STATE OF FLORIDA OFFICE OF THE ATTORNEY GENERAL DEPARTMENT OF LEGAL AFFAIRS RESPONDENTS.

Transcription

1 STATE OF FLORIDA OFFICE OF THE ATTORNEY GENERAL DEPARTMENT OF LEGAL AFFAIRS IN THE INVESTIGATION OF: L AGENCY FILE NO. GLOBAL CONNECTIONS, INC. a/k/a GLOBAL DISCOVERY VACATIONS, PREMIUM DESTINATIONS, LLC, GVV, FLORIDA, INC. d/b/a GLOBAL VACATION NETWORK and GLOBAL VACATION VENTURES, INC., RESPONDENTS. ~~~~~~~~~~~~~~~~~~~~-----'/ ASSURANCE OF VOLUNTARY COMPLIANCE FOR GLOBAL VACATION VENTURES, INC. Pursuant to the provisions of Chapter 501, Part II, Florida Statutes, the Office of the Attorney General, Department of Legal Affairs, State of Florida ("Attorney General") has investigated the business practices of GLOBAL VACATION VENTURES, INC. (hereafter corporately and/or alternatively referred to as "GVV" or "RESPONDENT"). RESPONDENT has voluntarily and fully cooperated with the Department's investigation; denies having failed to comply with any applicable provisions of Florida law and now agrees to enter into this Assurance of Voluntary Compliance (AVC), without any admission

2 of wrongdoing or the adjudication of any fact or law in order to amicably resolve the Attorney General's investigation. Pursuant to Section (6), Florida Statutes, the Attorney General agrees to accept this A VC in termination of its investigation of RESPONDENT solely as to the acts and practices which were the subject of the Investigation. All Parties to this AVC agree that the tenns and conditions of this AVC are fair, reasonable and consistent with the public interest and the doctrines of applicable law. Tiris AVC is made without trial or adjudication of fact or law and is being entered into for the sole purpose of amicably resolving disputed claims regarding this Irivestigation, absent the necessity of protracted and expensive litigation. The Attorney General and RESPONDENT have negotiated the terms of this A VC in good faith and have entered into this A VC to bring this matter to an agreed resolution. Neither the fact of any provision contained in this AVC nor any action taken hereunder shall constitute, or be construed, as an admission by RESPONDENT for any purpose, of any fact or any violation of any state law, rule, or regulation. Further, this AVC neither constitutes evidence of any liability, fault, or wrongdoing. by RESPONDENT or its concession as to the validity of the Investigation. Finally, this AVC is not evidence of an approval, sanction or authorization by the Attorney General of any act or practice of RESPONDENT. 2 INITIALS@

3 The obligations imposed under this AVC are continuing in nature and shall apply to and be binding upon RESPONDENT whether it is acting through its principals, officers, directors, shareholders, representatives, employees, agents, independent contractors, successors and assigns, or acting through any limited liability company, corporation or other business entity whose acts, practices or policies are directed, formulated, or controlled by RESPONDENT. I. ATIORNEY GENERAL'S ALLEGATIONS (WITHOUT ADMISSION OF WRONGDOING OR WRONGFUL INTENT BY GLOBAL VACATION VENTURES, INC.) 1. Respondent, GLOBAL VACATION VENTURES, INC., is an active State of Florida corporation established in or around 2004, with its principal office located in West Palm Beach,. Palm Beach County, Florida. GLOBAL VACATION VENTURES, INC. is a Florida-based Distributor of GLOBAL CONNECTIONS, INC. vacation club and travel services products. 2. GLOBAL VACATION VENTURES, INC. is a licensed Florida seller of travel which markets and sells vacation club and travel services products to consumers in Florida. 3. Beginning in or around at least 2010, the Office of the Attorney General for the State of Florida began receiving complaints from consumers who claimed that they were deceptively induced into attending vacation club and travel services seminars sponsored by certain Florida-based distributors of vacation club and travel services products of GLOBAL CONNECTIONS, INC. which is located in Overland Park, Kansas. 4. GVV denies it engaged in any wrongful or unlawful conduct and contends that its business practices were and are consistent with industry best practices and that fair and adequate disclosures were and are made to consumers. Regardless, after the Attorney General made GVV aware of the consumer complaints and throughout the investigation, GVV, although it disputed 3 fc) ) INITIALS --;"=7,

4 the basis for such consumer complaints, fully and completely cooperated with the Attorney General in its investigation, addressed such consumer complaints, and made certain voluntary modifications to its business processes and procedures to reduce or eliminate the possibility of consumer confusion or dissatisfaction. 's. The Attorney General and RESPONDENT have negotiated the terms of this AVC in good-faith and have entered into this AVC to bring this matter to an agreed resolution. This A VC constitutes the full and final resolution and termination of the Attorney General's Investigation and the release of all potential civil claims, if any, between the Attorney General and GVV relating to the matters investigated. Neither the fact of, nor any provision contained in this AVC; nor any action taken hereunder shall constitute, or be construed as: (a) an admission by RESPONDENT for any purpose, of any fact or of any violation of any state law, rule, or regulation, nor does this agreement constitute evidence of any liability, fault, or wrongdoing by RESPONDENT; or (b) a concession by RESPONDENT as to the validity of any consumer complaint; or ( c) an approval, sanction or authorization by the Attorney General of any act or practice of GVV. II. NON-MONETARY TERMS AND CONDITIONS 6. In order to promote customer confidence in RESPONDENT'S business and in recognition of the mission of the Office of the Attorney General to promote and ensure fair consumer trade practices in the State of Florida, RESPONDENT, whether it is acting through its principals, officers, directors, shareholders, representatives, employees, agents, independent contractors, successors and assigns, or acting through any limited liability company, corporation or other business entity whose acts, practices or policies are directed, formulated,. r controlled 4

5 by RESPONDENT, shall comply with and not violate any applicable law, rule, regulation including, but not limited to, the provisions of Chapter 501, Part II, Florida's Deceptive and Unfair Trade Practices Act, and F.S (the Florida Free Gift Advertising Law). 7. RESPONDENT shall not distribute within the State of Florida either directly or by an independent third party on its behalf any advertisements and/or offerings to the public which use the word "free," including the use of terms such as "awarded," "prize," "absolutely without charge," "free of charge," and words or groups of words of similar intent which reasonably lead a person to believe that he or she may receive, or has been selected to receive, something of -value, entirely or in part without a requirement of compensation in any form from the recipient, unless the item or portion of an item unconditionally offered as "free" shall in fact be free, without obligation or requirement of consideration in any form. However, any person so receiving and accepting such offer may be required to pay any necessary transportation or delivery charges directly to the United States Postal Service or other regulated public carrier provided that such charges are disclosed in the offer. 8. RESPONDENT shall further not distribute or make any statements within the State of Florida either directly or by an independent third party on its behalf any advertisements and/or incentives to the public which offer items as free with conditions or obligations necessary to acceptance, including travel to a pick up location, unless the advertisements and/or incentives ' clearly and conspicuously disclose all conditions and/or obligations 1 including but not limited 1 "Clear and Conspicuous" or "Clearly and Conspicuously", except as otherwise indicated, shall mean a statement that, regardless of the medium in which it is made, is readily understandable and presented in such size, color, contrast, duration, location, and audibility, compared to the other infonnation with which it is presented, that it is readily apparent to the person to whom it is disclosed. If e). a statement modifies, explains, or clarifies other information with which it is presented, it must be presented in proximity to the information it modifies in a manner that is readily apparent and understandable. 5 INITIALS - -T r--

6 to the following: a. Any fees or costs relating to the travel; b. When such fees or costs are due; and c. The ratio or percentage of marketing incentives issued to conswners who attended one of RESPONDENT'S sales presentations during the preceding year versus the number of conswners who attempted to redeem and who actually received the marketing incentives provided by RESPONDENT at sales presentations. Failure to disclose this information in writing constitutes an unfair and deceptive trade practice pursuant to chapter 501. Any contract entered into in violation of this subsection is void and the purchaser is entitled to a full refund of any moneys paid to RESPONDENT. 9. RESPONDENT shall use commercially reasonable efforts to ensure that at least ninety percent (90%), measured on a rolling 12-month basis, of all consumers who are offered, and in turn accept, a marketing incentive or other item of value in connection with consumers' attendance at RESPONDENT'S sales presentation, utilize said marketing incentive or other item of value no later than one (1) year from the date upon which a consumer attends one of RESPONDENT'S sales presentations. By way of example only, if 100 consumers are offered a free cruise, attend a presentation and seek to attend the free cruise within one year, at least 90 of those consumers must be able to book and/or attend the offered cruise within the year. 10. To further support compliance and the above referenced disclosures, RESPONDENT shall publish all terms and conditions associated with each promotional item offered to consumers by GVV within the State of Florida either on such promotional item or via an Internet 6 INITIALS ~)

7 website stated on any promotional item and shall not materially overstate the cash value of the promotional item. 11. To the extent that GLOBAL VACATION VENTURES, INC. engages any third-party marketing entities to prepare and distribute (or to assist in such preparation and distribution of) advertisements or similar communications to consumers and/or schedule (or to assist in the scheduling of) appointments with consumers to attend vacation club and travel services seminars conducted or sponsored by or on behalf of GVV within the State of Florida, t.lien (a) GVV shall.exercise commercially reasonable diligence in engaging only legally-compliant third party marketing entities; (b) GVV shall provide notice to each engaged third-party marketing entity of the requirements detailed above in Paragraphs 7 and 8; and (c) and GVV shall discontinue such engagement in the event GVV receives written notice that such third-party marketing entity has repeatedly failed or refused to comply with such requirements or with other applicable laws. 12. GVV agrees when advertising to the public, extending marketing incentives and/or conducting vacation club package seminars to the public, not to misrepresent which business background information being presented to the public relates to the local distributor and which background information relates to any larger fulfillment provider, including, but not limited to, GLOBAL CONNECTIONS, INC. GVV further agrees not to make any misrepresentations to consumers with respect to: 1) the identity of the company selling the vacation club and travel services products; 2) the identity of the company which is the actual fulfillment center for the vacation club and travel services products; 3) which company's BBB ratings are being displayed or provided; 4) the number of consumers served by GVV over a particular period of time and/or length of time; and 5) the length oftime that GVV has been in the business of selling 7 INITIALS@

8 the product which is the subject of the vacation club and/or travel services packages seminar and/or any other being seminar conducted by GVV. 13. Respondent, GLOBAL VACATION VENTURES, INC., agrees to provide consumers attending sales presentations with access to view a date-specific list of destination-based properties currently available for reservations through the travel club program during the succeeding twelve".'month period via a web page or print-out hard copy of the webpage containing such information. Respondent, GLOBAL VACATION VENTURES, INC., further agrees. to clearly disclose to consumers during sales presentations where the list may be found on the Internet and how the list may be accessed. Consumers who purchase a membership from RESPONDENT shall have access to the list for at least three (3) days following the date that the consumer signs the membership purchase agreement. 14. Respondent, GLOBAL VACATION VENTURES, INC., agrees not to make false or misleading statements of fact concerning the reasons for, existence of or amounts of price reductions as it relates to the sale of vacation club and travel services products. 15. Respondent, GLOBAL VACATION VENTURES, INC., agrees to accurately represent during sales presentations for vacation club and travel services products, membership and material membership characteristics, uses and benefits as set forth in the membership documents. Further, RESPONDENT agrees to fully describe vacation club and travel services of the membership that is, or will be, offered for sale, including pricing and options of such membership. 16. Respondent, GLOBAL VACATION VENTURES, INC., agrees not to make any statements materially inconsistent with the membership documents or misrepresent any fact or 8 INITIALSQ ~

9 statement of fact material to the transaction such that a conswner reasonably believes the represented or suggested state of affairs to be better than it actually is or otherwise failing to reveal a material fact, the omission of which would reasonably tend to mislead a conswner. 17. Respondent, GLOBAL VACATION VENTURES, INC., agrees to fully describe the vacation club and travel services products or membership options that are, or will be, offered for sale. 18. Respondent, GLOBAL VACATION VENTURES, INC., shall continue with its standard business practice of providing for a right to cancel the membership purchase agreement without penalty for a period of three (3) calendar days from the date that the consumer signs the membership purchase agreement, such three (3) day period starting the calendar day after the date the conswner signs the membership purchase agreement. As stated in the membership docwnents as of the date of this AVC, if the third calendar day falls on a Sunday or legal holiday, then the right to cancel expires on the day immediately following that Sunday or legal holiday. III. MONETARY TER.i'1S AND CONDITIONS A. ATTORNEYS' FEES, INVESTIGATIVE FEES AND/OR COSTS 19. Respondent, GLOBAL VACATION VENTURES, INC., agrees to pay a total of FIVE THOUSAND DOLLARS AND ZERO CENTS ($5,000.00) in current and future attorneys' fees, investigative fees and/or costs made payable by cashier's check or other certified funds to the "Legal Affairs Revolving Trust Fund" and the payment due hereunder, along with the original AVC bearing the notarized signature of RESPONDENT, will be simultaneously delivered to the Office of the Attorney General. 9 INITIALS ~

10 20. The payment described above shall be made payable as stated and shall be directed to the attention of Assistant Attorney General Carol E. A. DeGraffenreidt, Office of the Attorney General, 1515 North Flagler Drive, Suite 900, West Palm Beach, Florida RESPONDENT'S interest in funds paid in conjunction with this AVC shall fully and completely divest when the A VC is fully executed by all Parties. IV. FUTURE VIOLATIONS 22. Provided that Respondent, GLOBAL VACATION VENTURES, INC., complies with the terms of this A VC, no civil penalties shall be sought against it or imposed hereunder for any conduct arising prior to the date of the execution of this A VC. However, in the event that RESPONDENT fails to comply with the terms and conditions of this AVC, then such actions are by statute prima facie evidence of a violation of Chapter 501, Part II, Florida Statutes as to RESPONDENT, and may subject RESPONDENT to any and all civil penalties and sanctions authorized by law. For a two (2) year period commencing upon the Effective Date and terminating two (2) years thereafter, for the purpose of resolving disputes with respect to RESPONDENT'S compliance with this A VC, should the Attorney General have a reasonable basis to allege that RESPONDENT failed to comply with the terms of this A VC, then the Attorney General will notify RESPONDENT in writing of the specific failure of compliance, I identify with particularity the term(s) of this AVC that the practice appears to violate, and provide RESPONDENT with thirty (30) days to respond to the notification. Nothing in this provision shall preclude the Attorney General from instituting any action or proceeding to enforce this AVC in accordance with Florida Statute (6). 10 INITIALS -r{f2 ~,,,,..-)

11 23. Respondent, GLOBAL VACATION VENTURES, INC., moreover consents to venue and jurisdiction for any proceedings necessary to enforce the terms of the AVC, within the Fifteenth Judicial Circuit Court, in and for Palm Beach County, Florida. V. MISCELLANEOUS TERMS 24. Respondent, GLOBAL VACATION VENTURES, INC., shall further ensure that the terms and conditions detailed under "II. NON-MONETARY TERMS AND CONDITIONS" on Page 4 of this AVC are known to its representatives, agents, employees, managers, officers, directors, assigns, successors, independent contractors and/or any other persons acting under, by, through or on its behalf. The obligations imposed by this AVC are continuing in nature and shall apply to RESPONDENT'S successors and assigns as well as any and all new representatives,,agents, employees, managers, officers, directors, assigns, successors, independent contractors, any other person acting under, by, through or on its behalf and/or any other persons who become engaged in the business activities of RESPONDENT whose acts, practices or policies are directed, formulated, or controlled by GLOBAL VACATION VENTURES, INC. 25. RESPONDENT, including its officers, directors, shareholders and/or employees, shall not implement any change in the form of doing business or the organizational identity of any of the existing business entities or create any new business entities as a method of avoiding the obligations and terms and conditions set forth in this A VC. This provision should not be construed to prevent GVV from changing its name or its form of doing business so long as the successor business is bound by the provisions of this AVC. '26. RESPONDENT shall preserve and retain all relevant business and financial records 11

12 relating to the acts and practices at issue in this AVC and other information reasonably sufficient to establish compliance with the provisions of this A VC for two (2) years from the date of this AVC, and shall make any and all books and records available to the Department within three (3) business days of any reasonable request; provided, however, any information and/or materials which RESPONDENT believes constitute a "trade secret", as defined in and/or are protected from disclosure under F.S. Ch. 688, F.S (1)(c), or shall be brought to the 'attention of the Office of the Attorney General, and the Parties both agree to submit the disputed matter(s) for expedited review and ruling by the Fifteenth Judicial Circuit Court, in and for Palm Beach County, Florida. 27. Any personal or financial information of consumers and customers, in the custody, control or possession of RESPONDENT shall be securely stored in such a manner as to reasonably protect against inadvertent disclosure of consumer information. RESPONDENT, including any representative, agent, employee, successor, and assign within its direction and control, shall not, directly or indirectly, market, sell, share or otherwise disclose the name, contact information, or financial information of any consumer or customer in its care, custody or control except in accordance with applicable law. 28. Nothing herein shall be construed as a general waiver of any private right, cause of action, or remedy of any private person against Respondent, GLOBAL VA CATION VENTURES, INC. Similarly, nothing contained herein shall waive the right of Respondent, GLOBAL VACATION VENTURES, INC., to assert any lawful defenses in response to a consumer complaint. 12 INITIALS p) ~... '== '----

13 29. In consideration for RESPONDENT'S execution and delivery of this AVC and the fees provided for in Paragraph 19, the Department is waiving pursuant to this settlement and in consideration of RESPONDENT'S performance hereunder the civil penalties that might otherwise be due for the alleged acts and practices at issue under Sections or , Florida Statutes, of up to $15,000 per violation in consideration of the parties' entry into this AVC. 36. Upon entry of this A VC, and payment of all required current and future attorneys' fees, investigative fees and/or costs and consumer restitution, the Office of the Attorney General shall close its civil investigation into the acts and practices of Respondent at issue herein. Notwithstanding any other provision of this AVC, nothing herein shall be construed to impair,.compromise or affect any right of any government agency other than the Office of the Attorney General for the State of Florida. 37. Respondent, GLOBAL VACATION VENTURES, INC., moreover consents to venue and jurisdiction for the entry of a Final Judgment, or any other proceeding necessary to enforce the terms of the A VC, within the Fifteenth Judicial Circuit Court, in and for Palm Beach County, Florida. 38. The Attorney General and GVV agree that neither the existence of, nor the terms of this AVC shall be deemed to constitute evidence, except as permitted by (6) in any action or proceeding between the Parties involving a Released Claim to support a defense asserted by GVV or any Releasee of res judicata, collateral estoppel, compromise and settlement, accord 'and satisfaction, release or other theory of claim preclusion, issue preclusion or other legal or equitable defenses. This A VC shall not create any private rights or causes of action in any third 13

14 parties. 39. This AVC is the final, complete, and exclusive statement of the parties' agreement on the matters contained in this AVC, and it supersedes, terminates and replaces any and all previous negotiations and agreements, injunctions, orders and instruments as may exist between the parties. Other than any representation expressly stated in this A VC, the parties have not made any representations or warranties to each other, and neither party's decision to enter into this AVC is based upon any statements by the other party outside of those in this AVC. No change or modification of this AVC shall be valid unless in writing and signed by both parties. 40. Although the Parties jointly participated in the negotiation of the terms articulated in this AVC, no provision herein shall be construed for or against either Party on the grounds that any one Party was more heavily involved in the preparation of the A VC and/or its terms. 41. The parties agree that nothing in this AVC shall be construed to prohibit RESPONDENT from engaging in business in Florida in accordance with the terms of this AVC and all applicable laws of the State of Florida in accordance with the terms of this A VC and all,applicable laws of the State of Florida, nor shall be construed as relieving RESPONDENT of the obligation to comply with all applicable laws. This A VC does not constitute an endorsement or approval by the Attorney General of any of RESPONDENT'S business practices and RESPONDENT shall make no representation to the contrary. 42. The Attorney General and RESPONDENT agree that if any of the substantive laws cited in this AVC change due to amendment, repeal, or disposition by the legislature, an agency, or court so that such change permits any action prohibited by any section of this A VC, that section of this A VC shall be severed and shall no longer have any force or effect. The remaining terms 0) 14 INITIALS.,..._ \._/ -= ,;..----_

15 and conditions of this A VC shall remain enforceable as if such illegal, invalid, or unenforceable clause, section or other provision had not been contained herein. 43. It is a condition of each of the Attorney General's obligations under this AVC that RESPONDENT has fully and timely performed all of RESPONDENT'S obligations under this AVC. 44. Notice to either of the parties to this AVC shall made by overnight delivery or certified mail at the addresses set forth below unless any party notifies the other party in writing of 'another address to which notices should be provided: AS TO THE ATTORNEY GENERAL: Carol E. A. DeGraffenreidt Assistant Attorney General - Consumer Protection Division 1515 North Flagler Drive # 900 West Palm Beach, FL Office Telephone Number: (561) Facsimile No.: (561) Electronic Mail Address: carol.degraffenreidt@myfloridalegal.com AS TO THE RESPONDENT: Matthew Inman, Director GLOBAL VACATION VENTURES, INC. 801 S. Olive Avenue, Suite 1206 West Palm Beach, FL Electronic Mail Address: globalcri@yahoo.com VI. EFFECTIVE DATE 45. The effective date (the "Effective Date") of this A VC shall be the date of its execution and delivery by the Department of Legal Affairs. Acceptance by the Department of Legal Affairs shall be established by the signature of the Division Director of the Consumer Protection 15 INITIALS p"j.,._. '-..../ -~-

16 Division. The receipt by the Department of Legal Affairs of any monies pursuant to the AVC does not constitute acceptance by the Department of Legal Affairs, and any monies received shall be returned to RESPONDENT in the event that this AVC is not accepted and fully executed by the Department of Legal Affairs. 46. This AVC shall be subject to acceptance by the Office of the Attorney General, Department of Legal Affairs, and shall be established by the signature of Deputy Attorney General Patricia A. Conners. This A VC shall become effective on the "Effective Date," which shall be the date upon which the Deputy Attorney General accepts and executes this AVC. 47. The receipt by the Office of the Attorney General, Department of Legal Affairs, of any monies from RESPONDENT pursuant to this A VC does not constitute acceptance by the Office, and any monies received shall be returned to RESPONDENT if the A VC is not accepted and fully executed by the Office of the Attorney General, Department of Legal Affairs I, MATTHEW INMAN, Director of GLOBAL VACATION VENTURES, INC., a..ffirm, by my signature on the following page, that I have authority to execute this A VC on behalf of GLOBAL VACATION VENTURES, INC.; that I am acting within the scope of my authority as its corporate representative; and that I am hereby binding GLOBAL VACATION VENTURES, INC. to the terms and conditions ofthis AVC. 48. This A VC may be signed in multiple counterparts, each of which shall be considered an original, and all of which together will constitute one and the same agreement. 49. It is further agreed that in.pdf format and facsimile copies of signatures and notary seals may be accepted as original for the purposes of establishing the existence of this 16 OOTIALS _~)-

17 AVC, and this AVC may be executed in counterparts, the compilation of which all constitute the full and final agreement of the Parties. SIGNATURES FOLLOW ON SEPARATE PAGESS 17 INITIALS

18 GLOBAL VACATION VENTURES, INC. Agreed to and signed this t Sr day of tljr'm~o 15, by the below-stated person who stated and affirmed as follows: BY MY SIGNATURE I hereby affirm that I am acting in my capacity and within my authority as the Owner/Principal Officer of GLOBAL VACATION VENTURES, INC., and that by my signature I am binding GLOBAL VACATION VENTURES, INC., to the terms and conditions of this Assurance ofvoluntary Compliance. By: CTOR ON VENTURES, INC. STATE OF FLORIDA ) 'COUNTY OF PALM BEACH ) BEFORE ME, this /Sf1'- day of IJ~. 2015, an officer duly authorized J, to take acknowledgments in the State of fi-p1l1 ~, personally appeared MATTHEW INMAN who acknowledged before me that he executed the foregoing instrument NO ARYPUBLI M ~ T hosjiv (print, type or stamp commissioned name of Notary Public) NORMAN T. FROSCHER NOTAAYPUBUC STATE OF FLORIDA Camm# FF EJCplreS 2/10/2018.Personally known~ Produced Identification V (check one) Type of Identification Produced: fl.crt.f tfl /jf.,c(/~ Ct~~ 18

19 FOR THE ATTORNEY GENERAL'S OFFICE Signed this~y of~ 2015,. -~--;~ Carol!. A. D a nre1dt J\.ssistan.t Attorney ener Office of the Attorney General Consumer Protection Division Florida Bar No North Flagler Drive, Suite 900 West P~ Beach, Florida, Telephone No.: (561) Facsimile No.: (561) Electronic mail: carol.degraffenreidt@myfloridalegal.com Accepted this J. day of q~v '2015 LKatherme. Kiziah South Florida Bureau Chief Consumer Protection Division 1515 North Flagler Drive, Suite 900 West Palm Beach, Florida l Telephone No.: (561) Facsimile No.: (561) Electronic mail: Katherine.Kiziah@myfloridalegal.com 19 INITIALS