STATE OF FLORIDA DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES DIVISION OF MOTORIST SERVICES DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES, DIVISION OF MOTORIST SERVICES, Petitioner, Case No.: MS-14-464 License No.: VI-1041856 v. GSA AUCTIONS, LLC, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, the Department of Highway Safety and Motor Vehicles, Division of Motorist Services, files this Administrative Complaint against GSA Auctions, LLC, Respondent, and alleges: 1. Petitioner is the state agency charged with regulating the business of buying, selling, or dealing in motor vehicles or offering or displaying motor vehicles for sale, pursuant to section 20.24 and chapter 320, Florida Statutes, and Rule 28-106.2015, Florida Administrative Code. 2. Respondent is, and has been at all times material hereto, a licensed motor vehicle dealer in the State of Florida, having been issued license number VI-1041856, based upon the application identifying Georigios Alexopoulos as Manager. The address of record is 4701 Southwest 45" Street, Building 16, Bay 32, Davie, Florida 33314. 3. Section 319.23(6), Florida Statutes, provides that in the case of the sale of a motor vehicle by a licensed dealer to a general purchaser, the dealer, upon application signed by the es ~ purchaser, shall file the application for certificate of title within 30 days from the delivery of the vehicle to the purchaser. 4. Section 320.131(2), Florida Statutes, provides that no more than two temporary tags shall be issued to the same person for the same vehicle. 5. Section 320.131, Florida Statutes, provides the lawful issuance of a temporary tag. 6. Section 320.27(9)(b)5, Florida Statutes, states the a motor vehicle dealer must comply with the terms of any bona fide written, executed agreement, pursuant to the sale of a motor vehicle. COUNT ONE 7. Petitioner realleges and incorporates as if fully stated herein the allegations contained in the paragraphs above. 8. On or about January 2, 2013, Nicole Black purchased a salvage rebuildable 2006 Lexus, VIN JTJHW31U860046329, from Respondent. 9. On or about January 2, 2013, Respondent issued temporary tag AWF4139 to Ms. Black for the 2006 Lexus, VIN JTJHW31U860046329. 10. As of January 2, 2013, the 2006 Lexus, VIN JTJHW31U860046329 had not been inspected therefore a temporary tag could not be issued to the vehicle. 11. Based on the foregoing, Respondent violated section 320.27(9)(b)6, Florida Statutes, through a violation of section 320.131, Florida Statutes, by issuing a temporary tag unlawfully. COUNT TWO 12. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and five, above. 13. Onor about November 15, 2012, Christopher Romano purchased a salvage rebuildable 2007 Volkswagen, VIN WVWLK73C87E035680, from Respondent. 14. Onor about November 15, 2012, Respondent issued temporary tag AVQ4269 to Mr. Romano for the 2007 Volkswagen, VIN WV WLK73C87E035680. 15. As of November 15, 2012, the 2007 Volkswagen, VIN WV WLK73C87E035680 had not been inspected therefore a temporary tag could not be issued to the vehicle. 16. _ Based on the foregoing, Respondent violated section 320.27(9)(b)6, Florida Statutes, through a violation of section 320.131, Florida Statutes, by issuing a temporary tag unlawfully. COUNT THREE 17. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and five, above. 18. Onor about January 10, 2013, Respondent issued temporary tag AWH8227 to Mr. Romano for the 2007 Volkswagen, VIN WV WLK73C87E035680 referenced in paragraph 13 above. 19. As of January 10, 2013, the 2007 Volkswagen, VIN WV WLK73C87E035680 had not been inspected therefore a temporary tag could not be issued to the vehicle. 20. Based on the foregoing, Respondent violated section 320.27(9)(b)6, Florida Statutes, through a violation of section 320.131, Florida Statutes, by issuing a temporary tag unlawfully. COUNT FOUR 21. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and five, above. 22. | Onor about March 26, 2013, Respondent issued temporary tag AXN6913 to Mr. Romano for the 2007 Volkswagen, VIN WVWLK73C87E035680 referenced in paragraph 13 above. 23. As of March 26, 2013, the 2007 Volkswagen, VIN WV WLK73C87E035680 had not been inspected therefore a temporary tag could not be issued to the vehicle. 24. Based on the foregoing, Respondent violated section 320.27(9)(b)6, Florida Statutes, through a violation of section 320.131, Florida Statutes, by issuing a temporary tag unlawfully. COUNT FIVE 25. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and five, above. 26. | Onor about May 14, 2013, Respondent issued temporary tag AYH7516 to Mr. Romano for the 2007 Volkswagen, VIN WV WLK73C87E035680 referenced in paragraph 13 above. 27. As of May 14, 2013, the 2007 Volkswagen, VIN WV WLK73C87E035680 had not been inspected therefore a temporary tag could not be issued to the vehicle. 28. Based on the foregoing, Respondent violated section 320.27(9)(b)6, Florida Statutes, through a violation of section 320.131, Florida Statutes, by issuing a temporary tag unlawfully. COUNT SIX 29. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and four, above. 30. As indicated in paragraphs 13, 18, 22, and 26 above, Respondent issued four temporary tags to the same person for the same vehicle. 31. Based on the foregoing, Respondent violated section 322.27(9)(b)17, Florida Statutes, through a violation of section 320.131(2), Florida Statutes, by issuing more than two temporary tags to the same person for the same vehicle. COUNT SEVEN 32. _ Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and five, above. 33. On or about February 12, 2013, Marco Jacome purchased a salvage rebuildable 2010 Volvo, VIN YV1390MS8A2490380, from Respondent. 34. | Onor about February 12, 2013, Respondent issued temporary tag AWU6282 to Mr. Jacome for the 2010 Volvo, VIN YV1390MS8A2490380. 35. As of February 12, 2013, the 2010 Volvo, VIN YV1390MS8A2490380 had not been inspected therefore a temporary tag could not be issued to the vehicle. 36. Based on the foregoing, Respondent violated section 320.27(9)(b)6, Florida Statutes, through a violation of section 320.131, Florida Statutes, by issuing a temporary tag unlawfully. COUNT EIGHT 37. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and five, above. o o 38. | Onor about February 6, 2013, Robert Gray purchased a salvage rebuildable 2007 Ford, VIN AlFTWW33P57EA89001, from Respondent. 39. | Onor about February 6, 2013, Respondent issued temporary tag AWS1137 to Mr. Gray for the 2007 Ford, VIN AlFTWW33P57EA89001. 40. As of February 6, 2013, the 2007 Ford, VIN AlFTWW33P57EA89001 had not been inspected therefore a temporary tag could not be issued to the vehicle. 41. Based on the foregoing, Respondent violated section 320.27(9)(b)6, Florida Statutes, through a violation of section 320.131, Florida Statutes, by issuing a temporary tag unlawfully. COUNT NINE 42. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and five, above. 43. Onor about February 12, 2013, Reed Rodrigues purchased a salvage rebuildable 2012 Mercedes, VIN 4JGBF8GE8CA783408, from Respondent. 44. Onor about February 12, 2013, Respondent issued temporary tag AWU6700 to Mr. Rodrigues for the 2012 Mercedes, VIN 4JGBF8GE8CA783408. 45. Asof February 12, 2013, the 2012 Mercedes, VIN 4JGBF8GE8CA783408 had not been inspected therefore a temporary tag could not be issued to the vehicle. 46. Based on the foregoing, Respondent violated section 320.27(9)(b)6, Florida Statutes, through a violation of section 320.131, Florida Statutes, by issuing a temporary tag unlawfully. COUNT TEN 47. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and five, above. 48. | Onor about April 1, 2013, Respondent issued temporary tag AXR4998 to Mr. Rodrigues for the 2012 Mercedes, VIN 4JGBF8GE8CA783408 referenced in paragraph 43 above. 49. Asof April 1, 2013, the 2012 Mercedes, VIN 4JGBF8GE8CA783408 had not been inspected therefore a temporary tag could not be issued to the vehicle. 50. Based on the foregoing, Respondent violated section 320.27(9)(b)6, Florida Statutes, through a violation of section 320.131, Florida Statutes, by issuing a temporary tag unlawfully. COUNT ELEVEN 51. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and five, above. 52. | Onor about April 18, 2013, Jimel Brown purchased a 1998 Nissan, VIN 1N4DL01D9WC157792, from Respondent. 53. | Onor about April 18, 2013, Respondent issued temporary tag AXY2363 to Mr. Brown for the 1998 Nissan, VIN 1N4DL01D9WC157792. 54. As of April 18, 2013, the 1998 Nissan, VIN IN4DL01D9WC157792 had not been inspected therefore a temporary tag could not be issued to the vehicle. 55. Based on the foregoing, Respondent violated section 320.27(9)(b)6, Florida Statutes, through a violation of section 320.131, Florida Statutes, by issuing a temporary tag unlawfully. COUNT TWELVE 56. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and six, above. 57. In September 2012, Gamank Investment Ltd. purchased a 2004 Bentley Coupe, from Respondent in the amount of $36,070.00. 58. As of the filing of this Administrative Complaint Gamank Investment Ltd. Has not received the 2004 Bently Coupe from Respondent. 59. Respondent agreed to pay Gamank Investment Ltd. $22,500.00 as settlement for the undelivered 2004 Bentley Coupe. 60. As of the filing of this Adminsitrative Complaint Respondent has only paid Gamank Investment Ltd. approximately$6,500.00. 61. Based on the foregoing, Respondent violated sections 320.27(9)(b)5, Florida Statutes, by failing to comply with the terms of any bona fide written, executed agreement, pursuant to the sale of a motor vehicle. COUNT THIRTEEN 62. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and six above. 63. | Onor about August 3, 2012, Enemi George purchased a 1998 Toyota, VIN 4T1BG28K7WU 195033, from Respondent. 64. | Onor about February 21, 2013, Mr. George purchased a 2000 Saturn, VIN 1G8ZY1273 YZ117427, from Respondent. 65. | Onor about February 26, 2013, Mr. George purchased a 2012 Toyota, 4T1B83FKBCU074148, from Respondent. o o 66. Mr. George paid for all three vehicles referenced in paragraphs 63, 64, and 65 above, in full, with his credit card. Respondent then informed Mr. George he had to pay by wire transfer and Mr. George completed the wire transfer in the full amount for all three vehicles. Respondent informed Mr. George he would reimburse him the amount that was paid on his credit card. 67. As of the filing of this Administrative Complaint Mr. George has not received any of the vehicles he has paid for nor has he received the promised reimbursement to his credit card. 68. Based on the foregoing, Respondent violated sections 320.27(9)(b)5, Florida Statutes, by failing to comply with the terms of any bona fide written, executed agreement, pursuant to the sale of a motor vehicle. COUNT FOURTEEN 69. _ Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and six, above. 70. | Onor about November 13, 2012, Frank Arlia purchased a 2012 Jeep, VIN 1C4RJFAG4CC253198, from Respondent, and submitted payment of $14,048.00 as payment in full for the vehicle. 71. On or about November 14, 2012, Respondent advised Mr. Arlia that the vehicle was not rebuildable and could only be sold for parts. 72. Mr. Arlia tried to bid on other vehicles but was unsuccessful therefore he requested a refund of the $14,048.00. 73. As of the filing of this Administrative Complaint Respondent has not refunded Mr. Arlia his payment of $14,048.00, oO a 74. Based on the foregoing, Respondent violated sections 320.27(9)(b)5, Florida Statutes, by failing to comply with the terms of any bona fide written, executed agreement, pursuant to the sale of a motor vehicle. COUNT FIFTEEN 75. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and three, above. 76. Onor about June 13, 2013, Armand Lamorissiere Lopez purchased a 2012° Mercedes, VIN 2DDGF8BB7CR1 93361, from Respondent. 77. On or about June 13, 2013, Respondent delivered the 2012 Mercedes, VIN 2DDGF8BB7CR1 93361, to Mr. Lamorissiere. 78. Respondent failed to file the application for certificate of title by July 13, 2013, or within 30 days of June 13, 2013. 79. Onor about August 26, 2013, Respondent filed the application for certificate of title for the 2012 Mercedes, VIN 2DDGF8BB7CR193361, which was 44 days after the statutorily required timeframe. 80. Based on the foregoing, Respondent violated section 320.27(9)(b)6, Florida Statutes, through a violation of section 319.23(6), Florida Statutes, by failing to timely file an application for certificate of title to a motor vehicle. COUNT SIXTEEN 81. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and six, above. 82. Onor about August 5, 2012, Chris Cole paid Respondent $1,400.00 as a down payment on a vehicle. 10 o on 83. On or about September 2, 2012, Mr. Cole requested a Refund of the $1,400.00, from Respondent. 84. Respondent keeps advising Mr. Cole that he has to wait 90 days for reimbursement. 85. As of the filing of this Administrative Complaint Respondent has not paid Mr. Cole the $1,400.00 he is owed. 86. Based on the foregoing, Respondent violated sections 320.27(9)(b)5, Florida Statutes, by failing to comply with the terms of any bona fide written, executed agreement, pursuant to the sale of a motor vehicle. COUNT SEVENTEEN 87. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and six, above. 88. | Onor about March 6, 2013, Christopher Gyiripah purchased a 2013 Kia, VIN S5XYKTDA24DG348472, from Respondent and paid a total of $8,600.00 toward the vehicle. 89. Respondent later informed Mr. Gyiripah that he had not won the vehicle and Mr. Gyiripah requested a refund of the $8,600.00. 90. Respondent has refunded Mr. Gyiripah a total of $2,000.00. 91. As of the filing of this Administrative Complaint Respondent has not refunded Mr. Gyiripah the remaining $8,600 due to him. 92. Based on the foregoing, Respondent violated sections 320.27(9)(b)5, Florida Statutes, by failing to comply with the terms of any bona fide written, executed agreement, pursuant to the sale of a motor vehicle. 11 COUNT EIGHTEEN 93. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and six, above. 94. Onor about February 13, 2013, Isa Alabi purchased a 1999 Toyota, VIN 4T3ZF13C7XU114309, from Respondent, in the amount of $2,104.00. 95. Respondent then informed Mr. Alabi that the 1999 Toyota, VIN 4T3ZF13C7XU1 14309, had been sold to someone else. 96. Mr. Alabi then requested a refund of the $2,104.00. Respondent informed Mr. Alabi that he had to wait 60 days to receive his refund. 97. As of the filing of this Administrative Complaint Mr. Alabi has not received his refund of $2,104.00 from Respondent. 98. Based on the foregoing, Respondent violated sections 320.27(9)(b)5, Florida Statutes, by failing to comply with the terms of any bona fide written, executed agreement, pursuant to the sale of a motor vehicle. COUNT NINETEEN 99. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and six, above. 100. On or about March 20, 2013, Richard Nichols deposited $1,000.00 with Respondent in order to bid on vehicles. 101. Onor about July 16, 2013, Mr. Nichols requested a refund of the $1,000.00 as he no longer wanted to bid on any vehicles. 102. As of the filing of this Administrative Complaint Respondent has not refunded Mr. Nichols the $1,000.00. 12 o a 103. Based on the foregoing, Respondent violated sections 320.27(9)(b)5, Florida Statutes, by failing to comply with the terms of any bona fide written, executed agreement, pursuant to the sale of a motor vehicle. COUNT TWENTY 104. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and six, above. 105. Onor about February 8, 2013, Robert Warner purchased a 2012 Nissan, VIN JN8AZ1MW9CW207085, from Respondent. 106. On or about February 13, 2013, Mr. Warner paid to Respondent $13,700.00 for the 2012 Nissan, VIN JN8AZ1MW9CW207085. 107. Mr. Warner never received the 2012 Nissan, VIN JN8SAZIMW9CW207085 and on or about June 24, 2013, requested a refund from Respondent for the $13,700.00. 108. As of the filing of this Administrative Complaint Respondent has not refunded Mr. Warner the $13,700.00 owed. 109. Based on the foregoing, Respondent violated sections 320.27(9)(b)5, Florida Statutes, by failing to comply with the terms of any bona fide written, executed agreement, pursuant to the sale of a motor vehicle. COUNT TWENTY-ONE 110. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and six, above. 111. Onor about July 25, 2013, Richard Watchman purchased a 2009 Mercedes, VIN 4JGBF71E39A456510, from Respondent. 13 on oy 112. On or about July 30, 2013, Mr. Watchman paid Respondent $17,773.00 for the 2009 Mercedes, VIN 4JGBF71E39A456510. 113. As of the filing of this Administrative Complaint Mr. Watchman has not received the 2009 Mercedes, VIN 4JGBF71E39A456510, or a refund of the $17,773.00 paid for the vehicle. 114. Based on the foregoing, Respondent violated sections 320.27(9)(b)5, Florida Statutes, by failing to comply with the terms of any bona fide written, executed agreement, pursuant to the sale of a motor vehicle. COUNT TWENTY-TWO 115. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and six, above. 116. Onor about August 23, 2013, Arye Addady purchased a 2007 Honda from Respondent. 117. Onor about August 29, 2013, Mr. Addady paid Respondent $4,773.00 for the 2007 Honda. 118. As of the filing of this Administrative Complaint Mr. Watchman has not received the 2007 Honda, or a refund of the $4,773.00 paid for the vehicle. 119. Based on the foregoing, Respondent violated sections 320.27(9)(b)5, Florida Statutes, by failing to comply with the terms of any bona fide written, executed agreement, pursuant to the sale of a motor vehicle. COUNT TWENTY-THREE 120. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and six, above. a a 121. Onor about November 19, 2012, Ony Okeke deposited $6,500.00 with Respondent for the purchase of a vehicle. 122. Onor about February 20, 2013, Mr. Okeke requested a refund of the $6,500.00 from Respondent. 123. Respondent advised Mr. Okeke that there would be a $1,300.00 relist fee, which Mr. Okeke eventually agreed to. 124. As of the filing of this Administrative Complaint Mr. Okeke has not received his refund of $4,200.00. 125. Based on the foregoing, Respondent violated sections 320.27(9)(b)5, Florida Statutes, by failing to comply with the terms of any bona fide written, executed agreement, pursuant to the sale of a motor vehicle. COUNT TWENTY-FOUR 126. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and six, above. 127. Onor about August 8, 2013, Janis Priekuls purchased a 2013 Dodge from Respondent. 128. Onor about August 9, 2013, Ms. Priekuls paid Respondent $9,423.00 for the 2013 Dodge. 129. As of the filing of this Administrative Complaint Ms. Priekuls has not received the 2013 Dodge, or a refund of the $9,423.00 paid for the vehicle. 130. Based on the foregoing, Respondent violated sections 320.27(9)(b)5, Florida Statutes, by failing to comply with the terms of any bona fide written, executed agreement, pursuant to the sale of a motor vehicle. COUNT TWENTY-FIVE 131. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and six, above. 132. On or about September 16, 2013, Dejan Teofilovic purchased a 2012 Acura from Respondent. 133. Between September 13, 2013 and September 17, 2013, Mr. Teofilovic paid Respondent $15,754.00 for the 2012 Acura. 134. On or about October 1, 2013, Respondent informed Mr. Teofilovic that the payment of $15,754.00 had not been sent to Copart and the 2012 Acura had been sold to someone else and Mr. Teofilovic’s account was credited $1,000.00 as an inconvenience credit. 135. On or about October 6, 2013, Mr. Teofilovic purchased another 2012 Acura from Respondent. 136. Onor about October 16, 2013, Copart relisted the 2012 Acura for sale. Respondent informed Mr. Teofilovic that the payment had not been sent to Copart. 137. Onor about October 17, 2013, Mr. Teofilovic requested a refund of the $15,754.00 from Respondent. Mr. Teofilovic disputed the credit card charge of $3,000.00 with his credit card company. 138. As of the filing of this Administrative Complaint Mr. Watchman has not received a refund of $12,754.00. 139. Based on the foregoing, Respondent violated sections 320.27(9)(b)5, Florida Statutes, by failing to comply with the terms of any bona fide written, executed agreement, pursuant to the sale of a motor vehicle. 16 COUNT TWENTY-SIX 140. Petitioner realleges and incorporates as if fully stated herein the allegations contained in paragraphs one, two, and six, above. 141. Between January 14, 2013 and February 8, 2013, Theophilus Kofi-Opata purchased four vehicles from Respondent for a total of $13,574.00 plus an additional $4,700.00 for shipping the vehicles to Africa. 142. As of the filing of this Administrative Complaint Mr. Kofi-Opata has not received any of the vehicles he purchased or a refund of the $18,274.00 paid for the vehicles and shipping. 143. Based on the foregoing, Respondent violated sections 320.27(9)(b)5, Florida Statutes, by failing to comply with the terms of any bona fide written, executed agreement, pursuant to the sale of a motor vehicle. 144. There are numerous additional violations which are uncharged herein, but if charged and proven would be cumulative and the same type of violations as listed above. 145. The Department has conducted several records inspections on Respondent’s records. Respondent has failed to keep complete records on vehicles acquired and sold, failed to complete all necessary paperwork on a sale and various other violations which are uncharged herein. EXPLANATION OF RIGHTS You have the right to request a hearing to be conducted in accordance with sections 120.569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call and cross-examine witnesses, and to have subpoena(s) and subpoena(s) duces tecum issued on your behalf if a hearing is requested. In response to the allegations set forth above, you must make one of the following elections and oo ~ file your response within 21 days from the date of your receipt of this Administrative Complaint. Please make your election on the enclosed Election of Rights form and ensure that the Department receives it within 21 days. 1. If you admit the material fact(s) alleged in this Administrative Complaint, you may request a hearing, pursuant to section 120.57(2), Florida Statutes, before the Division of Motorist Services Hearing Officer. At this hearing, you would be given an opportunity to challenge the conclusions of law and/or present written and/or oral evidence in mitigation of any proposed penalty. A request for this type of hearing, in which no material facts are in dispute, should be directed to the Division of Motorist Services Legal Office by checking the appropriate space, marked as “1” on the Election of Rights form, and ensuring that the Department receives it within 21 days from the date of your receipt of this Administrative Complaint. 2. If you dispute any material fact alleged in this Administrative Complaint, you must present sufficient evidence of your dispute and you may request a hearing, pursuant to section 120.57(1), Florida Statutes, at the Division of Administrative Hearings before an Administrative Law Judge. A request for this type of evidentiary hearing, in which material facts are in dispute, should be directed to the Division of Motorist Services Legal Office by checking the appropriate space, marked as “2” on the Election of Rights form, specifying the material allegations of fact you are disputing -- a general denial is not sufficient -- and ensuring that the Division of Motorist Services Legal Office receives it within 21 days from the date of your receipt of this Administrative Complaint. If you elect an evidentiary hearing, you must keep the Division of Motorist Services Legal Office informed of your current mailing address; failure to do so may be considered a waiver of your right to an evidentiary hearing. In the event you fail to file your election in this matter with the Department within 21 days from your receipt of this Administrative Complaint, your failure may be considered a waiver of your right to dispute the alleged facts and the Department may proceed to enter a Final Order based upon the allegations contained in the Administrative Complaint. This document has been served on you by hand delivery, certified mail, or publication. All subsequent documents, orders, notices, or related correspondence will be provided to you by email at the email address you provided to the Department in your license application(s). In the event that no email address was provided in your license application(s), regular US mail will be utilized. If you provided the Department with an email address in your license application(s) you should check your email on a regular basis if an Administrative Complaint or Order of Emergency Suspension has been filed and served on you. Pursuant to section 120.573, Florida Statutes, mediation is not available for this proceeding. 18 WHEREFORE, the Department hereby gives notice of its intent to enter an Order imposing one or more of the following penalties: revocation or suspension of Respondent's license, imposition of an administrative fine, and/or any other relief deemed appropriate. DER:jde Copies furnished: Cathy Coleman Regional Administrator Dealer Licensing By certified mail to: Georigios Alexopoulos, Manager GSA Auctions, LLC 401 East Las Olas Boulevard #130 Ft. Lauderdale, Florida 33301 Damaris E. Reynolds Abmanal, Rependlde Assistant General Counsel Florida Bar # 37176 Department of Highway Safety and Motor Vehicles Neil Kirkman Building, Room A430 Tallahassee, Florida 32399 Telephone: (850) 617-3006 Filed in the official records of the Division of Motorist Services this a! | day of March, 2014.

Docket for Case No: 14-003188