Petitioner: DEPARTMENT OF FINANCIAL SERVICES
Respondent: SUSAN HOPE PINE
Judges: LARRY J. SARTIN
Agency: Department of Financial Services
Locations: Tallahassee, Florida
Filed: Jan. 24, 2006
Status: Closed
Settled and/or Dismissed prior to entry of RO/FO on Wednesday, April 5, 2006.
Latest Update: Dec. 23, 2024
FILED
we rJUN 2 2005
caMAY -6 PH 4:50 a
_ Bocketed by TN
DEPARTMENT OF FINANCIAL SERVICES >
TOM GALLAGHER
CHIEF FINANCIAL OFFICER
no raft py
IN THE MATTER OF: OD - I Yohe
RAYMOND PINTO CASE NO.: 64858-03-AG
ADMINISTRATIVE COMPLAINT.
TO: RAYMOND PINTO
1490 104" Avenue
Plantation, Florida 33322
Business Addresses:
RAYMOND PINTO
8181 West Broward Boulevard, Suite 204
Plantation, Florida 33324
-or-
RAYMOND PINTO
1370 N. University, #1370C
Plantation, Florida 33322
You, RAYMOND PINTO, 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, RAYMOND PINTO, are currently
licensed in this state as a Health (2-40) and Legal Expense (2-56) agent, license I.D. #A207789.
2. At all times pertinent to the dates and occurrences referred to herein, you,
RAYMOND PINTO, were licensed in this state as an insurance agent.
3. Pursuant to Chapter 626, Florida Statutes, the Florida Department of Financial
Services (“DFS”) has jurisdiction over your insurance licenses and appointments.
4. At all time material to the dates and occurrences specified herein, the United
States Workers of America Local 16 National Health Fund a/k/a or d/b/a HA WU National Health
Fund; Local 16 National Health (“Local 16”), engaged in the business of insurance, or operated
as one or more MEWAs in Florida.
5. On or about January 15, 2002, the United States Bankruptcy Court for the District
of New Jersey (Newark), in Case Number 01-42881, entered a Notice of Chapter 7 Bankruptcy
relative to Local 16.
6. At all times material to the dates and occurrences specified herein, Employers
Mutual, L.L.C. (“Employers Mutual”), engaged in the business of insurance, or ostensibly
operated as one or more MEWAs in Florida, by or through the following associations (non-
exhaustive):
(a) American Association of Agriculture
(b) Association of Automotive Dealers & Mechanics
(c) Association of Barristers & Legal Aids
(d) | Communication Trade Workers Association
(e) Construction Trade Workers Association
(f) American Coalition of Consumers
(g) Association of Cosmetologists
(h) Culinary and Food Services Workers Association
(i) Association of Educators
@) Association of Health Care Workers
(k) National Alliance of Hospitality & Innkeepers
0)) Association Manufactures & Wholesalers
(m) Association of Real Estate Agents
(n) Association of Retail Sellers
(0) National Association of Transportation Workers
(p) National Association of Independent Truckers.
7. On or about February 1, 2002, the United States District Court District of Nevada
in Elaine Chao v. James Graf, Employers Mutual, et al., CV-N-01-0698-DWH (RAM) ruled that
Employers Mutual and its related associations were not ERISA-qualified employee welfare
benefit plans and therefore were not preemptively exempt from state insurance codes, and
ordered that a Court Receiver or Independent Fiduciary administer Employers Mutual and its
related associations, and; if necessary, implement their orderly termination. Furthermore, the
Court ordered that the Independent Fiduciary collect, marshal, and administer the assets of
Employers Mutual and its related associations, process the health benefit claims, and pay those
that are found to be legitimate.
8. On or about August 14, 2001, DFS (then known as the Florida Department of
Insurance) in In the matter of: Employers Mutual, L.L.C., et al., Case No. 42660-01-CO, stated:
WHEREFORE, Employers Mutual, L.L.C., [et al.] ... are hereby
notified that the Department intends to enter a permanent Cease
and Desist Order pursuant to Section 626.9581, Florida Statutes,
prohibiting the transaction by you and all related entities of
insurance in the State of Florida, or relative to a subject of
insurance resident, located, or to be performed in this state, without
being licensed.
9. At all times material to the dates and occurrences specified herein, TRG was the
acronym or pseudonym for a multitude of entities that engaged in the busiaess of insurance, or
operated as one or more MEWAs in Florida, including, but not limited to:
(a) T.R.G. Marketing, LLC
(b) — T.R.G. Administration, LLC
(c) The Redwood Group, LLC.
10. On or about January 15, 2002, DFS (then known as the Florida Department of
Insurance), in Jn the matter of: T.R.G. Marketing, L.L.C., et al., Case No.: 43 160-Ol-CO, stated:
WHEREFORE, TRG, [et al.] ... are hereby notified that the
Department intends to enter a permanent Cease and Desist Order
pursuant to Section 626.9581, Florida Statutes, prohibiting the
transaction by you and all related entities of insurance in the State
of Florida, or relative to a subject of insurance resident, located, or
to be performed in this state, without being licensed.
11. In addition, other states have acted against TRG, including as follows:
(a) Kentucky issued a Restraining Order on November 2, 2001;
(b) Nevada issued a Cease and Desist Order on February 1, 2002; and
(c) Arkansas issued a Cease and Desist Order on July 23, 2002.
12. At all times material to the dates and occurrences specified herein American
Benefit Plans (“ABP”) engaged in the business of insurance, or operated as one or more MEWAs
in Florida, by or ostensibly through the various entities, associations, or individuals, including,
but not limited to: United Employers Voluntary Employee Beneficiary Association
(“UEVEBA”), Robert David Neal (individually and d/b/a American Benefit Plans) (“Neal”), and
the National Association of Working Americans (“NAWA”) — all of which are hereinafter
sometimes collectively referred to as “UEVEBA.” The aforementioned are and have been
identified with an ostensible health benefit plan known as the UltraMed Choice Major Medical
Plans.
13. On or about March 1, 2002, the U.S. Department of Labor, Pension and Welfare
Benefits Administration, in a letter to the Commissioner of the Arkansas Department of
Insurance, concluded:
Accordingly, in the [Department of Labor] view, [UEVEBA| is a
MEWA ... Therefore, ERISA’s preemption provisions do not apply
with respect to the UEVEBA arrangement (as distinguished from
any individual ERISA-covered plans that obtain benefits through
UEVEBA), and Arkansas is free to regulate the UEVEBA
arrangement in accordance with applicable state law. Further, even
if it [sic] the UEVEBA arrangement were itself found to be an
ERISA-covered plan, Title I of ERISA does not preclude the
application of Arkansas insurance law or regulations to the
UEVEBA arrangement in accordance with Section 514(b)(5)(A)
(29 U.S.C.A. 1144(b)(6)(A)] of ERISA.
14, On or about March 18, 2002, the U.S. Department of Labor, Pension and Welfare
Benefits Administration, in a letter to the Commissioner of the Texas Department of Insurance,
concluded:
Accordingly, in the [Department of Labor] view, [UEVEBA] is a
MEWA ... Therefore, ERISA’s preemption provisions would not
apply with respect to the UEVEBA arrangement (as distinguished
from any individual ERISA-covered plans that obtain benefits
through UEVEBA), and Texas may regulate the UEVEBA
arrangement in accordance with applicable state insurance law.
Further, even if the UEVEBA arrangement were itself found to be
an ERISA-covered plan, Title I of ERISA does not preclude the
application of Texas insurance law or regulations to the UEVEBA
arrangement in accordance with Section 514(b)(6)(A) [29
U.S.C.A. 1144(b)(6)(A)] of ERISA as described in our March 1,
2002, letter to the Arkansas Commissioner of Insurance.
15. On or about April 25, 2002, DFS, in In The Matter of: American Benefit Plans;
United Employers Voluntary Employee Beneficiary Association, Robert David, individually and
doing business as American Benefit Plans, National Association for Working Americans
[collectively referred to as “UEVEBA”’], et al., Case No. 43161-02-CO, ordered:
The Respondents [including UEVEBA], whether acting ia the
State of Florida as an insurer, a Multiple Employer Welfare
Arrangement, insurance agents, insurance agencies, insurance
adjuster, third-party administrators, managing general agents, or
otherwise engaging in the business of insurance, either directly or
indirectly through named and unnamed persons, entities, agerits, or
otherwise, shall forthwith CEASE AND DESIST from the
transaction of any new or renewal insurance business as or on
behalf of unauthorized insurers.
16. On or about May 25, 2002, DFS, in Case No. 43163-02-CO, stated:
WHEREFORE, the Respondents [UEVEBA] are hereby notified
that the Department intends to enter a permanent Cease and Desist
Order pursuant to Section 626.9581, Florida Statutes, prohibiting
the transaction by you and all related entities of insurance in the
State of Florida, or relative to a subject of insurance resident,
located, or to be performed in this state, without being licensed.
17. On or about May 28, 2002, the District Court of Travis County, Texas in Texas v,
American Benefit Plans; United Employers Voluntary Employee Beneficiary Association; Robert
David Neal, individually and doing business as American Benefit Plans, et al., Cause No.
GV200903, ruled, in its Final Judgment, Permanent Injunction and Order Appointing Permanent
Receiver, at paragraph 4, that:
Defendants have participated in the creation, marketing and sale of
unauthorized health care insurance plans. Defendants have
collected money, variously labeled as “premiums,”
“contributions,” “dues,” or other titles, from employers and
employees under these fraudulent health care plans, and failed to
pay claims of such employees and other beneficiaries and their
health care providers. Defendants further participated in the
creation of sham trusts in the name of United Employee Voluntary
Employee Beneficiary Association (“UEVEBA”) and United
Employers Voluntary Employee Beneficiary Association I
(UEVEBA), into which money from employers, employees, and
others were deposited and commingled. Defendants further
participated in procuring reinsurance in connection with such
health care plans from entities that do not hold certificates of
authority to act as an insurer or reinsurer in Texas. The activities
described above shall be collectively referred to as the
“Unauthorized Health Care Program.”
18. At all times material to the dates and occurrences specified herein, Highmark
Blue Cross Blue Shield (“Highmark BC/BS”) was not authorized to engage in the business of
insurance in Florida and not authorized to operate as a MEWA in Florida.
19. At all times material to the dates and occurrences herein, Local 16, Employers
Mutual, TRG, ABP, UEVEBA, and Highmark BC/BS transacted insurance as unauthorized
insurers or MEWAs in the State of Florida.
20. At all times relevant hereto, Quik Quote Insurance Brokers, Inc., a/k/a or fik/a
Quick Quote or Women’s Insurance Planning Center, Inc. (hereinafter “Quik Quote”), was a
Florida corporation engaged in the business of transacting insurance in Fiorida. Quik Quote
maintained offices at all times relevant hereto at 8181 West Broward Boulevard, Suite 204,
Plantation, Florida 33324, 1370 N. University, #1370C, Plantation, Florida 33322, or 7860
Peters Road, #111F, Plantation, Florida 33324-4027. In addition, Quik Quote acted through an ~
entity or entities that shared Quik Quote’s addresses and were known variously as the Bertany
Association for Travel and Leisure, Inc., the Business Association for Trade and Labor, Inc., or
BAFTAL (hereinafter collectively referred to as “BAFTAL”).
21. At no time material to the dates and occurrences herein did Local 16, Employers
Mutual, TRG, ABP, UEVEBA, or Highmark BC/BS possess Certificates of Authority from DFS
to engage in the business of insurance or to operate as MEWAs in Florida.
22. Neither Local 16, Employers Mutual, TRG, ABP, UEVEBA, or Highmark
BC/BS are subject to any exception to the licensure/Certificate of Authority requirement of the
Florida Insurance Code in order to lawfully engage in the business of insurance or to operate as
MEWAs in Florida.
23. At all times material to the dates and occurrences specified herein, Local 16,
Employers Mutual, TRG, ABP, UEVEBA, and Highmark BC/BS transacted the business of
insurance as insurers or operated as MEWAs in the State of Florida from or through the common
business premises of BAFTAL and Quik Quote.
24, At all times relevant hereto, you, RAYMOND PINTO, were a corporate officer of
BAFTAL and Quik Quote.
25. At all times material to the dates and occurrences herein, you, RAYMOND
PINTO, did directly or indirectly represent or aid Local 16, Employers Mutual, TRG, ABP,
UEVEBA, and Highmark BC/BS, unauthorized insurers or MEWAs, to transact insurance in the
State of Florida, or did directly or indirectly aid agent Susan Pine or independent licensed agents
as indicated in the numbered Counts below to unlawfully transact insurance in the State of
Florida.
26. The particularized harm resulting from you, RAYMOND PINTO, directly or
indirectly aiding or representing Local 16, Employers Mutual, TRG, ABP, UEVEBA, and
Highmark BC/BS in the State of Florida is that insurance premium dollars may be misused and
reserve and surplus funds may be unavailable such that the insurer may not be able to meet its
contractual and statutory obligations toward medical providers and residents of the State of
Florida. Furthermore, pursuant to Chapter 631, Florida Statutes, no state guarantee fund may be
used to pay unpaid claims and creditors. This may cause Floridians irreparable financial injury.
27. The Florida insurance buying public must depend on the integrity, competence,
honesty, and obedience to the law of an insurer, its agents, representatives, and administrators
when applying for and purchasing insurance. Insureds, medical providers, and the State of
Florida may incur and/or have incurred serious losses that may remain uncompensated due to the
solicitation, sales, and administration of unauthorized insurance by you, RAYMOND PINTO.
28. At all times pertinent to the dates and occurrences referred to herein, pursuant to
Section 626.592 and/or Section 626.839, Florida Statutes, you. RAYMOND PINTO, were
personally and fully liable and accountable for any wrongful acts, misconduct, or violations of
any provision of the Insurance Code committed either by you or anyone under your direct
supervision and control while acting on behalf of Quik Quote.
29. Directly or indirectly representing or aiding an unauthorized insurer which has not
satisfied the statutory safeguards poses a great risk of financial harm to the residents of Florida.
By collecting premium payments for or on behalf of unauthorized insurers or by soliciting
payments through fellow officers of BAFTAL or Quik Quote or through independent licensed
agents, each occurrence of which represents direct or indirect action by you, RAYMOND
PINTO, you aided and abetted the transaction of unauthorized health insurance in the State of
Florida.
30. References to you, RAYMOND PINTO, include persons acting under your direct
supervision and control and those whom you aided and abetted to commit violations of the
Insurance Code.
COUNT I
31. | The above general allegations are hereby realleged and fully incorporated herein
by reference.
32. On or about March 12, 2001 you, RAYMOND PINTO, as a licensed insurance
agent, caused to be sold to L.T., of Hollywood, Florida, a health insurance: plan through TRG.
You furnished L.T. with application forms which were completed and delivered to you, and you
began to collect fees on premiums paid by L.T. You induced L.T. to believe he was properly
covered by health insurance under the plan.
33. As a direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, an unauthorized insurer or MEWA, L.T. was sold an unauthorized health insurance plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), 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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
10
COUNT
34. The above general allegations are hereby realleged and fully incorporated herein
by reference.
35. On or about January 15, 2001 you, RAYMOND PINTO, as a licensed insurance
agent, caused to be sold to C.M., of Sunrise, Florida, a health insurance plan through TRG. You
furnished C.M. with application forms which were completed and delivered to you, and you
began to collect fees on premiums paid by C.M. You induced C.M and her husband to believe
they were properly covered by health insurance under the plan.
36. Asa direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, an unauthorized insurer or MEWA, C.M. was sold an unauthorized health insurance plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. No person shall transact in this state, or relative to a subject cf insurance resident,
located, or to be performed in this state, without complying with the applicable provisions of this
Code. [Section 624.11(1), 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];
1]
d. Violation of any provision of this Code or any law applicable to the business of
insurance in the course of dealing under the licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Sectior 626.901(1), Florida
Statutes].
COUNT Il
37. The above general allegations are hereby realleged and fully incorporated herein
by reference.
38. On or about January 15, 2001 you, RAYMOND PINTO, as a licensed insurance
agent, caused to be sold to V.R., of Pembroke Pines, Florida, a health insurance plan through
TRG. You furnished V.R. with application forms which were completed and delivered to you,
and you began to collect fees on premiums paid by V.R. You induced V.R. to believe she was
properly covered by health insurance under the plan.
39. Asa direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, an unauthorized insurer or MEWA, V.R. was sold an unauthorized health insurance plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, have violated or are
accountable under the following provisions of the Florida Insurance Code and Rules of the
12
Department of Financial Services which constitute grounds for the suspension or revocation of
your licenses and appointments:
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(1), Florida Statutes];
b. Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance. [Section 626.61 1(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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
13
COUNT IV
40. The above general allegations are hereby realleged and fully incorporated herein
by reference.
41. On or about January 15, 2001 you, RAYMOND PINTO, as a licensed insurance
agent, caused to be sold to M.D. a health insurance plan through TRG. You furnished M.D. with
application forms which were completed and delivered to you, and you began to collect fees on
premiums paid. You induced M.D. to believe she was properly covered by health insurance
under the plan.
42. As a direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, an unauthorized insurer or MEWA, M.D. was sold an unauthorized health insurance plan,
and has alleged that TRG has failed to pay medical bills in an approximate amount of $30,000.00
that should have been paid under the plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), Florida Statutes];
b. Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance. [Section 626.611(7), Florida Statutes];
14
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 licensure or appointment. {Section 626.621(2),
Florida Statutes};
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), F lorida
Statutes].
COUNT V
43. The above general allegations are hereby realleged and fully incorporated herein
by reference.
44, On or about February 16, 2001 you, RAYMOND PINTO, as a licensed insurance
agent, caused to be sold to M.A., of Miami Beach, Florida, a health insurance plan through TRG.
You furnished M.A. with application forms which were completed and delivered to you, and you
began to collect fees on premiums paid by M.A. You induced M.A. to believe he was properly
covered by health insurance under the plan.
15
45. As a direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, an unauthorized insurer or MEWA, M.A. was sold an unauthorized health insurance plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), 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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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
16
insurer not being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT VI
46. The above general allegations are hereby realleged and fully incorporated herein
by reference.
47. On or about December 17, 2001 you, RAYMOND PINTO, as a licensed
insurance agent, caused to be sold to Mull & Associates, P.A., and its eraployees P.M., D.P.,
D.S., C.F., M.N., and K.K., of Tavernier, Florida, health insurance plans through TRG. You
furnished the employees with application forms which were completed and delivered to you, and
you began to collect fees on premiums paid by the employees. You induced the employees and
their families to believe they were properly covered by health insurance under the plans.
48. Asa direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, an unauthorized insurer or MEWA, Mull & Associates, P.A. and its six employees were
sold unauthorized health insurance plans.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), Florida Statutes];
b. Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance. [Section 626.611(7), Florida Statutes};
17
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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT VII
49, The above general allegations are hereby realleged and fully incorporated herein
by reference.
50. On or about January 9, 2001 you, RAYMOND PINTO, as a licensed insurance
agent, caused to be sold to H.N., of Wesley Chapel, Florida, a health insurance plan through
TRG. You furnished H.N. with application forms which were completed and delivered to you,
and you began to collect fees on premiums paid. You induced H.N. to believe she was properly
covered by health insurance under the plan.
18
51. As a direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, an unauthorized insurer or MEWA, H.N. was sold an unauthorized health insurance plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), 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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT VIII
52. The above general allegations are hereby realleged and fully incorporated herein
by reference.
53. In or about August 2001 you, RAYMOND PINTO, as a licensed insurance agent,
caused to be sold to M.S., of Pensacola, Florida, a health insurance plan through TRG. You
induced M.S. to believe he was properly covered by health insurance under the plan.
54, As a direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, an unauthorized insurer or MEWA, M.S. was sold an unauthorized health insurance plan,
and has alleged that TRG has failed to pay medical bills in an approximate amount of $1,200.00
that should have been paid under the plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, aave 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. 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(1), Florida Statutes];
b. Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance. [Section 626.611(7), Florida Statutes];
20
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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT IX
55. The above general allegations are hereby realleged and fully incorporated herein
by reference.
56. Prior to May 2001 you, RAYMOND PINTO, as a licensed insurance agent,
caused to be sold to D.G., of Rockledge, Florida, a health insurance plan through TRG. You
induced D.G. to believe she and her husband were properly covered by health insurance under
the plan.
57. As a direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, an unauthorized insurer or MEWA, D.G. was sold an unauthorized health insurance plan,
2]
and has alleged that TRG has failed to pay medical bills that should have been paid under the
plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, ‘save 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. 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(1), 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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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
22
insurer not being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT X
58. The above general allegations are hereby realleged and fully incorporated herein
by reference.
59. In or about January 2001 you, RAYMOND PINTO, as a licensed insurance agent,
caused to be sold to Total Communications Service, Inc. and its employees 3.N., Z.N., D.N., and
J.B, of Melbourne, Florida, a health insurance plan through TRG. You began to collect fees on
premiums paid on the employees’ enrollment. You induced the employees and their family
members to believe they were properly covered by health insurance under the plan.
60. Asa direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, an unauthorized insurer or MEWA, Total Communications Service, Inc. and its employees
were sold an unauthorized health insurance plan, and have alleged that TRG has failed to pay
medical bills that should have been paid under the plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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 appliczble provisions of this
Code. [Section 624.11(1), Florida Statutes];
b. Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance. [Section 626.611(7), Florida Statutes];
23
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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT XI
6l. The above general allegations are hereby realleged and fully incorporated herein
by reference.
62. In or about September 11, 2001 you, RAYMOND PINTO, as a licensed insurance
agent, caused to be sold to Moultin Layne, P.L. and its employees, D.M., B.P., and S.L, of Vero
Beach, Florida, health insurance plans through TRG. You began to collect fees on premiums
paid on the employees’ enrollment. You induced them to believe they were properly covered by
health insurance under the plans.
24
63. Asa direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, an unauthorized insurer or MEWA, D.M., B.P., and S.L. were sold unauthorized health
insurance plans, and have alleged that TRG has failed to pay medical bills that should have been
paid under the plans.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), 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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [Section 626.621(6), Florida Statutes];
25
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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT XH
64. | The above general allegations are hereby realleged and fully incorporated herein
by reference.
65. On or about October 1, 2001 you, RAYMOND PINTO, as a licensed insurance
agent, caused to be sold to A.D., of Wellington, Florida, a health insurance plan through TRG.
You began to collect fees on premiums paid on A.D.’s enrollment. You induced A.D. and his
wife to believe they were properly covered by health insurance under the plan.
66. As a direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, an unauthorized insurer or MEWA, A.D. was sold an unauthorized health insurance plan,
and has alleged that TRG have failed to pay medical bills in an approximate amount of $200.00
that should have been paid under the plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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 applicadle provisions of this
Code. [Section 624.11(1), Florida Statutes];
26
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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT Xi
67. The above general allegations are hereby realleged and fully incorporated herein
by reference.
68. On or about November 28, 2001 you, RAYMOND PINTO, as a licensed
insurance agent, caused to be sold to D.M. Salon & Spa, Inc., and at least eight of its employees
and their family members, including D.M. and her spouse A.M., of Stuart, Florida, a health
insurance plan through TRG. You began to collect fees on premiums paid on the employees’
27
enrollment. You induced the employees and family members to believe they were properly
covered by health insurance under the plan.
69. Asa direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, unauthorized insurers or MEWAs, D.M. Salon & Spa, Inc. was sold an unauthorized
health insurance plan, and has alleged that TRG have failed to pay medical bills in an
approximate amount of $2,000.00 that should have been paid under the plan.
IT 1S THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), Florida Statutes];
b. Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance. [Section 626.61 1(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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
28
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT XIV
70. The above general allegations are hereby realleged and fully incorporated herein
by reference.
71. In or about August 1, 2001 you, RAYMOND PINTO, as a licensed insurance
agent, caused to be sold to V.B., of Jacksonville, Florida, a health insurance plan through TRG
You induced V.B. to believe she was properly covered by health insurance under the plan.
72. Asa direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, unauthorized insurers or MEWAs, V.B. was sold an unauthorized health insurance plan
and has alleged that TRG have failed to pay medical bills in an approximate amount of $505.00
that should have been paid under the plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), Florida Statutes];
29
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 licensure or appointment. [Section 626.621(2),
Florida Statutes]; |
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT XV
73. The above general allegations are hereby realleged and fully incorporated herein
by reference.
74. On or about September 11, 2001 you, RAYMOND PINTO, as a licensed
insurance agent, caused to be sold to Comprehensive Billing Solutions, Inc. and its employees
S.C. and D.R., of Sarasota, Florida, a health insurance plan through TRG. You induced S.C. and
her husband and D.R to believe they were properly covered by health insurance under the plan.
30
75. As a direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, unauthorized insurers or MEWAs, S.C. and D.R. were sold an unauthorized health
insurance plan, and have alleged that TRG has failed to pay medical bills that should have been
paid under the plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), 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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [Section 626.621(6), Florida Statutes];
31
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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT XVI
76. | The above general allegations are hereby realleged and fully incorporated herein
by reference.
77. In or about April 2001 you, RAYMOND PINTO, as a licersed insurance agent,
caused to be sold to J.R., of Cocoa, Florida, a health insurance plan through TRG. You induced
J.R. and his wife to believe they were properly covered by health insurance under the plan.
78. Asa direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, an unauthorized insurer or MEWA, J.R. was sold an unauthorized health insurance plan,
and has alleged that TRG has failed to pay medical bills in an approximate amount of $15,000.00
that should have been paid under the plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), 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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT XVII
79. The above general allegations are hereby realleged and fully incorporated herein
by reference.
80. In or around June 2001 you, RAYMOND PINTO, as a licensed insurance agent,
solicited agent R.S., of Miami, Florida, to sell a health insurance plan through Employers
Mutual. You provided R.S. with marketing materials in support of soliciting the public to enroll
in the plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, lave violated or are
accountable under the following provisions of the Florida Insurance Code and Rules of the
33
Department of Financial Services which constitute grounds for the suspension or revocation of
your licenses and appointments:
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(1), 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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
34
COUNT XVUI
81. The above general allegations are hereby realleged and fully incorporated herein
by reference.
82. In or around May 2001 you, RAYMOND PINTO, as a licensed insurance agent,
solicited agent J.B., of Tequesta, Florida, to sell a health insurance plar. through Employers
Mutual. You provided J.B. with marketing materials in support of soliciting the public to enroll
in the plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), 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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [Section 626.621(6), Florida Statutes];
f. No person shall, from offices or by personnel or facilities |ocated in this state...
directly or indirectly act as an agent for, or otherwise represent or aid on behalf of another, any
insurer not being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT XIX
83. The above general allegations are hereby realleged and fully incorporated herein
by reference.
84. On or about December 1, 2001 you, RAYMOND PINTO, as a licensed insurance
agent, caused to be sold to R.H., of Tavernier, Florida, a health insurance plan through TRG.
You furnished R.H. with application forms which were completed and delivered to you, and you
began to collect fees on premiums paid. You induced R.H. and his wife to believe they were
properly covered by health insurance under the plan.
85. As a direct or indirect result of you, RAYMOND PINTO, representing or aiding
TRG, an unauthorized insurer or MEWA, R.H. was sold an unauthorized health insurance plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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 appliczble provisions of this
Code. [Section 624.11(1), 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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT XX
86. The above general allegations are hereby realleged and fully incorporated herein
by reference.
37
87. On or about January 11, 2001 you, RAYMOND PINTO, as a licensed insurance
agent, caused to be sold to R.M. a health insurance plan through Local 16. You furnished R.M.
with application forms, and you began to collect fees on premiums paid. You induced R.M. and
his wife to believe they and their family were properly covered by health insurance under the
plan.
88. As a direct or indirect result of you, RAYMOND PINTO, representing or aiding
AEBA/Local 16, unauthorized insurers or MEWAs, R.M. was sold an unauthorized health
insurance plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), 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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
38
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT XxI
89. The above general allegations are hereby realleged and fully incorporated herein
by reference.
90. On or about January 25, 2002 you, RAYMOND PINTO, as a licensed insurance
agent, caused to be sold to R.S., of Jupiter, Florida, a health insurance plan through ABP. You
furnished R.S. with application forms which were completed and delivered to you, and you
began to collect fees on premiums paid on R.S.’s enrollment. You induced R.S. to believe she
was properly covered by health insurance under the plan.
91. As a direct or indirect result of you, RAYMOND PINTO, representing or aiding
ABP, unauthorized insurers or MEWAs, R.S. was sold an unauthorized health insurance plan,
and has alleged that ABP have failed to pay medical bills in excess of $1,625.00 that should have
been paid under the plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, have violated or are
accountable under the following provisions of the Florida Insurance Code and Rules of the
39
Department of Financial Services which constitute grounds for the suspension or revocation of
your licenses and appointments:
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(1), Florida Statutes];
b. Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance. [Section 626.61 1(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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Sectior. 626.901(1), Florida
Statutes].
40
COUNT XXII
92. The above general allegations are hereby realleged and fully incorporated herein
by reference.
93. Prior to December 1, 2001 you, RAYMOND PINTO, as a licensed insurance
agent, caused to be sold to B.E., of Jackson, Mississippi, a health insurance plan through ABP.
You induced B.E. to believe she was properly covered by health insurance under the plan.
94. As a direct or indirect result of you, RAYMOND PINTO, representing or aiding
ABP, an unauthorized insurer or MEWA, B.E. was sold an unauthorized health insurance plan,
and has alleged that ABP have failed to pay medical bills that should have been paid under thé’
plan.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), 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];
41
d. Violation of any provision of this Code or any law applicable to the business of
insurance in the course of dealing under the licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes).
COUNT XXIII
95. The above general allegations are hereby realleged and fully incorporated herein
by reference.
96. In or about February-March 2003 you, RAYMOND PINTO, as a licensed
insurance agent, aided and abetted agent Paul McCarthy in soliciting or enrolling Florida
consumers in a health insurance plan through Highmark BC/BS, an unauthorized insurer or
MEWA.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), Florida Statutes];
b. Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance. [Section 626.61 1(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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Sectior, 626.901(1), Florida
Statutes].
COUNT XXIV
97. The above general allegations are hereby realleged and fully incorporated herein
by reference.
43
98. In or about February-March 2003 you, RAYMOND PINTO, as a licensed
insurance agent, directly or indirectly representing or aiding Highmark BC/BS, caused to be
solicited to numerous insurance agents, including Manuel Arias, Jose Berrinquer, Ed Pauley,
Tony Donato, Joy Herro, and Sylvester Cuffy, a health insurance plan through Highmark BC/BS,
an unauthorized insurer or MEWA, for sale to Florida consumers.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), 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 applicab‘e to the business of
insurance in the course of dealing under the licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
44
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT XXV
99. The above general allegations are hereby realleged and fully incorporated herein
by reference.
100. In or about February-March 2003 you, RAYMOND PINTO, as a licensed
insurance agent, caused to be sold to K.B., of Ellenton, Florida, a health insurance plan through
Highmark BC/BS, an unauthorized insurer or MEWA.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), Florida Statutes];
b. Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance. [Section 626.611(7), Florida Statutes];
45
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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part [X) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
COUNT XXVI
101. The above general allegations are hereby realleged and fully incorporated herein
by reference.
102. In or about March 2003 you, RAYMOND PINTO, as a licensed insurance agent,
caused to be sold to J.B., of Sebastian, Florida, a health insurance plan through Highmark
BC/BS, an unauthorized insurer or MEWA.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, have violated or are
accountable under the following provisions of the Florida Insurance Code and Rules of the
46
Department of Financial Services which constitute grounds for the suspension or revocation of
your licenses and appointments:
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(1), Florida Statutes];
b. Demonstrated lack of fitness or trustworthiness to engage in the business of
insurance. [Section 626.61 1(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 licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
designated as Part IX) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [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 being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
47
COUNT XXVIT
103. The above general allegations are hereby realleged and fully incorporated herein
by reference.
104. In or about February-March 2003 you, RAYMOND PINTO, as a licensed
insurance agent, caused to be sold to D.R., of Hollywood, Florida, a health insurance plan
through Highmark BC/BS, an unauthorized insurer or MEWA.
IT IS THEREFORE CHARGED that you, RAYMOND PINTO, 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. 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(1), 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 applicab!e to the business of
insurance in the course of dealing under the licensure or appointment. [Section 626.621(2),
Florida Statutes];
e. In the 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 X (re-
48
designated as Part 1X) of this chapter, or having otherwise shown himself or herself to be a
source of injury or loss to the public. [Section 626.621(6), Florida Statutes];
f. No person shall, from offices or by personnel or facilities jocated in this state...
directly or indirectly act as an agent for, or otherwise represent or aid on behalf of another, any
insurer not being authorized to transact such business in this state. [Section 626.901(1), Florida
Statutes].
WHEREFORE, you, RAYMOND PINTO, 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 626.901, Florida Statutes, under the other referenced
Sections of the Florida Statutes as set out in this Administrative Complaint and under the
provisions of Rule Chapter 4-231, Florida Administrative 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. Your written response must be received by the
49
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.
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
50
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 Departments 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 and SIGNED this ‘ X yh _day of May, 2003.
boa, (Mar adller
N CHANDLER
Deputy Chief Financial Officer
31
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 the following:
RAYMOND PINTO, 1490 104” Avenue, Plantation, Florida 33322; RAYMOND PINTO, 8181
West Broward Boulevard, Suite 204, Plantation, Florida 33324; Raymond Pinto, 1370 N.
University, #1370C, Plantation, Florida 33322 by Certified Mail this ad day of June,
2003.
William W. Tharpe, Jr.
se Division of Legal Services
200 East Gaines St.
612 Larson Building
Tallahassee, Florida 32399-0333
(850) 413-4110
Florida Bar Number 312411
i 2. Auticle be COMPLETE THIS SECTION ON DELIVERY
A. Received by (Please Print Clearly) B. Date of Dpiivg
C. Signature 7
X AZ (e2LE ra
FUbO 3901 9844 2700 4379 D. is ll ey acess de ftom tem 12 Yes
3. Service Type CERTIFIED MAIL |
4. Restricted Delivery? (Extra Fee) { Yes
1. Article Addressed to: Rk Tak
RAYMOND PINTO 0 a
8181 W BROWARD BLVD STE 2! Poot Mey
33 '58-03-AG
ON, FL 33324 64858-03-A'
PLANTATI 33 C03
Tharpe
RESTRICTED
DELIVERY
i PS Form 3811, July 2004 Domestic Return Receipt
Docket for Case No: 06-000305PL
Issue Date |
Proceedings |
Apr. 05, 2006 |
Order Closing Files. CASE CLOSED.
|
Apr. 05, 2006 |
Order Granting Departments Motion for Offical Recognition.
|
Apr. 04, 2006 |
Department of Financial Services Motion to Relinquish Jurisdiction filed.
|
Mar. 27, 2006 |
Department of Financial Services` Notice of Response and Objections to Respondents` Request for Production of Documents filed.
|
Mar. 24, 2006 |
Respondents` Exhibit List filed.
|
Mar. 24, 2006 |
Respondents` Witness List filed.
|
Mar. 24, 2006 |
Department`s Motion for Official Recognition filed.
|
Mar. 21, 2006 |
Department of Financial Services` Witness List filed.
|
Mar. 21, 2006 |
Department of Financial Services` Exhibit List filed.
|
Mar. 06, 2006 |
Request for Admissions filed.
|
Mar. 06, 2006 |
Request for Production of Documents filed.
|
Mar. 06, 2006 |
Notice of Service of Respondents` First Set of Interrogatories to Petitioner filed.
|
Feb. 22, 2006 |
Notice of Deposition filed.
|
Feb. 09, 2006 |
Order of Pre-hearing Instructions.
|
Feb. 09, 2006 |
Notice of Hearing (hearing set for April 10 through 13, 2006; 9:30 a.m.; Tallahassee, FL).
|
Feb. 06, 2006 |
Joint Response to Initial Order filed.
|
Jan. 25, 2006 |
Order Opening DOAH Case Numbers 05-1641PL and 05-1642PL as DOAH Case Numbers 06-0305PL and 06-0306PL, and Consolidating Cases (formerly DOAH Case No. 05-1641PL and 05-1642PL).
|
Jan. 11, 2006 |
Letter to Judge Cohen from R. Fox requesting that case be reopened.
|
May 06, 2005 |
Administrative Complaint filed.
|
May 06, 2005 |
Amended Administrative Complaint filed.
|
May 06, 2005 |
Department of Financial Services Motion to Amend Administrative Complaint filed.
|
May 06, 2005 |
Petitioner`s Petition for Formal Section 120.57 (1) Administrative Proceeding filed.
|
May 06, 2005 |
Agency referral filed.
|