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DEPARTMENT OF FINANCIAL SERVICES vs ANGELA KAY BROWN, 04-002966PL (2004)

Court: Division of Administrative Hearings, Florida Number: 04-002966PL Visitors: 7
Petitioner: DEPARTMENT OF FINANCIAL SERVICES
Respondent: ANGELA KAY BROWN
Judges: LARRY J. SARTIN
Agency: Department of Financial Services
Locations: West Palm Beach, Florida
Filed: Aug. 20, 2004
Status: Closed
Settled and/or Dismissed prior to entry of RO/FO on Tuesday, November 30, 2004.

Latest Update: Dec. 23, 2024
FILED DEPARTMENT OF FINANCIAL SERVICES MAY 25 2004 Docketed by: TOM GALLAGHER CHIEF FINANCIAL OFFICER IN THE MATTER OF: oY V4 PL - CASE NO.: 76349-04-AG ANGELA KAY BROWN ADMINISTRATIVE COMPLAINT TO: ANGELA KAY BROWN 4607 Arlette Court Lake Worth, Florida 33461 ANGELA KAY BROWN 1888 N. Federal Hwy. Boyton Beach, Florida 33435 You, ANGELA KAY BROWN, license I.D. #A031718, 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: 4 GENERAL ALLEGATIONS 1. Pursuant to Chapter 626, Florida Statutes, you, ANGELA KAY BROWN, are currently licensed in this state as a Life Including Variable Annuity Agent (2-14), Life Including Variable Annuity & Health Agent (2-15), Life & Health Agent (2-18), General Lines Agent (Property & Casualty) (2-20), and a Health Agent (2-40). 2. At all times pertinent to the dates and occurrences referred to herein, you, ANGELA KAY BROWN, were licensed in this state as a Life Including Variable Annuity Agent (2-14), Life Including Variable Annuity & Health Agent (2-15), Life & Health Agent (2-18), General Lines Agent (Property & Casualty) (2-20), and a Health Agent (2-40). 3. Pursuant to Chapter 626, Florida Statutes, the Florida Department of Financial Services (hereinafter “Department”) has jurisdiction over your insurance licenses and appointments. 4, At all times relevant to the dates and occurrences referred to herein, you, ANGELA KAY BROWN, were President and primary agent of Brown Insurance Associates, Inc., a Florida corporation. 5. At all times relevant to the dates and occurrences herein, all funds received by you, ANGELA KAY BROWN, from consumers or on behalf of consumers representing premiums for insurance policies, were trust funds pursuant to Section 626.561 (1), Florida Statutes, and were received in a fiduciary capacity and were to be accounted for and paid over to the insurer, insured or others persons entitled thereto in the regular course of business. COUNT I 6. The above general allegations are hereby realleged and fully incorporated herein by reference. 7. On or about November 15, 2002, you, ANGELA KAY BROWN, accepted a cash down payment in the amount of FOUR HUNDRED EIGHTY-NINE AND 00/100 ($489.00) DOLLARS from S.D, of West Palm Beach, Florida, for an automobile insurance policy with Florida Automobile Joint Underwriting Association (FAJUA). 8. You, ANGELA KAY BROWN, furnished S.D. with a receipt numbered 055101, acknowledging the down payment. 9. You, ANGELA KAY BROWN, failed to properly submit the premium and application to the insurance company, thereby leaving S.D without insurance. IT IS THEREFORE CHARGED that you, ANGELA KAY BROWN, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Financial Services which constitute grounds for the suspension or revocation of your licenses and appointments: (a) All premiums, return premiums, or other funds belonging to insurers or others received by an agent, customer representative, or adjuster in transactions under his or her license are trust funds received by the licensee in a fiduciary capacity. An agent shall keep the funds belonging to each insurer for which he or she is not appointed, other than a surplus lines insurer, in a separate account so as to allow the department to properly audit such funds. The licensee in the applicable regular course of business shall account for and pay the same to the insurer, insured, other person entitled there to. Section 626.561(1), Florida Statutes; (b) Any agent, customer representative, or adjuster who, not being lawfully entitled thereto, either temporarily or permanently diverts or misappropriates such funds or any portion thereof or deprives the other person of a benefit therefrom commits...(b) If the funds diverted or misappropriated are more than $300, but less than $20,000, a felony of the third degree, punishable as provided in s.775.082, s. 775.083, or s. 775.084. Section 626.561(3)(b), Florida Statutes; (c) Demonstrated lack of fitness or trust worthiness to engage in the business of insurance. Section 626.611 (7), Florida Statutes; (d) Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626.611 (9), Florida Statutes; (e) Misappropriation, conversion, or unlawful withholding of moneys belonging to insurers or insureds or beneficiaries or to others and received in conduct of business under the license or appointment. Section 626.611(10), Florida Statutes; (f 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 appointment. Section 626.621(2), Florida Statutes; , (g) Failure or refusal, upon demand, to pay over to any insurer he or she represents or has represented any money coming into his or her hands belonging to the insurer. Section 626.621(4), Florida Statutes; (h) Knowingly collecting any sum as a premium or charge for insurance, which is not then provided, or is not in due course to be provided, subject to acceptance of the risk by the insurer, by an insurance policy issued by an insurer as permitted by this code. Section 626.9541(1)(0)1, Florida Statutes. COUNT II 10. The above general allegations are hereby realleged and fully incorporated herein by reference. 11. On or about May 25, 2003, you, ANGELA KAY BROWN, accepted a cash down payment in the amount of ONE HUNDRED SIXTY-FOUR AND 00/100 ($164.00) DOLLARS from J.T., of Delray Beach, Florida, for an automobile insurance policy with Vesta Fire Insurance Company (Space Coast Underwriters). You, ANGELA KAY BROWN, provided J.T. with a receipt with the deposit amount. 12. On or about July 2, 2003, you, ANGELA KAY BROWN, accepted a cash payment in the amount of ONE HUNDRED SEVEN AND 20/100 ($107.20) DOLLARS, from J.T. for two months of premium payments. You, ANGELA KAY BROWN, wrote “paid” on his notice of cancellation from Vesta Fire Insurance Company as a receipt. 13. On or about September 13, 2003, you, ANGELA KAY BROWN, accepted a cash payment in the amount of SIXTY-THREE AND 83/100 ($63.83) DOLLARS, from J.T. as the final payment for his six (6) month policy, terminating on November 25, 2003. You, ANGELA KAY BROWN, gave him a receipt numbered 719639. 14, On or about October 4, 2003, J.T. was involved in an automobile accident. The insurance company denied his claims because his coverage terminated on July 24, 2003. 15. You, ANGELA KAY BROWN, failed to properly submit policy premiums to the insurance company, thereby leaving your client without insurance. IT IS THEREFORE CHARGED that you, ANGELA KAY BROWN, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Financial Services which constitute grounds for the suspension or revocation of your licenses and appointments: (a) All premiums, return premiums, or other funds belonging to insurers or others received by an agent, customer representative, or adjuster in transactions under his or her license are trust funds received by the licensee in a fiduciary capacity. An agent shall keep the funds belonging to each insurer for which he or she is not appointed, other than a surplus lines insurer, in a separate account so as to allow the department to properly audit such funds. The licensee in the applicable regular course of business shall account for and pay the same to the insurer, insured, other person entitled there to. Section 626.561(1), Florida Statutes; (b) Any agent, customer representative, or adjuster who, not being lawfully entitled thereto, either temporarily or permanently diverts or misappropriates such funds or any portion thereof or deprives the other person of a benefit therefrom commits...(b) If the funds diverted or misappropriated are more than $300, but less than $20,000, a felony of the third degree, punishable as provided in s.775.082, s. 775.083, or s. 775.084. Section 626.561(3)(b), Florida Statutes; (c) Demonstrated lack of fitness or trust worthiness to engage in the business of insurance. Section 626.611 (7), Florida Statutes; (d) Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626.611 (9), Florida Statutes; (e) Misappropriation, conversion, or unlawful withholding of moneys belonging to insurers or insureds or beneficiaries or to others and received in conduct of business under the license or appointment. Section 626.611(10), Florida Statutes; 63) 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 appointment. Section 626.621(2), Florida Statutes; (g) Failure or refusal, upon demand, to pay over to any insurer he or she represents or has represented any money coming into his or her hands belonging to the insurer. Section 626.621(4), Florida Statutes; (h) Knowingly collecting any sum as a premium or charge for insurance, which is not then provided, or is not in due course to be provided, subject to acceptance of the risk by the insurer, by an insurance policy issued by an insurer as permitted by this code. Section 626.9541(1)(o)1, Florida Statutes. COUNT IIT 16. The above general allegations are hereby realleged and fully incorporated herein by reference. 17. Onor about July 30, 2003, you, ANGELA KAY BROWN, accepted a check payment of ONE THOUSAND THREE HUNDRED FIVE AND 00/100 ($1,305.00) DOLLLARS from N.H., owner of C.C.U. in Boca Raton, Florida, for the renewal of his worker’s compensation insurance with Florida Worker’s Compensation Joint Underwriting Association (FWCJUA). 18. You, ANGELA KAY BROWN, failed to properly submit the renewal premium to FWCIJUA, thereby leaving your client without worker’s compensation insurance. IT IS THEREFORE CHARGED that you, ANGELA KAY BROWN, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Financial Services which constitute grounds for the suspension or revocation of your licenses and appointments: (a) All premiums, return premiums, or other funds belonging to insurers or others received by an agent, customer representative, or adjuster in transactions under his or her license are trust funds received by the licensee in a fiduciary capacity. An agent shall keep the funds belonging to each insurer for which he or she is not appointed, other than a surplus lines insurer, in a separate account so as to allow the department to properly audit such funds. The licensee in the applicable regular course of business shall account for and pay the same to the insurer, insured, other person entitled there to. Section 626.561(1), Florida Statutes; (b) Any agent, customer representative, or adjuster who, not being lawfully entitled thereto, either temporarily or permanently diverts or misappropriates such funds or any portion thereof or deprives the other person of a benefit therefrom commits. ..(b) If the funds diverted or misappropriated are more than $300, but less than $20,000, a felony of the third degree, punishable as provided in s.775.082, s. 775.083, or s. 775.084. Section 626.561(3)(b), Florida Statutes; (c) Demonstrated lack of fitness or trust worthiness to engage in the business of insurance. Section 626.611 (7), Florida Statutes; (d) Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626.611 (9), Florida Statutes; (e) Misappropriation, conversion, or unlawful withholding of moneys belonging to insurers or insureds or beneficiaries or to others and received in conduct of business under the license or appointment. Section 626.611(10), Florida Statutes; (ff) 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 appointment. Section 626.621(2), Florida Statutes; (g) Failure or refusal, upon demand, to pay over to any insurer he or she represents or has represented any money coming into his or her hands belonging to the insurer. Section 626.621(4), Florida Statutes; (h) Knowingly collecting any sum as a premium or charge for insurance, which is not then provided, or is not in due course to be provided, subject to acceptance of the risk by the insurer, by an insurance policy issued by an insurer as permitted by this code. Section 626.9541(1)(0)1, Florida Statutes. COUNT IV 19. The above general allegations and paragraphs sixteen (16) through eighteen (18) are hereby realleged and fully incorporated herein by reference. 20. On or about August 13, 2003, you, ANGELA KAY BROWN, sent via facsimile, a Worker’s Compensation Certificate of Liability copy to C.D., Chief Financial Officer of JWR Construction Services. 21. The certificate stated that C.C.U. was insured by FWJUA under policy number WCO-0801-03. The certificate was signed by you, ANGELA KAY BROWN, and displayed the name of the sender as Brown Insurance. 22. You, ANGELA KAY BROWN, provided the false Worker’s Compensation Certificate of Liability knowing that C.C.U was not in fact covered by FWJUA. As a result thereof, you, ANGELA KAY BROWN exposed JWR Construction Services to potential risk and liability. IT IS THEREFORE CHARGED that you, ANGELA KAY BROWN, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Financial Services which constitute grounds for the suspension or revocation of your licenses and appointments: (a) If the license or appointment is willfully used, or to be used, to circumvent any of the requirements or prohibitions of this code. Section 626.611(4), Florida Statutes; (b) — Willfull 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 dissimination of information or advertising. Section 626.611(5), Florida Statutes; (c) Demonstrated lack of fitness or trust worthiness to engage in the business of insurance. Section 626.611 (7), Florida Statutes; (d) Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626.611 (9), Florida Statutes; (e) Willful failure to comply with, or willful violation of, any proper order or rule of the department, commission, or office or willful violation of any provision of this code. Section 626.611(13), Florida Statutes; . (f) 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 appointment. Section 626.621(2), Florida Statutes. COUNT V 23. The above general allegations are hereby realleged and fully incorporated herein by reference. 24, On or about August 18, 2003, you, ANGELA KAY BROWN, sent via facsimile, a Certificate of Liability copy to R.A., Executive Vice President, of Adler Group Construction (Adler). 25. The certificate stated that Pointe Site Development, a sub-contractor for Adler, was insured by TAPCO under policy number TPC-25632 for Commercial General Liability. The certificate was signed by you, ANGELA KAY BROWN, and displayed the name of the sender as Brown Insurance. 26. You, ANGELA KAY BROWN, provided the false Certificate of Liability knowing that Pointe Site Development was not in fact covered by TAPCO. As a result thereof, you, ANGELA KAY BROWN exposed Adler to potential risk and liability. IT IS THEREFORE CHARGED that you, ANGELA KAY BROWN, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Financial Services which constitute grounds for the suspension or revocation of your licenses and appointments: (a) If the license or appointment is willfully used, or to be used, to circumvent any of the requirements or prohibitions of this code. Section 626.61 1(4), Florida Statutes; (b) Willfull 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 dissimination of information or advertising. Section 626.611(5), Florida Statutes; (c) Demonstrated lack of fitness or trust worthiness to engage in the business of insurance. Section 626.611 (7), Florida Statutes; (d) Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626.611 (9), Florida Statutes; (e) Willful failure to comply with, or willful violation of, any proper order or rule of the department, commission, or office or willful violation of any provision of this code. Section 626.611(13), Florida Statutes; (63) 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 appointment. Section 626.621(2), Florida Statutes. COUNT VI 27. The above general allegations and paragraphs twenty-three (23) through twenty- six (26) are hereby realleged and fully incorporated herein by reference. 28. On or about August 18, 2003, you, ANGELA KAY BROWN, sent via facsimile, a Worker’s Compensation Certificate of Liability copy to R.A., Executive Vice President of Adler. 29. The certificate stated that Pointe Site Development was insured by CEIB under policy number W/203154 for Worker’s Compensation. The certificate was signed by you, ANGELA KAY BROWN, and displayed the name of the sender as Brown Insurance. 30. You, ANGELA KAY BROWN, provided the false Certificate of Liability knowing that Pointe Site Development was not in fact covered by CEIB Insurance. As a result thereof, you, ANGELA KAY BROWN exposed Adler Group Construction to potential risk and liability. 10 IT IS THEREFORE CHARGED that you, ANGELA KAY BROWN, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Financial Services which constitute grounds for the suspension or revocation of your licenses and appointments: (a) If the license or appointment is willfully used, or to be used, to circumvent any of the requirements or prohibitions of this code. Section 626.611(4), Florida Statutes; (b) Willfull 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 dissimination of information or advertising. Section 626.611(5), Florida Statutes; (c) Demonstrated lack of fitness or trust worthiness to engage in the business of insurance. Section 626.611 (7), Florida Statutes; (d) Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626.611 (9), Florida Statutes; (e) Willful failure to comply with, or willful violation of, any proper order or rule of the department, commission, or office or willful violation of any provision of this code. Section 626.611(13), Florida Statutes; (f) 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 appointment. Section 626.621(2), Florida Statutes. COUNT VII 31. The above general allegations are hereby realleged and fully incorporated herein by reference. 32. On or about September 29, 2003, you, ANGELA KAY BROWN, sent via facsimile, a Certificate of Liability copy to G.A., President of Supreme Builders, Inc (Supreme). 33. The certificate stated that Caldwell Air Conditioning and Heating, a sub- contractor of Supreme, was insured by Burlington Insurance Company under policy number 11 BUR-256457-1 for Commercial General Liability. The certificate was signed by you, ANGELA KAY BROWN, and displayed the name of the sender as Brown Insurance. 34. You, ANGELA KAY BROWN, provided the false Certificate of Liability knowing that Caldwell Air Conditioning and Heating was not in fact covered by Burlington Insurance Company. As a result thereof, you, ANGELA KAY BROWN exposed Supreme Builders, Inc to potential risk and liability. IT IS THEREFORE CHARGED that you, ANGELA KAY BROWN, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Financial Services which constitute grounds for the suspension or revocation of your licenses and appointments: (a) If the license or appointment is willfully used, or to be used, to circumvent any of the requirements or prohibitions of this code. Section 626.611(4), Florida Statutes; (b) — Willfull 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 dissimination of information or advertising. Section 626.611(5), Florida Statutes; (c) Demonstrated lack of fitness or trust worthiness to engage in the business of insurance, Section 626.611 (7), Florida Statutes; (d) Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626.611 (9), Florida Statutes; (e) Willful failure to comply with, or willful violation of, any proper order or rule of the department, commission, or office or willful violation of any provision of this code. Section 626.611(13), Florida Statutes; (63) 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 appointment. Section 626.621(2), Florida Statutes. 12 COUNT VI 35. The above general allegations and paragraphs thirty-two (32) through thirty-four (34) are hereby realleged and fully incorporated herein by reference. 36. On or about September 29, 2003, you, ANGELA KAY BROWN, sent via facsimile a Certificate of Liability copy to G.A., President of Supreme Builders, Inc. 37. The certificate stated that Caldwell Air Conditioning and Heating was insured by CEIB Insurance, under policy number WC-335546-1, for Worker’s Compensation. The certificate was signed by you, ANGELA KAY BROWN, and displayed the name of the sender as Brown Insurance. 38. You, ANGELA KAY BROWN, provided the false Certificate of Liability knowing that Caldwell Air Conditioning and Heating was not in fact covered by CEIB Insurance. As a result thereof, you, ANGELA KAY BROWN exposed Supreme Builders, Inc to potential risk and liability. IT IS THEREFORE CHARGED that you, ANGELA KAY BROWN, have violated or are accountable under the following provisions of the Florida Insurance Code and Rules of the Department of Financial Services which constitute grounds for the suspension or revocation of your licenses and appointments: (a) If the license or appointment is willfully used, or to be used, to circumvent any of the requirements or prohibitions of this code. Section 626.61 1(4), Florida Statutes; (b) Willfull 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 dissimination of information or advertising. Section 626.611(5), Florida Statutes; (c) Demonstrated lack of fitness or trust worthiness to engage in the business of insurance. Section 626.611 (7), Florida Statutes; (d) Fraudulent or dishonest practices in the conduct of business under the license or appointment. Section 626.611 (9), Florida Statutes; 13 (e) Willful failure to comply with, or willful violation of, any proper order or rule of the department, commission, or office or willful violation of any provision of this code. Section 626.611(13), Florida Statutes; (63) 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 appointment. Section 626.621(2), Florida Statutes. WHEREFORE, you, ANGELA KAY BROWN, 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 be provided under the provisions of Sections 626.611, 626.621, 626.681, 626.691, and 626.9521, Florida Statutes, and under the other referenced Sections of the Florida Statutes as set out in this Administrative Complaint. 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. Your written response must be received by the Department 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. 14 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 15 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. Hh DATED and SIGNED this BX day of / ) lo , 2004. name ph a Be KAREN CHANDLER Deputy Chief Financial Officer 16 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing ADMINISTRATIVE COMPLAINT and ELECTION OF PROCEEDING has been furnished to: Angela Kay Brown 4607 Arlette Court, Lake Worth, Florida 33461; Anggla akay Browny Le N. Federal Hwy., Boyton Beach, Florida 33435 by Certified Mail thi Bary of , 2004. > | A, William W. Tharpe, Jr. Division of Legal Services 200 East Gaines St. 612 Larson Building Tallahassee, Florida 32399-033 (850) 413-4110 Florida Bar Number 0312411 17

Docket for Case No: 04-002966PL
Issue Date Proceedings
Nov. 30, 2004 Order Closing File. CASE CLOSED.
Nov. 29, 2004 Petitioner`s Proposed Response to Order of Pre-Hearing Instructions filed.
Nov. 29, 2004 Exhibits filed.
Nov. 29, 2004 Motion to Abate/Stay Proceedings filed.
Nov. 29, 2004 Notice of Intent to Invoke Right to Silence filed.
Oct. 19, 2004 Order Granting Continuance and Re-scheduling Hearing (hearing set for December 14 and 15, 2004; 9:30 a.m.; West Palm Beach, FL).
Oct. 18, 2004 Petitioner`s Motion for Continuance filed.
Sep. 01, 2004 Order of Pre-hearing Instructions.
Sep. 01, 2004 Notice of Hearing (hearing set for October 27 and 28, 2004; 9:30 a.m.; West Palm Beach, FL).
Aug. 27, 2004 Response to Initial Order (filed by Petitioner via facsimile).
Aug. 23, 2004 Initial Order.
Aug. 20, 2004 Agency referral filed.
Aug. 20, 2004 Election of Proceeding filed.
Aug. 20, 2004 Administrative Complaint filed.
Source:  Florida - Division of Administrative Hearings

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