DEPARTMENT OF FINANCIAL SERVICES oe OG Tom GALLAGHER CHIEF FINANCIAL OFFICER JUN 17 2005 IN THE MATTER OF: , Docketed by: iy— ONYX UNDERWRITERS, INC. —_ex . / CASE NO.: 65742-03-AG O02 ISSO ADMINISTRATIVE COMPLAINT JO: Onyx Underwriters, Inc. 224 South Island Drive Golden Beach, Florida 33160 Onyx Underwriters, Inc. 560 NW 165th Street Road Miami, Florida 33169 Onyx Underwriters, Inc. P.O. Box 693760 Miami, Florida 33169 ONYX UNDERWRITERS, INC., is hereby notified that the Chief Financial Officer, f/k/a the Insurance Commissioner, of the State of Florida has caused to be made an investigation of its activities while licensed as a managing general agent in this state, as a result of which it is alleged: GENERAL ALLEGATIONS 1. Pursuant to Chapter 626, Florida Statutes, ONYX UNDERWRITERS, INC., is currently licensed in this state as a managing general agent. Its license identification number is A196663. 2. At all times pertinent to the dates and occurrences referred to herein ONYX UNDERWRITERS, INC., was licensed in this state as a managing general agent. 3. Pursuant to Chapter 626, Florida Statutes, and the Florida Insurance Code, the Florida Department of Financial Services, f/k/a the F lorida Department of Insurance, has jurisdiction over ONYX UNDERWRITERS, INC., insurance licenses and appointments. 4. At all times relevant to the dates and occurrences referred to herein, ONYX UNDERWRITERS, INC., was a Florida Incorporated managing general agent, located at 560 NW 165th Street Road, Miami, Florida 33169. ONYX UNDERWRITERS, INC., lists the following officers: a. Paul Fraynd as Secretary and Director. b. Saul Fraynd as President and Director. c. Marcos Fraynd as Director and Chairman. d. Gladys Fraynd as Director. e. Fanny Fraynd (Singer) as Director and Treasurer. 5. At all times pertinent to the dates and occurrences referred to herein, those listed in parts a through e of paragraph 4 as officers of ONYX UNDERWRITERS, INC., were also listed as officers of The Aries Insurance Company, a Florida incorporated insurance company, located at 560 NW 165th Street Road, Miami, Florida 33169. 6. At all times pertinent to the dates and occurrences referred to herein, those listed in parts a through e of paragraph 4 as officers of ONYX UNDERWRITERS, INC., were also listed as officers of Fenix Financial Group, Inc., a Florida incorporated financial group, located at 560 NW 165th Street Road, Miami, Florida 33169. 7. At all times pertinent to the dates and occurrences referred to herein, those listed in parts a through e of paragraph 4 as officers of ONYX UNDERWRITERS, INC., were also listed as officers of Onyx Insurance Group, Inc., a Florida incorporated insurance group, located at 560 NW 165th Street Road, Miami, Florida 33169. 8. At all times pertinent to the dates and occurrences referred to herein, those listed in parts a, b, c, and e, of paragraph 4 as officers of ONYX UNDERWRITERS, INC., were also listed as officers of The Green Tree Insurance Group, Inc., a Florida incorporated insurance group, located at 560 NW 165th Street Road, Miami, Florida 33169. 9. At all times pertinent to the dates and occurrences referred to herein, those listed in parts a, b, d, and e of paragraph 4 as officers of ONYX UNDERWRITERS, INC., were also listed as officers of Gamma Adjusters, Inc., a Florida corporation located at 560 NW 165th Street Road, Miami, Florida 33169. 10. At all times pertinent to the dates and occurrences referred to herein, those listed in parts a and b of paragraph 4 as officers of ONYX UNDERWRITERS, INC., were also listed as officers of Continental Premium Finance Corp., a Florida corporation, located at 2600 SW 3rd Avenue, Suite 710, Miami, Florida 33129. 11. At all times pertinent to the dates and occurrences referred to herein, those listed in parts a and b of paragraph 4 as officers of ONYX UNDERWRITERS, INC., were also listed as officers of Insurance Collection Services, Inc., a Florida corporation, located at 560 NW 165th Street Road, Miami, Florida 33169. . 12. Atall times pertinent to the dates and occurrences referred to herein, those listed in parts a, b, and c of paragraph 4 as officers of ONYX UNDERWRITERS, INC., were also listed as officers of Omega Finance Corp., a Florida Corporation, located at 560 NW 165th Street Road, Miami, Florida 33169. 13. Atall times pertinent to the dates and occurrences referred to herein, those listed in parts a and b of paragraph 4 as officers of ONYX UNDERWRITERS, INC., were also listed as officers of Octagon Computer Solutions, Inc., a Florida corporation, located at 560 NW 165th Street Road, Miami, Florida 33169. 14. At all times pertinent to the dates and occurrences referred to herein, ONYX UNDERWRITERS, INC., was appointed solely by Aries Insurance Company. 15. On January 1, 1993, ONYX UNDERWRITERS, INC. (hereinafter ONYX), entered into a contract with Aries Insurance Company (hereinafter Aries) whereby ONYX agreed to act as managing general agent for Aries. In said contract ONYX acknowledged that its relationship with Aries was fiduciary in nature. 16. On November 14, 2002, the Circuit Court for the Second Judicial Circuit in and for Leon County, Florida, in the case of Department of Insurance v. Aries Insurance Company, case number 02-CA-1128, named the Department of Financial Services. f/k/a The Department of Insurance, receiver for Aries Insurance Company for the purposes of liquidation. COUNT I 17. All statements, claims, and allegations of Paragraph 1 through 16, inclusive, are incorporated herein by reference. 18. Section c of paragraph 5 of the contract between ONYX and Aries, states that ONYX “agrees that all premiums and other monies belonging to the Company (Aries) and at any time in Agent’s (ONYX) possession shall be kept separate from Agent’s other funds and agrees that all premiums received by Agent on business written hereunder belonging to Company are held by Agent as a fiduciary in trust for the Company and shall not be used for any other purpose whatsoever. Agent agrees to establish a premium trust account for the purpose of effecting the terms hereof.” 19. ONYX routinely deposited monies accepted on behalf of Aries into the “ONYX concentration account”. From this concentration account ONYX would then forward monies to several different accounts including, but not limited to, the Aries trust account, the ONYX operating account, the ONYX refunds under $1000 account, the ONYX refunds over $1000 account, and the: ONYX payroll account. The Aries trust account received funds taken on behalf of Aries after enough monies had been drawn out of the concentration account, and sent to the other ONYX accounts, with the intent to keep ONYX, and its affiliates, solvent and functioning. 20. | ONYX failed to keep monies collected on behalf of Aries in its fiduciary capacity separate from ONYX’s other funds, used funds taken in their fiduciary capacity for unintended purposes, and failed to remit all funds due under the terms of the contract to the insurer on a monthly basis. 21. As of February 2003, ONYX had misappropriated approximately $52,000,000.00 from Aries. IT IS THEREFORE CHARGED that ONYX UNDERWRITERS, INC., has violated or is accountable under one or more of the following provisions of the Florida Insurance Code and Rules of the Department of Insurance, n/k/a the Department of Financial Services, which constitute grounds for the suspension or revocation of its license and appointments as a managing general agent: (a) All premiums, return premiums, or other funds belonging to insurers or others received by an agent, customer representative, or adjuster in transactions under his or her license are trust funds received by the licensee in a fiduciary capacity. An agent shall keep the funds belonging to each insurer for which he or she is not appointed, other than a surplus lines insurer, in a separate account so as to allow the department to properly audit such funds. The licensee in the applicable regular course of business shall account for and pay the same to the insurer, insured, or other person entitle thereto. [Section 626.561(1), Florida Statutes]; (b) The managing general agent shall render accounts to the insurer detailing all transactions and remit all funds due under the terms of the contract to the insurer on a monthly or more, frequent basis. [Section 626.7451(2), Florida Statutes]: (c) All funds collected for the account of the insurer shall be held by the managing general agent in a fiduciary capacity in a bank which is a member of the Federal Reserve System. This account shall be used for all payment as directed by the insurer. The managing general agent may retain no more then 60 days of estimated claims payments and allocated loss adjustment expenses. [Section 626.745 1(3), Florida Statutes]; (d) The Department shall deny an application for, suspend, revoke, or refuse to renew or continue the license or appointment of any ... managing general agent ... and it shall suspend or revoke the eligibility to hold a license or appointment of any such person, if it finds that as to the applicant, licensee, or appointee any one or more of the following applicable grounds exists: [Section 626.611, Florida Statutes]; (e) If the license or appointment is willfully used, or to be used, to circumvent any of the requirements or prohibitions of this code. [Section 626.611(4). Florida Statutes]; () Demonstrated lack of fitness or trustworthiness to engage in the business of insurance. [Section 626.611(7), Florida Statutes]; (g) Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment. [Section 626.611(8), Florida Statutes]; (h) Fraudulent or dishonest practices in the conduct of business under the license or appointment. [Section 626.611(9), Florida Statutes]; (i) Misappropriation, conversion, or unlawful withholding of moneys belonging to insurers or insureds or beneficiaries or to others received in conduct of business under the license or appointment. [Section 626.611(10), Florida Statutes]; Gj) Willful failure to comply with, or willful violation of, any proper order or tule of the department or willful violation of any provision of this code. [Section 626.611(13), Florida Statues]; (k) The Department may, in its discretion, deny an application for, suspend, revoke, or refuse to renew or continue the license or appointment of any ... managing general agent... and it may suspend or revoke the eligibility to hold a license or appointment of any such person, if it finds that as to the applicant, licensee, or appointee any one or more of the following applicable grounds exist under circumstances for which such denial, suspension, revocation, or refusal is not mandatory under s. 626.611: [Section 626.621, Florida Statutes]; () Violation of any provision of this Code or any law applicable to the business of insurance in the course of dealing under the licensure or appointment. [Section 626.621(2), Florida Statutes]; (m) In the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices, as prohibited under part IX of this chapter, or having otherwise shown himself or herself to be a source of injury or loss to the public or detrimental to the public interest. [Section 626.621(6), Florida Statutes]. COUNT II 22. All statements, claims, and allegations of Paragraph 1 through 16, inclusive, are incorporated herein by reference. 23. On or about September of 2001, ONYX began an in house financing program. ONYX provided Premium Finance Replacement Forms to insurance agents who in turn submitted them back to ONYX with a percentage of new Aries policies. These drafts were not supported by any line of credit. Accordingly, ONYX did not forward full payment for Aries policies received because ONYX did not receive full payment for Aries policies written under this system. 24. By initiating this in house financing program ONYX continued to write Aries insurance polices with the knowledge that Aries would not receive full payment for such policies. IT IS THEREFORE CHARGED that ONYX UNDERWRITERS, INC., has violated or is accountable under one or more of the following provisions of the Florida Insurance Code and Rules of the Department of Insurance, n/k/a the Department of Financial Services, which constitute grounds for the suspension or revocation of its license and appointments as a managing general agent: (a) All premiums, return premiums, or other funds belonging to insurers or others received by an agent, customer representative, or adjuster in transactions under his or her license are trust funds received by the licensee in a fiduciary capacity. An agent shall keep the funds belonging to each insurer for which he or she is not appointed, other than a surplus lines insurer, in a separate account so as to allow the department to properly audit such funds. The licensee in the applicable regular course of business shall account for and pay the same to the insurer, insured, or other person entitle thereto. [Section 626.561(1), Florida Statutes}; (b) All funds collected for the account of the insurer shall be held by the managing general agent in a fiduciary capacity in a bank which is a member of the Federal Reserve System. This account shall be used for all payment as directed by the insurer. The managing general agent may retain no more then 60 days of estimated claims payments and allocated loss adjustrnent expenses. [Section 626.7451(3), Florida Statutes]; (c) The Department shall deny an application for, suspend, revoke, or refuse to renew or continue the license or appointment of any ... managing general agent ... and it shall suspend or revoke the eligibility to hold a license or appointment of any such person, if it finds that as to the applicant, licensee, or appointee any one or more of the following applicable grounds exists: [Section 626.611, Florida Statutes]; (d) If the license or appointment is willfully used, or to be used, to circumvent any of the requirements or prohibitions of this code. [Section 626.611(4), Florida Statutes); (e) Demonstrated lack of fitness or trustworthiness to engage in the business of insurance. [Section 626.611(7), Florida Statutes]; (f) Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment. [Section 626.611(8), Florida Statutes]; . (g) Fraudulent or dishonest practices in the conduct of business under the license or appointment. [Section 626.611(9), Florida Statutes]; (h) — Misappropriation, conversion, or unlawful! withholding of moneys belonging to insurers or insureds or beneficiaries or to others received in conduct of business under the license or appointment. [Section 626.611(10), Florida Statutes]; (i) Willful failure to comply with, or willful violation of, any proper order or tule of the department or willful violation of any provision of this code. [Section 626.611(13), Florida Statues]; Gq) The Department may, in its discretion, deny an application for, suspend, revoke, or refuse to renew or continue the license or appointment of any ... managing general agent... and it may suspend or revoke the eligibility to hold a license or appointment of any such person, if it finds that as to the applicant, licensee, or appointee any one or more of the following applicable grounds exist under circumstances for which such denial, suspension, revocation, or refusal is not mandatory under s. 626.611: [Section 626.621, Florida Statutes]; (k) Violation of any provision of this Code or any law applicable to the business of insurance in the course of dealing under the licensure or appointment. [Section 626.621(2), Florida Statutes]; c0)) In the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices, as prohibited under part xX [redesignated as part IX] of this chapter, or having otherwise shown himself or herself to be a source of injury or loss to the public. [Section 626.621(6), Florida Statutes]. . COUNT I 25. All statements, claims, and allegations of Paragraph | through 16, inclusive, are incorporated herein by reference. 26. | Onor about the mid nineteen nineties, ONYX was approximately one year behind in entering new endorsements into their system and 6-8 months behind in processing new business. 27. Some time midyear 2002, the Department discovered ONYX was behind in processing approximately 60,000 endorsements. 28. Sometime in 2002, the Department discovered ONYX had failed to process more then 100,000. additional endorsements dating back to 1998 and 1999. 29. | ONYX continued to accept new business and new endorsements but failed to process these new policies and endorsements either in a timely fashion, or at all. "IT IS THEREFORE CHARGED that ONYX UNDERWRITERS, INC., has violated or is accountable under one or more of the following provisions of the Florida Insurance Code and Rules of the Department of Insurance, n/k/a the Department of Financial Services, which constitute grounds for the suspension or revocation of its license and appointments as a managing general agent: (a) The Department shall deny an application for, suspend, revoke, or refuse to renew or continue the license or appointment of any ... managing general agent ... and it shall suspend or revoke the eligibility to hold a license or appointment of any such person, if it finds that as to the applicant, licensee, or appointee any one or more of the following applicable grounds exists: [Section 626.611, Florida Statutes]; (b) Demonstrated lack of fitness or trustworthiness to engage in the business of insurance. [Section 626.611(7), Florida Statutes]; (c) Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment. [Section 626.611(8), Florida Statutes]; (d) Fraudulent or dishonest practices in the conduct of business under the license or appointment. [Section 626.611(9), Florida Statutes]; (e) The Department may, in its discretion, deny an application for, suspend, revoke, or refuse to renew or continue the license or appointment of any ... managing general agent... and it may suspend or revoke the eligibility to hold a license or appointment of any such person, if it finds that as to the applicant, licensee, or appointee any one or more of the following applicable grounds exist under circumstances for which such denial, suspension, revocation, or refusal is not mandatory under s. 626.611: [Section 626.621, Florida Statutes]; (f) Violation of any provision of this Code or any law applicable to the business of insurance in the course of dealing under the licensure or appointment. [Section 626,621(2), Florida Statutes]. COUNT IV 30. All statements, claims, and allegations of Paragraph 1 through 16, inclusive, are incorporated herein by reference. 31, ONYX routinely issued untimely refunds, or failed to issue any refunds, for cancelled policies. 32, ONYX misappropriated at least $3,014,976.45 by failing to provide refunds to at least 5,978 policyholders. IT IS THEREFORE CHARGED that ONYX UNDERWRITERS, INC., has violated or is accountable under one or more of the following provisions of the Florida Insurance Code and Rules of the Department of Insurance, n/k/a the Department of Financial Services, which constitute grounds for the suspension or revocation of its license and appointments as a managing general agent: (a) All premiums, return premiums, or other funds belonging to insurers or others received by an agent, customer representative, or adjuster in transactions under his or her license are trust funds received by the licensee in a fiduciary capacity. An agent shall keep the funds belonging to each insurer for which he or she is not appointed, other than a surplus lines insurer, in a separate account so as to allow the department to properly audit such funds. The licensee in the applicable regular course of business shall account for and pay the same to the insurer, insured, or other person entitle thereto. [Section 626.561(1), Florida Statutes]; (b) All funds collected for the account of the insurer shall be held by the managing general agent in a fiduciary capacity in a bank which is a member of the Federal Reserve System. This account shall be used for all payment as directed by the insurer. The managing general agent may retain no more then 60 days of estimated claims payments and allocated loss adjustment expenses. [Section 626.745 1(3), Florida Statutes]; (c) The Department shall deny an application for, suspend, revoke, or refuse to renew or continue the license or appointment of any ... managing general agent ... and it shall! suspend or revoke the eligibility to hold a license or appointment of any such person, if it finds that as to the applicant, licensee, or appointee any one or more of the following applicable grounds exists: [Section 626.611, Florida Statutes]; (d) If the license or appointment is willfully used, or to be used, to circumvent any of the requirements or prohibitions of this code. [Section 626.611(4), Florida Statutes]; (e) Demonstrated lack of fitness or trustworthiness to engage in the business of insurance. [Section 626.611(7), Florida Statutes]; (69) Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment. [Section 626.611(8), Florida Statutes]; (g) Fraudulent or dishonest practices in the conduct of business under the license or appointment. [Section 626.611(9), Florida Statutes]; (h). Misappropriation, conversion, or unlawful withholding of moneys belonging to insurers or insureds or beneficiaries or to others received in conduct of business under the license or appointment. [Section 626.611(10), Florida Statutes]; (i) Willful failure to comply with, or willful violation of, any proper order or tule of the department or willful violation of any provision of this code. [Section 626.61 1(13), Florida Statues}; @) The Department may, in its discretion, deny an application for, suspend, revoke, or refuse to renew or continue the license or appointment of any ... managing general agent... and it may suspend or revoke the eligibility to hold a license or appointment of any such person, if it finds that as to the applicant, licensee, or appointee any one or more of the following applicable grounds exist under circumstances for which such denial, suspension, revocation, or refusal is not mandatory under s. 626.611: [Section 626.621, Florida Statutes]; (k) Violation of any provision of this Code or any law applicable to the business of insurance in the course of dealing under the licensure or appointment. [Section 626.621(2), Florida Statutes]; 14 e)) In the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices, as prohibited under part X [redesignated as part IX] of this chapter, or having otherwise shown himself or herself to be a source of injury or loss to the public. [Section 626.621(6), Florida Statutes]. WHEREFORE, ONYX UNDERWRITERS, INC., is hereby notified that the Chief Financial Officer, f/k/a the Treasurer and Insurance Commissioner, intends to enter an Order suspending or revoking its license and appointments as a managing general agent or to impose such penalties as.may provided under one or more of the following provisions of Sections 626.611, 626.621, 626.681, 626.691, 626.7451 and 626.901, Florida Statutes, under the other referenced sections of the Florida Statutes as set out in this Administrative Complaint, and under the provisions of Rule Chapter 4-231, Florida Administrative Code. ONYX UNDERWRITERS, INC., is further notified that any order entered in this case revoking or suspending any license or eligibility for licensure held by ONYX UNDERWRITERS, INC., shall also apply to all other licenses and eligibility held by ONYX UNDERWRITERS, INC., under the Florida Insurance Code. NOTICE OF RIGHTS You have the right to request a proceeding to contest this action by the Department pursuant to sections 120.569 and 120.57, Florida Statutes, and Rule 28-107, Florida Administrative Code. The proceeding request must be in writing, signed by you, and must be filed with the Department within twenty-one (21) days of your receipt of this notice. Completion of the attached Election of Proceeding form and/or a petition for administrative hearing will suffice as a written request. The request must be filed with the General Counsel as acting Agency Clerk, at the Florida Department of Financial Services, 612 Larson Building, 200 East Gaines Street, Tallahassee, Florida 32399-0333. The Department must receive your written response no later than 5:00 p.m. on the twenty-first day after your receipt of this notice. Mailing the response on the twenty-first day will not preserve your right to a hearing. YOUR FAILURE TO RESPOND IN WRITING WITHIN TWENTY-ONE (21) DAYS OF YOUR RECEIPT OF THIS NOTICE 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 you request a proceeding, you must provide information that complies with the requirements of Rule 28-107.004, Florida Administrative Code. As noted above, completion of the attached Election of Proceeding form conforms to these requirements. Specifically, your response must contain: (a) The name and address of the party making the request, for purpose of service; (b) A statement that the party is requesting a hearing involving disputed issues of material fact, or a hearing not involving disputed issues of material fact; and (c) A reference to the notice, order to show cause, administrative complaint, or other communication that the party has received from the agency. If'a hearing of any type is requested, you have the right to be represented by counsel or other qualified representative at your expense, to present evidence and argument, to call and cross-examine witnesses, and to compel the attendance of witnesses and the production of documents by subpoena. If a proceeding is requested and there is no dispute of material fact, the provisions of section 120.57(2), Florida Statutes, apply. In this regard, you may submit oral or written evidence in opposition to the action taken by the Department or a written statement challenging the grounds upon, which the Department has relied. While a hearing 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. However, if you dispute material facts, which are the basis for the Department's action, you must request an adversarial proceeding pursuant to sections 120.569 and 120,57(1), Florida Statutes. 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, Florida. Failure to follow the procedure outlined with regard to your response to this notice may result in the request being denied. All prior oral communication or correspondence in this matter shall be considered freeform agency action, and no such oral communication or correspondence shall operate as a valid request for an administrative proceeding. Any request for an administrative proceeding received prior to the date of this notice shall be deemed abandoned unless timely renewed in compliance with the guidelines as set out above. Di f mMancial Se 1C€s f/k/a th D ‘partm: the De artment o I Nanc V: > ie De ent o DATED this_/ 7 day of Coie | / f Insurance. CERTIFICATE OF § THEREBY CERTIFY ; , th RWRITERS, INC., by Pa a) . ata Copy of the forego’ restricted U.S. Certified N° a Matthew A pad 250) se44 7722 Sa32 Fla. Bar. Nc. SENDER: COMPLETE THIS SECTION ON DELIVERY 614-3 , 2003. KAREN CHANDLER Deputy Chief Financial Officer 7160 3901 9844 7722 S83 7160 3901 9844 ??22 5825 a - i FULD 3901 9844 7722 5818 ' 7Lb0 3902 9844 7722 SAL . ONYX UNDERWRITERS, INC. * 224 SOUTH ISLAND DRIVE GOLDEN BEACH, FL 33160 Nowels DN ON DELIVERY DELIVERY B. Date of Delivery Date of Delivery a ——— ll | | | | | oem, i x Pxkgent (J Agent LO 3901 9844 7722 5832 ioe Type CERTIFIED MAIL ted Delivery? (Extra Fee) | Yes [7 Addressee 7) Addressee a Agent = —] Adcressee fy address ditferent trom item 1? [ma Yes ni? C]yes = enter delivary address bélow: No : [J No = Yes No Addressed to: Underwriters, Inc. N.E. Miami Gardens Drive #144 . Miami Beach, Florida 33179 Refersnceiformaton 65742-03-AG/AC June 17, 2003 Nowels . —_— 1 3811, July 2001 Demestic Return Receipt

Docket for Case No: 03-002550