May 28 2009 11:00 FROM : DEPT OF FINANCIAL SERVICES FAX NO. 285845 749R7? May. 26 2689 16:16AM PS MAY 12 2009 Docketed by KY CHIEF FINANCIAL OFFICER STATE OF FLORIDA IN THE MATTER OF: CASE NO.: 103533-09-AG WILLIAM F. ABDO ADMINISTRATIVE COMPLAINT TQ; WILLIAM F. ABDO 6131 Tuscony Circle Jacksonville, FI, 32277 WILLIAM F, ABDO 956 Cesery Boulevard Jacksonville, FL 32211 You, WILLIAM F. ABIDO, 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 a limited surety (bail bond) agent in this state and as a result of which it is alleged: GENERAL ALLEGATIONS 1. Pursuant to Chapter 648, Florida Statutes, you, WILLIAM F. ABDO, currently are licensed in this state as a limited surety (bail bond) agent, and were so licensed at all times relevant to the dates and occurrences referenced herein, Your license identification number is 1D070638. FROM May 28 2009 11:00 DEPT OF FINANCIAL SERVICES FAX NO. + S584o7r4ogr May. 28 2663 1@:11AM P4 2. Pursuant to Chapter 648, Florida Statutes, the Florida Department of Financial Services (hereinafter referred to as the “Department”) has jurisdiction over your license and appointments. 3. At all times relevant to the dates and occurrences referenced herein you, WILLIAM F. ABDO, were owner and the designated primary agent of Bill & Bill Bail Bonds, Inc. (“Bill & Bill Bail Bonds”) located at 956 Cesery Boulevard, Jacksonville, #L 32211. 4, You, WILLIAM F. ABDO, are the only person authorized to sign on the Bill & Bill Bail Bonds bank account. 5. At all times relevant to the dates and occurrences referenced hercin, Candace }loyd was not licensed as a limited surety (bail bond) agent in the State of llorida. 6. At all times relevant to the dates and occurrences teferenced herein, Candace Lloyd, was an cmployce of Bill & Bill Bail Bonds, 7. Atall times relevant to the dates and occurrences referenced herein, Mary Vickers was not licensed as a limited surety (bail bond) agent in the State of Florida. 8. At afl times relevant to the dates and occurrences referenced herein, Mary Vickers, was an employee of Bill & Bill Bail Bonds. 9. At all times relevant to the dates and occurrences referenced herein, Joni Burns was not licensed as a limited surety (bail bond) agent in the State of Florida, 10. At all times relevant to the dates and occurrences referenced herein, Joni Burns was an employee of Bill & Bill Bail Bonds. ll. At all times relevant to the dates and occurrences referenced herein, William Harold Smith was not licensed as a limited surety (bail bond) agent in the State of Florida. May 28 2009 11:01 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + 85845749? May. 25 2669 18:11AM PS 12, At all times relevant to the dates and occurrences refercnced herein, William Harold Smith, was an employee of Bill & Bill Bail Bonds, 13. William Harold Smith was convicted of a felony. 14. Pursuant to Section 648,30(1), Florida Statutes, “[a] person may not act in the capacity of a bail bond agent or temporary bail bond agent of perform any of the fimctions, duties, or powers prescribed for bail bond agents or temporary bail bond agents under this chapter unless that person is qualified, licensed, and appointed as provided in this chapter.” COUNT I 15. The above General Allegations are hereby realleged and fully incorporated herein by reference. 16. Onor about September 12, 2007, Carol Denise Bauman contacted Bill & Bill Bail Bonds to arrange bail for her son Brandon Green because he was incarcerated in the Duval County Jail. 17, You, WILLIAM F, ABDO, went to the Duval County Jail and posted bail for Brandon Green whereupon he was released. | 18. On that same date, Carol Denise Bauman went to Bill & Bill Bail Bonds. At that time and place, Carol Denise Bauman entered into a transaction with Bill & Bill Bail Bonds | employee William Harold Smith. 19. At that time and place, William Harold Smith completed all of the paperwork for the bond including all necessary forms and applications, explained the transaction to Carol Denise Bauman, showed Carol Denise Bauman where to.sign the necessary forms and collected premium payment for the bond. May 28 2009 11:01 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + 85845749? May. 25 2669 18:11AM Pe 20. You, WILLIAM F. ABDO, knowingly authorized and allowed an unlicensed employee to transact bail bond business. 21. You, WILLIAM VF. ABDO, aided and abetted William Harold Smith, an unlicensed person, in the transaction of bail bond business. IT TS THEREI'ORE CHARGLD that you, WILLIAM F. ABDO, have violated or are accountable under one or more of the following provisions of the Florida Insurance Code, and Rules of the Department of Financial Services, which constitutes grounds for the suspension or revocation of your licenses as an insurance agent in this state: (a) Has willfully used, or intended the use, of the license or appointment to circumvent any of the requirements or prohibitions of this chapter or the insurance code. [Section 648.45(2)(d), Florida Statutes] (b) Has demonsttated lack of fitness or trustworthiness to engage in the bail bond business. [Section 648.45(2)(c), Florida Statutes] (c) Has engaged in fraudulent or dishonest practices in the conduct of business under the license or appointment. [Section 648.45(2)(g), Florida Statutes] (d) ‘Has willfully failed to comply with or willfully violated any proper order or rule of the department ot willfully violated any provision of this chapter or the insurance code, [Section 648.45(2)(j), Florida Statutes] (e) Has demonstrated a course of conduct or practices which indicate that the liccnsee is incompetent, negligent, or dishonest or that property or rights of clients cannot safely be entrusted to him or her. [Section 648.45(2)(p), llorida Statutes] (f) Violation of any law relating to the business of bail bond insurance or violation of any provision of the insurance code. [Section 648.45(3)(c), l'lorida Statutes] May 28 2009 11:01 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + 85845749? May. 25 2669 1a:12AM Pr (g) Being found to be a source of injury or Joss to the public or detrimental to the public interest or being found by the department to be no longer carrying on the bail bond business in good faith. [Section 648.45(3)(e), Florida Statutes] (h) An insurer, managing general agent, bail bond agent, or temporary bail bond agent appointed under this chapter may not furnish to any person any blank forms, applications, stationary, business card, or other supplies to be used in soliciting, negotiating, or effecting bail bonds until such person has received from the department a license to act as a bail bond agent and is appointed by the insurer. This does not prohibit an unlicensed employee, under the direct supervision and control of a licensed and appointed bail bond agent, from possessing or executing in the bail bond agency, any forms, except for powers of attorney, bond forms, and collateral receipts, while acting in the scope of his or her employment. [Section 648.441(1), Plorida Statutes) 22, The above General Allegations are hereby realleged and fully incorporated herein by reference. 23, On or about September 1, 2007, Carol Denise Bauman was arrested. Carol Denise Bauman contacted Bill & Bill Bail Bonds to arrange bail for hersclf. 24. Carol Denise Bauman went to Rill & Bill Bail Bonds on Scptember 4, 2007 to pay an additional $200 on the bond premium. At that time and place, Carol Denise Bauman entered into a transaction with Bill & Bill Bail Bonds employees William Harold Smith and Mary Vickers. 24, At that time, you, WILLIAM F. ABDO, were not al Bill & Bill Bail Bonds. May 28 2009 11:02 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + S584o7r4ogr May. 28 2663 1@:12AmM Pe 26. Unlicensed Bill & Bill Bail Bonds employee, Mary Vickers, collected the money and issued a receipt #730927 to Carol Denise Bauman bearing her initials. 27. Carol Denise Bauman went back to Bill & Bill Bail Bonds on September 12, 2007 to pay an additional $500 on the bond premium, At that time and place, Carol Denise Bauman entered into a transaction with Bill & Bill Bail Bonds employee Mary Vickers. 28. At that time, you, WILLIAM F, ABDO, were not at Bill & Bill Bail Bonds. 29, Unlicensed Bill & Bill Bail Bonds employec, Mary Vickers, collected the money and issued a receipt to Carol Denise Bauman bearing her name. 30. William Harold Smith and Mary Vickers completed paperwork for the bond including all necessary forms and applications, explained the transaction, showed where to sign the necessary forms, and collected premium money from Carol Denise Bauman for the bond. 31. You, WILLIAM F. ABDO, knowingly authorized and allowed an unlicensed employee to transact bail bond business. 32, You, WILLIAM F. ABDO, aided and abetted an unlicensed person in the transaction of bail bond business. Il 18 THEREFORE CHARGED that you, WILLIAM F, ABDO, have violated or are accountable under one ot more of the following provisions of the Florida Insurance Code, and Rules of the Department of Financial Services, which constitutes grounds for the suspension or revocation of your licenses as a limited surety (bail bond) agent in this state: (a) Has willfully used, or intended the use, of the license or appointment to circumvent any of the requirements or prohibitions of this chapler or the insurance code. [Section 648.45(2)(d), Dlorida Statutes] May 28 2009 11:02 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + S584o7r4ogr May. 28 2663 1@:12AmM Pa (b) Has demonstrated lack of fitness or trustworthiness to engage in the bail bond business. [Section 648.45(2 (e), Florida Statutes] (c) Has engaged in fraudulent or dishonest practices in the conduct of business under the license or appointment. [Section 648,45(2)(g), Florida Statutes] (d) Has willfully failed to comply with or willfully violated any proper order or rule of the department or willfully violated any provision of this chapter or the insurance code. [Section 648.45(2)(j), Florida Statutes] (e) Has demonstrated a course of conduct or practices which indicate that the licensee is incompetent, negligent, or dishonest or that property or rights of clients cannot safely be entrusted to him or het. [Section 648.45(2)(p), Florida Statutes] (f) Violation of any law relating to the business of bail bond insurance or violation of any provision of the insurance code. [Section 648.43(3)(c), Florida Statutes] (2) Being found to be a source of injury or loss to the public or detrimental to the public interest or being found by the department to be no longer carrying on the bail bond business in good faith, [Section 648.45(3)(e), Florida Statutes] (h) An insurer, managing general agent, bail bond agent, or temporary bail bond agent appointed under this chapter may not furnish to any person any blank forms, applications, stationary, business card, or other supplics to be used in soliciting, negotiating, or effecting bail bonds until such person has received from the department a license to act as a bail bond agent and is appointed by the insurer. This does not prohibit an unlicensed employee, under the direct supervision and control of a licensed and appointed bail bond agent, from possessing or executing in the bail bond agency, any forms, except for powers of attorney, bond forms, and May 28 2009 11:02 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + 85845749? May. 25 2869 16:15AM Pia collateral receipts, while acting in the scope of his or her employment. [Section 648.441(1), Florida Statutes] COUNT HI 33. The above General Allegations are hereby realleged and fully incorporated herein by reference. 34, On or about July 9, 2007, George Jordan called went to Bill & Bill Bail Bonds to atrange bail for his brother, Ronnie Jordan, who was incarcerated, 35. At that time and place, George Jordan entered into a transaction with Bill & Bill Rail Bonds employee, Mary Vickers, to arrange the release of Ronnie J ordan. 36. Atthat time and place, Mary Vickers completed all of the paperwork for the bond including all necessary forms and applications, explained the transaction to George Jordan, showed George Jordan where to sign the necessary forms, and collected $1000 from George Jordan for the bond. 37. George Jordan has never met you, WILLIAM F. ABDO. 38. You, WILLIAM F. ABDO, were present at Bill & Bill Bail Bonds while Mary Vickers conducted this unlicensed transaction. 39. You, WILLIAM F. ABDO, knowingly authorized and allowed an unlicensed employee to transact bail bond business. 40. You, WILLIAM F, ABDO, aided and abetted Mary Vickers, an unlicensed person, in the transaction of bail bond business. rl I§ THEREFORE CHARGED that you, WILLIAM F. ABDO, have violated or are accountable under one or more of the following provisions of the llorida Insurance Code, and May 28 2009 11:03 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + 85845749? May. 28 2689 18:13AM Pil Rules of the Department of Financial Services, which constitutes grounds for the suspension or revocation of your licenses as a limited surety (bail bond) agent in this slate: (a) Has willfully used, or intended the use, of the license or appointment to circumvent any of the requirements or prohibitions of this chapter or the insurance code. [Section 648.45(2) (d), Plorida Statutes] (b) Has demonstrated lack of fitness or trustworthiness to engage in the bail bond business. |Section 648.45(2)(e), Florida Statutes] (c) Has engaged in fraudulent or dishonest practices in ihe conduct of business under the license or appointment. (Scction 648.45(2)(g), Florida Statutes] (d) Has willfully failed to comply with or willfully violated any proper order or rule of the department or willfully violated any provision of this chapter or the insurance code. [Section 648.45(2)(j), Florida Statutes] (c) Has demonstrated a course of conduct or practices which indicate that the licensce is incompetent, negligent, or dishoncst or that property or tights of clients cannot safely be entrusted to him or her. [Section 648.45(2)(p), Florida Statutes] (fh Violation of any law relating to the business of bai! bond insurance or violation of any provision of the insurance code. [Section 648.45(3)(c), Florida Statutes] (2) Being found to be a source of injury or loss to the public or detrimental to the public interest or being found by the department to be no longer carrying on the bail bond business in good faith. [Section 648.45(3)(e), Florida Statutes] (h) An insurer, managing general agent, bail bond agent, or temporary bail bond agent appointed under this chapter may not furnish to any person any blank forms, applications, stationary, business card, or other supplies to be used in soliciting, negotiating, or effecting bail May 28 2009 11:03 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + 85845749? May. 25 2669 16:15AM Pil2 bonds until such perso has received from the department a license to act as a bail bond agent and is appointed by the insurer. This does not prohibit an unlicensed employee, under the direct supervision and control of a licensed and appointed bail bond agent, from possessing or exceuting in the bail bond agency, any forms, except for powers of allorney, bond forms, and collateral receipts, while acting in the scope of his or her employment. [Section 648,441(1), Florida Statutes] COUNT LV 41. The above General Allegations are hereby realleged and fully incorporated herein by reference. 42. Pursuant to Section 648.387(4), Florida Statutes, “[a]n owner, operator, or primary agent may not employ, contract with, or usc the services of any person who has been charged with, found guilty of, or pled guilty or nolo contendere to a felony or a crime punishable by imprisonment of | year or more under the law of any jurisdiction, without regard to whether judgment was entered or withheld from the court.” 43, On ot about July 29, 1992, Bill & Bill Bail Bonds employee William [arold Smith was adjudicated guilty of Possession of a Controlled Substance, a felony, in the Circuit Court in and for Volusia County, in case number 91-1741 CY AES, 44. On or about September 11, 1997, Bill & Bill Bail Bonds employee William Harold Smith was adjudicated guilty of Retail Theft, a felony, in the Circuit Court in and for Volusia County, in case number CRC97-35252CF. 45. On or about January 13, 1999, Bill & Bill Bail Bonds employee William Ilarold Smith was adjudicated guilty of Burglary of a Dwelling, a felony, in ihe Circuit Court in and for Volusia County, in case number 97-35004CF. 10 May 28 2009 11:03 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + 85845749? May. 25 2669 16:14AM Piss 46. You, WILLIAM F. ABDO, knew that William Harold Smith was a convicted felon. 47. Subsequent to William Harold Smith being convicted of felonies, you, WILLIAM kK. ABDO, employed him at Bill & Bill Bail Bonds where he illegally conducted bail bond business. IT IS THEREFORE CHARGED that you, WILLIAM I, ABDO, have violated or ate accountable under one or more of the following provisions of the llorida Insurance Code, and Rules of the Department of Financial Services, which constitutes grounds for the suspension or revocation of your licenses as a limited surety (bail bond) agent in this state: (a) An owner, operator, or primaty agent may not employ, contract with, or use the services of any person who has been charged with, found guilty of, or pled guilty or nolo contendere to a felony or a crime punishable by imprisonment of 1 year or more under the law of any jurisdiction, without regard to whether judgment was entered or withheld from the court. [Section 648.387(4), Florida Statutes] (b) Knowingly aiding, assisting, procuring, advising, or abetting any person in the violation of or to violate a provision of the insurance code or any order or rule of the department, commission, or office. [Section 626.621(12), Florida Statutes] (c) Has willfully failed to comply with or willfully violated any proper order or rule of the department or willfully violated any provision of this chapter or the insurance code. [Section 648.45(2) (j), Florida Statutes] (d) Las demonstrated a course of conduct or practices which indicate that the licensee is incompetent, negligent, or dishonest or that property or rights of clients cannot safely be entrusted to him or her. [Section 648.45(2) (p), Florida Statutes] May 28 2009 11:04 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + 85845749? May. 25 2669 16:14AM P14 (e) Violation of any law relating to the business of bail bond insurance or violation of any provision of the insurance code. [Section 648.45(3) (c), Florida Statutes] (f Being found to be a source of injury or loss to the public or detrimental to the public interest or being found by the department to be no longer carrying on the bail bond business in good faith. [Section 648.45(3) (e), Florida Statutes] COUNT V 48. ‘The above General Allegations ate hereby realleged and fully incorporated herein by reference. 49. -On or about December 3, 2008, William Rodriguez contacted Candy and Kay’s River City Bail Bonds to arrange bail for his son William Rodriguez IT becausc he was incarcerated, Mr. Rodriguez spoke with Candace [loyd. 50, William Rodriguez met you, WILLIAM F. ABDO, and Candace Tloyd, an unlicensed individual, in an elementary schoo! parking lot as directed by Candace Lloyd. 51. At that time and place, and in your presence, William Rodriguez entered into a bail bond transaction with Candace Lloyd. 52. At that time and place, Candace Lloyd completed all of the paperwork for the bond including all necessary forms and applications, explained the terms and conditions of the bond to William Rodriguez, showed William Rodriguez where to sign the necessary forms, answered all of William Rodriguez's questions, and collected a premium payment of $650 for the bond. 53. The forms for the bond bear Candace Tloyd’s signature as a witness, her handwritten notations indicating receipt $650 cash bond premium received. 12 May 28 2009 11:04 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + 85845749? May. 25 2869 1a:14AM Pis 54. Candace Lloyd was wearing a cap that said Bill & Bill Bail Bonds during the unlicensed bail bond transaction. 55.. Candace Lloyd gave William Rodriguez a business card bearing the name and contact information for Bill & Rill Bail Bonds, 56. Candace Lloyd, an unlicensed individual, used Bill & Bill Bail Bonds forms, provided by you, WILLIAM F. ABDO, to conduct the transaction 57. You, WILLIAM F. ABDO, knowingly authorized and allowed an unlicensed person to transact bail bond business in your presence. 58. You, WILLIAM F. ABDO, signed the necessary forms for the bond. 59, You, WILLIAM F. ABDO, aided and abetted Candace Lloyd, an unlicensed person, in the unlaw/ul transaction of bail bond business. IT IS THEREFORE CHARGED that you, WILLIAM F, ABDO, have violated or are accountable under one or more of the following provisions of the Florida Insurance Code, and Rules of the Department of Financial Services, which constitutes grounds for the suspension or revocation of your licenses as an insurance agent in this state: (a) Tas willfully used, or intended the use, of the license. or appointment to circumvent any of the requirements or prohibitions of this chapter or the insurance code. [Section 648.45(2)(d), Llorida Statutes) (b) Has demonstrated lack of fitness or trustworthiness to cngage in the bail bond business. [Section 648.45(2)(e), Florida Statutes] (c) Has engaged in fraudulent or dishonest practices in the conduct of business under the license or appointment. [Section 648.45(2)(g), lorida Statutes] May 28 2009 11:04 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + 85845749? May. 25 2869 16:14AM P16 (d) _Has willfully failed to comply with or willfully violated any proper order or rule of the department or willfully violated any provision of this chapter or the insurance code. [Section 648.45(2)(), Florida Statutes] (e) Has demonstrated a course of conduct ot practices which indicate that the Jicensce is incompetent, negligent, or dishonest or that properly or rights of clients cannot safely be entrusted to him or her. [Section 648.45(2)(p), Florida Statutes] () Violation of any law relating to the business of bail bond insurance or violation of any provision of the insurance code. [Section 648,45(3)(c), Florida Statutes] (g) Being found to be a source of injury of loss to the public of detrimental to the public interest or being found by the department to be no longer carrying on the bail bond business in good faith. [Section 648.45(3)(e), Florida Statutes] (h) An insurer, managing general agent, bail bond agent, or temporary bail bond agent appointed under this chapter may fot furnish to any person any blank forms, applications, stationary, business card, ot other supplics to be used in soliciting, negotiating, or effecting bail bonds until such person has received from the department a license to act as a bail bond agent and is appointed by the insurer. This does not prohibit an unlicensed employee, under the direct supervision and control of a licensed and appointed bail bond agent, from possessing or executing in the bail bond agency, any forms, except for powers of attorney, bond forms, and collateral receipts, while acting in the scope of his or her employment. [Section 648.441(1), Florida Statutes) COUNT VI 60. The above General Allcgations are hereby realleged and fully incorporated herein by reference. May 28 2009 11:04 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + 85845749? May. 25 2669 16:15AM P17 61. On or about June 8, 2007, Mona Garrett went Bill & Bill Bail Bonds to arrange bail for her son Anthony Zurvalec because he was incarcerated, 62. At that time and place, Mona Garrett entered into a transaction with Bill & Bill Bail Bonds employee Mary Vickers. 63, At that time and place, Mary Vickers completed all of the paperwork for the bond including all necessary forms and applications, explained the transaction to Mona Garrctt, showed Mona Garrelt where to sign the necessary forms and collected premium payment for the bond. 64. You, WILLIAM F. ABDO, knowingly authorized and allowed an unlicensed employee to illegally transact bail bond business. 65. You, WILLIAM F. ABDO, aided and abetted Mary Vickers, an unlicensed person, in the illegal transaction of bail bond business. ITIS THEREFORE CHARGID that you, WILLIAM I. ABDO, have violated or are accountable under one or more of the following provisions of the Florida Insurance Code, and Rules of the Department of Financial Services, which constitutes grounds for the suspension of revocation of your licenses as an insurance agent in this stale: (a) Has willfully used, or intended the usc, of the liccnse or appointment to circumvent any of the requirements or prohibitions of this chapter or the insurance code. [Section 648.45(2)(d), Florida Statutes] (b) las demonstrated lack of fitness or trustworthiness to engage in the bail bond business. [Section 648.45(2)(e), Florida Statutes] (ce) Has engaged in fraudulent or dishonest practices in the conduct of business under the license or appointment. [Section 648.45(2)(g), Florida Statutes] 15 May 28 2009 11:05 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + S584o7r4ogr May. 28 2663 16:15AM Pls (a) IJas willfully failed to comply with or willfully violated any proper order or rule of the department or willfully violated any provision of this chapter or the insurance code. [Section 648.45(2)(j), Florida Statutes] (e) Has demonstrated a course of conduct of practices which indicate that the licensee is incompetent, negligent, or dishonest or that property or rights of clients cannot safcly be entrusted to him or her. [Section 648.45(2)(p), Florida Statutes} (f) Violation of any law relating to the business of bail bond insurance or violation of any provision of the insurance code, [Section 648.45(3)(c), Florida Statutes] (g) Being found to be a source of injury or loss to the public or detrimental to the public interest or being found by the department to be no longer carrying on the bail bond business in good faith. [Section 648.45(3)(e), Florida Statutes] (h) An insurer, managing general agent, bail bond agent, or temporary bail bond agent appointed undor this chapter may not furnish to any person any blank forms, applications, stationary, business card, or other supplies to be used in soliciting, negotiating, or effecting bail bonds until such person has received from the department a license to act as a bail bond agent and is appointed by the insurer. This does not prohibit an unlicensed employee, under the direct supervision and control of a licensed and appointed bail bond agent, from possessing or executing in the bail bond agency, any forms, except for powers of attorney, bond forms, and collateral receipts, while acting in the scope of his or her cmployment. [Section 648.441(1), Florida Statutes] COUNT VIT 66, The above General Allegations arc hereby realleged and fully incorporated herein by reference. 16 May 28 2009 11:05 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + 85845749? May. 25 2669 16:15AM P19 67. At all times relevant to the dates and occurrences referenced herein, you, WILLIAM E. ABDO, operated under a contract with a Managing General Agent (“MGA”) named Nidia Diaz. 68. You, WILLIAM F. ABDO, entered into a contract with Nidia Diaz on November 22, 2006, making her your MGA and authorizing you to write bonds. 69, You, WILLIAM F. ABDO, violated your contractual obligations with your MGA by not submitting bail bond reports and payments to the surety in a timely manner, and failing to return collateral in a timely fashion. 70, , On August 6, 2007, your MGA tcrminated your authority to write bonds in a letter from Nidia Diaz. q1. As of August 6, 2007, you, WILLIAM F. ABDO, owed an outstanding balance of $17,442.64 to your MGA, $4,255.30 of which was collateral that you, WILLIAM F. ABDO, failed to return to indernnitors. [LIS THERLEORE CHARGED that you, WILLIAM Ff. ABDO, have violated or are accountable under one or more of the following provisions of the Florida Insurance Code, and Rules of the Department of Financial Services, which constitutes grounds for the suspension or revocation of your licenses as an insurance agent in this state: (a) Has demonstrated lack of fitness or trustworthiness to engage in the bail bond business. [Section 648.45(2)(e), Florida Statutes] (b) Has demonstrated a lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment. [Section 648.45(2)(f), Florida Statutes] May 28 2009 11:05 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + 85845749? May. 25 2869 16:16AM Pee (c) Is guilty of misappropriation, conversion, or unlawful withholding of moneys belonging lo a surety, a principal, or others and received in the conduct of business under a license. [Section 648.45(2)(h), Florida Statutes] (d) Has willfully failed to comply with or willfully violated any proper order or rule of the department or willfully violated any provision of this chapter or the insurance code. [Section 648.45(2)(j), Florida Statutes] (ce) Has demonstrated lack of good faith in carrying out contractual obligations and agreements, [Section 648.45(2)(1), Florida Stalutes| (f) Has failed to return collateral. [Section 648.45(2)(n), Florida Statutes] (p) Has demonstrated a course of conduct or practices which indicale that the licensee is incompetent, negligent, or dishonest or that property or tights of clients cannot safely be entrusted to him or her. [Section 648.45(2)(p), Florida Statutes] (h) Violation of any law relating to the business of bail bond insurance or violation of any provision of the insurance code. | Section 648.45(3)(¢), Florida Statutes] (i) Being found to be a source of injury or loss to the public or detrimental to the public interest or being found by the department to no longer carrying on the bail bond business in good faith. [Scction 648.45(3)(e), Florida Statutes] WHEREFORE, you, WILLIAM I, ABDO, are hereby notified that the Chief Financial Officer intends to enter an Order suspending or revoking your licenses and appointments as a limited surety (bail bond) agent, or to impose such penalties as may be provided under the provisions of Chapter 648, Florida Statutes, and under the other referenced sections of the Florida Statutes as set out in this Administrative Complaint. You are further notified that any order entered in this case revoking or suspending any liccnse or eligibility for hcensure held by 18 May 28 2009 11:06 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + S584o7r4ogr May. 28 2669 1e:16AM Pel you shall also apply to all other licenses and eligibility held by you under the Florida Insurance Code. NOTICE OF RIGHTS You have the right to request a procceding to contest this action by the Department of Financial Services ("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. Compiction 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 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"). 19 May 28 2009 11:06 FROM : DEPT OF FINANCIAL SERVICES FAs NO. : 8564874987 May. 26 2669 16:16AM P22 (b) ‘The name, address, telephone number, facsimile number of the attorney of qualificd 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 Heatings. Unless the majority of witnesses are located clsewhere, 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. Amy request for an 20 May 28 2009 11:06 FROM :DEPT OF FINANCIAL SERVICES FAX NO. + S584o7r4ogr May. 25 2663 16:17AM Pes administrative proceeding received prior to the date of this notice shall be deemed abandoned unless timely renewed in compliance with the guidelincs as set oul 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 ana) 2009. TAMMY TESYON Deputy Chief Financial Officer 21 May 28 2009 11:07 FROM : DEPT OF FINANCIAL SERVICES FAs NO. : 8564874987 May. 26 2689 16:17AM P24 CERTIFICATE OF SERVICE THEREBY CERTIFY that a true and correct copy of the foregoing ADMINISTRATIVE COMPLAINT and the following LLECTION OF PROCEEDING has been furnished to: WILLIAM F. ABDO 6131 Tuscony Circle Jacksonville, 1’, 32277 WILLIAM I’. ABDO 956 Cesery Boulevard Jacksonville, FL 32211 By Certified Mail this l WK aay of U ag » 2009, WmfGAUTIER KITCHEN da Department of Financial Services Division of Legal Services 200 East Gaines St. 612 Larson Building Tallahassee, Florida 32399-0333 (850) 413-4210 Florida Bar Number 689793 22

Docket for Case No: 09-002927PL