FILED NOV 26 2018. rai Docketed by. CHIEF FINANCIAL OFFICER JIMMY PATRONIS STATE OF FLORIDA IN THE MATTER OF: CASE NO. 234781-18-AG SAMUEL JACKS l ADMINISTRATIVE.COMPLAINT Samuel Jacks 499 NW 70° Ave, Suite 204 Plantation, Florida 33317 Samuel Jacks 13755 Carlton Dr. Davie, FL 33330 Samuel Jacks (“Respondent”), license LD. #A128727, is 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 life (2-16), health (2-40), life and health (2-18) and general lines (2-20) insurance agent in this state, as a result of which it is alleged: GENERAL ALLEGATIONS, 1. Pursuant to chapter 626, Florida Statutes, Respondent is currently licensed in this state as a life (2-16), health (2-40), life and health (2-18) and general lines (2-20) insurance agent. 2. At all times pertinent to the dates and occurrences referred to herein, Respondent was licensed in this state as a life (2-16), health (2-40), life and health (2-18) and general lines (2-20) insurance agent. 3. Pursuant to chapter 626, Florida Statutes, the Florida Department of Financial Services (hereinafter referred to as the “Department”) has jurisdiction over Respondent’s insurance license(s) and appointment(s). 4. Respondent is the president, only officer, and agent in charge of Pelican Insurance Agency, Inc. (“Pelican”). COUNT.L 5. The above general allegations are hereby realleged and fully incorporated herein by reference. 6. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 7. At all times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 8. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 9. At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business. 10. At all times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 11. At all times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling (“Manual”) with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 12. At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 13. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for On the Rise Investments, LLC, at 4515 Treehouse Lane #12-G, Tamarac, FL 33319. 14. The declination letter reflected that Florida Family Insurance (“Florida Family”) would not provide insurance coverage for 4515 Treehouse Lane #12-G, Tamarac, FL 33319. 15. Atall times relevant to the dates and occurrences herein, neither Pelican nor any of its employees or officers were appointed by Florida Family to write property insurance. 16. Florida Family did not generate the declination letter for 4515 Treehouse Lane #12- G, Tamarac, FL 33319. Had Florida Family generated the declination letter, it would have included quote numbers and an updated Florida Family logo. 17. The declination letter for 4515 Treehouse Lane #12-G, Tamarac, FL 33319 was falsified. 18. Citizens wrote a policy for 4515 Treehouse Lane #12-G, Tamarac, FL 33319 based in part on the false declination letter. 19. Pelican and Jacks received commissions for the policy written by Citizens for 4515 Treehouse Lane #12-G, Tamarac, FL 33319. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (b) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. ' (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” (e) Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1; Knowingly: a. Filing with any supervisory ot 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.” (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual.” 20. The above general allegations are hereby realleged and fully incorporated herein by reference. 21. ‘At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 22. Atal times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 23. At all times relevarit to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. oO Oy 24. At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business. 25. At all times relevant to the dates and occurrences referenced hetein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 26. At all times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 27. At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must:-be submitted for Underwriting review.” 28. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for On the Rise Investments, LLC, at 5120 SW 40 Ave #7A, Fort Lauderdale, FL 33314. 29, The declination letter reflected that Florida Family Insurance (“Florida Family’) would not provide insurance coverage for On the Rise Investments, LLC, at 5120 SW 40 Ave #7A, Fort Lauderdale, FL 33314. 30. At all times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 31. Florida Family did not generate the declination letter for On the Rise Investments, LLC, at 5120 SW 40 Ave #7A, Fort Lauderdale, FL 33314. Had Florida Family generated the declination letter, it would have included quote numbers and an updated Florida Family logo. 32. The declination letter for On the Rise Investments, LLC, at 5120 SW 40 Ave #7A, Fort Lauderdale, FL 33314 was falsified. 33. Citizens wrote a policy for On the Rise Investments, LLC, at 5120 SW 40 Ave #7A, Fort Lauderdale, FL 33314 based in part on the false declination letter. 34. Pelican and Jacks received commissions for the policy written by Citizens for On the Rise Investments, LLC, at 5120 SW 40 Ave #7A, Fort Lauderdale, FL 33314. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. NM cr (b) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasoriably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public,” (e) Section 626.9541(1)}(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1, 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.” fax (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual.” COUNT HI 35. The above general allegations are hereby realleged and fully incorporated herein by reference. 36. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 37, Atall times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 38. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 39. At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business. 40. At all times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 41. Atall times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or MO ‘- & (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 42. _ At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 43. Between August 12, 2014 and F ebruary 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for On the Rise Investments, LLC, at 4205 N. University Dr., Apt. 111, Sunrise, FL 33351. 44. The declination letter reflected that Florida Family Insurance (“Florida Family”) would not provide insurance coverage for On the Rise Investments, LLC, at 4205 N. University Dr., Apt. 111, Sunrise, FL 33351. 45. Atal] times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 46. Florida Family did not generate the declination letter for On the Rise Investments, LLC, at 4205 N. University Dr., Apt. 111, Sunrise, FL 33351. Had Florida Family generated the declination letter, it would have included quote numbers and an updated Florida Family logo. 47. The declination letter for On the Rise Investments, LLC, at 4205 N. University Dr., Apt. 111, Sunrise, FL 33351 was falsified. 48. Citizens wrote a policy for On the Rise Investments, LLC, at 4205 N. University Dr., Apt. 111, Sunrise, FL 33351 based in part on the false declination letter: 10 7 49. Pelican and Jacks received commissions for the policy written by Citizens for On the Rise Investments, LLC, at 4205 N. University Dr., Apt. 111, Sunrise, FL 33351. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license of appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (b) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment.;.” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, 11 c it service representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” (e) Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1, 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.” (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other — from any insurer, agent, broker, or individual.” COUNT IV 50. The above general allegations are hereby realleged and fully incorporated herein i by reference. 51. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 52. Atall times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 53. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 12 ‘a a 54. At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business. 55. At all times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 56. At all times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 57. At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 58. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for On the Rise Investments, LLC, at 7503 Kimberly Blvd., Unit 110, N. Lauderdale, FL. 13 nm 59. The declination letter reflected that Florida Family Insurance (“Florida Family”) would not provide insurance coverage for On the Rise Investments, LLC, at 7503 Kimberly Blvd., Unit 110, N. Lauderdale, FL. 60. At all times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 61. Florida Family did not generate the declination letter for On the Rise Investments, LLC, at 7503 Kimberly Blvd., Unit 110, N. Lauderdale, FL. Had Florida Family generated the declination letter, it would have included quote numbers and an updated Florida Family logo. 62. The declination letter for On the Rise Investments, LLC, at 7503 Kimberly Blvd., Unit 110, N. Lauderdale, FL was falsified. 63. Citizens wrote a policy for On the Rise Investments, LLC, at 7503 Kimberly Blvd., Unit 110, N. Lauderdale, FL based in part on the false declination letter. 64. Pelican and Jacks received commissions for the policy written by Citizens for On the Rise Investments, LLC, at 7503 Kimberly Blvd., Unit 110, N. Lauderdale, FL. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. 14 oO (b) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasonably: adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated jack of fitness or trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative's, service representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” (e) Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1, 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.” 15 Pa (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or telative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual.” COUNT V 65. The above gencral allegations are hereby realleged and fully incorporated herein by reference. 66. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 67. Atall times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. . 68. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 69. At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business. 70, At all times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 71. At all times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or 16 fa a (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 72. At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 73. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for On the Rise Investments, LLC, at 7503 Kimberly Blvd., Unit 110, N. Lauderdale, FL. 74. The declination letter reflected that Florida Family Insurance (“Florida Family”) would not provide insurance coverage for On the Rise Investments, LLC, at 4222 Inverrary Blvd., #4703, Lauderhill, FL 33319. 75, Atall times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance, 76. Florida Family did not generate the declination letter for On the Rise Investments, LLC, at 4222 Inverrary Blvd., #4703, Lauderhill, FL 33319. Had Florida Family generated the declination letter, it would have included quote numbers and an updated Florida Family logo. Ti The declination letter for On the Rise Investments, LLC, at 4222 Inverrary Blvd., #4703, Lauderhill, FL 33319 was falsified. 78. Citizens wrote a policy for On the Rise Investments, LLC, at 4222 Inverrary Blvd., #4703, Lauderhill, FL 33319 based in part on the false declination letter. 17 79. Pelican and Jacks teceived commissions for the policy written by Citizens for On the Rise Investments, LLC, at 4222 Inverrary Blvd., #4703, Lauderhill, FL 33319. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (b) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the ” transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer tepresentative’s, service representative’s, or managing general agent’s license or appointment. (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative's, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, 18 service representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices... or having othetwise show himself or herself to be a source of injury or loss to the public.” (e) Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1:: 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.” (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[(e] a false or fraudulent written ot oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual.” COUNT VI 80. The above general allegations are hereby realleged and fully incorporated herein by reference. 81. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 82. Atall times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 83. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 19 ra 84. At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business. 85. — Atall times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 86. Atall times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 87. At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 88. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for Milan Development Group LLC at 4449 Treehouse Lane, Unit C, Tamarac, FL 33319. 20 ~ 89. The declination letter reflected that Florida Family Insurance (“Florida Family”) would not provide insurance coverage for Milan Development Group LLC at 4449 Treehouse Lane, Unit C, Tamarac, FL 33319," 90. At all times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 91. Florida Family did not generate the declination letter for Milan Development Group LLC at 4449 Treehouse Lane, Unit C, Tamarac, FL 33319. Had Florida Family generated the declination letter, it would have included quote numbers and an updated Florida Family logo. 92. The declination letter for Milan Development Group LLC at 4449 Treehouse Lane, Unit C, Tamarac, FL 33319 was falsified. 93. Citizens wrote a policy for Milan Development Group LLC at 4449 Treehouse Lane, Unit C, Tamarac, FL 33319 based in part on the false declination letter. 94. Pelican and Jacks received commissions for the policy written by Citizens for Milan Development Group LLC at 4449 Treehouse Lane, Unit C, Tamarac, FL 33319. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his license{s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license of appointinent. 21 Oo O (b) Section 626.611(1), Florida Statutes, which ‘provides, in relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the ” transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. . (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.62 1(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” (e) Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1. Knowingly: a. Filing with any supervisory or other public official, b. Making, publishing, disseminating, circulating, c. Delivering to any person, d. Placirig before the public, ec. Causing, directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the public, any false material statement.” 22 (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual.” COUNT VII 95. The above general allegations are hereby realleged and fully incorporated herein by reference. 96. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 97. Atal times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 98. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 99. At all times relevant to the dates and occurrences referenced herein; Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business. 100. Atall times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 101. Atall times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or 23 a a (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 102, At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 103. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for Milan Development Group LLC at 9150 NW 98™ Drive Apt 309, Coral Springs, FL 33065. 104. The declination letter reflected that Florida Family Insurance (“Florida Family”) would not provide insurance coverage for Milan Development Group LLC at 9150 NW 98" Drive Apt 309, Coral Springs, FL 33065. 105. Atall times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 106. Florida Family did not genetate the declination letter for Milan Development Gtoup LLC at 9150 NW 98™ Drive Apt 309, Coral Springs, FL 33065. Had Florida Family generated the declination letter, it would have included quote numbers and an updated Florida Family logo. 107. The declination letter for Milan Development Group LLC at 9150 NW 98™ Drive Apt 309, Coral Springs, FL 33065 was falsified. 108. Citizens wrote a policy for Milan Development Group LLC at 9150 NW 98™ Drive Apt 309, Coral Springs, FL 33065 based in part on the false declination letter. 24 109. Pelican and Jacks received commissions for the policy written by Citizens for Milan Development Group LLC at 9150 NW 987 Drive Apt 309, Coral Springs, FL 33065. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (b) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, 25 om oO sefvice representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” (e) Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1. 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.” (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual.” COUNT VIII 110. The above general allegations are hereby realleged and fully incorporated herein by reference. 111. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 112. Atall times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 113. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 26 114. At all times relevant to the dates and occurtences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business. 115. Atall times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 116. Atall times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 117. At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 118. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for Milan Development Group LLC at 6061 Shakerwood Circle, Unit 202, Tamarac, FL 33319. 27 a 119. The declination letter.reflected that Florida Family Insurance (“Florida Family”) would not provide insurance coverage for Milan Development Group LLC at 6061 Shakerwood Circle, Unit 202, Tamarac, FL 33319. 120. At all times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 121. Florida Family did not generate the declination letter for Milan Development Group LLC at 6061 Shakerwood Circle, Unit 202, Tamarac, FL 33319. Had Florida Family generated the declination letter, it would have included quote numbers and an updated Florida Family logo. 122. The declination letter for Milan Development Group LLC at 6061 Shakerwood Circle, Unit 202, Tamarac, FL 33319 was falsified. 123. Citizens wrote a policy for Milan Development Group LLC at 6061 Shakerwood Circle, Unit 202, Tamarac, FL 33319 based in part on the false declination letter. 124, Pelican and Jacks received commissions for the policy written by Citizens for Milan Development Group LLC at 6061 Shakerwood Circle, Unit 202, Tamarac, FL 33319. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension of revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service tepresentative’s, or managing general agent’s license or appointment. 28 A fa (b) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer tepresentative’s, service representative’s, or managing general agent’s license or appointment. (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness of trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” (e) Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1. 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.” 29 a a (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual.” COUNT IX 125. The above general allegations are hereby realleged and fully incorporated herein by reference. 126. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 127. Atall times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 128. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 129. At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business. 130. At all times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 131. Atal times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or 30 (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 132, At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either: “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 133. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for Milan Development Group LLC at 9255 SW 1* Street, Unit 602, Plantation, Florida 33324. 134. The declination letter reflected that Florida Family Insurance (“Florida Family”) would not provide insurance coverage for Milan Development Group LLC at 9255 SW 1* Street, Unit 602, Plantation, Florida 33324. 135, Atall times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 136. Florida Family did not generate the declination letter for Milan Development Group LLC at 9255 SW 1* Street, Unit 602, Plantation, Florida 33324. Had Florida Family generated the declination letter, it would have included quote numbers and an updated Florida Family logo. 137. The declination letter for Milan Development Group LLC at 9255 SW 1* Street, Unit 602, Plantation, Florida 33324 was falsified. 138. Citizens wrote a policy for Milan Development Group LLC at 9255 SW 1“ Street, Unit 602, Plantation, Florida 33324 based in ‘part on the false declination letter. 31 wy ‘oa 139. Pelican and Jacks received commissions for the policy written by Citizens for Milan Development Group LLC at 9255 SW 1* Street, Unit 602, Plantation, Florida 33324. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (b) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, .customer representative’s, service representative’s, or managing general agent’s license or appointment. (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, 32 service representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” {e) Section 626.9541({1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1. Knowirigly: 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.” (f) Section 626.9541(1)(K)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual.” COUNT X 140. The above general allegations are hereby realleged and fully incorporated herein by reference. 141. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 142, Atall times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 143. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 33 ry 144. At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business. 145. Atall times relevant to the dates and occurrences referenced ‘herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 146. Atall times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 147. At all times relevant,to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, cither “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 148. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for Grand Capital Investments LLC, at 3640 N. 56" Ave, Apt. 414, Hollywood, FL 33021... 34 oO 149. The declination letter reflected that Florida Family Insurance (‘Florida Family”) would not provide insurance coverage for Grand Capital Investments LLC, at 3640 N. 56 Ave, Apt. 414, Hollywood, FL 33021. 150. Atall times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 151. Florida Family did not generate the declination letter for Grand Capital Investments LLC, at 3640 N. 56% Ave, Apt. 414, Hollywood, FL 33021. Had Florida Family generated the declination letter, it would have included quote numbers and an updated Florida Family logo. 152. The declination letter for Grand Capital Investments LLC, at 3640 N. 56% Ave, Apt. 414, Hollywood, FL 33021 was falsified. 153. Citizens wrote a policy for Grand Capital Investments LLC, at 3640 N. 56" Ave, Apt. 414, Hollywood, FL 33021 based in part on the false declination letter. 154. Pelican and Jacks received commissions for the policy written by Citizens for Grand Capital Investments LLC, at 3640 N. 56" Ave, Apt. 414, Hollywood, FL 33021. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. 35 a (b) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the ” transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” (e) Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1. 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.” 36 Oo (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual.” COUNT XI 155. The above general allegations are hereby realleged and fully incorporated herein by reference. . 156. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 157. Atall times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 158. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 159. ‘At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business. ~ 160. Atall times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 161. tall times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen's Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or 37 ‘-) (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 162. At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 163. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for Grand Capital Investments LLC, at 1201 SW52nd Ave #106-2, North Lauderdale, FL 33068. 164. The declination letter reflected that Florida Family Insurance (“Florida Family”) would not provide insurance coverage for Grand Capital Investments LLC, at 1201 SW52nd Ave #106-2, North Lauderdale, FL 33068. 165. Atall times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 166. Florida Family did not generate the declination letter for Grand Capital Investments LLC, at 1201 SW52nd Ave #106-2, North Lauderdale, FL 33068. Had Florida Family generated the declination letter, it would have included quote numbers and an updated Florida Family logo. 167. The declination letter for Grand Capital Investments LLC, at 1201 SW52nd Ave #106-2, North Lauderdale, FL 33068 was falsified. 168. Citizens wrote a policy for Grand Capital Investments LLC, at 1201 SW52nd Ave #106-2, North Lauderdale, FL 33068 based in part on the false declination letter. 38 ‘al 169. Pelican and Jacks received commissions for the policy written by Citizens for Grand Capital Investments LLC, at 1201 SW52nd Ave #106-2, North Lauderdale, FL 33068. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (b) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, 39 service representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” (e) Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1. Knowingly: a. Filing with any supervisory or other public official, b. Making, publishing, disseminating, circulating, c. Delivering to any pefson, d. Placing before the public, e. Causing, directly or indirectly, to be made, published, disseminated, circulated, deliyered to any person, or placed before the public, any false material statement.” (f) Section 626.9541(1)(k)l, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer; agent, broker, or itidividual.” COUNT XII 170. The above general allegations are hereby realleged and fully incorporated herein by reference. 171. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 172. Atal] times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 173. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 40 a a 174. At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business. 175. Atall times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 176. Atall times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet alli other applicable underwriting criteria. 177. At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 178. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for Grand Capital Investments LLC, at 1161 W. River Drive Unit 1, Margate, FL 33063. 41 oO 179. The declination letter reflected that Florida Family Insurance (“Florida Family”) would not provide insurance coverage for Grand Capital Investments LLC, at 1161 W. River Drive Unit 1, Margate, FL 33063. 180. Atal] times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 181. Florida Family did not generate the declination letter for Grand Capital Investments LLC, at 1161 W. River Drive Unit 1, Margate, FL 33063. Had Florida Family generated the declination letter, it would have included quote numbers and an updated Florida Family logo. 182. The declination letter for Grand Capital Investments LLC, at 1161 W. River Drive Unit 1, Margate, FL 33063 was falsified. 183. Citizens wrote a policy for Grand Capital Investments LLC, at 1161 W. River Drive Unit 1, Margate, FL 33063 based in part on the false declination letter. 184. Pelican and Jacks received commissions for the policy written by Citizens for Grand Capital Investments LLC, at 1161 W. River Drive Unit 1, Margate, FL 33063. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or'revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. 42 ry (b) Section 626.611(1), Florida Statutes, which provides, in-relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, sefvice representative's, or managing general agent’s license or appointment. (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment if “in the cotiduct of business under the license or appointment, engaging in unfair methods of competition or in urifair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” (e) Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1. 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.” 43 a fa (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the putpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual.” COUNT XII 185. The above general allegations are hereby realleged and fully incorporated herein by reference. 186. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 187. Atall times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 188. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 189. At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business, 190. At all times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 191. Atall times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to'be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or 7 oO Oy (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 192. At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 193. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for Grand Capital Investments LLC, at 1204 NE 5th Terr. Unit 1, Fort Lauderdale, FL 33304. 194. The declination letter reflected that Florida Family Insurance (“Florida Family”) would not provide insurance coverage for Grand Capital Investments LLC, at 1204 NE 5th Terr. Unit 1, Fort Lauderdale, FL 33304. 195. Atall times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 196. Florida Family did not generate the declination letter for Grand Capital Investments LLC, at 1204 NE 5th Terr. Unit 1, Fort Lauderdale, FL 33304. Had Florida Family generated the declination letter, it would have included quofe numbers and an updated Florida Family logo. 197. The declination letter for Grand Capital Investments LLC, at 1204 NE 5th Terr. Unit 1, Fort Lauderdale, FL 33304 was falsified. 198. Citizens wrote a policy for Grand Capital Investments LLC, at 1204 NE Sth Terr. Unit 1, Fort Lauderdale, FL 33304 based in part on the false declination letter. 45 i“ 199. Pelican and Jacks received commissions for the policy written by Citizens for Grand Capital Investments LLC, at 1204 NE 5th Terr. Unit 1, Fort Lauderdale, FL 33304. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or matiaging general agent’s license or appointment. (b) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment.;.” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment, (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or’ trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or: revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative's, 46 service representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfait methods of competition or in unfair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” (e) Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entties — 1. 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.” (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit, from any insurer, agent, broker, or individual.” COUNT XIV 200. The above general allegations are hereby realleged ahd fully incorporated herein by reference. 201. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 202. Atall times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 203. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 47 o ‘a 204. At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“‘Citizens”) was a residual market entity and was a market of last fesort when placing business. 205. At all times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 206. tall times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and -(c) The property owner and property to be insured meet all other applicable underwriting criteria. 207. At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “g document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 208. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for Premium Coastal Investments, LLC at 1305 S. Flagler Ave, Apt 119, Pompano Beach FL 33060. 48 ‘-) 209. The declination letter reflected that Florida Family Insurance (“Florida Family”) would not provide insurance coverage for Premium Coastal Investments, LLC at 1305 S. Flagler Ave, Apt 119, Pompano Beach FL 33060. 210. Atall times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 211. Florida Family did not generate the declination letter for Premium Coastal Investments, LLC at 1305 S. Flagler Ave, Apt 119, Pompano Beach FL 33060. Had Florida Family generated the declination lettef, it would have included quote numbers and an updated Florida Family logo. 212. The declination letter for Premium Coastal Investments, LLC at 1305 S. Flagler Ave, Apt 119, Pompano Beach FL 33060 was falsified. 213. Citizens wrote a policy for Grand Capital Investments LLC, at Premium Coastal Investments, LLC at 1305 S. Flagler Ave, Apt 119, Pompano Beach FL 33060 based in part on , the false declination letter. 214. Pelican and Jacks received commissions for the policy written by Citizens for Premium Coastal Investments, LLC at 1305 S. Flagler Ave, Apt 119, Pompano Beach FL 33060. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, 49 adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (b) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the 2 transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer Tepresentative’s, service representative’s, or managing general agent’s license or appointment. (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or feotvesntiienss to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment if “in. the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfait or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” {c) Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1. 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. 50 ~™ ry Causing, directly or indirectly, to be made, published, disseminated, circulated, delivered to any‘person, or placed before the public, any false material statement.” (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual.” COUNT XV 215. The above general allegations are hereby realleged and fully incorporated herein by reference. 216. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 217. Atall times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 218. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 219. At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business. 220. Atall times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 31 fa 221. Atall times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 222. At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 223. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for West Plantation Developments LLC at 3660 SW 60" Ave-Unit 3, Davie, FL 33314. 224. The declination Jetter reflected that Florida Family Insurance (“Florida Family”) would not provide insurance coverage for West Plantation Developments LLC at 3660 SW 60% Aye-Unit 3, Davie, FL 33314. 225. Atall times relevant to the dates arid occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 226. Florida Family did not generate the declination letter for West Plantation Developments LLC at 3660 SW 60" Ave-Unit 3, Davie, FL 33314. Had Florida Family generated the declination letter, it would have included ‘quote numbers and an updated Florida Family logo. 52 227. The declination letter for West Plantation Developments LLC at 3660 SW 60% Ave- Unit 3, Davie, FL 33314 was falsified. 228. Citizens wrote a policy for West Plantation Developments LLC at 3660 SW 60" Ave-Unit 3, Davie, FL 33314 based in part on the false declination letter. 229. Pelican and Jacks received commissions for the policy written by Citizens for West Plantation Developments LLC at 3660 SW 60% Ave-Unit 3, Davie, FL 33314. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (b) Section 626.6111), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the + transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, 33 customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” (e) Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1,, 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.” (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual.” COUNT XVI 230. The above general allegations are hereby realleged and fully incorporated herein by reference. 231. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 54 ‘a a 232. Atall times relevant to the dates and occurrences referenced herein, Brian Woodley was an employes of Pelican. 233. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 234, At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business. 235. Atall times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 236. Atall times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or (b) The premium for coverage from the authorized insurer is mofe than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 237. At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 55 MO cry 238. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for West Plantation Developments LLC at 2001 NW 96" Ter, 10H, Pembroke Pines, FL 33024. 239. The declination letter reflected that Florida Family Insurance (“Florida Family”) would not provide insurance coverage for West Plantation Developments LLC at 2001 NW 96" Ter, 10H, Pembroke Pines, FL 33024. 240. At all times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 241. Florida Family did not generate the declination letter for West Plantation Developments LLC at 2001 NW 96" Ter, 10H, Pembroke Pines, FL 33024. Had Florida Family generated the declination letter, it would have included quote numbers and an updated Florida Family logo. 242. The declination letter for West Plantation Developments LLC at 2001 NW 96" Ter, 10H, Pembroke Pines, FL 33024 was falsified. 243. Citizens wrote a policy for West Plantation Developments LLC at 2001 NW 96% Ter, 10H, Pembroke Pines, FL 33024 based in part on the false declination letter. 244. Pelican and Jacks received commissions for the policy written by Citizens for West Plantation Developments LLC at 2001 NW 96" Ter, 10H, Pembroke Pines, FL 33024. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is 56 o grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (b) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” (e) Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1. Knowingly: a. Filing with any supervisory or other public official, b. Making, publishing, 37 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.” (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual.” COUNT XVII 245. The above general allegations are hereby realleged and fully incorporated herein by reference. 246. At all times relevant to the dates and occurrences referenced herein, Respondent was the owner, managing member, an agent in chatge of Pelican in Plantation, Florida. 247, Atall times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 248. At all times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 249. At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last fesort when placing business. 250. At all times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 58 251. Atall times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 252. At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 253. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for West Plantation Developments LLC at 2832 Fillmore St #17, Hollywood, FL 33020. 254. The declination letter reflected that Florida Family Insurance (“Florida Family”) would not provide insurance coverage for West Plantation Developments LLC at 2832 Fillmore St #17, Hollywood, FL 33020. 255. Atall times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 256. Florida Family did not generate the declination letter for West Plantation Developments LLC at 2832 Fillmore St #17, Hollywood, FL 33020. Had Florida Family generated the declination letter, it would have included quote numbers and an updated Florida Family logo. 59 al a 257. The declination letter for West Plantation Developments LLC at 2832 Fillmore St #17, Hollywood, FL 33020 was falsified. 258. Citizens wrote a policy for West Plantation Developments LLC at 2832 Fillmore St #17, Hollywood, FL 33020 based in part on the false declination letter. 259. Pelican and Jacks received commissions for the policy written by Citizens for West Plantation Developments LLC at 2832 Fillmore St #17, Hollywood, FL 33020. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his license(s) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (b) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (c) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, adjuster’s, 60 Oo customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” (e) Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1. 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.” (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual.” COUNT XVIII 260. The above general allegations are hereby realleged and fully incorporated herein by reference. 261. At all times relevant to the dates and occurrences teferenced herein, Respondent was the owner, managing member, an agent in charge of Pelican in Plantation, Florida. 61 la 262. tall times relevant to the dates and occurrences referenced herein, Brian Woodley was an employee of Pelican. 263. Atall times relevant to the dates and occurrences referenced herein, Robert James Peppe was an employee of Pelican. 264. At all times relevant to the dates and occurrences referenced herein, Citizens Property Insurance Corporation (“Citizens”) was a residual market entity and was a market of last resort when placing business. 265. Atall times relevant to the dates and occurrences referenced herein, Citizens was a State of Florida governmental entity, subject to Public Records Requests under Chapter 119, Florida Statutes. 266. Atall times relevant to the dates and occurrences referenced herein, a dwelling was only eligible to be written, pursuant to Citizen’s Personal Lines Underwriting Manual — Dwelling with Citizens if: (a) An authorized insurer is not willing to write the risk at its approved rates; or (b) The premium for coverage from the authorized insurer is more than 15 percent greater than the premium for comparable coverage from Citizens; and (c) The property owner and property to be insured meet all other applicable underwriting criteria. 267. At all times relevant to the dates and occurrences referenced herein, Citizens Manual required agents to upload, in conjunction with the application for insurance, either “a document which shows that there is no-offer of coverage or a document which shows a comparison quote must be submitted for Underwriting review.” 62 268. Between August 12, 2014 and February 20, 2016, Pelican submitted a declination letter in conjunction with an application for a DP-3 policy for Ludaeorum Investing LLC at 5200 NW 31° Ave #H156, Fort Lauderdale, FL 33309. . 269. The declination letter reflected that Florida Family Insurance (“Florida Family”) would not provide irisurance covetage for Ludaeorum Investing LLC at 5200 NW 31" Ave #H156, Fort Lauderdale, FL 33309. 270. Atall times relevant to the dates and occurrences herein, neither Pelican nor any of its officers or employees were appointed by Florida Family to write property insurance. 271. Florida Family did not generate the declination letter for Ludaeorum Investing LLC at 5200 NW 31° Ave #H156, Fort Lauderdale, FL 33309. Had Florida Family generated the declination letter, it would have included quote numbers and an updated Florida Family logo. 272. The declination letter for Ludaeorum Investing LLC at 5200 NW 31* Ave #H156, Fort Lauderdale, FL 33309 was falsified. 273. Citizens wrote a policy for Ludaeorum Investing LLC at 5200 NW 31* Ave #H156, Fort Lauderdale, FL 33309 based in part on the false declination letter. 274. Pelican and Jacks received commissions for the policy written by Citizens for Ludaeorum Investing LLC at 5200 NW 31 Ave #H156, Fort Lauderdale, FL 33309. IT IS THEREFORE CHARGED that Respondent has violated one or more of the following provisions of the Florida Statutes, which constitute grounds for the suspension or revocation of his licenses) as a life, including variable annuities, health, and general lines insurance agent. (a) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Fraudulent or dishonest practices in the conduct of business under the license or appointment...” is grounds for compulsory refusal, suspension, or revocation of an agent’s, title agency’s, 63 ‘a adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (b) Section 626.611(1), Florida Statutes, which provides, in relevant part, “Demonstrated lack of reasonably adequate knowledge and technical competence to engage in the ” transactions authorized by the license or appointment...” is grounds for compulsory refusal, suspension, or tevocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (c) Section 626.611(1}, Florida Statutes, which provides, in relevant part, “Demonstrated lack of fitness or trustworthiness to engage in the business of insurance...” is grounds for compulsory refusal, suspension, of revocation of an agent’s, title agency’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment. (d) Section 626.621(6), Florida Statutes, which provides that it is grounds for discretionary refusal, suspension, or revocation of an agent’s, adjuster’s, customer representative’s, service representative’s, or managing general agent’s license or appointment if “in the conduct of business under the license or appointment, engaging in unfair methods of competition or in unfair or deceptive acts or practices... or having otherwise show himself or herself to be a source of injury or loss to the public.” (e} Section 626.9541(1)(e), Florida Statutes, which defines unfair methods of competition and unfair or deceptive acts or practices, to include “False statements and entries — 1. 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. o oO Causing, directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the public, any false material statement,” (f) Section 626.9541(1)(k)1, Florida Statutes, which makes it a-deceptive act to: “Knowingly mak[e] a false or fraudulent written or oral statement or representation on, or relative to, an application or negotiation for an insurance policy for the purpose of obtaining a fee, commission, money, or other benefit from any insurer, agent, broker, or individual.” WHEREFORE, Respondent is hereby notified that the Chief Financial Officer intends to enter an Order suspending or revoking your license(s) and appointment(s) as an insurance agent or to impose such penalties as may be provided under the provisions of Sections 626.611, 626.621, 626.9541, 626.536, 626.641, 626.681, and 626.691, Florida Statutes, and under sections 69B- 231.080, 69B-231.110 and 69B-231.100 of the Florida Administrative Code, as set out in this Administrative Complaint. : 4 and SIGNED day of Dinlecrber 2018. ee a = 2a Gregory Thomas Director, Agent & Agency Services a tS 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 Julie Jones, DFS Agency Clerk, at the Florida Department of Financial Services, 612 Larson Building, 200 East Gaines Street, Tallahassee, Florida 32399-0390. 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. FAILURE TO ENSURE THAT YOUR WRITTEN RESPONSE IS RECEIVED BY THE DEPARTMENT 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 A _ FINAL 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) Thename, address, telephone number, facsimile number of the attorney or qualified representative of the respondent (if any) upoh 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) Astatement including the file number of the administrative complaint. If a hearing of any type is requested, you have the right to be represented by counsel of other qualified representative at your expense, to present evidence and argument, to call and cross- 66 examine witnesses, and to compel the attendance of witnesses and the production of documents by subpoena. Ifa 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 Departments action, you must request an adversarial proceeding pursuant to sections 120.569 and 120.57(1), Florida Statutes. These proceedings are held before a State Administrative Law Judge of the Division of Administrative Hearings. Unless the majority of witnesses are located elsewhere, the Department will request that the hearing be conducted in Tallahassee, Florida. Failure to follow the procedure outlined with regard to your response to this notice may result in the request being denied. All prior oral communication or correspondence in this matter shali be considered free form 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 attomey will discuss this matter with you until the response has been received by. the Department. 67 CERTIFICATE OF SERVICE I HEREBY CERTIFY a true and correct copy of the foregoing ADMINISTRATIVE COMPLAINT and ELECTION OF PROCEEDING has been furnished to uel Jacks at 499 NW 70" Ave, Suite 204, Plantation FL 33317 by USPS certified mail this, day of ] ov omer , 2018. /s/ Colleen D. Mullen Colleen D. Mullen Florida Bar Number 100327 Department of Financial Services Office of the General Counsel 200 East Gaines Street Tallahassee, Florida 32399-0333 Phone number: (850) 413-4243 Colleen.mullen@myfloridacfo.com qu 72945 qaqu 7039 567? TI0b = ak 70598 155 1 7299 9991 7039 S67? 3650 68 oO STATE OF FLORIDA DEPARTMENT OF FINANCIAL SERVICES DIVISION OF LEGAL SERVICES IN THE MATTER OF: SAMUEL JACKS CASE NO.: 234781-18-AG / ELECTION.OF PROCEEDING. I have received and have read the Administrative Complaint filed by the Florida Department of Financial Services ("Department") against me, including the Notice of Rights contained therein, and I understand my options. I am requésting disposition of this matter as indicated below. (CHOOSE ONE) 1] I do not dispute any of the Department's factual allegations and I do not desire a hearing. ] understand that by waiving my right to a hearing, the Department may enter a final order that adopts the Administrative Complaint and imposes the sanctions sought, including suspending or revoking my licenses and appointments as may be appropriate. 2. I do not dispute any of the Department's factual allegations and I hereby elect a proceeding to be conducted in accordance with Section 120,57(2), Florida Statutes. In this regard, I desire to (CHOOSE ONE): {] Submit a written statement and documentary evidence in lieu of a hearing; or {] Personally attend a hearing conducted by a department hearing officer in Tallahassee; or [J Attend that same hearing by way of a telephone conference call. 3. ] I do dispute one or more of the Department's factual allegations. I hereby request a hearing pursuant to Section 120.57(1), Florida Statutes, to be held before the Division of Administrative Hearings. I have attached to this election form the information required by Rule 28-106.2015, Florida Administrative Code, as specified in subparagraph (c) of the Notice of Rights. Specifically, I have identified the disputed issues of material fact. TO PRESERVE YOUR RIGHT TO A HEARING, YOU MUST FILE YOUR RESPONSE WITH THE DEPARTMENT OF FINANCIAL SERVICES WITHIN TWENTY-ONE (21) DAYS OF YOUR RECEIPT OF THE ADMINISTRATIVE COMPLAINT. THE RESPONSE MUST BE RECEIVED.BY THE DEPARTMENT NO LATER THAN 5:00 P.M. ON THE TWENTY-FIRST DAY AFTER YOUR RECEIPT OF THE ADMINISTRATIVE COMPLAINT. The address for filing is: Julie Jones, DFS Agency Clerk, Florida Department of Financial Services, 612 Larson Building, 200 East Gaines Street, Tallahassee, Florida 32399-0390. Signature ‘Print Name Dates see DO Date Administrative eis - _ Complaint Received. on se ie se te . If you are represented by an attorney or qualified Phone No: ix representative, please attach to this election form his - a or her name, address, telephone and fax numbers 69

Docket for Case No: 19-004611PL