Petitioner: DEPARTMENT OF FINANCIAL SERVICES
Respondent: HANI RIHAN
Judges: BRAM D. E. CANTER
Agency: Department of Financial Services
Locations: Sarasota, Florida
Filed: Mar. 30, 2005
Status: Closed
Settled and/or Dismissed prior to entry of RO/FO on Tuesday, September 13, 2005.
Latest Update: Jan. 03, 2025
FLORIDA _
DEPARTMENT OF
FINANCIAL SERVICES ~ FILED
TOM GALLAGHER FEB 23 2505
CHIEF FINANCIAL OFFICER
Dosketed Sy°, 7 YZ seuerent
STATE OF FLORIDA
IN THE MATTER OF:
CASE NO.: 72633-04-/
HANI RIHAN
ADMINISTRATIVE COMPLAINT
TO: HANI RIHAN
American Insurance Agencies of Greater FL =
240 N. Washington Blvd., Ste. 200 / =
Sarasota, Florida 34236-5978 L
HANI RIHAN
5450 Bentgrass Drive, Apt. 103
Sarasota, Florida 34235-2661
ce: Nicholas Sardelis, Esquire
Sardelis and Bowles, L.L.P.
2033 Main Street, Suite 502
Sarasota, Florida 34237-6091
You, HANI RIHAN, license I.D. #A303133, 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 (2003), you, HANI RIHAN, are
currently licensed in this state as a Life & Health Agent (2-18).
2. At all times pertinent to the dates and occurrences referred to herein, you, HANI
RIHAN, were licensed in this state as a Life & Health Agent (2-18).
3. Pursuant to Chapter 626, Florida Statutes (2003), 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, HANI
RIHAN, represented the Alliance for Affordable Services as a Life and Health (2-18) Agent
(hereinafter, "Alliance"), and were a manager of Cornerstone Marketing. Cornerstone Marketing
sold the products of Alliance. You sold insurance products through Alliance that were
underwritten by the Mid-West National Life Insurance Company of Tennessce (hereinafter,
"Mid-West"). Your insurance appointment with Mid-West was terminated by Mid-West on
December 3, 2002.
COUNT I
5. The above general allegations are hereby realleged and fully incorporated herein
by reference.
6. On or about October 3, 2001, you, HANI RIHAN, went to the home of D.B., of
Venice, Florida, in order to sell her a Mid-West health insurance policy. D.B.'s husband was
also present at this time. You, HANI RIHAN, completed the insurance application relevant to
questions you asked of D.B. While filling out the application for insurance, both D.B. and her
husband informed you, HANI RIHAN, that D.B. had suffered a heart attack some two (2) years
prior and as a result was hospitalized for three (3) days. You, HANI RIHAN, completed and
signed the application, had D.B. sign it, and collected from D.B. and her husband, check #9199,
payable to Mid-West, in the amount of FOUR HUNDRED THIRTY-EIGHT AND 07/100
($438.07) DOLLARS, as a down payment for this health insurance.
7. Where the insurance application asked whether D.B. had, “any other medical or
surgical advice, hospitalizations, treatment, operations, or testing in the last five (5) years," you,
HANI RIHAN, listed the answer as "NO."
8. As a result of some responses to some of the questions on D.B.'s insurance
application, D.B. was required to complete, supplement to the insurance application, an
additional questionnaire regarding "High Blood Pressure." This questionnaire was also
completed by you, HANI RIHAN, relevant to the questions asked of D.B. Where the
questionnaire asked whether D.B. had ever had any history of heart or circulatory problems you,
HANI RIHAN, listed the answer as "NO." Where the questionnaire asked whether D.B. had
ever been hospitalized for high blood pressure or circulatory problems, you, HANI RIHAN,
listed the answer as "NO."
9. On or about November 21, 2001, Mid-West notified D.B. that her policy was
effective, but with an exclusionary endorsement for "hypertension, hypertensive heart disease
any treatment in connection with or any complications therefrom." D.B. subsequently cancelled
her extant health insurance policy since the Mid-West policy was now effective. D.B. made
payments on her Mid-West policy for approximately three (3) months.
10. Upon reviewing D.B.'s actual medical records, Mid-West discovered the evidence
of D.B.'s 1999 hospitalization as a result of hypertension and her diagnosed coronary artery
disease. Because of the omission of this information from D.B.'s application for insurance, Mid-
West cancelled her health insurance policy on or about January 22, 2002. A premium refund
was issued to D.B. by Mid-West.
11. D.B. is now unable to secure health insurance.
IT IS THEREFORE CHARGED that you, HANI RIHAN, 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 license and appointments:
(a) Willful misrepresentation of any insurance policy or annuity contract or willful
deception with regard to any such policy or contract, done cither in person or by any form of
dissemination of information or advertising. Section 626.611(5), Florida Statutes (2001).
(b) Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance. Section 626.611(7), Florida Statutes (2001).
(c) Demonstrated lack of reasonably adequate knowledge and technical competence
to engage in the transaction authorized by the license or appointment. Section 626.611(8),
Florida Statutes (2001).
(d) Fraudulent or dishonest practices in the conduct of business under the license or
appointment. Section 626.611(9), Florida Statutes (2001).
(e) Willful failure to comply with, or willful violation of, any proper order or rule of
the Department or willful violation of any provision of this code. Section 626.611(13), Florida
Statutes (2001).
(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 (2001).
(g) In the conduct of business under the license or permit, engaging in unfair methods
of competition or in unfair or deceptive acts or practices, as prohibited under part IX 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 (2001).
(h) Knowingly making a false or fraudulent written or oral statement or
representation on, or relative to, an application or negotiation for an insurance policy for the
purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker,
or individual. Section 626.9541(1)(k), Florida Statutes (2001).
COUNT II
12. The above general allegations are hereby realleged and fully incorporated herein
by reference.
13. On or about February 25, 2002, you, HANI RIHAN, went to the office of M.K.,
of New Port Richey, Florida, in order to sell her a Mid-West health insurance policy for her and
her husband. You, HANI RIHAN, led MLK. to believe that pre-existing conditions would be
covered by this new policy, provided that she already had extant health insurance coverage.
You, HANI RIHAN, completed the insurance application relevant to questions you asked of
M.K. While filling out the application for insurance, M.K. informed you, HANI RIHAN, that
M.K.'s husband had high blood pressure and had just begun taking medication for this condition.
You, HANI RIHAN, completed and signed the application, and had M.K. sign it.
14. Where the insurance application asked whether M.K., or her husband, had ever
had any history of high blood pressure, you, HANI RIHAN, listed the answer as "NO."
15. Where the insurance application asked whether M.K., or her husband, were
currently taking any medication, you, HANI RIHAN, listed the answer as "NO."
16. In or around April, 2002, M.K.'s husband submitted a claim to Mid-West for
payment of various medical testing, which had been ordered by their doctor. The claim was
denied by Mid-West on or about July 26, 2002. The claim was denied by Mid-West because,
relying upon M.K. and her husband's medical records, the claim was based upon a pre-existing
condition. Specifically, that pre-existing condition was M.K.'s husband's history of high-blood
pressure and the fact that he had been prescribed medication for that condition. Mid-West stated
that no benefits are provided for any loss resulting from a pre-existing condition.
IT IS THEREFORE CHARGED that you, HANI RIHAN, 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 license and appointments:
(a) Willful 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
dissemination of information or advertising. Section 626.611(5), Florida Statutes (2002).
(b) | Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance. Section 626.611(7), Florida Statutes (2002).
(c) Demonstrated lack of reasonably adequate knowledge and technical competence
to engage in the transaction authorized by the license or appointment. Section 626.611(8),
Florida Statutes (2002).
(d) Fraudulent or dishonest practices in the conduct of business under the license or
appointment. Section 626.611(9), Florida Statutes (2002).
(e) Willful failure to comply with, or willful violation of, any proper order or rule of
the Department or willful violation of any provision of this code. Section 626.611(13), Florida
Statutes (2002).
(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 (2002).
(g) In the conduct of business under the license or permit, engaging in unfair methods
of competition or in unfair or deceptive acts or practices, as prohibited under part LX 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 (2002).
(h) Knowingly making a false or fraudulent written or oral statement or
representation on, or relative to, an application or negotiation for an insurance policy for the
purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker,
or individual. Section 626.9541(1)(k), Florida Statutes (2002).
COUNT I
17. The above general allegations are hereby realleged and fully incorporated herein
by reference.
18. On or about December 6, 2001, you, HANI RIHAN, went to the home of P.J., of
Palm Harbor, Florida, in order to sell her, and her husband, a Mid-West health insurance policy,
Prior to your arrival at her home, P.J. told you over the telephone that she had a past history of
leukemia, but had been released by her doctor. You, HANI RIHAN, led P.J. to believe that her
past history of leukemia would not hinder her from obtaining health coverage from Mid-West.
You, HANI RIHAN, completed the insurance application relevant to questions you asked of P.J.
While filling out the application for insurance, P.J. reminded you again, HANI RIHAN, of her
past history of leukemia. You, HANI RIHAN, completed and signed the application, and had
P.J. sign it.
19. Where the insurance application asked whether P.J., or her husband, had ever had
any history of leukemia, you, HANI RIHAN, listed the answer as "NO."
20. On or about February 25, 2002, Mid-West denied the application for health
insurance of P.J. and her husband. The application was denied, in part, because Mid-West, upon
revicw of P.J. and her husband's medical records, discovered P.J.'s history of leukemia.
IT IS THEREFORE CHARGED that you, HANI RIHAN, 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 license and appointments:
(a) Willful 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
dissemination of information or advertising. Section 626.611(5), Florida Statutes (2002).
(b) | Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance. Section 626.61 1(7), Florida Statutes (2002).
(c) Demonstrated lack of reasonably adequate knowledge and technical competence
to engage in the transaction authorized by the license or appointment. Section 626.61 1(8),
Florida Statutes (2002).
(d) Fraudulent or dishonest practices in the conduct of business under the license or
appointment. Section 626.611(9), Florida Statutes (2002).
(e) Willful failure to comply with, or willful violation of, any proper order or rule of
the Department or willful violation of any provision of this code. Section 626.611(13), Florida
Statutes (2002).
(p 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 (2002).
(g) In the conduct of business under the license or permit, engaging in unfair methods
of competition or in unfair or deceptive acts or practices, as prohibited under part [X 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 (2002).
(h) Knowingly making a false or fraudulent written or oral statement or
representation on, or relative to, an application or negotiation for an insurance policy for the
purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker,
or individual. Section 626.9541(1)(k), Florida Statutes (2002).
COUNT IV
21. The above general allegations are hereby realleged and fully incorporated herein
by reference.
22. On or about September 19, 2001, you, HANI RIHAN, sold S.D., and her husband,
of St. Petersburg, Florida, a Mid-West Basic Hospital/Medical-Surgical Expense Certificate.
You explained to them that to obtain the surgeon benefit, one could see any surgeon connected
with the Beechstreet Network.
23. However, the Mid-West policy that you sold them only covers surgery performed
in a hospital or outpatient facility.
24, On or about March 26, 2002, S.D. had a biopsy and surgery performed by a
doctor with the Suncoast Medical Group, and submitted a claim to Mid-West. That claim was
denied because the facility was not an outpatient facility.
IT IS THEREFORE CHARGED that you, HANI RIHAN, 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 license and appointments:
(a) Willful 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
dissemination of information or advertising. Section 626.611(5), Florida Statutes (2001).
(b) Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance. Section 626.61 1(7), Florida Statutes (2001).
(c) Demonstrated lack of reasonably adequate knowledge and technical competence
to engage in the transaction authorized by the license or appointment. Section 626.611(8),
Florida Statutes (2001).
(d) Fraudulent or dishonest practices in the conduct of business under the license or
appointment. Section 626.611(9), Florida Statutes (2001).
(e) Willful failure to comply with, or willful violation of, any proper order or rule of
the Department or willful violation of any provision of this code. Section 626.61 1(13), Florida
Statutes (2001).
(fh 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 (2001).
(g) In the conduct of business under the license or permit, engaging in unfair methods
of competition or in unfair or deceptive acts or practices, as prohibited under part IX 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 (2001).
(h) Knowingly making a false or fraudulent written or oral statement or
representation on, or relative to, an application or negotiation for an insurance policy for the
purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker,
or individual. Section 626.9541(1)(k), Florida Statutes (2001).
COUNT V
25. The above general allegations are hereby realleged and fully incorporated herein
by reference.
26. On or about March 9, 2001, you, HANI RIHAN, sold C.L., and her husband, of
Pinellas Park, Florida, a basic hospital medical expense plan from Mid-West. You explained to
them that after payment of a single ONE-THOUSAND AND 00/100 ($1,000) DOLLAR
deductible, all hospital admissions for the year would be covered.
27. Inreliance upon your representations, C.L., and her husband, later raised their
deductible to FIFTEEN HUNDRED AND 00/100 ($1,500) DOLLARS.
28, Only later did C.L., and her husband, discover that the deductible was to be paid
for each hospital admission, not only once per year. As a result, C.L. and her husband have
incurred unpaid medical claims.
IT IS THEREFORE CHARGED that you, HANI RIHAN, 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 license and appointments:
11
(a) Willful 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
dissemination of information or advertising. Section 626.611(5), Florida Statutes (2001).
(b) Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance, Section 626.611(7), Florida Statutes (2001).
(c) Demonstrated lack of reasonably adequate knowledge and technical competence
to engage in the transaction authorized by the license or appointment. Section 626.611(8),
Florida Statutes (2001).
(d) Fraudulent or dishonest practices in the conduct of business under the license or
appointment. Section 626.611(9), Florida Statutes (2001).
(e) Willful failure to comply with, or willful violation of, any proper order or rule of
the Department or willful violation of any provision of this code. Section 626.611(13), Florida
Statutes (2001).
(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 (2001).
(g) In the conduct of business under the license or permit, engaging in unfair methods
of competition or in unfair or deceptive acts or practices, as prohibited under part [X 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 (2001).
(b) Knowingly making a false or fraudulent written or oral statement or
representation on, or relative to, an application or negotiation for an insurance policy for the
12
purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker,
or individual. Section 626.9541(1)(k), Florida Statutes (2001).
COUNT VI
29. The above general allegations are hereby realleged and fully incorporated herein
by reference.
30. During your tenure as a manager of Cornerstone Marketing, you, HANI RIHAN,
encouraged agents, who were subordinate to you, to misrepresent the terms of the insurance
products they sold, to falsify information on applications, and/or to generate misleading
advertising, in order to generate commissions and/or association fees.
31. Specifically, you, HANI RIHAN, instructed (or arranged for the instruction of)
agents subordinate to you to deliberately leave out information regarding pre-existing conditions
on applications for insurance. You, HANI RIHAN, instructed (or had instructed) agents to
deliberately misrepresent the amount of possible annual rate-increases. You, HANI RIHAN,
instructed (or had instructed) agents to never reveal to insureds brochures published by Mid-
West, which contradicted what you, or your agents, told those insureds regarding their coverage
with Mid-West.
IT IS THEREFORE CHARGED that you, HANI RIHAN, 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 license and appointments:
(a) Willful 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
dissemination of information or advertising. Section 626.611(5), Florida Statutes (2001).
13
(b) Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance. Section 626.611({7), Florida Statutes (2001).
(c) Demonstrated lack of reasonably adequate knowledge and technical competence
to engage in the transaction authorized by the license or appointment. Section 626.611(8),
Florida Statutes (2001).
(d) Fraudulent or dishonest practices in the conduct of business under the license or
appointment. Section 626.611(9), Florida Statutes (2001).
(e) Willful failure to comply with, or willful violation of, any proper order or rule of
the Department or willful violation of any provision of this code. Section 626.611(13), Florida
Statutes (2001).
(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 (2001).
(g) In the conduct of business under the license or permit, engaging in unfair methods
of competition or in unfair or deceptive acts or practices, as prohibited under part [X 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 (2001).
(h) Knowingly aiding, assisting, procuring, advising, or abetting any person in the
violation of or to violate a provision of the insurance code or any order or rule of the department.
Section 626.621(12), Florida Statutes (2001).
(i) Knowingly making, issuing, circulating, or causing to be made, issued, or
circulated, any estimate, illustration, circular, statement, sales presentation, omission, or
14
comparison which misrepresents the benefits, advantages, conditions, or terms of any insurance
policy. Section 626.9541(1)(a), Florida Statutes (2001).
q) Knowingly making, publishing, disseminating, circulating, or placing before the
public, or causing, directly or indirectly, to be made, published, disseminated, circulated, or
placed before the public . .. 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)(b), Florida Statutes (2001).
(k) Knowingly . . . 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), Florida Statutes (2001).
(1) Knowingly making a false or fraudulent written or oral statement or
representation on, or relative to, an application or negotiation for an insurance policy for the
purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker,
or individual. Section 626.9541(1)(k), Florida Statutes (2001).
WHEREFORE, you, HANI RIHAN, 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 (2003), 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 (2003), and Rule 28-107, Florida
Administrative Code. The proceeding request must be in writing, signed by you, and must be
15
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.
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.
{f 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.
16
If a proceeding is requested and there is no dispute of material fact, the provisions of
Section 120.57(2), Florida Statutes (2003), 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 (2003). 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
reswtit 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 (2003), is not
available. No Department attorney will discuss this matter with you until the response has been
received by the Department of Financial Services.
day oftebcuary. 2005.
.N CHANDLER
Deputy Chief Financial Officer
17
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing ADMINISTRATIVE
COMPLAINT and ELECTION OF RIGHTS has been furnished to: Nicholas Sardelis, Esq.,
Counsel for Respondent, Sardelis and Bowles, L.L.P., 2033 Main Street, Suite 502, Sarasota,
Florida 34237-6091, by Certified Mail this \Suay of Ee br 1.0 = , 2005.
Michael T. Ruff a
Florida Bar Number 688541
Division of Legal Services
612 Larson Building
200 East Gaines Street
Tallahassee, Florida 32399-033
Phone: (850) 413-4134
Fax (850) 487-4907
Attorney for Department
ETHIS SECTION ON DELIVERY |
hat
cow B, Date, Delivery
2. Article Number
vm
7LbO 390) WH4 2b74 eaee
COMPLETE THIS SECTION ON DELIVERY
MN Received by (Please Print Cleatty)
Cl agent
70
{_j Addressee
{1 Agent \) . ee
Addressee Ap nt Kony ‘
= D. ts delivery address differe a asoW: Con
a i) addres
D, Is delivery address different stoner is veg, entat very
IYES, enter defivary adgyéss
3. Service Tyre CERTIFIED MAIL
4. Restricted Delivery? (Extra Fee) izes
1. Article Addressed to: ;
HANI S. RIHAN .
5450 BENTGRASS DRIVE, APT. 103
SARASOTA, FL 34235
72633-04-AG AC
72053-04AG A 92/15/2005
02/15/2005
RESTRICTED | Ruff | post | |
DELIVERY Hobhlbusalbushtlaudlat
ic Return Receipt
PS Form 3811, July 2001 Domestic Return Receipt
Docket for Case No: 05-001163PL
Issue Date |
Proceedings |
Sep. 13, 2005 |
Order Closing File. CASE CLOSED.
|
Sep. 09, 2005 |
Amended Motion to Relinquish Jurisdiction filed.
|
Sep. 08, 2005 |
Motion to Relinquish Jurisdiction filed.
|
Aug. 25, 2005 |
Subpoena Duces Tecum filed.
|
Aug. 25, 2005 |
Notice of Filing, subpoena duces tecum without deposition filed.
|
Aug. 24, 2005 |
Order Granting Continuance (parties to advise status by September 26, 2005).
|
Aug. 23, 2005 |
Joint Motion for Continuance filed.
|
Aug. 22, 2005 |
Joint Motion for Extension of Time to File Pre-hearing Stipulation filed.
|
Aug. 18, 2005 |
Notice of Submission of Exhibits filed.
|
Aug. 18, 2005 |
Notice of Taking Depositions filed.
|
Aug. 15, 2005 |
Witness List filed.
|
Aug. 10, 2005 |
Notice of Taking Telephonic Deposition Duces Tecum filed.
|
Aug. 10, 2005 |
Qualified Protective Order.
|
Aug. 09, 2005 |
Emergency Motion for Protective Order or in the Alternative to Quash Subpoena Duces Tecum filed.
|
Jul. 05, 2005 |
Subpoena ad Testificandum filed.
|
Jun. 24, 2005 |
Notice of Taking Depositions (P. Johnson, M. Tidwell, L. Beene, M. Goss) filed.
|
Jun. 24, 2005 |
Notice of Taking Telephonic Deposition (Records Custodian) filed.
|
Jun. 24, 2005 |
Notice of Production from Non-Party Mid-West National Life Insurance Company of Tennessee filed.
|
May 20, 2005 |
Order Granting Continuance and Re-scheduling Hearing (hearing set for August 30 through September 1, 2005; 9:00 a.m.; Sarasota, FL).
|
May 16, 2005 |
Unopposed Motion for Continuance of Hearing filed.
|
May 13, 2005 |
Notice of Appearance filed.
|
Apr. 26, 2005 |
Interrogatories filed.
|
Apr. 26, 2005 |
Notice of Service of Interrogatories filed.
|
Apr. 26, 2005 |
Request to Produce filed.
|
Apr. 13, 2005 |
Order of Pre-hearing Instructions.
|
Apr. 13, 2005 |
Notice of Hearing (hearing set for July 12 through 14, 2005; 9:00 a.m.; Sarasota, FL).
|
Apr. 12, 2005 |
Joint Response to Initial Order filed.
|
Mar. 31, 2005 |
Initial Order.
|
Mar. 30, 2005 |
Notice of Appearance (filed by N. Sardelis, Esquire).
|
Mar. 30, 2005 |
Election of Proceeding filed.
|
Mar. 30, 2005 |
Administrative Complaint filed.
|
Mar. 30, 2005 |
Agency referral filed.
|