FILED JUL 06 2018 FFICER Docketed by OAS. STATE OF FLORIDA DEPARTMENT OF FINANCIAL SERVICES, Petitioner, CASE NO.: 226656-18-AG v. DEBORAH A. AICHELE, Respondent. ADMINISTRATIVE COMPLAINT Deborah A. Aichele 1500 S. Ocean Blvd., PH1 Pompano Beach, FL 33062 Deborah A. Aichele (“Deborah Aichele”), license #P092490, is hereby notified that the Chief Financial Officer of the State of Florida has caused to be made an investigation of her 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, Deborah Aichele, is currently licensed in this state as a general lines agent. 2. At all times pertinent to the dates and occurrences referred to herein, Deborah Aichele was licensed in this state as a general lines agent. 3. At all times pertinent to the dates and occurrences referred to herein, Deborah Aichele was employed by Hays Companies of Florida (“Hays Companies”). 4, At all times pertinent to the dates and occurrences referred to herein, Deborah Aichele was a Vice President with Hays Companies. 5. At all times pertinent to the dates and occurrences referred to herein, Jaimie Hogeland was employed by Hays Companies, 6. At all times pertinent to the dates arid occurrences referred to herein, Jaimie Hogeland was an Account Manager with Hays Companies. 7. At all times pertinent to the dates and occurrences referred to herein, Jaimie Hogeland was a member of Deborah Aichele’s team at Hays Companies. 8. Pursuant to chapter 626, Florida Statutes, the Florida Department of Financial Services (the “Department”) has jurisdiction over her license and appointments. COUNT I 9. The above general allegations are hereby realleged and fully incorporated herein by reference. 10. ‘In or around November of 2016, C.G., an Executive Vice President with Grossinger Autoplex, Inc. (“Grossinger Autoplex”), an entity that owned multiple autodealership in Illinois, sought to purchase Dealer Open Lot insurance coverage on behalf of Grossinger Autoplex. 11. ‘In or around November of 2016, Deborah Aichele began assisting C.G. with the purchase of Dealer Open Lot insurance coverage. 12, OnNovember 30, 2016, Jaime Hogeland sent Deborah Aichele a Dealer Open Lot insurance coverage proposal for Grossinger Autoplex (the “Real C.G, Proposal”). 13. In relation to the section of the Real C.G. Proposal entitled “Dealers Open Lot - Option II,” the insurance coverage limits, offered by Certain Underwriters at Lloyds (“CU Lloyds”), were listed as follows: $5,000,000 Blanket Per Occurrence (Including Weather) $5,000,000 Per Occurrence and Aggregate for Earth Movement $5,000,000 Per Occurrence and Aggregate for Flood 14. Deborah Aichele did not send C.G, the Real C.G. Proposal. 15. On November 30, 2016, Deborah Aichele sent C.G. an altered proposal (the “Altered C.G, Proposal”). 16. In relation to the section of the Altered C.G. Proposal entitled “Dealers Open Lot — Option II,” the insurance coverage limits, offered by CU Lloyds, were listed as follows: $ 110,000,000 Blanket Per Occurrence (Including Weather) $ 110,000,000 Per Occurrence and Aggregate for Earth Movement $ 110,000,000 Per Occurrence and Aggregate for Flood 17, Deborah Aichele altered the Real C.G. Proposal. 18. Deborah Aichele created the Altered C.G. Proposal, 19. C.G. and/or Grossinger Autoplex reviewed the Altered C.G. Proposal. 20. -C.G. and/or Grossinger Autoplex chose Option II of the Altered C.G, Proposal. 21. C.G. and/or Grossinger Autoplex decided to purchase the insurance coverage listed in Option If of the Altered C.G. Proposal. 22. .G. and/or Grossinger Autoplex believed that the insurance coverage limits listed in paragraph 16 herein were the insurance coverage limits on the insurance policy that Grossinger Autoplex had been offered and/or had purchased from CU Lloyds. 23. C.G. and/or Grossinger Autoplex did not know or understand that she/it was sent an altered proposal by Deborah Aichele. 24. C.G. and/or Grossinger Autoplex did not know or understand that the insurance coverage limits listed in paragraph 13 herein were the actual insurance coverage limits on the insurance policy that Grossinger Autoplex had been offered and/or had purchased from CU Lloyds. 25. The insurance coverage limits listed in paragraph 13 herein were the actual insurance coverage limits on the insurance policy that Grossinger Autoplex had been offered and/or had purchased from CU Lloyds. 26. Deborah Aichele knew or should have known that she altered the Real C.G. Proposal. 27. Deborah Aichele knew or should have known that she created the Altered C.G. Proposal. 28. Deborah Aichele knew or should have known that she sent C.G. an altered proposal. 29. Deborah Aichele knew or should have known that the insurance coverage limits listed in paragraph 16 herein were not the actual insurance coverage limits on the insurance policy that Grossinger Autoplex had been offered and/or had purchased from CU Lloyds. 30. Deborah Aichele knew or should have known that the insurance coverage limits listed in paragraph 13 herein were the actual insurance coverage limits on the insurance policy that Grossinger Autoplex had been offered and/or had purchased from CU Lloyds. 31. Deborah Aichele received a commission, from an insurer, agent, broker, or individual, on the sale of the insurance policy that Grossinger Autoplex purchased from CU Lloyds. © 32. Deborah Aichele knew or should have known that she would receive a commission, from an insurer, agent, broker, or individual, on the sale of the insurance policy that Grossinger Autoplex purchased from CU Lloyds. IT IS THEREFORE CHARGED that, based on some or all of the foregoing facts contained in this Count, Deborah Aichele has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of her license as an insurance agent in this state: (a) Section 626.611(g), Florida Statutes, which provides that it is a violation to demonstrate a lack of fitness or trustworthiness to engage in the business of insurance. (b) Section 626.611(h), Florida Statutes, which provides that it is a violation to demonstrate a lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by license or appointment. (c) Section 626.611(3), Florida Statutes, which provides that it is a violation to engage in fraudulent or dishonest practices in the conduct of business under the license or appointment. (d) Section 626.621(2), Florida Statutes, which provides that violation of any provision of Florida Insurance Code or of any law applicable to the business of insurance in the course of dealing under the license or appointment is grounds for revocation suspension of a license. (e) Section 626.621(6), Florida Statutes, which provides that it is a violation to, in the conduct of business under the license or appointment, engage 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 loss to the public. (f) Section 626.9541(1)(a)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfait or deceptive act or practice to knowingly make, issue, circulate, or cause to be made, issued, or circulated, any estimate, illustration, circular, statement, sales presentation, omission, or comparison which misrepresents the benefits, advantages, conditions, or terms of any insurance policy. (g) Section 626.9541(1)(b), Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly making, publishing, disseminating, circulating, or placing before the public, or causing, directly or indirectly, to be made, published, disseminated, circulated, or placed before the public: 1, In anewspaper, magazine, or other publication, 2. In the form of a notice, circular, pamphlet, letter, or poster, 3. Over any radio or television station, or 4, Inany other way, an advertisement, announcement, or statement containing any assertion, representation, or statement with respect to the business of insurance, which is untrue, deceptive, or misleading. (h) = Section 626.9541(1)(e)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly: s Make, publish, disseminate, circulate, Deliver to any person, Place before the public, e. Cause, directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the public, F any false material statement. (i) Section 626.9541(1)(k)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly make a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual. COUNT II 33. | The above general allegations and paragraph 25 herein are hereby realleged and fully incorporated herein by reference. 34. On July 24, 2017, Deborah Aichele sent C.G. a Certificate of Insurance (‘Grossinger COI”) showing that Grossinger Autoplex was insured with CU Lloyds for the following insurance coverage limits: $ 120,000,000 Blanket Comprehensive and Collission (Including Weather) $ 120,000,000 Earth Movement $ 120,000,000 Flood 35. Capital One, N.A. was listed on the Grossinger COI as an additional interest. 36, Grossinger Autoplex was not insured through CU Lloyds for some of the insurance coverage limits that were listed on the Grossinger COI (specifically, Grossinger Autoplex was not insured through CU Lloyds for the insurance coverage limits identified in paragraph 34 herein). 37. | Deborah Aichele knew or should have known that Grossinger Autoplex was not insured through CU Lloyds for some of the insurance coverage limits that were listed on the Grossinger COI (specifically, Grossinger Autoplex was not insured through CU Lloyds for the insurance coverage limits identified in paragraph 34 herein). 38. | Deborah Aichele created the Grossinger COI, or the Grossinger COI was created at the direction, request, and/or supervision of Deborah Aichele. IT IS THEREFORE CHARGED that, based on some or all of the foregoing facts contained in this Count, Deborah Aichele has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of her license as an insurance agent in this state: (a) Section 626.611(g), Florida Statutes, which provides that it is a violation to demonstrate a lack of fitness or trustworthiness to engage in the business of insurance. (b) — Section 626.611(h), Florida Statutes, which provides that it is a violation to demonstrate a lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by license or appointment. (c) Section 626.611(i), Florida Statutes, which provides that it is a violation to engage in fraudulent or dishonest practices in the conduct of business under the license or appointment. (d) Section 626.621(2), Florida Statutes, which provides that violation of any provision of Florida Insurance Code or of any law applicable to the business of insurance in the course of dealing under the license or appointment is grounds for revocation suspension of a license. (ce) Section 626.621(6), Florida Statutes, which provides that it is a violation to, in the conduct of business under the license or appointment, engage 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 loss to the public. (63) Section 626.9541(1)(a)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly make, issue, circulate, or cause to be made, issued, or circulated, any estimate, illustration, circular, statement, sales presentation, omission, or comparison which misrepresents the benefits, advantages, conditions, or terms of any insurance policy. (g) Section 626.9541(1)(b), Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly making, publishing, disseminating, circulating, or placing before the public, or causing, directly or indirectly, to be made, published, disseminated, circulated, or placed before the public: In a newspaper, magazine, or other publication, . Inthe form of a notice, circular, pamphlet, letter, or poster, Over any radio or television station, or In any other way, AY Ne an advertisement, announcement, or statement containing any assertion, representation, or statement with respect to the business of insurance, which is untrue, deceptive, or misleading, ch) = Section 626.9541(1)(e)l, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly: b. Make, publish, disseminate, circulate, c. Deliver to any person, d. Place before the public, e. Cause, directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the public, any false material statement. COUNT IIT 39. The above general allegations are hereby realleged and fully incorporated herein by reference. 40. In or around November of 2016, C.M., the Controller for Alvin Autoland, Inc. (“Alvin Autoland”), an entity that owned multiple autodealership in Texas, sought to purchase Dealer Open Lot insurance coverage on behalf of Alvin Autoland. 41. In or around November of 2016, Deborah Aichele began assisting C.M. with the purchase of Dealer Open Lot insurance coverage. 42. On November 18, 2016, Jaime Hogeland sent Deborah Aichele a Dealer Open Lot insurance coverage proposal for Alvin Autoland (the “Real C.M. Proposal”). 43. In relation to the section of the Real C.M. Proposal entitled “Dealers Open Lot ~ Option II,” the insurance coverage limits, offered by CU Lloyds, were listed as follows: $5,000,000 Blanket Per Occurrence (Including Weather) $5,000,000 Per Occurrence and Aggregate for Earth Movement $5,000,000 Per Occurrence and Aggregate for Flood 44. Deborah Aichele did not send C.M. the Real C.M. Proposal. 45. On November 19, 2016, Deborah Aichele sent C.M. an altered proposal (the “Altered C.M. Proposal”). 46. In relation to the section of the Altered C.M. Proposal entitled “Dealers Open Lot — Option II,” the insurance coverage limits, offered by CU Lloyds, were listed as follows: $ 40,000,000 Blanket Per Occurrence (Including Weather) $ 40,000,000 Per Occurrence and Aggregate for Earth Movement $40,000,000 Per Occurrence and Aggregate for Flood 47.. Deborah Aichele altered the Real C.M. Proposal. 10 48. | Deborah Aichele created the Altered C.M. Proposal. 49. _C.M. and/or Alvin Autoland reviewed the Altered C.M. Proposal. 50. C.M. and/or Alvin Autoland chose Option II of the Altered C.M. Proposal. 51, C.M. and/or Alvin Autoland decided to purchase the insurance coverage listed in Option II of the Altered C.M. Proposal. 52, CM. and/or Alvin Autoland believed that the insurance coverage limits listed in paragraph 46 herein were the insurance coverage limits on the insurance policy that Alvin Autoland had been offered and/or had purchased from CU Lloyds. $3. CM. and/or Alvin Autoland did not know or understand that he/it was sent an altered proposal by Deborah Aichele. 54, CM. and/or Alvin Autoland did not know or understand that the insurance coverage limits listed in paragraph 43 herein were the actual insurance coverage limits on the insurance policy that Alvin Autoland had been offered and/or had purchased from CU Lloyds. 55. The insurance coverage limits listed in paragraph 43 herein were the actual insurance coverage limits on the insurance policy that Alvin Autoland had been offered and/or had purchased from CU Lloyds. 56. Deborah Aichele knew or should have known that she altered the Real C.M. Proposal. 57, Deborah Aichele knew or should have known that she created the Altered C.M. Proposal. 58. Deborah Aichele knew or should have known that she sent C.M. an altered proposal. ll 59. | Deborah Aichele knew or should have known that the insurance coverage limits listed in paragraph 46 herein were not the actual insurance coverage limits on the insurance policy that Alvin Autoland had been offered and/or had purchased from CU Lloyds. 60. Deborah Aichele knew or should have known that the insurance coverage limits listed in paragraph 43 herein were the actual insurance coverage limits on the insurance policy that Alvin Autoland had been offered and/or had purchased from CU Lloyds. 61. Deborah Aichele received a commission, from an insurer, agent, broker, or individual, on the sale of the insurance policy that Alvin Autoland purchased from CU Lloyds. 62. Deborah Aichele knew or should have known that she would receive a commission, from an insurer, agent, broker, or individual, on the sale of the insurance policy that Alvin Autoland purchased from CU Lloyds. IT IS THEREFORE CHARGED that, based on some or all of the foregoing facts contained in this Count, Deborah Aichele has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of her license as an insurance agent in this state: (a) Section 626.611(g), Florida Statutes, which provides that it is a violation to demonstrate a lack of fitness or trustworthiness to engage in the business of insurance. (b) Section 626.611(h), Florida Statutes, which provides that it is a violation to demonstrate a lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by license or appointment. (c) Section 626.61 1(i), Florida Statutes, which provides that it is a violation to engage in fraudulent or dishonest practices in the conduct of business under the license or appointment. 12 (d) Section 626.621(2), Florida Statutes, which provides that violation of any provision of Florida Insurance Code or of any law applicable to the business of insurance in the course of dealing under the license or appointment is grounds for revocation suspension of a license. (e) Section 626.621(6), Florida Statutes, which provides that it is a violation to, in the conduct of business under the license or appointment, engage 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 or herself to be a source of loss to the public. ® Section 626.9541(1)(a)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly make, issue, circulate, or cause to be made, issued, or circulated, any estimate, illustration, circular, statement, sales presentation, omission, or comparison which misrepresents the benefits, advantages, conditions, or terms of any insurance policy. (g) Section 626.9541(1)(b), Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly making, publishing, disseminating, circulating, or placing before the public, or causing, directly or indirectly, to be made, published, disseminated, circulated, or placed before the public: 1, Ina newspaper, magazine, or other publication, 2. Inthe form of a notice, circular, pamphlet, letter, or poster, 3. Over any tadio or television station, or 4, In any other way, an advertisement, announcement, or statement containing any assertion, representation, or statement with respect to the business of insurance, which is untrue, deceptive, or misleading. 13 th) Section 626.9541(1e)!, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly: . Make, publish, disseminate, circulate, Deliver to any person, Place before the public, . Cause, directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the public, fee any false material statement. a) Section 626.9541(1)(k)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly make a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual. COUNT IV 63. | The above general allegations and paragraphs, as well as paragraphs 40, 41, 43, 61, and 62 herein, are hereby realleged and fully incorporated herein by reference. 64. On November 21, 2016, Deborah Aichele sent C.M. a revised altered proposal (the “Revised Altered C.M. Proposal”). 65. In relation to the section of the Revised Altered C.M. Proposal entitled “Dealers Open Lot — Option II,” the insurance coverage limits, offered by CU Lloyds, were listed as follows: $ 40,000,000 Blanket Per Occurrence (Including Weather) $ 40,000,000 Per Occurrence and Aggregate for Earth Movement $ 40,000,000 Per Occurrence and Aggregate for Flood 66. Deborah Aichele altered the Altered C.M. Proposal. 14 67. | Deborah Aichele created the Revised Altered C.M. Proposal. 68. _C.M. and/or Alvin Autoland reviewed the Revised Altered C.M. Proposal. 69. In the alternative to paragraph 50 herein, C.M. and/or Alvin Autoland chose Option II of the Revised Altered C.M. Proposal. 70. ‘In the alternative to paragraph 51 herein, C.M. and/or Alvin Autoland decided to purchase the insurance coverage listed in Option II of the Revised Altered C.M. Proposal. 71. C.M. and/or Alvin Autoland believed that the insurance coverage limits listed in paragraph 65 herein were the insurance coverage limits on the insurance policy that Alvin Autoland had been offered and/or had purchased from CU Lloyds. 72. _C.M. and/or Alvin Autoland did not know or understand that he/it was sent an altered proposal by Deborah Aichele. 73. ©.M. and/or Alvin Autoland did not know or understand that the insurance coverage limits listed in paragraph 81 herein were the actual insurance coverage limits on the insurance policy that Alvin Autoland had been offered and/or had purchased from CU Lloyds. 74. The insurance coverage limits listed in paragraph 81 herein were the actual insurance coverage limits on the insurance policy that Alvin Autoland had been offered and/or had purchased from CU Lloyds. 75. | Deborah Aichele knew or should have known that she altered the Altered C.M. Proposal. 76. Deborah Aichele knew or should have known that she created the Revised Altered C.M. Proposal. 77, Deborah Aichele knew or -should have known that she sent C.M. an altered proposal. 78. Deborah Aichele knew or should have known that the insurance coverage limits listed in paragraph 65 herein were not the actual insurance coverage limits on the insurance policy that Alvin Autoland had been offered and/or had purchased from CU Lloyds. 79. Deborah Aichele knew or should have known that the insurance coverage limits listed in paragraph 43 and/or 81 herein were the actual insurance coverage limits on the insurance policy that Alvin Autoland had been offered and/or had purchased from CU Lloyds. 80. On November 22, 2016, Jaime Hogeland sent Deborah Aichele a Revised Dealer Open Lot insurance coverage proposal for Alvin Autoland (the “Revised Real C.M. Proposal”). 81. In relation to the section of the Revised Real C.M. Proposal entitled “Dealers Open Lot — Option II,” the insurance coverage limits, offered by CU Lloyds, were listed as follows: $5,000,000 Bianket Per Occurrence (Including Weather) $5,000,000 Per Occurrence and Aggregate for Earth Movement $ 5,000,000 Per Occurrence and Aggregate for Flood 82. Deborah Aichele never sent C.M. the Revised Real C.M. Proposal. IT IS THEREFORE CHARGED that, based on some or all of the foregoing facts contained in this Count, Deborah Aichele has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of her license as an insurance agent in this state: (a) Section 626.611(g), Florida Statutes, which provides that it is a violation to demonstrate a lack of fitness or trustworthiness to engage in the business of insurance. (b) Section 626.611(h), Florida Statutes, which provides that it is a violation to demonstrate a lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by license or appointment. 16 (c) Section 626.611(i), Florida Statutes, which provides that it is 2 violation to engage in fraudulent or dishonest practices in the conduct of business under the license or appointment. (d) ‘Section 626.621(2), Florida Statutes, which provides that violation of any provision of Florida Insurance Code or of any law applicable to the business of insurance in the course of dealing under the license or appointment is grounds for revocation suspension of a license. (e) Section 626.621(6), Florida Statutes, which provides that it is a violation to, in the conduct of business under the license or appointment, engage 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 loss to the public. (f) Section 626.9541(1)(a)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly make, issue, circulate, or cause to be made, issued, or circulated, any estimate, illustration, circular, statement, sales presentation, omission, or comparison which misrepresents the a advantages, conditions, or terms of any insurance policy. (g) Section 626.9541(1)(b), Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly making, publishing, disseminating, circulating, or placing before the public, or causing, directly or indirectly, to be made, published, disseminated, circulated, or placed before the public: 1. In a newspaper, magazine, or other publication, 2. Inthe form of a notice, circular, pamphlet, letter, or poster, 3. Over any radio or television station, or 4, In any other way, 17 an advertisement, announcement, or statement containing any assertion, representation, or statement with respect to the business of insurance, which is untrue, deceptive, or misleading. (h) Section 626.9541(1)(e)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly: Make, publish, disseminate, circulate, Deliver to any person, . Place before the public, Cause, directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the public, p Aes any false material statement. (i) Section 626.9541(1)(k)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly make a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual. COUNT V 83. The above general allegations are hereby realleged and fully incorporated herein by reference. 84, In or around October or November of 2016, J.O., a Manager with Orr Auto, Inc, (“Orr Auto”), an entity that owned multiple autodealership in Texas, sought to purchase Dealer Open Lot insurance coverage on behalf of Orr Auto. 85. In or around October or November of 2016, Deborah Aichele began assisting J.O. with the purchase of Dealer Open Lot insurance coverage. 18 86. In or around October or November of 2016, J.O. and/or Orr Auto purchased an insurance policy with Besso Limited Insurance (“Besso”). 87, On or around-November 1, 2016, Deborah Aichele sent J.O. a Besso insurance policy (“Altered Orr Policy”) showing that Orr Auto was insured with Besso for the following insurance coverage limits: USD 80,000,000 ultimate net loss, any one Loss at Named Locations, subject to USD 80,000,000 in the aggregate in respect of the peril of Earthquake. 88. | Orr Auto was not insured through Besso for the amount of insurance coverage that was listed in the Altered Orr Policy. 89. On November 1, 2016, Besso issued Orr Auto an insurance policy (“Real Orr Policy”). 90. Pursuant to the Real Orr Policy, Orr Auto was insured for the following insurance coverage limits: USD 5,000,000 ultimate net loss, any one Loss at Named Locations, subject to USD 5,000,000 in the aggregate in respect of the peril of Earthquake. : 91, Deborah Aichele never sent J.O. and/or Orr Auto the Real Orr Policy. 92. Deborah Aichele knew or should have known that Orr Auto was not insured through Besso for the amount of insurance coverage that was listed in the Altered Orr Policy. 93. Deborah Aichele created the Altered Orr Policy. 19 94, JO. and/or Orr Auto believed that the insurance coverage limits listed in the Altered Orr Policy were the insurance coverage limits on the insurance policy that Orr Auto purchased from Besso. 95. _J.O. and/or Orr Auto did not know or urlderstand that he/it was sent an altered insurance policy by Deborah Aichele. 96. J.O. and/or Orr Auto did not know or understand that the insurance coverage limits listed in paragraph 90 herein were the actual insurance coverage limits on the insurance policy that Orr Auto purchased from Besso. 97, | Deborah Aichele knew or should have known that she altered the Real Orr Policy. 98. Deborah Aichele knew or should have known that she created the Altered Orr Policy. 99. Deborah Aichele knew or should have known that the insurance coverage limits listed in the Altered Orr Policy were not the actual insurance coverage limits on the insurance policy that Orr Auto had been offered and/or had purchased from Besso. 100. Deborah Aichele knew or should have known that the insurance coverage limits listed in paragraph 90 herein were the actual insurance coverage limits on the insurance policy that Orr Auto had been offered and/or had purchased from Besso. 101. Deborah Aichele received a commission, from an insurer, agent, broker, or individual, on the sale of the Real Orr Policy. 102. Deborah Aichele knew or should have known that she would receive a commission, from an insurer, agent, broker, or individual, on the sale of the insurance policy that Orr Auto purchased from Besso. 20 IT IS THEREFORE CHARGED that, based on some or all of the foregoing facts contained in this Count, Deborah Aichele has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of her license as an insurance agent in this state: (a) Section 626.611(g), Florida Statutes, which provides that it is a violation to demonstrate a lack of fitness or trustworthiness to engage in the business of insurance. (b) Section 626.611(h), Florida Statutes, which provides that it is a violation to demonstrate a lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by license or appointment. (c) Section 626.611(), Florida Statutes, which provides that it is a violation to engage in fraudulent or dishonest practices in the conduct of business under the license or appointment. (d) Section 626.621(2), Florida Statutes, which provides that violation of any provision of Florida Insurance Code or of any law applicable to the business of insurance in the course of dealing under the license or appointment is grounds for revocation suspension of a license. (e) Section 626.621(6), Florida Statutes, which provides that it is a violation to, in the conduct of business under the license or appointment, engage 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 loss to the public. () Section 626.9541(1)(a)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly make, issue, circulate, or cause to be made, issued, or circulated, any estimate, illustration, circular, statement, 21 sales presentation, omission, or comparison which misrepresents the benefits, advantages, conditions, or terms of any insurance policy, (g) Section 626.9541(1)(b), Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly making, publishing, disseminating, circulating, or placing before the public, or causing, directly or indirectly, to be made, published, disseminated, circulated, or placed before the public: In a newspaper, magazine, or other publication, In the form of a notice, circular, pamphlet, letter, or poster, Over any radio or television station, or In any other way, Repo an advertisement, announcement, or statement containing any assertion, representation, or statement with respect to the business of insurance, which is untrue, deceptive, or misleading. (h) —— Section 626.9541(1)(e)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly: b. Make, publish, disseminate, circulate, c. Deliver to any person, d. Place before the public, e. Cause, directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the public, any false material statement. — i) Section 626.9541(1)(k)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly make a false or fraudulent written or oral statement or representation on, or relative to, an application or 22 negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual. COUNT VI 103. The above general allegations are hereby realleged and fully incorporated herein by reference. 104. In or around March or April of 2017, G.F., a Controller with Gulf Coast Auto Group, Inc. (“Gulf Auto”), an entity that owned multiple autodealership in Texas, sought to purchase Dealer Open Lot insurance coverage on behalf of Gulf Auto. 105. In or around March or April of 2017, Deborah Aichele was assisting G.F. with the purchase of Dealer Open Lot insurance coverage. 106. In or around March or April of 2017, G.F. and/or Gulf Auto purchased an insurance policy with Besso. 107. On Jume 23, 2017, Deborah Aichele sent D.R., an individual employed by Branch Banking & Trust (“BB&T”), a Besso insurance policy (“Altered Gulf Policy”) showing that Gulf Auto was insured with Besso for the following insurance coverage limit: USD 42,000,000 any one Occurrence (Policy Limit). 108. Gulf Auto was not insured through Besso for the amount of insurance coverage that was listed in the Altered Gulf Policy. 109. On April 1, 2017, Besso issued Gulf Auto an insurance policy (“Real Gulf Policy”). 110, Pursuant to the Real Gulf Policy, Gulf Auto was insured through Besso for the following insurance coverage limit: USD 5,000,000 any one Occurrence (Policy Limit). 23 111. Deborah Aichele never sent BB&T, G.F. and/or Gulf Auto the Real Gulf Policy. 112. Deborah Aichele knew or should have known that Gulf Auto was not insured through Besso for the amount of insurance coverage that was listed in the Altered Gulf Policy. 113, Deborah Aiche altered the insurance policy issued by Besso. 114. Deborah Aichele created the Altered Gulf Policy. 115. BB&T, G.F. and/or Gulf Auto believed that the insurance coverage limit listed in the Altered Gulf Policy was the insurance coverage limit on the insurance policy that Gulf Auto purchased from Besso. 116. BB&T, G.F. and/or Gulf Auto did not know or understand that it/he was sent an altered insurance policy by Deborah Aichele. 117. BB&T, G.F. and/or Gulf Auto did not know or understand that the insurance coverage limit listed in paragraph 110 herein was the actual insurance coverage limit on the insurance policy that Gulf Auto purchased from Besso. 118. Deborah Aichele knew or should have known that she altered the Real Gulf Policy. 119. Deborah Aichele knew or should have known that she created the Altered Gulf Policy. 120. Deborah Aichele knew or should have known that the insurance coverage limit listed in the Altered Gulf Policy was not the actual insurance coverage limit on the insurance policy that Gulf Auto had been offered and/or had purchased from Besso. 24 121. Deborah Aichele knew or should have known that the insurance coverage limit listed in listed in paragraph 110 herein was the actual insurance coverage limit on the insurance policy that Gulf Auto had been offered and/or had purchased from Besso. 122. Deborah Aichele received a commission, from an insurer, agent, broker, or individual, on the sale of the Real Gulf Policy. 123. Deborah Aichele knew she would receive a commission, from an insurer, agent, broker, or individual, on the sale of the Real Gulf Policy. IT IS THEREFORE CHARGED that, based on some or all of the foregoing facts contained in this Count, Deborah Aichele has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of her license as an insufance agent in this state: (a) Section 626.611(g), Florida Statutes, which provides that it is a violation to demonstrate a lack of fitness or trustworthiness to engage in the business of insurance. (6) ‘Section 626.611(h), Florida Statutes, which provides that it is a wiataston to demonstrate a lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by license or appointment. (c) Section 626.611(i), Florida Statutes, which provides that it is a violation to engage in fraudulent or dishonest practices in the conduct of business under the license or appointment. (d) Section 626.621(2), Florida Statutes, which provides that violation of any provision of Florida Insurance Code or of any law applicable to the business of insurance in the course of dealing under the license or appointment is grounds for revocation suspension of a license. 25 (e) Section 626.621(6), Florida Statutes, which provides that it is a violation to, in the conduct of business under the license or appointment, engage 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 loss to the public. 63) Section 626.9541(1)(a)l, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly make, issue, circulate, or cause to be made, issued, or circulated, any estimate, illustration, circular, statement, sales presentation, omission, or comparison which misrepresents the benefits, advantages, conditions, or terms of any insurance policy. (g) Section 626.9541(1)(b), Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly making, publishing, disseminating, circulating, or placing before the public, or causing, directly or indirectly, to be made, published, disseminated, circulated, or placed before the public: In a newspaper, magazine, or other publication, . In the form of a notice, circular, pamphlet, letter, or poster, Over any radio or television station, or In any other way, APN an advertisement, announcement, or statement containing any assertion, representation, or statement with respect to the business of insurance, which is untrue, deceptive, or misleading. (h) Section 626.9541(1)(e)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly: b. Make, publish, disseminate, circulate, c. Deliver to any person, d. Place before the public, 26 e. Cause, directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the public, any false material statement. (i) Section 626.9541(1)(k)l, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly make a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual COUNT VII 124. The above general allegations, and paragraphs 109 and 110 herein, are hereby realleged and fully incorporated herein by reference. 125. On June 23, 2017, Deborah Aichele sent §.W., a Senior Vice President of Dealer Finance with BB&T, a Certificate of Insurance (“Gulf Auto COI”) showing that Gulf. Auto was insured with Lloyds for the following insurance coverage limits: $ 40,000,000 Collision $ 40,000,000 Comprehensive (except Flood, Earthquake and False Promise) $ 40,000,000 Comprehensive — Weather 126. BB&T Insurance Center was listed on the Gulf Auto COI as an additional interest. 127. Gulf Auto was not insured through Lloyds for some of the insurance coverage limits that were listed on the Gulf Auto COI (specifically, Gulf Auto was not insured through Lloyds for the insurance coverage limits identified in paragraph 125 herein). 128, Deborah Aichele knew or should have known that Gulf Auto was not insured through Lloyds for some of the insurance coverage limits that were listed on the Gulf Auto COI 27 (specifically, Gulf Auto was not insured through Lloyds for the insurance coverage limits identified in paragraph 125 herein). 129. Deborah Aichele created the Gulf Auto COI, or the Gulf Auto COI was created at the direction, request, and/or supervision of Deborah Aichele. IT IS THEREFORE CHARGED that, based on some or all of the foregoing facts contained in this Count, Deborah Aichele has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of her license as an insurance agent in this:state: (a) Section 626.611(g), Florida Statutes, which provides that it is a violation to demonstrate a lack of fitness or trustworthiness to engage in the business of insurance. (b) Section 626.611(h), Florida Statutes, which provides that it is a violation to demonstrate a lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by license or appointment. (c} Section 626.611(i), Florida Statutes, which provides that it is a violation to engage in fraudulent or dishonest practices in the conduct of business under the license or appointment. (d) Section 626.621(2), Florida Statutes, which provides that violation of any provision of Florida Insurance Code or of any law applicable to the business of insurance in the course of dealing under the license or appointment is grounds for revocation suspension of a license. (e) Section 626.621(6), Florida Statutes, which provides that it is a violation to, in the conduct of business under the license or appointment, engage 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 loss to the public. 28 () Section 626.9541(1)(a)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly make, issue, circulate, or cause to be made, issued, or circulated, any estimate, illustration, circular, statement, sales presentation, omission, or comparison which misrepresents the benefits, advantages, conditions, or terms of any insurance policy. (g) Section 626.9541(1)(b), Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly making, publishing, disseminating, circulating, or placing before the public, or causing, directly or indirectly, to be made, published, disseminated, circulated, or placed before the public: In a newspaper, magazine, or other publication, In the form of a notice, circular, pamphlet, letter, or poster, Over any radio or television station, or In any other way, * PP Po an advertisement, announcement, or statement containing any assertion, representation, or statement with respect to the business of insurance, which is untrue, deceptive, or misleading. (h) = Section 626.9541(1)(e)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly: s Make, publish, disseminate, circulate, Deliver to any person, Place before the public, . Cause, directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the public, s a2 9 any false material statement. 29 COUNT VII 130. The above general allegations are hereby realleged and fully incorporated herein by reference. 131. In or around May of 2017, R.D’A., the Controller for the Beck and Masten Buick GMC, Inc. (“B&M”), an entity that owned multiple autodealership in Texas, sought to purchase Dealer Open Lot insurance coverage on behalf of B&M. 132. In or around May of 2017, Deborah Aichele began assisting R.D’A. with the purchase of Dealer Open Lot insurance coverage. 133, Lloyds issued B&M an insurance policy (“Real B&M Policy”) for the period July 7, 2017 to July 7, 2018. 134, Pursuant to the Real B&M Policy, B&M was insured through Lloyds for the following insurance coverage limit: USD 10,000,000 Any One loss and in the annual aggregate EXCESS OF LOSS OF USD 1,000,000 ANY ONE LOSS. 135. On July 6, 2017, Deborah Aichele sent R.D’A. and S.W. a Certificate of Insurance (“B&M COI”) showing that B&M was insured with Lloyds for the following insurance coverage limit: Excess Wind/Hail/Flood - $85,300,000 excess / $1,000,000 per occurrence 136. BB&T was listed on the B&M COI as an additional interest. 137. B&M was not insured through Lloyds for the amount of Excess Wind/Hail/Flood insurance coverage that was listed on the B&M COI. 138. Deborah Aichele knew or should have known that B&M was not insured through Lloyds for the amount of Excess Wind/Hail/Flood coverage that was listed on the B&M COI. 30 139. Deborah Aichele created the B&M COI, or the B&M COI was created at the direction, request, and/or supervision of Deborah Aichele. IT IS THEREFORE CHARGED that, based on some or all of the foregoing facts contained in this Count, Deborah Aichele has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of her license as an insurance agent in this state: (a) Section 626.611(g), Florida Statutes, which provides that it is a violation to demonstrate a lack of fimess or trustworthiness to engage in the business of insurance. (b) =‘ Section 626.611¢h), Florida Statutes, which provides that it is a violation to demonstrate a lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by license or appointment, (c) Section 626.611(i), Florida Statutes, which provides that it is a violation to engage in fraudulent or dishonest practices in the conduct of business under the license or appointment. (d) Section 626.621(2), Florida Statutes, which provides that violation of any provision of Florida Insurance Code or of any law applicable to the business of insurance in the course of dealing under the license or appointment is grounds. for revocation suspension of a license. (ec) Section 626.621(6), Florida Statutes, which provides that it is a violation to, in the conduct of business under the license or appointment, engage 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 loss to the public. (63) Section 626.9541(1}(a)1, Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly make, issue, 31 circulate, or cause to be made, issued, or circulated, any estimate, illustration, circular, statement, sales presentation, omission, or comparison which misrepresents the benefits, advantages, conditions, or terms of any insurance policy. (g) Section 626.9541(1)(b), Florida Statutes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly making, publishing, disseminating, circulating, or placing before the public, or causing, directly or indirectly, to be made, published, disseminated, circulated, or placed before the public: In a newspaper, magazine, or other publication, In the form of a notice, circular, pamphlet, letter, or poster, Over any radio or television station, or In any other way, e-wN > an advertisement, announcement, or statement containing any assertion, representation, or statement with respect to the business of insurance, which is untrue, deceptive, or misleading. (h) = Section 626.9541(1)(e)1, Florida Stamtes, which provides that it is an unfair method of competition and/or an unfair or deceptive act or practice to knowingly: . Make, publish, disseminate, circulate, Deliver to any person, Place before the public, Cause, directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the public, cho any false material statement. WHEREFORE, Deborah Aichele is hereby notified that the Chief Financial Officer intends to enter an Order suspending or revoking her license and appointment as an insurance agent or to impose such penalties as may be provided under the provisions of sections 626.611, 32 626.621, 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. DATED and SIGNED this_(gt)_ day of _ Jul} , 2018, et Gregory Thomas Director, Division of Insurance Agent and Agency Services 33 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 chapter 28-106, 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 a petition for administrative hearing are required. The request must be filed with Julie Jones, DFS Agency Clerk, at the Florida Department of Financial Services, 612 Larson Building, 200 East Gaines Street, Tallahassee, Florida 32399-0390. 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. FAILURE TO ENSURE THAT YOUR WRITTEN RESPONSE IS RECEIVED BY THE DEPARTMENT 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 A FINAL ORDER OF SUSPENSION OR REVOCATION WILL BE ENTERED AGAINST YOU. If you request a proceeding, you must provide information that complies with the requirements of Rule 28-106,2015, Florida Administrative Code. Specifically, your response must contain: (a) The name, address, telephone number, and facsimile number (if any) of the respondent (for the purpose of requesting a hearing in this matter, you are the "respondent"). 34 (b) The name, address, telephone number, and facsimile number of the attorney or qualified representative of the respondent (if any) upon whom service of pleadings and other papers shall be made. (c) A statement requesting an administrative hearing identifying those material facts that are in dispute. If there are none, the petition must so indicate. (4) A statement of when the respondent received notice of the administrative complaint. (e) A statement including the file number of the administrative complaint. 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 an administrative law judge of the State of Florida Division of Administrative Hearings. Unless the majority of witnesses are located elsewhere, the Department will request that the hearing be conducted in Tallahassee, Florida. 35 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 free form 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 before the date of this notice shall be deemed abandoned unless timely renewed in compliance with the guidelines as set out above. Mediation of this matter pursuant to section 120.573, Florida Statutes, is not available. No Department attorney will discuss this matter with you during the time frame in which you have to request a hearing. 36 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint and Election of Proceeding has been furnished to: Deborah A. Aichele, at 1500 S. Ocean Blvd., PH1, Pompano Beach, FL 33062, by Certified Mail, Restricted Delivery thi day of _, \ca\ N , 2018. A au 7099 3938 7035 4580 NENT Robert Fox Senior Attorney Department of Financial Services Office of the General Counsel 612 Larson Building 200 East Gaines Street Tallahassee, Florida 32399-0333 37 STATE OF FLORIDA DEPARTMENT OF FINANCIAL SERVICES OFFICE OF THE GENERAL COUNSEL DEPARTMENT OF FINANCIAL SERVICES, Petitioner, CASE NO.: 226656-18-AG v. DEBORAH A. AICHELE, Respondent, ELECTION OF PROCEEDING J have received and have read the Administrative Complaint filed by the Florida Department of Financial Services ("Department") against me, including the Notice of Rights contained therein, and I understand my options. I'am requesting disposition of this matter as indicated below. (CHOOSE ONE) 1. [] IJdonot dispute any of the Department’s factual allegations and I do not desire a hearing. |] understand that by waiving my right to a hearing, the Department may enter a final order that adopts the Administrative Complaint and imposes the sanctions sought, including suspending or revoking my licenses and appointments as may be appropriate, 2. 1 donot dispute any of the Department's factual allegations and I hereby elect a proceeding to be conducted in accordance with section 120.57(2), Florida Statutes, In this regard, I desire to (CHOOSE ONE): {] Submit a written statement and documentary evidence in lieu of a hearing; or [] Personally attend a hearing conducted by a department hearing officer in Tallahassee; or [] Attend that same hearing by way of a telephone conference call. 3. [ ] 1 dg dispute one or more of the Department's factual allegations. ] hereby request a hearing pursuant to section 120.57(i), Florida Statutes, to be held before the Division of Administrative Hearings. I have attached to this election form the information required by Rule 28-106.2015, Florida Administrative Code, as specified in subparagraph (c) of the Notice of Rights. Specifically, I have identified the disputed issues of material fact. TO PRESERVE YOUR RIGHT TO A HEARING, YOU MUST FILE YOUR RESPONSE WITH THE DEPARTMENT OF FINANCIAL SERVICES WITHIN TWENTY-ONE (21) DAYS OF YOUR RECEIPT OF THE ADMINISTRATIVE COMPLAINT, THE RESPONSE MUST BE RECEIVED BY THE DEPARTMENT NO LATER THAN 5:00 P.M. ON THE TWENTY-FIRST DAY AFTER YOUR RECEIPT OF THE ADMINISTRATIVE COMPLAINT. The address for filing is: Julie Jones, DFS Agency Clerk, Florida Department of Financial Services, 612 Larson Building, 200 East Gaines Street, Tallahassee, Florida 32399-0390, Signature Print Name Date: Po i SE ae Address. Date Administrative Complaint Received: _ sa sn en setting ee If you are represented by an attorney or qualified Phone No.: eee representative, please attach to this election form his or her name, address, telephone and fax numbers Fax No: See E-mail iene ee chi peecenery 38 UNITED STATES. . io = = = — POSTAL SERVICE July 31, 2018 Dear Joshua Shepard Aichele: The following is in response to your request for proof of delivery on your item with the tracking number: 9171 9999 9170 3545 8041 49. Item Details Status: Delivered, Left with Individual Status Date / Time: July 12, 2018, 10:59 am Location: POMPANO BEACH, FL 33062 Postal Product: First-Class Mail® Extra Services: Certified Mail™ Returm Receipt Electronic Shipment Details Weight: 14lb, 5.30z Recipient Signature Ly Signature of Recipient: \ | \ IK Address of Recipient: | SSF” Note: Scanned image may reflect a different destination address due to Intended Recipient's delivery instructions on file. Thank you for selecting the United States Postal Service® for your mailing needs. If you require additional assistance, please contact your local Post Office™ or a Postal representative at 1-800-222-1811. Sincerely, United States Postal Service® 475 L'Enfant Plaza SW Washington, D.C. 20260-0004

Docket for Case No: 19-000554PL