STATE OF FLORIDA DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES, Petitioner, Case No.: MS-19-001 v. License No.: VI-1104736 MB COLLECTION, INC., Respondent. f ADMINISTRATIVE COMPLAINT Petitioner, the Department of Highway Safety and Motor Vehicles, files this Administrative Complaint against Respondent, MB Collection Inc., 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 Chapter 320 and section 20.24, Florida Statutes, and Rule 28-106.2015, Florida Administrative Code. 2. A motor vehicle dealer is defined as “any person engaged in the business of buying, selling, or dealing in motor vehicles or offering or displaying motor vehicles for sale at wholesale or retail .. . pursuant to an agreement as defined in s. 320.60(1).” Fla. Stat. § 320.27(1)(c). 3. A franchised motor vehicle dealer is defined as “...any person who engages in the business of repairing, servicing, buying, selling, or dealing in motor vehicles pursuant to an agreement as defined in s. 320.60(1).” Fla. Stat. § 320.27(1)(c)(1). 4, 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-1104736, based upon the application identifying Yonatan Benyehuda as President. The physical and mailing address of record is 2550 NW 1* Avenue, Boca Raton, Florida 33431-6602. Page | of 10 DHSMV v. MB COLLECTION, INC, Case No.: MS-19-001 License No.: VI-1104736 Filed February 12, 2019 9:47 AM Division of Administrative Hearings 5. Florida Statute § 320.27(9)(b)(3) and (6), provides that the Department may deny, suspend, or revoke any license issued hereunder or under the provisions of Fla. Stat. §320.77 or §320.771, upon proof that a licensee has committed, with sufficient frequency so as to establish a pattern of wrongdoing on the part of a licensee, violations of one or more of the following activities: “Misrepresentation or false, deceptive, or misleading statements with regard to the sale or financing of motor vehicles which any motor vehicle dealer has, or causes to have, advertised, printed, displayed, published, distributed, broadcast, televised, or made in any manner with regard to the sale or financing of motor vehicles.” 6. Florida Statute §320.27(12), in pertinent part, provides that the Department “may levy and collect a civil fine, in an amount not to exceed $1,000 for each violation, against any licensee if it finds that the licensee has violated any provision of this section or has violated any other law of this state...” COUNT ONE 7. The Department realleges and incorporates paragraphs 1-6 above as if fully set forth herein. 8. In or about August of 2018, Respondent published an advertisement on eBay for the sale of a 2008 Volkswagen Beetle-New 2 door Automatic SE (VIN: 3VWPF3 1Y08M403209) and stated as follows: “SUPER clean Florida owned NON-SMOKER and garage kept car in outstanding condition! Tested at highway speeds and a true pleasure to drive. Exterior is stunning and shines a deep and glossy. Interior equally clean. Only two previous owners and EXTENSIVE service history documented. Freezing cold A/C. Good tire and brakes. Just serviced with oil and fluids. Harvest Beige color code (off- white/taupe). We purposely took close to 70 high-resolution pictures so that you can see the entire car with precision and clarity . .. THERE’S NOTHING TO HIDE!” Page 2 of 10 DHSMV v. MB COLLECTION, INC. Case No.: MS-19-001 License No.: VI-1104736 9. Respondent’s eBay advertisement also contained photographs of a different mint condition 2008 VW New Beetle Convertible 2dr Automatic SE which were purported to be photographs of the 2008 Volkswagen Beetle-New 2dr Automatic SE (VIN: 3VWPF31Y08M403209). 10, Respondent’s eBay advertisement contained at least one photograph of a different vehicle purporting to be the 2008 Volkswagen Beetle-New 2dr Automatic SE (VIN: 3VWPF31Y08M403209), which was taken on May 31, 2018, predating when Respondent acquired the 2008 Volkswagen Beetle-New 2dr Automatic SE (VIN: 3VWPF31Y08M403209) on July 13, 2018. 11. Onor about August 16, 2018, the 2008 Volkswagen Beetle-New 2 door Automatic SE (VIN: 3VWPF31Y08M403209) was purchased by Ronald Rausch for $8,799, after viewing Respondent’s eBay advertisement. 12. The 2008 Volkswagen Beetle-New 2 door Automatic SE (VIN: 3VWPF31Y08M403209) was delivered to Ronald Rausch on or about August 24, 2018. 13. The 2008 Volkswagen Beetle-New 2 door Automatic: SE (VIN: 3VWPF31Y08M403209) delivered to Ronald Rausch was in poor condition. It had various defects not previously disclosed to the purchaser in Respondent’s advertisement or portrayed in the sale photographs and/or description. 14. Based on the foregoing, Respondent has, or caused to have, advertised, printed, displayed, published, distributed, broadcast, televised, and/or made in any manner, a misrepresentation and/or false, deceptive, or misleading statements with regard to the sale of the motor vehicle in violation of section 320.27(9)(b)(3), Florida Statutes. Page 3 of 10 DHSMV v. MB COLLECTION, INC. Case No.: MS-19-001 License No.: VI-1104736 COUNT TWO 15. The Department realleges and incorporates paragraphs 1-6 above as if fully set forth herein. 16. In or about September of 2018, Respondent published an advertisement on Ebay for the sale of a 2012 Volkswagen Passat 4dr Sedan DSG R-Line PZEV (VIN: WVWMP7AN1CE549584) and stated as follows: “We are a licensed and bonded dealership . . . You are looking at an absolute near perfect condition 2012 Volkswagen CC R-line Edition with the optional sport package wheels and loaded heavily with MANY options including dual heated seats, satellite radio, Bluetooth, leather, and MANY more factory options! This car has been garage kept and looks as close to perfect as can be. Florida owned by an adult non-smoker and religiously serviced. This car was much love for and it shows. You will not find a single Dent, ding or major scratch and the interior is immaculate! The car had an extended warranty with just expired 8 months ago so all services are up to date including fresh fluids, newer brakes, and freshly installed tires.” 17. On or about September 10, 2018, the 2012 Volkswagen Passat 4dr Sedan DSG R- Line PZEV (VIN: WVWMP7AN1CE549584) was purchased by Jonathan Willis for $9,000, after viewing Respondent’s eBay advertisement. 18. | Respondent was not a bonded dealership at the time the eBay advertisement was placed. Respondent’s surety bond, issued by Hudson Insurance Company, expired or was cancelled effective on or about August 9, 2018. 19. The 2012 Volkswagen Passat 4dr Sedan DSG R-Line PZEV (VIN: WVWMP7AN1CE549584) was delivered to Jonathan Willis on or about October 5, 2018. 20. The 2012 Volkswagen Passat 4dr Sedan DSG R-Line PZEV (VIN: WVWMP7ANICES549584) delivered to Jonathan Willis was in poor condition. It had various defects not previously disclosed to the purchaser in Respondent’s advertisement or portrayed in the sale photographs and/or description which provided misrepresentations, false, deceptive and/or Page 4 of 10 DHSMV v. MB COLLECTION, INC. Case No.: MS-19-001 License No.: VI-1104736 misleading statements as to the condition on the vehicle purchased by Mr. Willis to include: an extremely loud hammering in the engine; trouble code light for engine was lit; trouble code light for airbag was lit; trouble code for ABS light was lit; trouble code for Electronic Traction Control light was lit; trouble code for Parking Brake Service light was lit; trouble code for Traction Control light was lit; trouble code for Steering Assist light was lit; vehicle had dents to include on the passenger side quarter panel and/or driver’s side front door; dings to include the driver’s side rocker panel; worn paint on bumper; and/or scratches on the trunk. 21. Based on the foregoing, Respondent has, or caused to have, advertised, printed, displayed, published, distributed, broadcast, televised, and/or made in any manner, a misrepresentation and/or false, deceptive, or misleading statement regarding the sale of a motor vehicle in violation of section 320.27(9)(b)(3), Florida Statutes. COUNT THREE 22. The Department realleges and incorporates paragraphs 1-6 above as if fully set forth herein. 23. In or about September of 2018, Respondent published an advertisement on eBay for the sale of a 2007 Volkswagen New Beetle Convertible 2dr Automatic Triple White (VIN: 3VWFF31Y47M409766) and stated as follows: “We are a licensed and bonded dealership . .. Stunning VW Beetle convertible with an automatic transmission and rare ‘triple white’ edition. Garage kept car owned by a non-smoker and much loved for it and it shows. We purposely took over 60 high resolution pictures so that you can see the entire car with precision . . -THERE’S NOTHING TO HIDE! Test driven at highway speeds and a true pleasure to drive. If 10 is a new car, then this beauty is a strong 9.5! Both interior and exterior are IMECCABLY clean as the pics show. Test driven at highway speeds and a true pleasure to drive. Loaded with all possible options including power convertible top, dual heated seats, Monsoon premium sound and all the other goodies including power windows/locks/mirrors, keyless entry and alarm, cruise control, and MANY more factory options.” Page 5 of 10 DHSMV v. MB COLLECTION, INC. Case No.: MS-19-001 License No.: VI-1104736 24. Respondent’s eBay advertisement also contained photographs of a mint condition 2007 Volkswagen New Beetle Convertible (VIN: 3VWPF31 Y08M403209), to include a close-up photograph of the dash display that did not include lit trouble indicator lights. 25. On or about September 30, 2018, the 2007 Volkswagen New Beetle Convertible 2dr Automatic Triple White (VIN: 3VWFF31Y47M409766) was purchased by Gary Huckabee for $7,299, after viewing Respondent’s eBay advertisement. 26. | Respondent was not a bonded dealership at the time the eBay advertisement was placed. Respondent’s surety bond, issued by Hudson Insurance Company, expired or was cancelled effective on or about August 9, 2018. 27, The 2007 Volkswagen New Beetle Convertible 2dr Automatic Triple White (VIN: 3VWFF31Y47M409766) was delivered to Gary Huckabee on or about October 6, 2018. 28. The 2007 Volkswagen New Beetle Convertible 2dr Automatic Triple White (VIN: 3VWFF31Y47M409766) delivered to Gary Huckabee was in poor condition. It had various defects not previously disclosed to the purchaser in Respondent’s advertisement or portrayed in the sale photographs and/or description, which provided misrepresentations, false, deceptive and/or misleading statements as to the condition of the vehicle purchased by Mr. Huckabee to include: trouble code light for engine was lit; trouble code light for airbag was lit; trouble code light for seat belt was lit; trouble code temperature light was lit; air conditioner did not work; radio did not work; visible separation and/or damage to convertible top; driver side door handle was missing; driver side door lock was broken; grease on the armrest; brushing around gear box was missing; damage to bumper; ignition housing damaged; deep gnashes in the paint; rust in the paint; tires were worn, cupped and mismatched; oil leak from brake vacuum pump; ball joint damage; CV boots torn; window does not drop when door opened causing damage to convertible top; Page 6 of 10 DHSMV v. MB COLLECTION, INC. Case No.: MS-19-001 License No.: VI-1104736 incorrect flow to secondary air injection system; cylinder misfire; leak in air intake system; air injection hose broken; trunk seal torn; and/or the battery was installed incorrectly and splash shield was damaged. 29. Based on the foregoing, Respondent has, or caused to have, advertised, printed, displayed, published, distributed, broadcast, televised, and/or made in any manner, a misrepresentation and/or false, deceptive, or misleading statements with regard to the sale of the motor vehicle in violation of section 320.27(9)(b)(3), Florida Statutes. COUNT FOUR 30. | The Department realleges and incorporates paragraphs 1-6 above as if fully set forth herein. 31. ‘In or about September of 2018, Respondent published an advertisement on eBay for the sale of a 2002 GMC Safari AWD (VIN: 1GKEL19X72B512630) and stated as follows: “We are a licensed and bonded dealership ... Very clean and well maintained 2002 Safari AWD with original miles! NON-smoker owned vehicle that was much loved for and it shows. We purposely took over 90 close-up/high resolution pictures so that you can see the entire car with clarity! Interior is spotless! Exterior is super clean with only very minor wear and tear. Drives EXCELLENT and has just gone through a service with documentation. A lot of new parts installed. Tested at highway speeds and a true pleasure to drive with straight alignment.” 32. On or about September 26, 2018, the 2002 GMC Safari AWD (VIN: 1GKEL19X72B512630) was purchased by Fabio Ventilato for $7,799, after viewing Respondent’s eBay advertisement. 33. | Respondent was not a bonded dealership at the time the eBay advertisement was placed. Respondent’s surety bond, issued by Hudson Insurance Company, expired or was cancelled effective on or about August 9, 2018. 34. The 2002 GMC Safari AWD (VIN: 1GKEL19X72B512630) was delivered to Fabio Ventilato on or about October 8, 2018. Page 7 of 10 DHSMV v. MB COLLECTION, INC. Case No.: MS-19-001 License No.: VI-1104736 35. The 2002 GMC Safari AWD (VIN: 1GKEL19X72B512630) delivered to Fabio Ventilato was in poor condition. It had various defects not previously disclosed to the purchaser in Respondent’s advertisement or portrayed in the sale photographs and/or description which provided misrepresentations, false, deceptive and/or misleading statements as to the condition on the vehicle purchased by Mr. Willis to include: the entire undercarriage and accompanying mechanical parts were completed rusted, dangerous, and/or unrepairable. 36. Based on the forgoing, Respondent has, or caused to have, advertised, printed, displayed, published, distributed, broadcast, televised, and/or made in any manner, a misrepresentation and/or false, deceptive, or misleading statements with regard to the sale of the motor vehicle in violation of section 320.27(9)(b)(3), Florida Statutes. COUNT FIVE 37. The Department realleges and incorporates paragraphs 1-6 above as if fully set forth herein. 38. In or about May or June of 2018, Respondent published an advertisement on eBay for the sale of a 2008 Volkswagen Beetle-New 2dr Automatic SE Convertible (VIN: 3VWRF31Y68M412103) and stated as follows: “Gorgeous Gecko green Beetle convertible with only 79,900 original miles. This is a 1 owner Florida garage kept car that was much loved for and it shows. We purposefully took very high-resolution pictures so that you can see the car with precision. The paint shines deep and glossy and there’s no doubt this car did not spend much time in the elements. Interior also very clean showing just minimal wear. The top works perfectly and the A/C is cold. Tires/brakes are good and an oil change was recently performed. The previous owner traded this Beetle in for a 2017 Beetle. An adult in his 50’s. No signs of pets nor kids inside the car. Test driven at highway speeds and a true pleasure to drive with perfectly straight alignment.” The advertisement further states that: “. . . if you are getting this car shipped and are unhappy upon receipt, we will gladly take the car back and refund you. This is how confident we are with this beautiful gecko green Beetle.” Page 8 of 10 DHSMV v. MB COLLECTION, INC. Case No.: MS-19-001 License No.: VI-1104736 39, On or about June 4, 2018, the 2008 Volkswagen Beetle-New 2dr Automatic SE Convertible (VIN: 3VWRF31Y68M412103) was purchased by Mary Mascarella for $8,500, after viewing Respondent’s eBay advertisement. 40. The 2008 Volkswagen Beetle-New 2dr Automatic SE Convertible (VIN: 3VWRF31Y68M412103) was delivered to Mary Mascarella on or about June 9, 2018. 41. Mary Mascarella refused to accept delivery of the 2008 Volkswagen Beetle-New 2dr Automatic SE Convertible (VIN: 3VWRF31Y68M412103) due to the poor condition of the vehicle. Mary Mascarella shipped the vehicle back to Respondent at her own expense. Respondent refused to refund Mary Mascarella upon receipt of the returned vehicle. 42. The 2008 Volkswagen Beetle-New 2dr Automatic SE Convertible (VIN: 3VWRF31Y68M412103) delivered to Mary Mascarella was in poor condition. It had various defects not previously disclosed to the purchaser in Respondent’s advertisement or portrayed in the sale photographs and/or description which provided misrepresentations, false, deceptive and/or misleading statements as to the condition on the vehicle purchased by Mary Mascarella to include: damage and/or dents to the exterior of the vehicle to include both driver and passenger doors; front and rear bumpers; trunk; driver and passenger front quarter panels; rear driver’s side quarter panel; interior arm rest damage; driver’s seat damage; driver’s inside door panel damage and/or door handle broken/damaged. *remainder of page intentionally left blank* Page 9 of 10 DHSMV v. MB COLLECTION, INC. Case No.: MS-19-001 License No.: VI-1104736 WHEREFORE, the Department hereby gives notice of its intent to enter an Order imposing one or more of the following penalties: revocation of Respondent’s license and/or any other relief deemed appropriate. ako This A day of January, 2019. CHRISTIE 8. UTT General Counseb 5 / vy, Cee : a 7 NS / 4 Lori Huskisson Assistant General Counsel Florida Bar No.: 0845531 Department of Highway Safety and Motor Vehicles 2900 Apalachee Parkway, A-432 Tallahassee, FL 32399-0504 Telephone: (850) 617-3101 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via certified mail to Yonatan Benyehuda, President, 2550 NW 1* Avenue, Boca Raton, Florida 33431-6602 this “™ day of January, 2019. Vi, | — LORI HUSKISSON Assistant General Counsel Page 10 of 10 DHSMV v. MB COLLECTION, INC. Case No.: MS-19-001 License No.: VI-1104736 Terry L. Rhodes A SAFER Executive Director 2900 Apalachee Parkway HIGHWAY SAFE ND MOTOR VEHICLES Tallahassee, Florida 32399-0500 www.fihsmv.gov January 3, 2019 RE: HSMV Case No.: MS-19-001 License No.: VI-1104736 Dear Yonatan Benyehuda, You have received an Administrative Complaint from the Department of Highway Safety and Motor Vehicles. You have certain legal rights under Sections 120.569 and 120.57, Florida Statutes, before any final agency action can be taken. The purpose of the following ELECTION OF RIGHTS FORM is to explain the options available to assist you in resolving your case. You may only choose one of the options. If you do not respond to the Administrative Complaint by filing a completed Election Of Rights Form or Petition For Hearing within twenty-one (21) days from receiving this paperwork, the Department will enter a final order of disciplinary action in this case (Rule 28-106.111, Florida Administrative Code). Please consult with an attorney if you have any questions or need further clarification about your legal rights in this case. _—_ ht e = 2 =e [aa Lori Huskisson Assistant General Counsel Department of Highway Safety and Motor Vehicles » Service * Integrity + Courtesy + Professionalism + Innovation « Excellence * An Equal Opportunity Employer ELECTION OF RIGHTS FORM FAILURE TO FILE THIS ELECTION OF RIGHTS FORM OR A PETITION FOR HEARING WITHIN THE TWENTY-ONE (21) DAYS CONSTITUTES A WAIVER OF YOUR RIGHT TO DISPUTE ISSUES OF MATERIAL FACT. This Election of Rights form or a Petition for Hearing must be received by the Department within twenty-one (21) days of your receipt of the Administrative Complaint. All paperwork must be filed (mail, fax, or email) with Joseph Gillespie, DHSMV Agency Clerk, Department of Highway Safety and Motor Vehicles, 2900 Apalachee Parkway, A-432, MS-2, Tallahassee, Florida 32399, Facsimile number: (850) 617-5112, and email address: OGCFiling@flhsmv.gov. Instructions: Please put a mark in ONE of the boxes below. Please attach any additional paperwork when filing this form, if the option you choose requires more information. 1. { ] Ino longer want to be a licensed motor vehicle dealer and I would like to settle this action now. I am including my signed Voluntary Revocation of License (Attachment A). 2. [ ]1 dispute some or all of the facts, which are set forth in the Administrative Complaint, and hereby request a formal evidentiary hearing under Section 120.57(1), Florida Statutes. I am including the Petition for Hearing (Attachment B) or other Petition for Hearing, which provides specific information required by Rule 28-106.201, Florida Administrative Code and by Section 120.569, Florida Statutes. I understand and agree, that if I file an insufficient Petition for Hearing, the petition shall be dismissed, pursuant to Section 120.569(2)(c), Florida Statutes, Iam also providing written proof (e.g. letters, emails, document receipts) to support my petition; however, I understand that I am not required to do so. 3. [ ] 1 admit the facts, which are set forth in the Administrative Complaint, but would like an opportunity to provide oral or written mitigation at an informal hearing. I am including the Petition for Hearing (Attachment B) or other Petition for Hearing, which provides specific information required by Rule 28-106.301, Florida Administrative Code and by Section 120.569, Florida Statutes. I understand and agree, that if I file an insufficient Petition for Hearing, the petition shall be dismissed, pursuant to Section 120.569(2)(c), Florida Statutes. Respondent/Dealer Signature Date Respondent/Dealer Printed Name Page 1 of DHSMV v. MB COLLECTION, INC. Case No.: MS-19-001 License No.: VI-1104736 STATE OF FLORIDA DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES, Petitioner, Case No.: MS-19-001 v. License No.: VI-1104736 MB COLLECTION, INC., Respondent. ATTACHMENT A VOLUNTARY REVOCATION OF LICENSE Comes now, MB COLLECTION, INC., hereinafter referred to as “licensee, “and voluntarily agrees to the revocation of their license as a motor vehicle dealer. Licensee understands and acknowledges that they are voluntarily ceasing to do business as a motor vehicle dealer. Licensee admits that there are currently outstanding sales transactions where payoffs of trade-in vehicles or lien applications have not been processed; applications for title and/or registration have not been applied for or completed; and/or that their required surety bond and/or garage liability insurance coverage has expired or has been cancelled. Licensee further acknowledges that an Administrative Complaint has been or may be filed against their license for failure to comply with the applicable Florida Statutes and Rules, which could result in the revocation of their license. Licensee understands that they would be entitled to a hearing on the alleged violations contained in an administrative complaint prior to the Department’s issuance of a Final Order revoking licensee’s motor vehicle dealer license. However, if the licensee wishes to resolve this matter without further proceedings, the licensee hereby freely and voluntarily waives and foregoes any further right to a hearing on the alleged violation(s) contained in the Administrative Page | of 2 DHSMV v. MB COLLECTION, INC. Case No.: MS-19-001 License No.: Vi-1104736 Complaint that has been filed or may be filed. The licensee agrees that their license will be revoked and become a part of their permanent record maintained by the Department. If an administrative complaint has been filed, a Final Order will be entered herein. Licensee further waives their right to seek judicial review of, or to otherwise challenge, appeal, or contest the Final Order revoking their license. Licensee further understands that their permanent record with the Department will be reviewed if they wish to apply for a motor vehicle dealer’s license in the future. SIGNED this day of. , 20 ‘ By: Yonatan Benyehuda, President MB Collection, Inc. Revised 12/18 Page 2 of 2 DHSMV v. MB COLLECTION, INC. Case No.: MS-19-001 License No.: VI-1104736 STATE OF FLORIDA DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES, Petitioner, Case No.: MS-19-001 v. License No.: VI-1104736 MB COLLECTION, INC., Respondent. ATTACHMENT B / PETITION FOR HEARING [INSTRUCTIONS: You must fill out each of the paragraphs below or your petition may be dismissed pursuant to Section 120.569, Florida Statutes.] Petitioner, MB Collection, Inc., by and through the undersigned representative, files this Petition for Hearing and states: 1. I have read the Department’s Administrative Complaint filed in this matter and understand my options. 2. The name and address of each agency affected: FLORIDA DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES at 2900 Apalachee Parkway, Tallahassee, Florida 32399. 3. Your name: Address: Email address: Facsimile Number: Telephone number: The name, address, and telephone number of your representative, if any, which shall be the address for service purposes during the course of the proceeding: 4. An explanation of how your substantial interests will be affected by the agency determination: Page 1 of 2 DHSMV v. MB COLLECTION, INC. Case No.: MS-19-001 License No.: VI-1104736 5. A statement of when and how you received notice of the agency decision: 6. A statement of all disputed issues of material fact. (If no material facts are in dispute, write “None”): 7. A concise statement of the ultimate facts alleged, including the specific facts you believe warrant reversal or modification of the agency’s proposed action: 8. A statement of the specific rules or statutes you believe require reversal or modification of the agency’s proposed action, including an explanation of how the alleged facts relate to the specific rules or statutes: 9. A statement of the relief you are asking for, stating precisely the action you wish the agency to take with respect to the agency’s proposed action: Filed on the day of : Signed Name Address Phone Number Email Address Page 2 of 2 DHSMV v. MB COLLECTION, INC. Case No.: MS-19-001 License No.: VI-1104736

Docket for Case No: 19-000728