STATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
DEPARTMENT OF INSURANCE ) AND TREASURER, )
)
Petitioner, )
)
vs. ) CASE NO. 87-3046
)
LARRY WAYNE LINDSAY, )
)
Respondent. )
)
RECOMMENDED ORDER
Pursuant to notice, the Division of Administrative Hearings, by its duly designated Hearing Officer, K. N. Ayers, held a public hearing in the above- styled cause on March 2 and 3, 1988, at Winter Haven, Florida.
APPEARANCES
For Petitioner: Robert V. Elias, Esquire
413-B Larson Building Tallahassee, Florida 32399-0300
For Respondent: Thomas R. Woods, Esquire
1709-D Mahan Drive Tallahassee, Florida 32308
By Administrative Complaint dated June 24, 1987, and Amended Administrative Complaint forwarded February 11, 1988, the Florida Department of Insurance and Treasurer, Petitioner, seeks to revoke, suspend, or otherwise discipline the license of Larry Wayne Lindsay, Respondent, as an Ordinary Life and General Lines Agent. As grounds therefor, it is alleged in some 54 counts that Respondent, as General Lines Agent for Friendly Insurance of Bartow, Inc. and as a stockholder of Friendly Insurance of Lake Wales, Inc., Friendly Auto Insurance of Winter Haven, Inc. and Friendly Auto Insurance of Haines City, Inc. caused customers to purchase insurance not required by law by misrepresentation; took cash payments for total premium payments from customers for automobile insurance, then forged their signatures on a premium finance contract and obtained money there from thereby defrauding insurance and premium finance companies; and that Respondent failed to remit insurance premiums to Dixie Insurance Company, all in violation of Sections 626.611 and 626.621, Florida Statutes.
Initially, charges were also preferred against Thomas Ross Shaw as General Lines Agent for Friendly Auto Insurance Agency of Winter Haven, Florida, alleging similar types of misconduct in operating an insurance agency. At the commencement of these proceedings, the charges against Shaw were dismissed by Petitioner, and these proceedings continued against only Respondent Lindsay.
Thereafter Petitioner called 7 witnesses, Respondent called 2 witnesses, including himself, and 30 exhibits were admitted into evidence. Of those 54
counts comprising the Administrative Complaint and amendment thereto, no evidence was submitted regarding counts 1 through 31, and 36 through 47, alleging clients coming into one of the agencies above-noted to purchase liability and PIP coverage and being fraudulently sold accidental death policies without their knowledge and/or consent. Charges represented by these counts must be dismissed for reason of Petitioner's failing to sustain its burden of proof of these charges. This leaves counts 33 and 34 of the original complaint and counts 49 through 53 of the Amended Complaint all alleging that Respondent received full payment for the premiums on auto insurance policies from clients, forged their signatures on finance agreements to obtain monies which were not fully paid off; and that he owed Dixie Insurance Company some $18,000 in premiums collected but not remitted to the insurer.
Proposed findings have been submitted by the parties. Treatment accorded those proposed findings is contained in the Appendix attached hereto and made a part hereof.
FINDINGS OF FACT
At all times material hereto Respondent was licensed as an Ordinary Life and General Lines Agent (Exhibit 1) and was the agent for Dixie Insurance Company at the Bartow office. As such, he had the authority to write policies binding the insurer.
At all times relevant hereto, Respondent was president and principal stockholder of Friendly Insurance Companies of Bartow, Winter Haven, Lake Wales and Haines City. The corporate records (Exhibit 3 for Polk County) show this to be the same as Friendly Auto Insurance of Lake Wales, Inc.
Respondent was the agent for Dixie Insurance Company only at the Bartow office. Dixie Insurance Company qualifies agents, not offices, to sell their policies. Respondent had no authority to act as agent for Dixie Insurance at any of these offices other than the Bartow office as the insurance company has but one agent per office.
To support the allegations in count 34 of the Administrative Complaint, Edward Bland testified, and Exhibits 21 through 23 were admitted. Bland applied for automobile insurance at Friendly Auto Insurance at the Winter Haven office, which he paid for by check in the amount of $728 (Exhibit 23) as full payment for the one year premium. Subsequent thereto, a Premium Finance Agreement was prepared on which Bland's signature was forged showing $546 of the premium to be financed. This finance agreement was signed by T. R. Shaw as agent.
Upon learning that the finance agreement had been issued on his coverage, Bland contacted the Winter Haven office manager, and after a few weeks of "run around" contacted the Department of Insurance and "got his money back." Bland never saw Shaw or Respondent.
Rafael Gomez, M.D. purchased automobile insurance on his three cars from Friendly Auto Insurance of Winter Haven in December 1985 for which he paid
$3452.71 for the annual premium. Subsequently thereto, he received a call from the Barnett Bank, which had financed one of the cars, to tell him that the bank needed evidence of insurance on the financed auto. Dr. Gomez contacted Ruth Kent, the office manager at the Winter Haven office, who assured him she would supply the bank with the necessary documentation. When the bank contacted Dr. Gomez later to again demand proof of insurance, Gomez went to the Winter Haven office and demanded to see his file. He made copies of certain documents which
he took to the bank. Dr. Gomez subsequently learned that a finance agreement had been entered into on his behalf, but without his knowledge or consent, and that the address shown on the agreement under his name was that of Ruth Kent. Although when accosted by Dr. Gomez with this information, Ms. Kent denied such an intentional act, this would have allowed her to hold the finance coupons and get all information supplied by the finance company to the borrower without Dr. Gomez learning that the policy for which he had paid in full was subsequently financed. After learning of the subterfuge, Dr. Gomez contacted the Department of Insurance.
Ruth Judd was office manager at the Friendly Insurance Agency of Haines City for a period of time ending in 1987 when she was terminated by Respondent. Ms. Judd contends she was only the office manager, and Respondent was the boss of the office and hired all employees. During the time she worked in the office, Ms. Judd testified several different people served as the licensed agent for the office, but they spent little time in the office with Donald Leroy Flentke, towards the end of his tenure, coming in only for his weekly paychecks. No evidence was presented from which a determination could be made that for a specific period of time any of the four offices were not being supervised by a licensed agent.
Ms. Judd testified she was aware of one policy for which the insured had paid the premium in full being submitted for a premium finance agreement with forged documents. She also was aware that monthly financing payments were made by the Haines City office on some three or four other premium finance agreements. Ms. Judd testified on March 2, 1988, that she was presently unemployed. Respondent called one witness that testified and produced documentary evidence (Exhibits 24 through 26) that on March 2, 1988, this witness purchased insurance from Ms. Judd at New Horizons and was required to buy an accidental death policy in order to obtain PIP coverage.
Exhibit 7 shows that an automobile insurance policy was issued to Jackie Bryan, the policy was sold through Friendly Insurance of Winter Haven, Inc., that the premium was financed, the borrower owed an additional $142.66 on the finance agreement, and the policy expired 2-26-86. Respondent acknowledged that his signature appears on the premium finance application. Some 5000 policies are sold by Respondent's agencies per year, and Respondent has no independent recollection of that finance agreement. Dixie Insurance Company issued a policy to Johnny Davis which was also financed through Envoy, but this application was signed by Shaw. Although Dixie Insurance Company had their own premium finance organization and, if the premium is financed, preferred to do the financing, Respondent testified that occasionally, if a client did not want to finance their premium through Dixie, the agency would go through another premium finance company such as Envoy.
Exhibits 9, 10, 11 and 12 show premium finance agreements were contracted for on behalf of Raymond Scott, Mark Turner, Kathy Smith and Cathy Phillips, but no auto insurance policies were issued by Dixie Insurance Company to these individuals. Only one of these finance agreements (Exhibit 12) purports to be prepared at the Bartow office, and two of the drafts (Exhibits 9 and 12) purport to be signed by Respondent. Respondent testified he neither signed those drafts nor authorized someone else to sign for him. The forgery on both Exhibits 9 and 12 appear to have been perpetrated by the same person.
Cathy Phillips, a friend of Ruth Kent, testified without contradiction that the signature purporting to be hers on Exhibit 12 was forged, that she never entered into a premium finance agreement with Envoy Finance Corporation,
and that she had never seen Exhibit 14 until presented to her by the Petitioner's attorney. Ms. Phillips did receive a past-due notice on one occasion and called Ruth Kent who told her not to worry about it, that everything was taken care of. Subsequently, Ms. Phillips' husband wrote a letter to Envoy Finance Corporation denying any knowledge of any insurance policy written by Friendly Insurance of Bartow.
Considerable testimony was submitted regarding the activities of Chuck Evans who was, at one time, employed by Respondent at the Winter Haven agency as a non-licensed employee with authority to write checks on the Trust Account. While the statements made by Evans to Department of Insurance officials contributed to the initiation of the investigation of Respondent's agencies, none of this testimony was relevant to the charges here at issue.
CONCLUSIONS OF LAW
The Division of Administrative Hearings has jurisdiction over the parties to, and the subject matter of, these proceedings.
In license disciplinary proceedings the Petitioner has to prove alleged violations of statutes or rules by clear and convincing evidence. Ferris v. Turlington, 510 So.2d 292 (Fla. 1987).
Grounds for disciplining the license of an insurance agent are contained in Sections 626.611 and 626.621, Florida Statutes. Section 626.611 lists the following grounds for compulsory revocation or suspension of license:
Lack of one or more of the qualifications for the license or permit as specified in this code.
Material misstatement, misrepresentation, or fraud in obtaining the license or permit or in attempting to obtain a license or permit.
Failure to pass to the satisfaction of the department any examination required under the code.
If the license or permit is willfully used, or to be used, to circumvent any of the require- ment or prohibitions of this code.
Willful misrepresentation of any insurance policy or annuity contract or willful deception with regard to any such policy or contract,
done either in person or by any form of dissem- ination or of information or advertising.
If, as an adjustor or claims investigator or agent permitted to adjust claims under this code, he has materially misrepresented to an insured or other interested party the terms and coverage of an insurance contract within intent and for the purpose of effecting settlement of claim for loss or damage or benefit under such contract on less favorable terms than those provided and contemplated by the contract.
Demonstrated lack of fitness or trust- worthiness to engage in the business of insurance.
Demonstrated lack of reasonably adequate
knowledge and technical competence to engage in the transactions authorized by the license or permit.
Fraudulent or dishonest practices in the conduct of business under the license or permit.
Misappropriation, conversion, or unlawful withholding of monies belonging to insurers or insured or beneficiaries or to others and
received in conduct of business under the license.
Rebating, or attempting thereat, or unlaw- fully dividing or offering to divide his commission with another.
Having obtained or attempting to obtain, or having used or using, a license as agent or solicitor for the purpose of soliciting or
handing "controlled business" as defined in
s. 626.730(3) with respect to general line agents, s. 626.784(2) with respect to life agents, and s. 626.830(3) with respect to health agents.
Willful failure to comply with, or willful violation of, any proper order or rule of the department or willful violation of any provi-
sion of this code.
Having been found guilty, or having pleaded guilty or nolo contendere to a felony in this state or any other state which involves moral turpitude, without regard to whether a judgment of conviction has been entered by the court having jurisdiction of such cases.
Section 626.621, Florida Statutes, lists the following grounds for discretionary revocation or suspension of a license:
Any cause for which issuance of the license or permit could have been refused had it then existed and been known to the department.
Violation of any provision of this code or of any other law applicable to the business
of insurance in the course of dealing under the license or permit.
Violation of any lawful order or rule of the department.
Failure or refusal, upon demand, to pay over to any insurer he represents or has represented any money coming into his hands belonging to the insurer.
Violation of the provision against twisting, as defined in s. 626.9541(1)(l).
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 or detrimental to the public interest.
Willful overinsurance of any property insurance risk.
Having been found guilty of, or having pleaded guilty or nolo contendere to, a felony in this state or any other state, without regard to whether a judgment of conviction has been entered by the court having jurisdiction of such cases.
If a life agent, violation of the code of ethics.
Cheating on an examination required for licensure.
Petitioner here contends Respondent has violated s. 626.611(7), (9),
(10) and (11), above listed, and Section 626.621(2).
The only evidence presented at this hearing was that someone at one or more of the Friendly Auto Insurance Agencies was guilty of "skimming" premiums or outright fraud in forging a client's signature on a premium finance application and financing a premium for a policy never issued or for a policy for which the insured paid the full year's premium. No evidence was presented that Respondent was involved in any of these transactions or was aware, or should have been aware, that such transactions were taking place.
Sections 626.611(13) and 626.621(2), above cited, allows violations of any provision of Chapter 626 to constitute grounds for disciplinary action. Those sections Respondent is alleged to violate are Sections 626.561(1), 626.747(1) and 626.734.
Section 626.561(1) provides in pertinent part:
All premiums, returned premiums or other funds belonging to insurers or others received by an agent ... in transactions under his license shall be trust funds so received by the licensee in a fiduciary capacity; and the licensee in the appli- cable regular course of business shall account for and pay the same to the insurer, insured, or other person entitled thereto.
Respondent's license was active only in the Bartow office, and no evidence was presented that any of the irregularities contained in the findings of fact above involved the Bartow office.
Section 626.747(1) provides:
Each branch place of business established by an agent or agency, firm, corporation, or association shall be in the active full-time charge of a licensed general lines agent. Any agent or agency, firm, corporation, or association which has established one or more branch places
of business shall be required to have at least one agent at each location of the agency including its headquarters location.
While there was testimony from one witness that the agent in charge of the Winter Haven and/or Haines City office appeared infrequently at the office, some three or four licensed agents served at this agency during the period 1985 through 1987, and the evidence was not clear and convincing that, at any specific time, the agency was not under the active full-time control of a licensed agent. No evidence was presented that the office manager, presumed to be unlicensed, forged the license agent's signature on all of the insurance documents generated by the agency which required the signature of the licensed agent, or that the agent did not personally sign the documents.
Section 626.734 under the title Corporations, Liability of Agent, provides:
Any general lines insurance agent who is an officer, director, stockholder, or employee of an incorporated general lines insurance agency shall remain personally and fully liable and accountable for any wrongful acts, misconduct, or violations of any provisions of this code committed by such licensee or by any person under his direct supervision and control while acting on behalf of the corporation.
This is not a statutory provision of which a licensee can be found to be in violation. This statute merely provides that officers and directors of a corporation whose agents misappropriate funds rightfully belonging to an insurance company, may be personally liable for the funds so misappropriated. In Hartnett v. Dept. of Insurance, 432 So.2d 135 (Fla. 3rd DCA 1983), the Court stated at p. 157:
The language of the statute conveys a clear and definite meaning -- any general lines agent who is an officer, director, stockholder, or employee of an incorporated general lines agency will be personally liable for violations of the insurance
code committed by himself or those under his supervision and control.
As pointed out by the Court, it is the agent and not the agency which is licensed. Each of the incorporated agencies had an agent authorized by the insurer to write policies and accept premiums for Dixie Insurance Company.
While Respondent may, pursuant to Section 621.734, be personally liable to Dixie Insurance Company for the premiums received at the agencies on policies written on Dixie Insurance Company, Respondent has not violated this statutory provision.
From the foregoing, it is concluded that Petitioner has failed to prove, by clear and convincing evidence, that Respondent violated the various provisions of Sections 626.611 and 626.621, Florida Statutes, as alleged. It is
RECOMMENDED that all charges against Larry Wayne Lindsay be dismissed. ENTERED this 8th day of April, 1988, in Tallahassee, Florida.
K. N. AYERS Hearing Officer
Division of Administrative Hearings The Oakland Building
2009 Apalachee Parkway
Tallahassee, Florida 32399-1550
(904) 488-9675
Filed with the Clerk of the Division of Administrative Hearings this 8th day of April, 1988.
APPENDIX TO RECOMMENDED ORDER, CASE NO. 87-3046
Treatment Accorded Petitioner's Proposed Findings of Fact
Included in HO #1.
Included in HO #2.
Included in HO #4.
Rejected. Not being present at certain time one day does not equate no presence during normal working hours.
Included in HO #6.
Included in HO #6.
Rejected. Agents at the Friendly Insurance Offices were licensed by Dixie Insurance Company to write binding policies on Dixie. No copy of such "agency" agreements was presented.
Included in HO #8.
Rejected. Part of this alleged indebtedness was charged off by Dixie Insurance Company, and no evidence was submitted that Respondent is personally liable for this indebtedness.
10-15. Included in HO #8 and #9.
Accepted.
Rejected as unsupported by the evidence.
Rejected, except insofar as included in HO #8.
Rejected as unsupported by the evidence. 20-21. Included in HO #10.
22-24. Included in HO #5.
25-27. Included in HO #4.
Treatment Accorded Respondent's Proposed Findings of Fact
Accepted only insofar as included in HO preamble.
Accepted.
Accepted with the inclusion of the word "credible" before evidence.
COPIES FURNISHED:
Robert V. Elias, Esquire Department of Insurance and
Treasurer
Office of Legal Services 413-B Larson Building
Tallahassee, Florida 32399-0300
Thomas F. Woods, Esquire
Gatlin, Woods, Carlson and Cowdery 1709-D Mahan Drive
Tallahassee, Florida 32308
Don Dowdell General Counsel
Department of Insurance and Treasurer
The Capitol, Plaza Level Tallahassee, Florida 32399-0300
Hon. William Gunter State Treasurer and Insurance Commissioner The Capitol, Plaza Level
Tallahassee, Florida 32399-0300
=================================================================
AGENCY FINAL ORDER
=================================================================
STATE OF FLORIDA DEPARTMENT OF INSURANCE AND TREASURER
IN THE MATTER OF:
LARRY WAYNE LINDSAY
Ordinary Life Agent DOAH Case No. 87-3046 Case No. 87-L-513RVE
General Lines - Property, Casualty, Surety and Miscellaneous Insurance Agent
/
FINAL ORDER
THIS CAUSE came on before the undersigned Insurance Commissioner of the State of Florida for consideration and final agency action. On June 24, 1987, the Department of Insurance (hereinafter the Department) filed an Administrative Complaint against LARRY WAYNE LINDSAY, Respondent, charging various violations of the Insurance Code. On February 4, 1988, the Department filed an Amended
Administrative complaint alleging additional violations of the Insurance Code. On March 2nd and 3rd, 1988, pursuant to Respondent's request of July 16, 1987, a formal hearing was held in Winter Haven, Florida, before the Honorable K. N. Ayers, Hearing Officer for the Division of Administrative Hearings, pursuant to Section 120.57(1), Florida Statutes. This administrative proceeding is memorialized in the proceedings (and accompanying exhibits) certified on March 11, 1988 and received by the Division of Administrative Hearings on March 21, 1988. After consideration of the evidence in the form of the testimony and exhibits presented at the hearing, and further consideration of the proposed recommended orders submitted by the parties, the Hearing Officer, on April 8, 1988, issued a Recommended Order (attached as Exhibit "A") to the Insurance Commissioner. Neither party filed exceptions. Upon a careful consideration and review of the complete record, and being otherwise fully advised in the premises, it is
The Hearing Officer's Findings of Fact are adopted in full as this agency's Findings of Fact.
The Hearing Officer's Conclusions of Law are adopted as this agency's Conclusions of Law, with the exception of the following:
The Hearing Officer, on page 12 of his Recommended Order, addressed Section 626.734, Florida Statutes. Therein he stated that Section 626.734 "merely provides that officers and directors of a corporation whose agency misappropriate funds rightfully belonging to an insurance company, may be personally liable for the funds so misappropriated." 1/ This conclusion is an erroneous statement of law, and therefore is rejected, for the reasons stated below.
As stated by the Third District in Hartnett v. Department of Insurance, 432 So.2d 155 (Fla. 3rd DCA 1983),
The language of the statute conveys a clear and definite meaning - any general lines agent who is an officer, director, stockholder, or employee of an incorporated
general lines agency will be personally liable for violations of the insurance code committed by himself of those under his supervision and control.
Id at 157. 2/ The statute is not, as erroneously concluded by the Hearing Officer, limited to instances involving misappropriation of funds. "[A]ny wrongful acts, misconduct, or violations of any provisions of this code" are actionable against the enumerated individuals based, in part, on this statute.
To conclude, as does the Hearing Officer on page 12, that "[t]his is not a statutory provision of which a licensee can be found to be in violation" is overly simplistic. This conclusion is rejected as an erroneous statement of law. Although section 626.734 carries no independent sanction for breach of its provisions, it does impose vicarious liability upon the individuals named therein, for any violation of the Insurance Code by someone under their supervision and control. While an officer, director, stockholder, or employee
may not violate section 626.734 itself, he may be found in violation of the Insurance Code because of the transgression of one under his supervision and control, based upon section 626.734. The statute, therefore, acts as a conduit, an enabling code, allowing the Department and others to seek redress against one who, while they may not have personally committed any violation, will still be held responsible based upon their position, authority and responsibility. This statute is consistent with the rule, recognized in the majority of jurisdictions, holding a licensee strictly liable for violations of the law resulting from his acts or those of his employees. See Surff Attractions, Inc.
v. Department of Business Regulation, Division of Alcoholic Beverages and Tobacco, 480 So.2d 1354, 1357 note 1 (Ervin, dissenting) (Fla. 1st DCA 1985), and Annot., 3 ALR 2d 107, 108 (1949).
The Hearing Officer further concluded on page 13: "While Respondent may, pursuant to Section 621.734 (sic), be personally liable to Dixie Insurance Company for the premiums received at the agencies on policies written on Dixie Insurance Company, Respondent has not *violated* this statutory provision" (emphasis between * in original). This "conclusion of law" is rejected as internally inconsistent and erroneous.
Implicit in this conclusion is the factual finding that Respondent is "personally liable to Dixie Insurance Company for the premiums received at the agencies on policies written on Dixie Insurance Company." If this was a factual conclusion of the Hearing Officer, then Respondent has violated Section 626.561(1), Florida Statutes, if not by his own personal misconduct then by the conduct of those individuals at the Friendly Auto Insurance Agencies under his direct supervision and control.
However, the facts, as determined by the Hearing Officer in his Recommended Order, do not reveal any support for this conclusion. Furthermore, his factual conclusions fail to make any determination as to the facts testified to by the now property manager and former marketing and underwriting manager for Dixie Insurance Company. In effect, thirteen pages of testimony is virtually ignored, with no resolution of facts in favor of either party. Therefore, based upon this record, this conclusion of law is rejected as lacking any basis in the record, internally inconsistent and erroneous.
The Hearing Officer's Recommendation that all charges against Larry Wayne Lindsay be dismissed is adopted, based upon the state of the record in this case.
ACCORDINGLY, all charges against Larry Wayne Lindsay in case number 87-L- 513RVE be and the same are hereby DISMISSED.
Any party to these proceedings adversely affected by this Order is entitled to seek reviewed of this Order pursuant to Section 120.68, Florida Statutes, and Rule 9.110 Fla.R.App.P. Review proceedings must be instituted by filing a petition or notice of appeal with the General Counsel, acting as the agency clerk, at 413-B Larson Building, Tallahassee, Florida, 32399-0300 and a copy of the same with the appropriate district court of appeal within thirty (30) days of rendition of this Order.
DONE and ORDERED this 11th day of July, 1987.
BILL GUNTER
Insurance Commissioner and Treasurer
ANN WAINWRIGHT
Assistant Insurance Commissioner and Treasurer
ENDNOTES
1/ The Hearing Officer's Conclusions of Law are not, for reasons unknown, separately numbered. Therefore, reference will be made to the page upon which the "conclusions" appears.
2/ This quote also appeared, somewhat inconsistently, in the Hearing Officer's Recommended Order at page 12.
COPIES FURNISHED TO:
Honorable K. N. Ayers Hearing Officer
Division of Administrative Hearings The Oakland Building
2009 Apalachee Parkway
Tallahassee, Florida 32399-1550
Robert V. Elias
Office of Legal Services
Department of Insurance and Treasurer 413-B Larson Building
Tallahassee, Florida 32399-0300
Thomas F. Woods, Esquire
Gatlin, Woods, Carlson and Cowdery 1709-D Mahan Drive
Tallahassee, Florida 32308
Larry Wayne Lindsay 1480 6th Street, N.Wc.
Winter Haven, Florida 33881
| Issue Date | Proceedings |
|---|---|
| Apr. 08, 1988 | Recommended Order (hearing held , 2013). CASE CLOSED. |
| Issue Date | Document | Summary |
|---|---|---|
| Jul. 11, 1988 | Agency Final Order | |
| Apr. 08, 1988 | Recommended Order | Respondent's license not active in some offices he owned where violations occurred. Evidence failed to prove respondent violated provisions of Ch. 626 |
DEPARTMENT OF INSURANCE AND TREASURER vs JOHNNY L. JOHNSON, 87-003046 (1987)
DEPARTMENT OF INSURANCE vs ROBERT WALTER BANDEL, 87-003046 (1987)
DEPARTMENT OF INSURANCE AND TREASURER vs RALPH EDWARD CARTER, 87-003046 (1987)
DEPARTMENT OF INSURANCE AND TREASURER vs STEVEN SCHNUR, 87-003046 (1987)
DEPARTMENT OF INSURANCE AND TREASURER vs. JON SCOTT ROBBINS, 87-003046 (1987)
