@6/17/2018 65:56 May 18 2010 11:15 8584146749 DEPR OGA PAGE @5/ag FILED Department of fusines and Profestional Reputation Deputy Agency Clerk ‘CLERK frandon Nichale Dete = 2/24/2010 Filo ® STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION REGULATORY COUNCIL OF COMMUNITY ASSOCIATION MANAGERS DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, Cage No. 2009-028644 ALL FLORIDA MANAGEMENT COMPANY, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint against ALL FLORIDA MANAGEMENT COMPANY ("Respondent"), and alleges: 1. Petitioner is the State agency charged with regulating the practice of community association management pursuant to Section 20,165 and Chapters 455 and 468, Part VIII, Florida Statutes, 2. community 3. Respondent is licensed in the State of Florida as a association management pusiness (“CAB”), CAB 3224. Respondent’s address of record with Petitioner is 9415 Sunset Dr. #149, Miami, Florida 33173. 4. Petitioner received complaints from Ixmgard Epstein Brierre (“Brierre’) against Respondent, as well as its officer, Document in Unnamed @6/17/2018 65:56 8584146749 May 18 2010 11et5 DBPR OA PAGE 46/89 Barbara M- Blanco (“Blanco”), alleging various acts of misconduct during the course of management. 5. At all times material hereto, Respondent, through Blanco, acted as the CAB for Lake and Tennis Villas Association (“Association”) . 6. Respondent committed, either through Blanco or through its employees, one or mere of the following acts during performance of management duties: a. Buthorized the use of numerous checks containing a forged signature; b. Attempted to persuade the person whose signature was forged to mislead the Association by agreeing to a version of the facts contrary to the truth. 7. Section 468.436(2) (b) (5), Florida Statutes, provides: Committing acts of gross misconduct or gross negligence in connection with the profession constitutes grounds for which the disciplinary actions in subsection (4) may be taken. 8. Section 468.436(2) (a), Florida Statutes, provides: The following acts constitute grounds for which the disciplinary actions in subsection (4) may be taken: Document in Unnamed @5/17/ 2018 65:56 8584146749 May 18 2010 11:15 DEPR OGA (a) Violation of any provision of 6&8. 455.227 (1). 9. Section 455.227(1) (m), Florida Statutes prohibits: Making deceptive, untrue, or fraudulent representations in ot related to the practice of a profession or employing a trick or scheme in of related to the practice of a profession, 10. Based on the foregoing, Respondent violated Section 458.436(2) (a), Florida Statutes, through a violation of Section 455.227(1) (mb, Florida Statutes by making fraudulent representations and/or employing a trick or scheme in relation to the CAM profession. The acts of Respondent would also arise to the level of gross misconduct during the course of her CAM responsibilities, thus constitute violation of Section 468.436(2) (b) (5), Florida Statutes. WHEREFORE, Petitioner respectfully requests the entry of an Order imposing, one or more of the penalties authorized by Sections 468.436(3) and 455.227(2), Florida Statutes, which includes, but not is not limited to: revocation or suspension of Respondent’s license, imposition of an administrative fine net exceeding five thousand dollars ($5,000.00) for each count or separate offense, issuance of a reprimand, placement of Document in Unnamed PAGE ar/ag 5/17/2818 65:56 B5e4146749 May 18 2010 11:16 DEPR OGA PAGE Respondent on probation for a period of time and subject to such conditions as the Board specifies, and/or the restriction of the authorized scope of practice by Respondent. Signed this 4™ By: DMM/tmy PC Found: 2-4-10 PC Found By: DMM Document in Unnamed day of February 2010, CHARLES LIEM, Interim Secretary Department of Business and Professional Regulation Diane Marger Moore Diane Marger Moore Assistant General Counsel Florida Bar No. 268364 Department of Business and Professional Regulation Office of the General Counsel 1940 N. Monroe Street, Ste. 42 Tallahassee, FL 32399-2202 (950) 414-8123 Telephone (850) 414-6749 Facsimile ae/ag May 18 2010 11:16 a5/17/ 2016 85:56 8584146749 DEPR OGA PAGE @9/ag NOTICE OF RIGHTS Respondent has the vight to request a hearing to be aonducted in accordance with Sections 120.569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to eall and cross-examine witnesses and to have subpoenas and subpoenas duces tecum igsued on his or her behalf if a hearing is requested. Rule 28-106.111, Florida Administrative Code, provides in part that if Respondent fails to request a hearing within twenty-one (21) days of receipt of an agency pleading, Respondent waives the right to request a hearing on the facts alleged. NOTICE REGARDING ASSESSMENT OF COSTS Respondent is placed on notice that Petitioner has incurred costs related to the investigation and prosecution of this matter. Pursuant to Section 455.227(3) (a)- Florida Statutes, the Board, or the Department when there is no Board, may assés6 costs related to the investigation and prosecution of the case excluding costs associated with an attorney's time, against the Respondent in addition to any other discipline imposed. Document in Unnamed

Docket for Case No: 10-002682