Aug 23 2005 10:41 Be/23/2885 16:39 8584874987 LEGAL SERVICES PAGE &2 FLORIDA DEPARTMENT OF FINANCIAL SERVICES TOM GALLAGHER CHIEF FINANCIAL OFFICER FILE D STATE OF FLORIDA. MAR 16 2005 IN THE MATTER OF: Dooketed by’ al CASE NO.: 80120-05-AG JOHN GIAQUINTO / 4 ADMINISTRATIVE COMPLAINT TO: JOHN GIAQUINTO 2022 SE 6th Lane Cape Coral , Florida 33990 JOHN GIAQUINTO P.O, Box 150814 Cape Coral , Florida 33915 You, JOHN GIAQUINTO, license LD. #2009788, are hereby notified that the Chief Financial Officer 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 1. Pursuant to Chapter 626, Florida Statutes, you, JOHN GIAQUINTO, are currently licensed in this state as a General Lines (Property & Casualty) (2-20) Agent. 2. At all times pertinent to the dates and occurrences referred to herein, you, JOHN GIAQUINTO, were licensed as an insurance agent in this state. 3. At all times pertinent to the dates and occurrences referred to herein, you, JOHN GIAQUINTO, were the sole Officer and Director of J.G, Enterprises of America, Inc., a Florida Aug 23 2005 10:41 @e/2d/26685 laisg 8584874987 LEGAL SERVICES PAGE Corporation, doing business in this state as an insurance agency also under the name of Great ~ Florida Insurance of Sanford. 4, At all times pertinent to the dates and occurrences referred to herein, you, JOHN GIJAQUINTO, were the sole owner of Great Florida Insurance of Sanford. | 5. At all times pertinent to the dates and occurrences referred to herein, you, JOHN GIAQUINTO, were the sole signatory on the Great Florida Insurance of Sanford Agency’s operating bank account. 6. At all times to pertinent to the dates and occurrences herein all funds received by you, JOHN GIAQUINTO, pursuant to Section 626.561, Florida Statutes, from consumers or on behalf of consumers were trust funds received in a fiduciary capacity and were to be paid over to persons entitled thereto in the regular course of business. COUNT I 7. The above general allegations are hereby realleged and fully incorporated herein by reference. 8. On April 28, 2003, N.S. of Sanford, Florida went to Great Florida Insurance of Sanford to purchase motor vehicle insurance. On that day, N.S. signed an application for automobile insurance coverage to be placed with Insurquest Insurance Company. 9. N.S. paid you, JOHN GIAQUINTO, THREE HUNDRED FIFTY SEVEN AND 34/100 DOLLARS ($357.34), as a down payment for this insurance coverage. 10. You, JOHN GIAQUINTO, provided N.S. with a receipt for his payment but failed to forward the payment to Insurquest Insurance Company, leaving N.S. subject to liability for lack of auto insurance coverage. ll. You, JOHN GIAQUINTO, failed to properly place automobile insurance coverage, 12. You, JOHN GIAQUINTO, have converted, misappropriated, or wrongfully - withheld fiduciary funds belonging to N.S. AS Aug 23 2005 10:42 Be/23/2085 16:39 8584874987 LEGAL SERVICES PAGE IT 1S THEREFORE CHARGED that you, JOHN GIAQUINTO, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Financial Services which constitute grounds for the suspension or revocation of your licenses and appointments: . (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...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 Statues; (b) Demonstrated lack of fitness or trustworthiness to engage in the business of insurance. Section 626.611(7), Florida Statutes; (c) . Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626.611(9), Florida Statutes; (d) Misappropriation, conversion, or unlawful withholding of moneys belongin gto insurers or insureds or beneficiaries or to others and received in conduct of business under the license or appointment. Section 626.611(10), Florida Statutes. co I 13. Paragraphs one (1) through six (6) are realleged and incorporated herein by reference. 14. On July 28, 2003, T.C. of St. Petersburg, Florida went to Great Florida Insurance of Sanford to purchase a homeowners insurance policy. On that day, T.C. signed an application for homeowners insurance to be placed with New America Insurance Company. 15. _‘T.C. paid you, JOHN GIAQUINTO, FIVE HUNDRED EIGHTY-SEVEN AND 00/100 DOLLARS ($587.00), as a down payment for this insurance coverage. 16. —_T.C’s application for homeowners insurance was denied by New American. Insurance Company for underwriting reasons and they sent.T.C. a refund check for the premium Ad Aug 23 2005 10:42 Be/23/2085 16:39 8584874987 LEGAL SERVICES PAGE paid. You, JOHN. GIAQUINTO, instructed T.C, to endorse the refund check and return it to you. 17, On August 22, 2003, you, JOHN GIAQUINTO, deposited T.C.’s refimd check into the Great Florida Insuratice of Sanford Agency’s operating account. You told Te: ‘that his homeowners insurance had been placed with Citizens Insurance Company. However, Citizens Insurance Company required a home inspection due to the age of the home, which was never completed, and the coverage was never issued. You, JOHN GLAQUINTO, never returned T.C.’s premium down payment. 18. You, JOHN GIAQUINTO, failed to place T.C.’s homeowners insurance in a timely manner. \ "19, You, J OHN GIAQUINTO, have converted, misappropriated, or wrongfully withheld fiduciary funds belonging to T.C. ) IT IS THEREFORE CHARGED that you, JOHN GIAQUINTO, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Financial Services which constitute grounds for the suspension or revocation of your licenses and appointments: (a) All premiums, retum 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...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 Statues; (b) Demonstrated lack of fitness or trustworthiness to engage in the busiriess of insurance. Section 626.611(7), Florida Statutes; | (c) Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626.611(9), Florida Statutes; a5 Aug 23 2005 10:43 Be/23/2085 16:39 8584874987 LEGAL SERVICES PAGE (4) = Misappropriation, conversion, or unlawful withholding of moneys belonging to ~ insurers or insureds or beneficiaries or to others and received in conduct of business under the license-or appointment. Section 626.61 1(10), Florida Statutes, COUNT IB 20. Paragraphs one (1) through six (6) are realleged and incorporated herein by reference, 21. Onor about March 2003, G.A. of Lake Mary, Florida contacted you, JOHN GIAQUINTO, to purchase homeowners insurance through the Qualsure Insurance Company. 22, On March 10, 2003, First Security Title Services, Inc., G.A.’s title company, provided you, JOHN GIAQUINTO, with check number 7027, in the amount of ONE THOUSAND TWO HUNDRED NINETY-SEVEN AND 00/100 DOLLARS ($1,297.00) as payment for G.A.’s homeowners insurance policy. 23, On or about March 17, 2003, you, JOHN GIAQUINTO, deposited said check in the. Great Florida Insurance of Sanford operating account but did not remit the premium payment to Qualsure Insurance Corporation. Consequently, G.A.’s homeowners insurance policy was cancelled on June 29, 2003 for non-payment of premiums. 24. = You, JOHN GIAQUINTO, failed to place G.A’s homeowners insurance in a timely manner. 29, You, JOHN GIAQUINTO, have converted, misappropriated, or wrongfully withheld fiduciary funds belonging to G.A. IT IS THEREFORE CHARGED that you, JOHN GIAQUINTO, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Financial Services which constitute grounds for the suspension or revocation of your licenses and appointments: (a) All premiums, return premiums, or other funds belonging to insurers or others Teceived 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... The licensee in the applicable AB Aug 23 2005 10:43 @e/2d/26685 larsg 8584874987 LEGAL SERVICES PAGE 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 Statues; (b) Demonstrated lack of fitness or trustworthiness to engage in the business of insurance, Section 626.611(7), Florida Statutes; (c). Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626.611(9), Florida Statutes; Gi) Misappropriation, conversion, or unlawful withholding of moneys belonging to insurers or insureds or beneficiaries or to others and received in conduct of business under the license or appointment. Section 626.611(10), Florida Statutes. \ COUNT IV . 26. Paragraphs one (1) through six (6) are realleged and incorporated herein by reference. 27. On March 6, 2003, C.B. of Orlando, Florida went to Great Florida Insurance of Sanford te purchase a homeowners insurance policy through New America Insurance Company. CB, paid you, JOHN GIAQUINTO, FIVE HUNDRED TWENTY-ONE AND 00/100 DOLLARS ($521.00), as a down payment for the insurance coverage. 28. OnApril 7, 2003, you, JOHN GIAQUINTO, were notified by New America Insurance Company that C.B.’s application did not meet underwriting requirements and the policy was therefore cancelled. 29, On April 18, 2003, New America Insurance Company issued a refund check to C.B. for the premium paid. You, JOHN GIAQUINTO, instructed C.B. to endorse the refund ; check and return it to you. 30, On April 24, 2003, you, JOHN GIAQUINTO, submitted a homeowners insurance application to Qualsure Insurance Company on behalf of C.B. Qualsure notified you, JOHN GIAQUINTO, that your binding authority had been terminated, and any business received after April 1, 2003 would not be bound. ay Aug 23 2005 10:43 Be/23/2085 16:39 8584874987 LEGAL SERVICES PAGE 31. On June 19, 2003, you, JOHN GIAQUINTO, deposited C.B.’s refund check into” the Great Florida Insurance of Sanford Agency’s operating account. You, JOHN GIAQUINTO never had a homeowners policy issued for C.B, and you never returned her premium down payment. 32. You, JOHN GIAQUINTO, failed to place C.B.’s homeowners insurance coverage in a timely manner. 33. You, JOHN GIAQUINTO, have converted, misappropriated, or wrongfully withheld fiduciary funds belonging to C.B. IT IS THEREFORE CHARGED that you, JOHN GIAQUINTO, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Financial: Services which constitute grounds for the suspension or revocation of your licenses and appointments: (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. ..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 Statues; (b) Demonstrated lack of fitness or trustworthiness to engage in the business of insurance. Section 626.611(7), Florida Statutes; (c) Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626.611(9), Florida Statutes; (d) Misappropriation, conversion, or unlawful withholding of moneys belonging to insurers or insureds or beneficiaries or to others and received in conduct of business under the license or appointment. Section 626.611(10), Florida Statutes. iis) Aug 23 2005 10:43 88/23/2665 16:39 8584874987 LEGAL SERVICES PAGE COUNT V 34. Paragraphs one (1) through six (6) are realleged and incorporated herein by reference. ; 35. On July 21, 2003, T.S. of Lutz; Florida contacted you, JOHN GIAQUINT O, to purchase a homeowners insurance policy through New America Insurance Company. On that day, T.S.’s title company, Great American Title & Abstract Corp., issued to you, JOHN GIAQUINTO, a check in the amount of ONE THOUSAND TWENTY-THREE AND 00/100 DOLLARS ($1,023.00) for full premium payment of the policy. 36. On July 29, 2003, you, JOHN GIAQUINTO, deposited said check into the Great Florida Insurance of Sanford operating account but did not remit the premium payment to New America Insurance Company. 37. On August 29, 2003, New America Insurance Company notified you, JOHN GIAQUINTO, that policy coverage for T.S. was denied for underwriting reasons and also because of a lack of premium payment. 38. You, JOHN GIAQUINTO, failed to inform T.S. of his lack of homeowners insurance and you failed to refund his premium payment, leaving him without homeowners insurance coverage from July 21, 3003 through July 21, 2004, 39. You, JOHN GIAQUINTO, failed to place T.S.’s homeowners insurance coverage. 40. You, JOHN GIAQUINTO, have converted, misappropriated, or wrongfully withheld fiduciary funds belonging to T.S. IT IS THEREFORE CHARGED that you, JOHN GIAQUINTO, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Financial Services which constitute grounds for the suspension or revocation of your licenses and appointments: (a) All premiums, return premiums, or other funds belonging to insurers ot others recejved by an agent, customer representative, or adjuster in transactions under his or her license are trust finds received by the licensee in a fiduciary capacity... The licensee in the applicable ag Aug 23 2005 10:44 @e/2a/26685 la;sg 8584874987 LEGAL SERVICES PAGE 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 Statues; (b) Demonstrated lack of fitness or trustworthiness to engage in the business of insurance. Section 626.611(7), Florida Statutes; ; (c) Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626.611(9), Florida Statutes; (d Misappropriation, conversion, or unlawful withholding of moneys belonging to insurers or insureds or beneficiaries or to others and received in conduct of business under the license or appointment. Section 626.611(10), Florida Statutes, \ . CO Vv. 41. Paragraphs one (1) through six (6) are hereby realleged and fully incorporated herein by reference. 42. On August 6, 2003, ACC Builders (ACC) of Lake Mary, Florida contacted you, JOHN GIAQUINTO, to purchase a commercial liability insurance policy through Tapco Underwriters, a surplus lines carrier. On that day, ACC provided you, JOHN GIAQUINTO, with check number 1182, in the amount of ONE THOUSAND FIVE HUNDRED EIGHTEEN AND 00/100 DOLLARS ($1,518.00) as premium payment for the policy. 43. On August 7, 2003, you, JOHN GIAQUINTO, deposited said check in the Great Florida Insurance of Sanford operating account but failed to remit payment to Tapco Underwriters. 44, On September 12, 2003, the premium finance company, Capitol Premium Plan, Inc., contacted Karri Coffman, who purchased Great Florida Insurance of Sanford from you, JOHN GIAQUINTO, on August 29, 2003, and notified her that no contract, application, or down payment had been received from the policy. 45. You, JOHN GIAQUINTO, failed to place the requested commercial liability insurance with Tapco Underwriters and you did not return the premium payment to ACC. 18 Aug 23 2005 10:44 @e/2d/26685 laisag 8584874987 LEGAL SERVICES PAGE 46. You, JOHN GIAQUINTO, have converted, misappropriated, or wrongfully withheld fiduciary funds belonging to ACC. IT IS THEREFORE CHARGED that you, JOHN GIAQUINTO, have violated or are accountable under the following provisions of the Floridd Insurance Code and Rules of the Department of Financial Services which constitute grounds for the suspension or revocation of your licenses and appointments: (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... The licensee in the applicable regular course of usinss shall account for and pay the same to the insurer, insured, or other person entitle thereto. Section 626.561(1), Florida Statues; (b) Demonstrated lack of fitness or trustworthiness to engage in the business of insurance. Section 626.611(7), Florida Statutes; (c) Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626.611(9), Florida Statutes; (d) Misappropriation, conversion, or unlawful withholding of moneys belonging to insurers or insureds or beneficiaries or to others and received in conduct of business under the license or appointment. Section 626.611(10), Florida Statutes, COUNT VII 47, Paragraphs one (1) through six (6) are hereby realleged and incorporated herein by reference. ; ; 48, On July 18, 2003, L.B. of Sanford, Florida contacted you, JOHN GIAQUINTO, to purchase a homeowners insurance policy through the American Mercury Insurance Company (Mercury). On that day, L.B. provided you with a premium payment in the amount of FOUR, HUNDRED NINETY-EIGHT AND 00/100 DOLLARS ($498.00). 49. You, JOHN GIAQUINTO, forwarded a payment in the amount of THREE HUNDRED SIXTY-SIX AND 00/100 DOLLARS to Mercury on behalf of L.B. with a check 10 11 Aug 23 2005 10:44 48/23/2665 16:39 8584874987 LEGAL SERVICES PAGE from the Great Florida Insurance of Sanford operating account. On September 29, 2003, Mercury returned said check for non-sufficient funds, 50. On October 15, 2003, you, JOHN GIAQUINTO, replaced the non-sufficient funds check with a Visa credit card payment. As a result of your actions L.B.’s homeowners insurance had an effective date of October 15, 2003 instead of July 18, 2003 as requested, leaving L.B. with a lack of coverage and subject to liability for three (3) months. 51. You, JOHN GIAQUINTO, failed to place L.B.’s homeowners insurance in a titnely manner. 52. You, JOHN GIAQUINTO, have converted, misappropriated, or wrongfully withheld fiduciary fands belonging to L.B. ITIS THEREFORE CHARGED that you, JOHN GIAQUINTO, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Financial Services which constitute grounds for the suspension or revocation of “your licenses and appointments: (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...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 Statues; (b) Demonstrated lack of fitness or trustworthiness to engage in the business of insurance. Section 626.611(7), Florida Statutes; (c) Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626.611(9), Florida Statutes; (d) Misappropriation, conversion, or unlawful withholding of moneys belonging to insurers or insureds or beneficiaries or to others and received in conduct of business under the license or appointment. Section 626.611(10), Florida Statutes, 1] . 12 Aug 23 2005 10:45 08/23/2665 16:39 8584874987 LEGAL SERVICES PAGE COUNT VII 53. Paragraphs one (1) through six (6) are hereby realleged and incorporated herein by reference, . ; 54. Onor about July 15, 2003, TP. of Saint Petersburg; Florida-contacted you, JOHN GIAQUINTO, to purchase a homeowners insurance policy with the New America Insurance Company (New America). On said date, the title company handling the closing transaction, Chicago Title Insurance Company, issued a check directly to New America on behalf of T.P. 65 On July 25, 2003, New America sent you, JOHN GIAQUINTO a memo stating that the check from the title company was being returned because the insurer had not received an application for T.P. \ ' 56, Asa result of your failure to file the proper application for T.P. New America issued a cancellation notice effective July 29, 2003, leaving T.P. without the homeowners insurance policy he had purchased from you, JOHN GIAQUINTO. 57. You, JOHN GIAQUINTO, failed to properly and timely place T.P.’s homeowners insurance coverage. IT 18 THEREFORE CHARGED that you, JOHN GIAQUINTO, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Financial Services which constitute grounds for the suspension or revocation of your licenses and appointments: (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 competence to engage in the transactions authorized by the license or appointment. Section 626.611(8), Florida Statutes; (c) Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626,.611(9), Florida Statutes. 12 . 13 Aug 23 2005 10:45 @e/2d/26685 larsg 8584874987 LEGAL SERVICES PAGE WHEREFORE, you, JOHN GIAQUINTO, are hereby notified that the Chief Financial * Officer 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 626.611, 626.621, 626.681, 626.691, and 626.9521, Florida Statutes, and under the other . referenced Sections of the Florida Statutes as set out in this Administrative Complaint. 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. Your written response must be received by the Department 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; 13 . 14 Aug 23 2005 10:45 @e/2/26685 laisg 8584874987 LEGAL SERVICES PAGE (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) Avreference to the notice, order to show cause, administrative complaint, or other communication that the party has received from the agency. wee gnarl i “Ifa 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 td the action taken by the Department or a written statement challenging the grounds upon which the Department has telied, 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. 15 Aug 23 2005 10:45 O8/29/2085 1:39 8584874987 LEGAL SERVICES PAGE 16 Mediation of this matter pursuant to Section 120.573, Florida Statutes, is not available. ~- No Department attomey will discuss this matter with you until the response has been received by the Department of Financial Services. DATED and SIGNED this {Oday of_MAarch. , 2005. KAREN CHANDLER Deputy Chief Financial Officer te, ore ott “e 2) ane os aus _ 15 + Aug 23 2005 10:45 08/23/2665 16:39 8584874987 LEGAL SERVICES PAGE 17 CERTIFICATE OF SERVICE IHEREBY CERTIFY that a true and correct copy of the foregoing ADMINISTRATIVE COMPLAINT and ELECTION OF PROCEEDING has been furnished to: JOHN GIAQUINTO, 2022 SE 6th Lane, Cape Coral, Florida 33990; 5 JOHN GIAQUINTO, P.O, Box 150814, Cape , Coral, Florida 33915 by Certified Mail this [b@ day of Marth. , 2005, cof tp William W. Tharpe, Jr. Division of Legal Services 200 East Gaines St, f 612 Larson Building \ Tallahassee, Florida 32399-033 \ (850) 413-4110 Florida Bar Number 0312411 16

Docket for Case No: 05-003004PL