ae, aiilinal i.. bath a u . Vy a __ STATE OF FLORIDA ) o «a DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION & C BOARD OF ACCOUNTANCY Oe a : Jf BAG OEY DEPARTMENT OF BUSINESS AND GOOG & 3 PROFESSIONAL REGULATION, Ben 2 ! PZ SO Petitioner, (0 24 2 Le vs. CASE NO. 97-20953 KENNETH JACOBSON, Respondent. / _—_ ADMINISTRATIVE COMPLAINT COMES NOW the Department of Business and Professional Regulation, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the BOARD OF ACCOUNTANCY against KENNETH JACOBSON, hereinafter referred to as "Respondent," and alleges: 1. Petitioner is the state agency charged with regulating the practice of certified public accounting, pursuant to Section 20.165, Florida Statutes; Chapter 455, Florida Statutes; and Chapter 473, Florida Statutes. - 2, Respondent is, and has been at all times material hereto, a certified public accountant in the State of Florida, having been issued license number AC 0016874. 3. Respondent's address of record is 3345 Picadilly Lane, Jacksonville, Florida 32057-5410, 4.” ” Respondent participated in the placement of an advertisement in the St. Petersburg Times in or around April 1996, which read, “ERER TRIP TO GERMANY FOR TWO with 10K interest returned in full in 12 months sae “oe ] . UW with opportunity to make millions call Mr. Jacobson, C.P.A. (904) 731-0933.” 5. Respondent answered inquiries to the advertisement advising that a business venture, through Global Exploratidiis, Inc., was raising money to Tecover a train of art buried in Germany; that monies invested would be returned within a year through funds from pre-sold media rights; and that investors would receive a free ttip to Germany. 6. Respondent provided the names and telephone numbers of potential investors to the individual responsible for raising capital for the venture, but had no other involvement with the venture. 7. At least one investor failed to have his investment returned as promised. 8. Respondent allowed his name, C.P.A. designation and telephone number to be used in connection with the business venture of Global Explorations, Inc., but failed to verify the existence of the media contracts, failed to discuss the venture directly with the President or other officers of Global Explorations, Inc., failed to check references or to perform other due diligence. 9. Section 473.323(1)(f), Florida Statutes, states that advertising goods or services in a manner that is fraudulent, false, deceptive, or misleading in form or content shall constitute " grounds for which disciplinary actions may be taken. 10. Based upon the foregoing, Respondent is in violation of Section 473. 323(1)(f), Florida Srautes, and | is therefore subject to disciplinary actions. WHEREFORE, Petitioner respectfully requests that the Board of Accountancy enter an Order imposing one or more of the following penalties: revocation or suspension of Respondent's YW license, imposition of probation, imposition of an administrative fine and/or any other relief that ~ the Board deems appropriate. \ SIGNED this & day of COUNSEL FOR DEPARTMENT: Charles F. Tunnicliff Senior Attorney Florida Bar #0153831 Department of Business and Professional Regulation Northwood Centre 1940 N. Monroe St. Tallahassee, Florida 32399-0792 (850) 487-9629 CFT/mih 716/99 PCP: JR/SO/MM 6/2/99 7) 1999. Thomas G. Thomas Chief Attorney FILED Department of Business and Professional Requtation CLERK DATE DEPUTY CLERK Prsncyltflidele 7-15-44

Docket for Case No: 00-002412