DEPARTMENT OF FINANCIAL SERVICES Docketed by: a Tom GALLAGHER CHIEF FINANCIAL OFFICER JN THE MATTER OF: : CASE NO.: 71299-03-AG LEON NICHOLAS YANNAROUDIS / ADMINISTRATIVE COMPLAINT TO: LEON NICHOLAS YANNAROUDIS 1311 Ironworks Lane Tarpon Springs, Florida 34689-2935 LEON NICHOLAS YANNAROUDIS c/o The Insurcare Group, Inc. 1569 Main Street Dunedin, Florida 34698-4650 You, LEON NICHOLAS YANNAROUDIS, are hereby notified that the Chief Financial Officer of the State of Florida has caused to be made an investigation of your 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, you, LEON NICHOLAS YANNAROUDIS, currently are licensed in this state as a Life, Health and Variable Annuity (2- 15), Life (2-16), Life and Health (2-18), Health (2-40), and Resident Customer Representative (4-40) agent. Your license identification number is A291677. 2. At all times pertinent to the dates and occurrences referred to herein, you, LEON NICHOLAS YANNAROUDIS, were licensed in this state as an insurance agent and were affiliated with The Insurcare Group, Inc. 3. Pursuant to Chapter 626, Florida Statutes, and the Florida Insurance Code, the Florida Department of Financial Services has jurisdiction over your insurance licenses and appointments. 4. At all times material to the dates and occurrences herein, TRG was the acronym or pseudonym for a number of entities that engaged in the business of insurance, or operated as one or more Multiple Employer Welfare Arrangements (hereafter, “MEWaAs’) in Florida, including, but not limited to: (a) T.R.G. Marketing, LLC (b) _‘T.R.G. Administration, LLC (c) The Redwood Group, LLC 5. Atall times material to the dates and occurrences herein, TRG was an entity unauthorized to conduct insurance business in the state of Florida. COUNT I 6. The above General Allegations are hereby realleged and fully incorporated herein by reference. 7. On or about November 7, 2000, you, LEON NICHOLAS YANNAROUDIS, solicited and induced CGS, of Clearwater, Florida, to enter into a health benefit contract with TRG. 8. Asa direct or indirect result of you, LEON NICHOLAS YANNAROUDIS, representing or aiding TRG, an unauthorized insurer or MEWA, CGS has incurred medical bills that have not been paid. 9. At the time of your, LEON NICHOLAS YANNAROUDIS, solicitation, inducement, and representations concerning the aforementioned TRG health benefit plan of CGS, and all times thereafter, TRG was not authorized to transact insurance or MEWA business in Florida, and was not subject to any exception to the Florida Insurance Code licensure requirements. IT IS THEREFORE CHARGED that you, LEON NICHOLAS YANNAROUDIS, have .. violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Florida Department of Financial Services, which constitute grounds for the suspension or revocation of your licenses and appointments as an insurance agent: (a) No person shall transact in this State, or relative to a subject of insurance resident, located, or to be performed in this state, without complying with the applicable provisions of this code. [Section 624.11, Florida Statutes]. (b) | Demonstrated lack of fitness or trustworthiness to engage in the business of insurance. [Section 626.611(7), Florida Statutes]. (c) Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment. [Section 626.611(8), Florida Statutes]. (d) Violation of any provision of this Code or any law applicable to the business of insurance in the course of dealing under the license or appointment. [Section 626.621(2), Florida Statutes]. (ce) Inthe conduct of business under the license or appointment, engaging 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 injury or loss to the public or detrimental to the public interest. [Section 626.621(6), Florida Statutes]. (f) No person shall, from offices or by personnel or facilities located in this state... directly or indirectly act as an agent for, or otherwise represent or aid on behalf of another, any insurer not then authorized to transact such insurance in this state. [Section 626.901(1), Florida Statutes]. WHEREFORE, you, LEON NICHOLAS YANNAROUDIS, are hereby notified that the. . Chief Financial Officer intends to enter an Order suspending or revoking your licenses and appointments as an insurance agent or to impose such penalties as may provided under the provisions of Sections 626.611, 626.621, 626.681, 626.691, and 626.901, Florida Statutes, under the other referenced sections of the Florida Statutes as set out in this Administrative Complaint, and under the provisions of Rule 4-231, Florida Administrative Code. You are further notified that any order entered in this case revoking or suspending any license or eligibility for licensure held by you shall also apply to all other licenses and eligibility held by you under the Florida Insurance Code. 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 Rule 28-107, 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/or a petition for administrative hearing will suffice as a written request. The request must be filed with the General Counsel as acting Agency Clerk, at the Florida Department of Financial Services, 612 Larson Building, 200 East Gaines Street, Tallahassee, Florida 32399-0333. The Department must receive your written response 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. YOUR FAILURE TO RESPOND IN WRITING 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 AN ORDER OF REVOCATION WILL BE ENTERED AGAINST YOU. If you request a proceeding, you must provide information that complies with the requirements of Rule 28-107.004, Florida Administrative Code. As noted above, completion of the attached Election of Proceeding form conforms to these requirements. Specifically, your response must contain: (a) The name and address of the party making the request, for purpose of service; (b) A statement that the party is requesting a hearing involving disputed issues of material fact, or a hearing not involving disputed issues of material fact; and, (c) A reference to the notice, order to show cause, administrative complaint, or other communication that the party has received from the agency. 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 a State administrative law judge of the Division of Administrative Hearings. Unless the majority of witnesses are located elsewhere, the Department will request that the hearing be conducted in Tallahassee, Florida. 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 freeform 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 prior to 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 until the response has been received by the Department of Financial Services. DATED this 6 7A day of Octe boy , 2003. KAREN CHANDLER Deputy Chief Financial Officer CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing Administrative Complaint and following Election of Proceeding has been furnished to LEON NICHOLAS YANNAROUDIS, 1311 Ironworks Lane, Tarpon Springs, Florida 34689-2935, and LEON NICHOLAS YANNAROUDIS, c/o The Insurcare Group, Inc., 1569 Main Street Dunedin, Florida 34698- 4650, by restricted U.S. Certified Mail this @-fA day of Oc-#ddar——«, 2003. Speytrye Greg S. M Florida Department of Financial Services Division of Legal Services 200 East Gaines Street 612 Larson Building Tallahassee, Florida 32399-0333 (850) 413-4180 Florida Bar Number 0131369 COMPLETE THIS SECTION ON DELIVERY won FAbD SAL WHY 2700 2641 3. Service Typp CERTIFIED MAIL 4, Restricted Delivery? (Extra Fee) Sllves 1. Article Addressed to: Sai tion LEON NICHOLAS YANNAROUDIS 1311 IRONWORKS LANE , AG AC 34689-2935 71299-03- TARPON SPRINGS, FL 10/06/2003 Pe . Marr y PS Form 3811 WH 2001 J Domestic Return Receipt

Docket for Case No: 03-004232PL