AND CONSUMER
SERVICES, DIVISION OF LICENSING,
Petitioner,
CASE NO.: CD2003-0295
Vv. B 9600135 |.
OD ba
PORT SERVICES INTERNATIONAL, INC.,
EDWARD EBMEIER, PRESIDENT,
Respondent.
/
ADMINISTRATIVE COMPLAINT
COMES NOW the Department of Agriculture and Consumer Services, 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:
Port Services International, Inc.
Edward Ebmeier, President
10329 Buena Venture
Boca Raton, Florida 33498
Respondent holds a Class "B" Security Officer School, number B 9600135, effective
April 24, 1997, issued pursuant to Chapter 493, Florida Statutes. As set forth below, an
investigation of Respondent by Petitioner has revealed facts that justify action provided for in
Section 493.6118(2), Florida Statutes.
Count I
During the period March 8, 2003, to March 23, 2003, in Broward County, Florida,
Respondent committed fraud, deceit, negligence or misconduct in the course of activities
regulated by Chapter 493, Florida Statutes, in that Respondent employed fraudulently licensed
security officers to conduct activities regulated under Chapter 493, Florida Statutes. Respondent
is in violation of section 493.6118(1)(f), Florida Statutes
Count II
During the period March 8, 2003, to March 23, 2003, in Broward County, Florida
Respondent committed knowingly violated, advised, encouraged, or assisted in the violation of
state and federal statutes in the course of business regulated under this chapter in that Respondent
employed unlicensed and fraudulently licensed security officers. Respondent is in violation of
section 493.6118(1)(k), Florida Statutes.
Count HT
During the period March 8, 2003, to March 23, 2003, in Broward County, Florida,
Respondent employed unlicensed security officers to conduct activities regulated under Chapter
493, Florida Statutes. Respondent is in violation of Section 493.611 8(1)(n), Florida Statutes.
WHEREFORE, Petitioner intends to take disciplinary action pursuant to Section
493.6118(2), Florida Statutes, including, but not limited to a reprimand, probation, administrative
fines, suspension of licenses or revocation of licenses.
Dated this 25th day of March 2003.
John M. Russi, Director
Division of Licensing
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
to the Division of Licensing within 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 that 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 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.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing Administrative Complaint has been
electronically transmitted to the Division of Licensing, West Palm Beach Regional Office, this
2s" day of March 2003, for hand delivery to Edward Ebmeier, President, Port Services
International, Inc., Fort Lauderdale City Jail, 1301 West Broward Boulevard, Fort Lauderdale,
Florida.
K aah Ravel "Broneaw
Kristi Reid Bronson
Assistant General Counsel
Department of Agriculture and Consumer
Services, Division of Licensing
Post Office Box 6687
Tallahassee, Florida 32314-6687
(850) 488-3492
JR/
Docket for Case No: 03-001526
Issue Date |
Proceedings |
Sep. 05, 2003 |
Order Closing File. CASE CLOSED.
|
Aug. 15, 2003 |
Joint Status Report (filed by Respondent via facsimile).
|
Aug. 15, 2003 |
Motion for Extension of Time to File Status Report or in the Alternative to Amend the Administrative Com filed by Petitioner.
|
Aug. 13, 2003 |
Notice of Change of Address filed by M. Wargo.
|
Jun. 19, 2003 |
Order Granting Continuance and Placing Case in Abeyance (parties to advise status by August 15, 2003).
|
Jun. 13, 2003 |
Motion for Abeyance filed by Petitioner.
|
May 30, 2003 |
Notice of Intent to Use Similar Fact Evidence filed by Petitioner.
|
May 23, 2003 |
Petitioner`s First Request for Admissions filed.
|
May 23, 2003 |
Notice of Serving Discovery filed by Petitioner.
|
May 23, 2003 |
Notice of Appearance of Counsel (filed by S. Bensko).
|
May 13, 2003 |
Order of Pre-hearing Instructions issued.
|
May 13, 2003 |
Notice of Hearing issued (hearing set for July 8 and 9, 2003; 9:00 a.m.; Fort Lauderdale, FL).
|
May 07, 2003 |
Response to Initial Order (filed by Petitioner via facsimile).
|
Apr. 30, 2003 |
Amended Administrative Complaint filed.
|
Apr. 30, 2003 |
Administrative Complaint filed.
|
Apr. 30, 2003 |
Response to Administrative Complaint, Petition and Request for Formal Hearing, and Statement of Disputed Issues of Material Fact in Response to Allegations of Administrative Complaint filed.
|
Apr. 30, 2003 |
Election of Rights filed.
|
Apr. 30, 2003 |
Agency referral filed.
|
Apr. 30, 2003 |
Initial Order issued.
|