" ~ FILED MAY 22 2001 Treasurer and insurance Com ner Docketed by: ( 4 THE TREASURER OF THE STATE OF FLORIDA DEPARTMENT OF INSURANCE TOM GALLAGHER ae IN THE MATTER OF ROBERT A. GREENBERG CASE NO.: 42187-01-AG / ADMINISTRATIVE COMPLAINT TO: ROBERT A. GREENBERG ROBERT A. GREENBERG 10520 NW 267" STREET 4725 NW 113™ AVENUE MIAMI, FLORIDA 33172 SUNRISE, FLORIDA 33323 * You, ROBERT A. GREENBERG, are hereby notified that pursuant to Chapter 626, Florida Statutes, the Insurance Commissioner of the State of Florida has caused to be made an investigation of your activities as an insurance agent in this State, as a result of which it is alleged: GENERAL ALLEGATIONS 1. You, ROBERT A. GREENBERG are currently licensed and eligible for licensure in this state asa life, variable annuity and health agent (0215), a life and health agent (0218), and as a health agent (0240). 2. At all times material to the dates and occurrences herein, you, ROBERT A. GREENBERG were eligible for licensure as an insurance agent in this State. 3. Atall times material to the dates and occurrences herein, “N.A.P.T.” was the acronym or pseudonym for a multitude of entities that engaged in the business of insurance, or operated as one or more Multiple Employer Welfare Arraligements (hereafter, “MEWAs”) in Florida, including: National Association of Physical Therapists National Association of Professionals & Technicians National Association of Professional Technical National Association of Professional Truckers National Association of Professional Traders National Association of Chiropractic Professionals National Association of Dental Professionals [Dental Division] National Tourism & Hospitality Association [Division] National Veterinarian Association National Real Estate Association [Division] Physician’s Choice Limited a/k/a Physician’s Choice, Ltd. . 4. Section 624.02, Florida Statutes defines “Insurance” as: “Insurance” is a contract whereby one undertakes to indemnify another or pay or allow a specified amount or a determinable benefit upon determinable contingencies. 5. Section 624.03, Florida Statutes defines “Insurer” as: “Insurer” includes every person engaged as indemnitor, surety, or contractor in the business of entering into contracts of insurance or annuity. 6. Section 624.09, Florida Statutes defines “Authorized”, “Unauthorized insurer” as: (1) An “authorized” insurer is one duly authorized by a subsisting certificate of authority issued by the department to transact insurance in this state. (2) An “unauthorized” insurer is one not so authorized | i 7. Section 624.10, Florida Statutes defines “Transacting insurance” as: “Transact” with AU TEE care respect to insurance includes any of the following, in addition to other applicable provisions of the code: (1) solicitation or inducement. (2) Preliminary negotiations. (3) Effectuation of a contract of insurance. (4) Transaction of matters subsequent to the effectuation of a contract of insurance and arising out of it. 8. Section 624.437(1), Florida Statutes defines “Multiple Employer Welfare Arrangement” (hereafter, “MEWA”) as: [ajn employee welfare benefit plan or any other arrangement which is established or maintained for the purpose of offering or providing health insurance benefits or any other benefits, described in s. 624.33, other than life insurance benefits, to the employees of two or more - employers, or to their beneficiaries. 9, All insurers and MEWAs are required by Florida Insurance Code to possess a Certificate of Authority from the Department in order to conduct business in this State. 10. At no time material to the dates and occurrences herein, did N.A.P.T. or any of the entities for which it was the acronym or pseudonym, possess a Certificate of Authority from the Department to engage in the business of insurance, or to operate as a MEWA, in Florida. 11. Neither N.A.P.T., nor any of the entities for which it was the acronym or pseudonym, was ‘ subject to any exception to the licensure requirement of the Florida Insurance Code in order to lawfully engage in the business of insurance or to operate as a MEWA, in Florida. COUNT I 12. All statements, claims, and allegations of Paragraphs 1 through 11, inclusive, are " incorporated herein by reference. 13. In or about March, 2000, you, ROBERT A. GREENBERG, contacted Sawgrass Dental of Sunrise, Florida, for the purpose of inducing it and its employees, including Melissa Bower, to enter into [a] health benefits contract(s) with N.A.P.T. { 14. In or about March, 2000 you, ROBERT A. GREENBERG, solicited and induced Sawgrass Dental and its employees, including Melissa Bower to enter into [a] health benefits contract(s) with N.A.P.T. 15. As part of your solicitation of Sawgrass Dental and its employees, you represented to it and to its employees, including Melissa Bower, that N.A.P.T. was a self-insured “association” and therefore exempt from the regulation and oversight of the Department by virtue of the federal Employee Retirement Income Security Act (hereafter, “ERISA”). 16. At the time that you made the representation set forth in the foregoing paragraph, you knew or should have known that it was false, as you knew or should have known that N.A.P.T. operated as an insurer or as a MEWA, and therefore, required a Certificate of Authority from the Department in order to transact business in Florida. 17. Inor about March, 2000, Sawgrass Dental and its participating employees, including Melissa Bower, did, based upon your solicitation, enter into [a] health benefits contract(s) with N.AP.T. 18. At the time of your solicitation, inducement, representations concerning, and sale of the N_AP.T. contract and at all times thereafter, N.A.P.T. was not authorized to transact insurance or MEWA business in Florida, and was not subject to any exception to the licensure requirement, of all of which you knew or should have known. COUNT II 19. All statements, claims, and allegations of Paragraphs 1 through 11, inclusive, are incorporated herein by reference. 20. In or about mid- 2000, you, ROBERT A. GREENBERG, contacted the Florida State Massage Therapy Association in Winter Park, Florida to solicit the statewide health insurance business of its membership. 21. Alternatively, in or about mid-2000, you, ROBERT A. GREENBERG, contacted the Florida State Massage Therapy Association in Winter Park, Florida to solicit and induce it to endorse to its statewide membership your sale to the membership of health benefit contracts issued by N.A.P.T. 4 22. As part of your solicitation of the Florida State Massage Therapy Association and its . membership, you represented to them that N.A.P.T. was a self-insured “association” and therefore exempt from the regulation and oversight of the Department by virtue of the federal Employee Retirement Income Security Act (hereafter, “ERISA”). 23. At the time that you made the representation set forth in the foregoing paragraph, you knew or should have known that it was false, as you knew or should have known that N.A.P.T. operated as an insurer or as a MEWA, and therefore, required a Certificate of Authority from the Department in order to transact business in Florida. 24. In or about September, 2000, one Sally Curtis of Cape Coral, Florida did, based upon your solicitation, enter into a health benefit contract with N.A.P.T. through you. 25. At the time of your solicitation, inducement, representations concerning, and sale of the N.A.P.T. contract, and at all times thereafter, N.A.P.T. was not authorized to transact insurance or MEWA business in Florida, and was not subject to any exception to the licensure requirement, all of which you knew or should have known. COUNT Ill 26. All statements, claims, and allegations of Paragraphs | through 11, inclusive, are incorporated herein by reference. 27. In or about mid- 2000, you, ROBERT A. GREENBERG, contacted the Florida State Massage Therapy Association in Winter Park, Florida to solicit the statewide health insurance business of its membership. 28. Alternatively, in or about mid-2000, you, ROBERT A. GREENBERG, contacted the Florida State Massage Therapy Association in Winter Park, Florida to solicit and induce it to endorse to its statewide membership your sale to the membership of health benefit contracts issued by N.A.P.T. 29. As part of your solicitation of the Florida State Massage Therapy Association and its membership, you represented to them that N.A.P.T. was a self-insured “association” and therefore exempt from the regulation and oversight of the Department by virtue of the federal Employee Retirement Income Security Act (hereafter, “ERISA”). - 30. At the time that you made the representation set forth in the foregoing paragraph, you knew or should have known that it was false, as you knew or should have known that N.A.P.T. operated as an insurer or asa MEWA, and therefore, required a Certificate of Authority from the Department in order to transact business in Florida. 31. In or about July, 2000, one Francella W. Fleming of Pembroke Pines, Florida did, based upon your solicitation, enter into a, health benefit contract with N.A.P.T. through you. 32. At the time of your solicitation, inducement, representations concerning, and sale of the N.A.P.T. contract, and at all times thereafter, N.A.P.T. was not authorized to transact insurance or MEWA business in Florida, and was not subject to any exception to the licensure requirement, all of which you knew or should have known. COUNT IV 33. All statements, claims, and allegations of Paragraphs | through 11, inclusive, are incorporated herein by reference. _ 34, In or about mid- 2000, you, ROBERT A. GREENBERG, contacted the Florida State Massage Therapy Association in Winter Park, Florida to solicit the statewide health insurance business of its membership. 35, Alternatively, in or about mid-2000, you, ROBERT A. GREENBERG, contacted the Florida State Massage Therapy Association in Winter Park, Florida to solicit and induce it to endorse to its statewide membership your sale to the membership of health benefit contracts issued by N.A.P.T. 36. As part of your solicitation of the Florida State Massage Therapy Association and its er pee membership, you represented to them that N.A.P.T. was a self-insured “association” and therefore exempt from the regulation and oversight of the Department by virtue of the federal Employee Retirement Income Security Act (hereafter, “ERISA”). . 37. At the time that you made the representation set forth in the foregoing paragraph, you knew or should have known that it was false, as you knew or should have known that N.A.P.T. operated as an insurer or as a MEWA, and therefore, required a Certificate of Authority from the Department in order to transact business in Florida. 38. In or about October, 2000, one Donna Rosenblum of Pembroke Pines, Florida did, based upon your solicitation, enter into a health benefit contract with N.A.P.T. through you. 39. At the time of your solicitation, inducement, representations concerning, and sale of the N.A-P.T. contract, and at all times thereafter, N.A.P.T. was not authorized to transact insurance or MEWA business in Florida, and was not subject to any exception to the licensure requirement, all of which you knew or should have known. COUNT V 40. All statements, claims, and allegations of Paragraphs 1 through 11, inclusive, are incorporated herein by reference. 41. In or about mid- 2000, you, ROBERT A. GREENBERG, contacted the Florida State Massage Therapy Association in Winter Park, Florida to solicit the statewide health insurance business of its membership. 42. Alternatively, in or about mid-2000, you, ROBERT A. GREENBERG, contacted the Florida State Massage Therapy Association in Winter Park, Florida to solicit and induce it to endorse to its statewide membership your sale to the membership of health benefit contracts issued by N.A.P.T. 43. As part of your solicitation of the Florida State Massage Therapy Association and its OP aie: statewide membership your sale to the membership of health benefit contracts issued by N.A.P.T. membership, you represented to them that N.A.P.T. was a self-insured “association” and therefore exempt from the regulation and oversight of the Department by virtue of the federal Employee Retirement Income Security Act (hereafter, “ERISA”). 44. At the time that you made the representation set forth in the foregoing paragraph, you knew or should have known that it was false, as you knew or should have known that N.A.P.T. operated as an insurer or as a MEWA, and therefore, required a Certificate of Authority from the Department in order to transact business in Florida. 45. In or about September, 2000, one D. Sue Bankosky of Naples, Florida did, based upon your solicitation, enter into a health benefit contract with N.A.P.T. through you. 46. At the time of your solicitation, inducement, representations concerning, and sale of the N.A.P.T. contract, and at all times thereafter, N.A.P.T. was not authorized to transact insurance or MEWA business in Florida, and was not subject to any exception to the licensure requirement, all of which you knew or should have known. COUNT VI 47. All statements, claims, and allegations of Paragraphs | through I1, inclusive, are incorporated herein by reference. 48. In or about mid- 2000, you, ROBERT A. GREENBERG, contacted the Florida State Massage Therapy Association in Winter Park, Florida to solicit the statewide health insurance business of its membership. ~~” 49, Alternatively, in or about mid-2000, you, ROBERT A. GREENBERG, contacted the Florida State Massage Therapy Association in Winter Park, Florida to solicit and induce it to endorse to its 50. As part of your solicitation of the Florida State Massage Therapy Association and its creer eee FORE rent Be RW State Massage Therapy Association i in Winter Park, Florida to solicit and induce it to endorse to its - statewide membership your sale to the membership of ‘health benefit contracts issued by NAPT. membership, you represented to them that N.A.P.T. was a self-insured “association” and therefore exempt from the regulation and oversight of the Department by virtue of the federal Employee Retirement Income Security Act (hereafter, “ERISA”). 51. At the time that you made the representation set forth in the foregoing paragraph, you knew or should have known that it was false, as you knew or should have known that N.A.P.T. operated as an insurer or asa MEWA, and therefore, required a Certificate of Authority from the Department in order to transact business in Florida. 52. In or about December, 2000, one Shirley Anne of Niceville, Florida did, based upon your solicitation, enter into a health benefit contract with N.A.P.T. through you. : 53. At the time of your solicitation, inducement, representations concerning, and sale of the N.A.P.T. contract, and at all times thereafter, NAPT. was not authorized to transact insurance or MEWA business in Florida, and was not subject to any exception to the licensure requirement, all of which you knew or should have known. COUNT VII 54. All statements, claims, and allegations of Paragraphs 1 through 11, inclusive, are incorporated herein by reference. 55. In or about mid- 2000, you, ROBERT A. GREENBERG, contacted the Florida State Massage ; Therapy Association in Winter I Park, Florida to solicit the statewide health insurance business of its : membership. 56. Alternatively, in or about mid-2000, you. ROBERT A GREENBERG, contacted the Florida - 57. As part of: your solicitation of the Florida State Massage Therapy Association and its Sat ae Serena membership, you represented to them that NAP. was a self-insured “association” and therefore exempt from the regulation and oversight of the Department by virtue of the federal Employee Retirement Income Security Act (hereafter, “ERISA”). 58. At the time that you made the representation set forth in the foregoing paragraph, you knew or should have known that it was false, as you knew or should have known that N.A.P.T. operated as an insurer or as a MEWA, and therefore, required a Certificate of Authority from the Department in order to transact business in Florida. 59. In or about June, 2000, one Teresa Cohen of Lake Mary, Florida did, based upon your solicitation, enter into a health benefit contract with N.A.P.T. through you. 60. At the time of your solicitation, inducement, representations concerning, and sale of the N.A.P.T. contract, and at all times thereafter, N.A.P.T. was not authorized to transact insurance or MEWA business in Florida, and was not subject to any exception to the licensure requirement, all of which you knew or should have known. BASED UPON ALL OF THE FOREGOING, IT IS THEREFORE CHARGED that you, ROBERT A. GREENBERG, have violated or are accountable under the following provisions of the. Florida Insurance Code and Rules of the State Treasurer and Insurance Commissioner, which violations constitute grounds for the revocation or suspension of your insurance licenses and eligibility for licensure: A). No person shall transact insurance in this state, or relative to a subject of i insurance resident, located, or rr to be performed i in this s state, without complying with the applicable provisions of this ~ Code. [Section 624.11, Florida Starts} B). No person shall act as an insurer, and no insurer or its agents, attorneys, subscribers, | or representatives shall directly or indirectly transact insurance in this state except as authorized by a subsisting certificate of authority issued to the insurer by the Department, except as to such transactions as are expressly otherwise provided for in this code [Section 624.401(1), Florida Statutes]; 10 Se eae HSA se REE AER C). No person shall, from offices or by personnel or facilities located in this state, or in any other state or country, directly or indirectly act as agent for, or otherwise aid on behalf of another, any insurer not then authorized to transact insurance in this state in: (a). The solicitation, negotiation, procurement, or effectuation of insurance or annuity contracts, or renewals thereof; (0). The dissemination of information as to coverage or rates; (c). The forwarding of applications; (d). The delivery of policies or contracts; (e). The inspection of risks; (f). The fixing of rates; (g). The investigation or adjustment of claims or losses; or (h). The collection or forwarding of premiums; or in any other manner represent or assist such an insurer in the transaction of insurance with respect to subjects of insurance resident, located, or to be performed in this state. [Section 626.901(1), Florida “ Statutes]; D). Ifan unauthorized insurer fails to pay in full or in part any claim or loss within the provisions of any insurance contract which is entered into in violation of this section, any person who knew or reasonably should have known that such contract was entered into in violation of this section and who solicited, negotiated, took application for, or effectuated such insurance contract is liable to the insured for the full amount of the claim or loss not paid. [Section 626. 9010), Florida Statutes] F). In addition to any other penalties provided i in thei insurance code any insurance eget licensed in this state who in this state represents or aids an unauthorized insurer in violation of s. 626.90 1 commits a misdemeanor of the second degree, punishable as provided in s. 775.082 or s. 775.083, and each such violator shall be liable, personally, jointly, and severally with any other person or persons liable 11 ~ a nascent a a RSS WE teense therefor, for payment of taxes payable on account of such insurance under s. 626.938. [Section 626.902, Florida Statutes]. F). No person shall engage in this state in any trade practice which is defined in this part as, or determined pursuant to s.626.951 or s.626.9561 to be, an unfair method or competition or an unfair or deceptive act or practice involving the business of insurance. [Section 626.9521(1), Florida Statutes}; G). Any person who violates any provision of this part shall be subject to a fine in an amount not greater than $2,500 for each non-willful violation and not greater than $20,000 for each willful violation. Fines’under this subsection may not exceed an aggregate amount of $10,000 for all non- willful violations arising out of the same action or an aggregate amount of $100,000 for all willful violations arising out of the same action. The fines authorized by this subsection may be imposed in addition to any other applicable penalty. [Section 626.9521(2), Florida Statutes}; H). Knowingly making, issuing, circulating, or causing to be made, issued, or circulated, any estimate, illustration, circular, statement, sales presentation, omission, or comparison which: ‘ 1. misrepresents the benefits, advantages, conditions, or terms of any insurance policy; 2. is a misrepresentation for the purpose of inducing, or tending to induce, the lapse, forfeiture, exchange, conversion, or surrender of any insurance policy; 3. uses any advertisement that would mislead « or otherwise cause a reasonable person to believe mistakenly that the state or r the Federal Goverment is responsible for the insurance j i AnH pe, sales. activities ‘of 2 any person c or r stands behind any p person’s s credit ¢ or r that the person, state, or the Federal Government s guarantees any retums on insurance products 0 or is a source of payment of any insurance obligation of or sold by any person. [Section 626.9541(1)(a), Florida Statutes]; 1). Knowingly making, publishing, disseminating, circulating, or placing before the . public, 12 4 ery SRA Florida Statutes]; 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. in the form of a notice, circular, pamphlet, letter, or poster, 3. over any radio 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. [Section 626.9541(1)(c), J). Knowingly: ‘ a. Filing with any supervisory or other public official, b. Making, publishing, disseminating, circulating, c. Delivering to any person, : : ; ' d. Placing before the public, e. Causing, directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the public, any false material statement [Section 626.9541(1)(e)1., Florida Statutes}: K). Knowingly making any false entry of a material fact in any book, report, or statement of any person, or r Knowingly omitting to make a true entry of any material fact pertaining to the business of such person in nany book, report, or statement of such person. [Section 626.9541(1)(e)2. “Florida Statutes]; L). Committing or erfoming with such foe as to indicate a general business Practice any a. Misrepresenting pertinent facts or ' insurance policy Provisions r i ing to coverages at issue; 13 shh gibt tie even ati b. Failing to acknowledge and act promptly upon communications with respect to claims; c. Denying claims without conducting reasonable investigations based upon available information; d. Failing to affirm or deny full or partial coverage of claims, and, as to partial coverage, the dollar amount or extent of coverage, or failing to provide a written statement that the claim is being investigated, upon the written request of the insured within 30 days after proof-of-loss statements have been completed; e, Failing to promptly provide a reasonable explanation in writing to the insured of the basis in the insurance policy, in relation to the facts or applicable law, for denial of a claim or for the offer of a compromise settlement; f. Failing to promptly notify the insured of any additional information necessary for the processing of a claim; or g. Failing to clearly explain the nature of the requested information and the “reasons why such information is necessary. [Section 626.9541(1)(1)3., Florida Statutes]. WHEREFORE, you, ROBERT A. GREENBERG, are hereby notified that the Treasurer and Insurance Commissioner intends to enter 2 an 1 Order: I, Revoking or ‘suspending y your licenses as an insurance agent in this state pursuant to Sections 626, 61] and 626. 621, Florida Statutes; I. “Imposing a an administrative penalty for the willful violation of Section 626. 7010), Florida Statutes ? . whe mM. , "Holding you personaly responsible for the payment of all unpaid claims of those F lorida residents to whom you or the agents working under you, sold contracts or policies issued by N. AP. T., in accordance with Section 626. 901(2), Florida Statutes: 14 bis ae is _ Counsel acting as the Agency Clerk, Department of Insurance. If served by U. S. Mail the Petition or Election should be addressed t to the Florida Department of Insurance at 612 Larson Buildi IV. Holding you personally responsible for the payment of taxes on account of the coverage afforded under the N.A.P.T. contracts or policies pursuant to Section 626.938, Florida Statutes, in accordance with Section 626.902(2), Florida Statutes; . V. Imposing an administrative penalty for the willful violation of Section 626.9541(1)(a), Florida Statutes; VI. Imposing an administrative penalty for the willful violation of Section 626.954 1(1)(b), Florida Statutes; VII. Imposing an administrative penalty for the willful violation of Section 626.9541 (1)(e)L., Florida Statutes; VIE. Imposing an administrative penalty for the willful violation of Section 626.9541(1)(e)2., Florida Statutes; i. Imposing an administrative penalty for the willful violation of Section 626.9541(1)(0)2., Florida Statutes. NOTICE OF RIGHTS Pursuant to Sections 120.569 and 120.57, Florida Statutes and Rule Chapter 28-106, Florida Administrative Code (F.A.C.), you have a right to request a proceeding to contest this action by the Department. You may elect a proceeding by completing the attached Election of Rights form or filing a Petition. Your Petition or Election ofa proceeding must be in writing and must be filed with the General _ Tallahas See, F orida 32399-0333. if Express Mail or hand delivery i is utilized, the Petition or Election should be _ delivered to 612 Larson Building, 200 East Gaines Street, Tallahassee, Florida 32399-0333. The Petition or Election must be received by, and filed in the Department within twenty-one (21) days of the date of your receipt of this notice. 15 YOUR FAILURE TO RESPOND TO THIS ADMINISTRATIVE COMPLAINT WITHIN TWENTY-ONE (21) DAYS WILL CONSTITUTE A WAIVER OF YOUR RIGHT TO REQUEST A PROCEEDING ON THE MATTERS ALLEGED HEREIN, AN ORDER OF REVOCATION WILL BE ENTERED AGAINST YOU AND MONETARY ADMINISTRATIVE PENALTIES WILL BE ASSESSED. If a proceeding: is requested and there is no dispute of fact the provisions of Section 120.57(2), Florida Statutes would apply. In this regard you may submit oral or written evidence in opposition to the action taken by this agency or a written statement challenging the grounds upon which the agency has relied. While a hearing is normally not required in the absence or 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. If you dispute material facts which are the basis for this agency's action you may request a formal adversarial proceeding pursuant to Sections 120.569 and 120.57(1), Florida Statutes. If you request this type of proceeding, the request must comply with all of the requirements of Rule Chapter 28-106, F.A.C. and contain: . . a) 6 6A statement identifying with particularity the allegations of the Department which you dispute and the nature of the dispute; b) An explanation of what relief you are seeking and believe you are entitled to; 2) Any « other information which you. contend i is material. apts These proceedings are held before a State administrative law judge of the Division of Administrative __ Hearings. Unless the majority of witnesses are located elsewhere the Department wil request that the wake. _ hearing be conducted i in Tallahassee. If: you request a shearing, you have the right to be represented by counsel, or other “qualified: representative, to take! testimony, to call and cross-examine witnesses, 5, and to ha subpoena and Subpoena duces tecum issued on n your behalf. Youa are hereby notifi at mediation under section 120.573, Florida Statutes, is not available. 16 remem pn i Failure to follow the procedure outlined with regard to your response to this notice may result in the request being denied. All prior correspondence in this matter shall be considered freeform agency action, and no such correspondence shall operate as a valid request for an administrative proceeding. Any request for administrative proceeding received prior to the date of this notice shall be deemed abandoned unless timely renewed in compliance with the guidelines as set out above. You are hereby further notified that you have a right to request an advisory opinion or information letter as to your status and as to the éffect of certain acts and transactions under the Retirement Income Security Act (ERISA) pursuant to ERISA Proc. 76-1, from the Pension and Welfare Benefits Administration of the United States Department of Labor, 200 Constitution Avenue NW, Washington, D.C. 20210 : | QND ; : DATED and SIGNED this z day of May, 2001. Kenney Shipley - Deputy Insurance Commissioner 4 ot see BF 2 | ' ! : a j a cc Ve ee sehen nesses CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been sent by Certified Mail thisQ2™ fay of May, 2001 to: ROBERT A. GREENBERG ROBERT A. GREENBERG 10520 NW 26™ STREET - 4725 NW 113™ AVENUE MIAMI, FLORIDA 33172 SUNRISE, FLORIDA 33323 LUKE S. BROWN ; : Senior Executive Attorney : Unauthorized Entities Supervisor : ‘Florida Department of Insurance ‘ _ 200 East Gaines Street, 6 Floor oe : : Tallahassee, Florida 32399-0333 Telephone: 850/413-4040 Fax: 850/ 488-2632

Docket for Case No: 01-002867PL