REPRESENTING. ALEX SINK | ¢ CHIEF FINANCIAL OFFIG! STATE OF FLORIDA ,. IN THE MATTER OF: ADLER INSURANCE, INC. CASE NO.: 99111-09-AG ADMINISTRATIVE COMPLAINT ADLER INSURANCE, INC. 6625 MIAMI LAKES DR. STE. #227 MIAMI LAKES, FL 33014 ADLER INSURANCE, INC. 15106 NW 89" CT. MIAMI LAKES, FL 33108-1364 You, ADLER INSURANCE, INC., license I.D. #L016850, 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 agency in this state, as a result of which it is alleged: GENERAL ALLEGATIONS 1. Pursuant to Chapter 626, Florida Statutes, you, ADLER INSURANCE, INC., are currently licensed in this state as an insurance agency. 2. At all times pertinent to the dates and occurrences referred to herein, you, ADLER INSURANCE, INC., were licensed in this state as an insurance agency, license [.D. L016850. 3. Pursuant to Chapter 626, Florida Statutes, the Florida Department of Financial Services (“Department”) has jurisdiction over your insurance agency license and appointments. 4. Rule 69B-222.050, Florida Administrative Code, allows the following actions by unlicensed agency personnel on an incidental basis only: taking an application for insurance at an agent’s office, giving quotes in the office, and receiving premiums at the office. 5. Rule 69B-222.060, Florida Administrative Code, prohibits the following actions at any time by unlicensed agency personnel: advising as to insurance needs or matters, binding coverage, recording additional property under existing policies, and engaging in the substantive discussion of insurance products. COUNT I 6. The above general allegations are hereby realleged and fully incorporated herein by reference. 7. You, ADLER INSURANCE, INC., by, through, and with your owner, president, secretary, treasurer, and registered agent, Oslayda Vento, an unlicensed individual, operated and transacted insurance without a licensed agent. 8. Specifically you, ADLER INSURANCE, INC., acting by, through, and with Oslayda Vento, an unlicensed individual, transacted insurance by executing homeowners, auto, commercial, and property and casualty insurance contracts and renewals, and submitting false information to the Department of Financial Services relating to your transactions of insurance. 9. You, ADLER INSURANCE, INC., took homeowners, auto, commercial, and property and casuaity insurance applications and premiums on a non-incidental basis, effectuated contracts and renewals, and bound coverage contrary to Rules 69B-222.050 and 69B-222.060 of the Florida Administrative Code. 10. Additionally you, ADLER INSURANCE, INC., by, through, and with your unlicensed owner, president, secretary, treasurer, and registered agent, Oslayda Vento, submitted false information to the Department, including but not limited to falsifying an employer certification by forging the signature of one Kendra Bulluck, an agent licensed by the Department and the former agent-in-charge of Adler. IT IS THEREFORE CHARGED that you, ADLER INSURANCE, INC., have violated or are accountable under provisions of one or more of the following: the Florida Statutes or the Florida Administrative Code, which constitute grounds for the suspension or revocation of your license(s) as a Florida insurance agency: (a) Lack by the agency of one or more of the qualifications for the license as specified in this code. [Section 626.6115(1), Florida Statutes]; (b) If the license is used; or to be used, to circumvent any of the requirements or prohibitions of this code. [Section 626.6215(2), Florida Statutes]; (c) 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. [Section 626.6215(5)(d), Florida Statutes]; (d) Violation of any lawful order or rule of the department. [Section 626.6215(5)(e), Florida Statutes]; (e) In the conduct of business under the license, engaging in unfair methods of competition or in unfair or deceptive acts or practices as prohibited under part IX of this chapter. [Section 626.6215(5)(h), Florida Statutes]; (f) Fraudulent or dishonest practices in the conduct of business arising out of activities related to insurance or the insurance agency. [Section 626.6215(5)(), Florida Statutes]; (g) Demonstrated lack of fitness or trustworthiness to engage in the business of insurance arising out of activities related to insurance or the insurance agency. [Section 626.6215(5)(k), Florida Statutes]; (h) Knowingly: a. Filing with any supervisory or other public official, b. Making, publishing, disseminating, circulating, c. Delivering to any person, d. Placing before the public, e. 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)()1., Florida Statutes]; (i) Comparing insurance products; advising as to insurance needs or insurance matters; or interpreting policies or coverages. [Rule 69B-222.060(1), Florida Administrative Code]; Gj) Binding new, additional, or replacement coverage for new or existing customers, or binding coverage on or recording additional property under existing policies. [69B- 222.060(2), Florida Administrative Code]. WHEREFORE, you, ADLER INSURANCE, INC., are hereby notified that the Chief Financial Officer intends to enter an Order suspending or revoking your licenses and appointments as an insurance agency or to impose such penalties as may be provided under the provisions of Sections 626.611, 626.621, 626.681, 626.691, and 626.9521, Florida Statutes, and under the other referenced Sections of the Florida Statutes as set out in this Administrative Complaint. NOTICE OF RIGHTS You have the right to request a proceeding to contest this action by the Department pursuant to Sections 120.569 and 120.57, Florida Statutes, and Rule 28-106, 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 acting as the 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 SUSPENSION OR REVOCATION WILL BE ENTERED AGAINST YOU. If you request a proceeding, you must provide information that complies with the requirements of Rule 28-106.2015, 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, address, and telephone number, and facsimile number (if any) of the respondent (for the purpose of requesting a hearing in this matter, you are the "respondent"). (b) The name, address, telephone number, facsimile number of the attorney or qualified representative of the respondent (if any) upon whom service of pleadings and other papers shall be made. (c) A statement requesting an administrative hearing identifying those material facts that are in dispute. If there are none, the petition must so indicate. (d) A statement of when the respondent received notice of the administrative complaint. (e) A statement including the file number to the administrative complaint. If a hearing of any type is requested, you have the right to be represented by counsel or other qualified representative at your expense, to present evidence and argument, to call and cross-examine witnesses, and to compel the attendance of witnesses and the production of documents by subpoena. If a proceeding is requested and there is no dispute of material fact, the provisions of Section 120.57(2), Florida Statutes, apply. In this regard, you may submit oral or written evidence in opposition to the action taken by the Department or a written statement challenging the grounds upon which the Department has relied. While a hearing is normally not required in the absence of a dispute of fact, if you feel that a hearing is necessary, one will be conducted in Tallahassee, Florida, or by telephonic conference call upon your request. However, if you dispute material facts which are the basis for the Department’s action, you must request an adversarial proceeding pursuant to Sections 120.569 and 120.57(1), Florida Statutes. These proceedings are held before a State Administrative Law Judge of the Division of Administrative Hearings. Unless the majority of witnesses are located elsewhere, the Department will request that the hearing be conducted in Tallahassee, Florida. Failure to follow the procedure outlined with regard to your response to this notice may result in the request being denied. All prior oral communication or correspondence in this matter shall be considered freeform agency action, and no such oral communication or correspondence shall operate as a valid request for an administrative proceeding. Any request for an administrative proceeding received prior to the date of this notice shall be deemed abandoned unless timely renewed in compliance with the guidelines as set out above. Mediation of this matter pursuant to Section 120.573, Florida Statutes, is not available. No Department attorney will discuss this matter with you until the response has been received by the Department. DATED and SIGNED this_§ day of April, 2009. TAMMY TESVON Deputy Chief Financial Officer 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: ADLER INSURANCE, INC., 6625 MIAMI LAKES DR. STE. #227, MIAMI LAKES, FL 33014 and to ADLER INSURANCE, INC., 15106 NW 897 CT., MIAMI LAKES, FL 33108-1364, by Certified Mail this day of April, 2009. Annee Vans Annie Wang : Fla. Bar No. 57863 Department of Financial Services Division of Legal Services 612 Larson Building . 200 East Gaines Street Tallahassee, Florida 32399-0333 (850) 413-4134 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: ADLER INSURANCE, INC., 6625 MIAMI LAKES DR. STE. #227, MIAMI LAKES, FL 33014 and to ADLER INSURANCE, INC., 15106 NW 89" CT., MIAMI LAKES, FL-33108-1364, by Certified Mail this day of April, 2009. Anne W. Annie Wang Fla. Bar No. 57863 Department of Financial Services Division of Legal Services 612 Larson Building 200 East Gaines Street Tallahassee, Florida 32399-0333 (850) 413-4134 qrececetentecnennannneeceeesnneccenssenennsomenitannaraneecmeerenuscesenen cen 2. Article Number 7ibO 3901 9445 1731 9279 COMPLETE THIS SECTION ON DELIVERY WY, en ioe 3. Service Type CERTIFIED MAIL 4. Restricted Delivery? (Extra Fee) 1. Article Addressed to: ADLER INSURANCE , INC. . 5 * 15106 NW 89TH COURT Reference Information f MIAMI LAKES, FL 33108-1364 99111-09-AC / April 8, 2009 Wang RESTRICTED ' PS Form 3811, January 2005 Domestic Return Receipt

Docket for Case No: 09-002834