a ore webb. eek beeen ee . : a DEPARTMENT OF INSURANCE ~ INSURANCE CofssioneR . : Docketed by: TOM GALLAGHER IN THE MATTER OF: CRAIG JOSEPH GOODIE CASE NO.: 41323-01-AG ml fe i il A al Di A eS = FILED ae ole MAY 11 2001 THE TREASURER OF THE STATE OF FLORIDA TREASURER AND / Or-235le _ ADMINISTRA RATIVE COMPLAINT 0B eh) 1. TO: CRAIG JOSEPH GOODIE 1184 Whiteheart Court _Marco, Florida 33937-5061 CRAIG JOSEPH GOODIE Southwest Financial Planning Group 3504 Radio Road Naples, Florida 33942-3 3750 You, CRAIG 10s if E, ire hereby notified that , pursvant to Chapter 626, a ‘ angie wheres, eo investigation of your activities while licensed a as an insurance 2 agent in this State, as a result of which it is alleged: re an Florida Statutes, ‘the Insurance Commissioner of the S State of Florida has ‘caused to be made an ci mh ea nl a i ant a Ae El a , shares of stock in AYO. 517. 061, Florida Statu kat i ld, anh Ada AN AN ee cae 3. “At all times Pp ferred to herein, you, CRAIG © JOSEPH GOODE, were associated with and: acted as agent for one Michael Kehl, Chief Executive Officer of AIO, in the sale to Florida residents of. securities in ‘the form of common 4. The sharés of stock issued, offered for sale and sold by you, CRAIG JOSEPH GOODIE: as 8 agent for ‘AIO and Michael Kel are securities a as defined i in section 517.012, Florida Statutes’ “ 5. The shares of stock issued, offered for sale and sold by you, CRAIG JOSEPH GOODE, as agent for AIO and Michael Kekl, were nt reitred with the state of Florida. Departinat of f " Banking and Finance CDBF" ), as required pursuant to section 517. 07, Florida Statutes, and were not exempt from such registration requirements, either under the provisions of section 517.051 or Stet ces ote iss fetes = ds | payment from spproninatly sixty dole ersons, ‘inclu ing is individua y ideniied” Aue bth ened Aaa Lina cnet tenement Omni cad ale ttl alta onl ln, : 2. The above general allegations, are hereby realleged and filly incorporated by reference. " ° “to. ‘Inc or r around November, 1999 and May, 2000, u CRAIG J OSEPH GOODIE, conferred with Ja ames -s Cobb, a fornier in insurance client, to effect the sale e and purchase of stock i in AIO. ° - You, CRAIG JOSEPH GOODIE, accepted two payments from, James Cobb, one in the sum of $4, 000 payable to AIO and o one in the sum of $5, 000 for purchase of. such stock in AIO. Ati is s THEREFORE CHARGED t that you, CRAIG JOSEPH GOODIE, have Violated and Spetitte te Woe Bey ae, se Sande: ie! “ate accountable under the following provisions of the Florida Insurance Code and Rules of the Me Sg psa tty bon , Department of insurarice hich constitute gids for the suspension or revocation of your licenses and eligibility as an insurance agent: - “(a) Demonstrated lack of fitness or trustworthiness to engage in the business of ~ insurance. [Section 626.611(7), Florida Statutes}; . (b) Demonstrated lack of reasonably adequate knowledge and technical confidence to engage in the transactions authorized by the license or appointment. [Section 626.61 1(8), Florida Statutes]; owes SS Gaaaoieo eae I nO ‘abo October of 1999 and May, 2000 you, CRAIG JOSEPH GOODIE, ‘conferred cates a a a al te A acepid three payments from fimE Esch each in nthe s sum of $5, 000 for a total of $15,000 for purchase of such stock ins 0. “You b advised I James Eset 1 that he could expect to ) make two to three times the amount of his investment and that i it was no risk and safe. have violated and “Florda insurance Code and rules of the 7 licenses and city as an insurance agent: : “ial co Denmonsitated ‘ick ‘of Riness: or * frustworthiness to engage in the business of insurance. {Section 626.611(7), Florida Statutes]; (b) Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the licensing appointment. [Section 626.611(8), Florida Statutes}; ” ” (c) In the conduct of business under the license or permit, engaging in unfair © “methods of competition or in unfair or deceptive acts or practices as prohibited under Part X of this Chapter, or having otherwise shown himself to be a source of injury or loss to the public. ‘[Section 626. 8216, }, Florida Statutes.” licenses and eligibility as an insurance agent: (a) ‘Demonsirated lack of fitness or inistworthiness to engage’ jin the business of insurance. [Sesion 626. 61 10), “Florida Statutes) - OB) Demioistrated jack of reasonably siege knowledge and technic al confidence t to ; engage in the transactions authorized by the license or appointment. {Section 626. 61 18), Florida . Statutes} . (c) In the conduct of business under the license or permit engaging in n unfair methods . of competion 0 or in unfair or 3 deceptive a acts or r practices, as prohibited under Part x of this ; Chapter or having othervise shown himself to be a source of i injury or loss to the public. [Section -_ 626.621(6), Florida Statutes}. (b) | Demonsiraied th the lack of reasonably adequate knowledge and technical confidence - to’ engage in transaction authorized by’ the license or appointment. [Section 626.61 1(8), Florida Statutes); (c) “In the conduct of business under ‘the license or Permit, engaging in unfair methods 626 62106), Florida Statutes at lh et a a le ll mca 17. The above General Allegations ¢ are realleged and incorporated herein fully by reference. sve 18, On or r about Janay 2000 and June, 2000, you, CRAIG JOSEPH GOODE, confered. : with Ricky Tux and Susan Tutezynsk, forme insurance ce clients, for the purchase of stock in AIO You represented that you "chee ‘ed out” the company andy you accepted two payments —_ oe RMR kek am meee from them totaling $3, 500 for a Purchase of stock in AT . rors _astouabl u der the fo vif 3 ing provisions of the Fovida Taisurance Code and rules of the Department of of Insurance wi constitutes round for’ the suspension or revocation of your aa ak ee insurance. [Section 626.611(7), Florida Statutes} (b) Demonstrated lack of Fresonably adequate knowledge and technical confidence to ahaha Reel Spletih Sad tite Ret ai a ee ee ses the lice nse OF appointment. a 1s THEREFORE CHARGED that you, CRAIG JOSEPH GOODE, have violated are pareerver veay wore A a de ONG UO ET Cee nny TOUT NOE Ee MOTTO NeTTeN OW phe a atl Ak Pere wit wr Senetees (c) Inthe conduct of ‘business under the license or permit, engaging in unfair methods : oft competition or in unfair or deceptive acts or practices, as prohibited under Part X of this : Chapter, or having otherwise shown himsel to injury or loss to the public. [Section 626. e166, Florida Siauies)” WHEREFORE, you, CRAIG 108 PH GOODIE, are ehihy notified that the treasurer Insurance Commissioner and Treasurer rintends to enter an ‘Order revoking or suspending your , ligense(3) and eligibility for licensure a as an insurance agent or to impose such lesser penalties a as may be proper under the provisions of Sections 626, Florida Statutes, and under the other © : referenced sections of the Florida Statutes as set out in this Administrative Complaint, You are ; u - further notified that any y order entered i in this case revoking or suspending any license or eligibility for licensure held by you shall also apply to to all other lisenses and cligibility held by you under the - Foca Insuvance Code. or filing a Petition. Your Petition or Election of a proceeding must be in writing and must be filed phe arekc et her iia or ees ction shou ith the General Counsel acting as the Agency Clerk, Department of Insurance, If served by U! s. the Department. You may elect a pact ae by completing the attached Election of Rights form : atger | ene te, SM a I Sk ls ile at, ~ 120. 370) em nen nen, “ Siemens a TT WITHIN TWENTY- Y-ONE (21) DAYS WILL Ife a proceeding is requested and ther is no 0 pte of fact th the provisions of Section orida Statutes would i soply In this regard you may submit | oral. or r written evidence in opposition to the action taken by this agency or a written statement challenging the grounds a upon which the agency has relied While a hearing i is normally not required i in the absence of a ° dispute: of fact, if you feel that a bearing is necessary on one will be conducted i in 2 Talhassee, Florida Yee OF ry telephonic conference call upon your request, Ifyou dispute mat erial facts which are the basis for this eens action you may requests a Seibiee wgs tee Sys Beatie. estes ininistrative e Hearings, Unless Seay ares are located elsewhere the Department qualified representative, to take sino, to call and to cross-examine ¢ witnesses, and to have a subpoena and subpoena duces t tecum issued 0 on n your behalf. You are “hereby notified that mediation under ‘Section 120.573, Florida Statutes, is not available. oe. . Failure to > follow the procedure outlined with regard to your response to this notice may 22, abies a all La . result in ‘the request being denied. All prior correspondence in this matter shall be considered freeform. agency action, and no such comespondence shal operate asa valid request for an x oft t is notice shall be deemed abandoned unless inal renewed in compliance with the guidelines as $ set out it above. | “DATED and SIGNED this JI" dayor MAY _, 2001. Deputy Insurance Commissioner

Docket for Case No: 03-003237