STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, : FLORIDA REAL ESTATE COMMISSION FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, DIVISION OF REAL ESTATE, Petitioner, pr» Jeiqel vs. FDBPR Case N° 2002005449 2002000951 ANNA E. OWENS, Respondent. / ADMINISTRATIVE COMPLAINT State of Florida, Department of Business and Professional Regulation, Division of Real Estate (“Petitioner”) files this Administrative Complaint against Anna E. Owens (“Respondent”) and alleges: ESSENTIAL ALLEGATIONS OF MATERIAL FACT 1. Petitioner is a state government licensing and regulatory agency charged with the responsibility and duty to prosecute Administrative Complaints pursuant to the laws of the State of Florida, in particular Section 20.165 and Chapters 120, 455 and 475, of the Florida Statutes and the tules promulgated pursuant thereto. 2. Respondent is and was at all times material hereto a licensed Florida real estate salesperson, issued license number 646586 in accordance with Chapter 475 of the Florida Statutes. 3. The last license issued was as a salesperson with Home Builders Showcase, Inc., 15125 Heronglen Drive, Lithia, Florida 33547. FDBPR v. Anna E. Owens Case No. 2002005449 Administrative Complaint 4. During the course of an official investigation, Petitioner discovered that Respondent employs a mortgage fraud scheme. 5. Respondent’s mortgage fraud scheme includes, but is not limited to, providing the lender or mortgage broker with altered or completely fabricated documents such as W-2 forms; credit reports; lease agreements; and payroll records. 6. Respondent employed this scheme while providing services to: . Miguel Arias; . Charles Cooper; . Johnny Williams; . Eleida Williams; . Tony Johnson; and . Tharastine Johnson. COUNT I Based upon the foregoing, Respondent is guilty of fraud, misrepresentation, concealment, false promises, false pretenses, dishonest dealing by trick, scheme or device, culpable negligence, or breach of trust in any business transaction in violation of Section 475.25(1)(b), Florida Statutes. 7. 8. ADDITIONAL ESSENTIAL ALLEGATIONS OF MATERIAL FACT Petitioner realleges and incorporates herein Paragraphs One throughThree above. On or about February 17, 1987, the Department of Insurance and Treasurer (DIT) issued FDBPR v. Anna E. Owens Case No. 2002005449 Administrative Complaint a Final Order against Respondent, suspending Respondent’s license with DIT for six months. 9. Subsequently, Respondent failed to reveal on her application for a real estate salesperson’s license that DIT had taken action against Respondent’s license with DIT. COUNT II Based upon the foregoing, Respondent is guilty of fraud, misrepresentation, concealment, false promises, false pretenses, dishonest dealing by trick, scheme or device, culpable negligence, or breach of trust in any business transaction in violation of Section 475.25(1)(b), Florida Statutes. COUNT Il Based upon the foregoing, Respondent has obtained a license by means of fraud, misrepresentation, or concealment in violation of Section 475.25(1)(m), Florida Statutes. WHEREFORE, Petitioner respectfully requests the Florida Real Estate Commission, or the Department of Business and Professional Regulation, as may be appropriate, to issue a Final Order as final agency action finding the Respondent(s) guilty as charged. The penalties which may be imposed for violation(s) of Chapter 475 of the Florida Statutes, depending upon the severity of the offense(s), include: revocation of the license or registration or permit; suspension of the license, registration or permit for a period not to exceed ten (10) years, imposition of an administrative fine of up to $1,000 for each count or offense; imposition of investigative costs; issuance of a reprimand; imposition of probation subject to terms including, but not limited to, requiring the licensee, registrant or permitee to complete and pass additional real estate education courses; publication; or FDBPR v. Anna E. Owens Case No. 2002005449 Administrative Complaint any combination of the foregoing which may apply. See Section 475.25(1), Florida Statutes (2001) and Florida Administrative Code Rule 61J2-24.001. The penalties which may be imposed for violation(s) of Chapter 455 of the Florida Statutes, depending upon the severity of the offense(s), include: revocation of the license, registration, or permit; suspension of the license, registration, or permit for a period not to exceed ten (10) years; imposition of an administrative fine of up to $5,000 for each count or offense; imposition of investigative costs; issuance of a reprimand; imposition of probation subject to terms including, but not limited to, requiring the licensee, registrant, or permitee to complete and pass additional real estate education courses; publication; restriction of practice; injunctive or mandamus relief; imposition of a cease and desist order; or any combination of the foregoing which may apply. See Section 455.227, Florida Statutes (2001) and Florida Administrative Code Rule 61J2-24.001. SIGNED this__ 23 /*? dayor Hltac Oo 2003. Department of Business and Professional Regulation mtn oy oF p PILED - By: . Pp, Director, Division of Real Estate Prison CO SSonyy p oF Rear Esta tg lations FDBPR v. Anna E. Owens Case No. 2002005449 Administrative Complaint ATTORNEY FOR PETITIONER LORENZO LEVEL, Senior Attorney Florida Bar N° 0165123 Division of Real Estate Department of Business and Professional Regulation, Legal Section - Suite N 802 Hurston Bldg. North Tower 400 West Robinson Street Orlando, Florida 32801-1772 (407) 481-5632 (407) 317-7260 FAX LL/ PCP: MV/JR 3/03 NOTICE TO RESPONDENTS PLEASE BE ADVISED that mediation under Section 120.573 of the Florida Statutes, is not available for administrative disputes involving this type of agency action. PLEASE BE FURTHER ADVISED that pursuant to this Administrative Complaint you may request, within the time proscribed, a hearing to be conducted in this matter in accordance with Sections 120.569 and 120.57 of the Florida Statutes; that you have the right, at your option and expense, to be represented by counsel or other qualified representative in this matter; and that you have the right, at your option and expense, to take testimony, to call and cross-examine witnesses, and to have subpoena and subpoena duces tecum issued on your behalf if a formal hearing is requested. PLEASE BE FURTHER ADVISED that if you do not file an Election of Rights form or some other responsive pleading with the Petitioner within twenty-one (21) days of receipt of this Administrative Complaint, the Petitioner will file with the Florida Real Estate Commission a motion requesting an informal hearing and entry of an appropriate Final Order which may result in the suspension or revocation of your real estate license or registration. Please see the enclosed Explanation of Rights and Election of Rights form.

Docket for Case No: 03-002019PL