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1 STATE OF FLORIDA OFFICE OF THE ATTORNEY GENERAL DEPARTMENT OF LEGAL AFFAIRS IN THE INVESTIGATION OF: AGENCY FILE NO. Ll FEDERAL SAFETY COMPLIANCE INC., an Active State of Florida Corporation, FEDERAL COMPLIANCE PUBLICATIONS, INC. an Active State of Florida Corporation AND JOSEPH MISHKIN, INDIVIDUALLY AND AS A PRINCIPAL, OWNER, AND/OR OFFICER OF FEDERAL SAFETY COMPLIANCE, INC. AND FEDERAL COMLIANCE PUBLICATION, INC., RESPONDENTS ~/ ASSURANCE OF VOLUNTARY COMPLIANCE FOR FEDERAL SAFETY COMPLIANCE, INC., FEDERAL COMPLIANCE PUBLICATIONS, INC AND JOSEPH MISHKIN 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 FEDERAL SAFETY COMPLIANCE INC., FEDERAL COMPLIANCE PUBLICATIONS, INC. and JOSEPH MISHKIN (hereafter corporately and/or altematively refetted to as the "RESPONDENTS"). The RESPONDENTS agree to enter into this Assurance of Voluntary Compliance (A VC), without an admission that they have violated the law in order to amicabl resolve the

2 Attorney General's investigation of the RESPONDENTS, pursuant to Agency Case No. Ll and Section (6) of the Florida Statutes. The Attorney General, by the signature of her Division Director affixed hereto, does hereby accept the instant AVC and in turn tenninates the Attorney General's investigation as it concerns the RESPONDENTS by virtue of the authority vested in the Office of the Attorney General, pursuant to Section (6) of the Florida Statutes. I. ATTORNEY GENERAL'S ALLEGATIONS I. The Respondent, FEDERAL SAFETY COMPLIANCE INC., is an active State of Florida corporation established in or around 2012, with its principal office located in Miami, Dade County, Florida. FEDERAL SAFETY COMPLIANCE INC. markets and/or marketed information packets to businesses purportedly aimed at ensuring that the businesses were in compliance with Occupational Safety and Health Act (OSHA) rules and regulations. 2. The Respondent, FEDERAL COMPLIANCE PUBLICATIONS, INC., is an active State of Florida corporation established in or around 20 11, with its principal office located in Hollywood, Broward County, Florida. FEDERAL COMPLIANCE PUBLICATIONS, INC. markets and/or marketed infonnation packets to businesses purportedly aimed at ensuring that the businesses were in compliance with Occupational Safety and Health Act (OSHA) rules and regulations. 3. The Respondent, JOSEPH MISHKIN, is a natural person who is and/or was registered with the Florida Department of State, Division of Corporations, as a Principal, Owner and/or Officer of FEDERAL COMPLIANCE PUBLICATIONS, INC. and FEDERAL SAFETY COMPLIANCE, INC. 2

3 4. As a Principal, Owner and/or Officer of FEDERAL COMPLIANCE PUBLICATIONS, INC. and FEDERAL SAFETY COMPLIANCE, INC., the Respondent, JOSEPH MISHKIN, presently, and/or at all times material to the allegations in this A VC, participated in, controlled and/or possessed the authojity to control the acts and practices of FEDERAL COMPLIANCE PUBLICATIONS, INC. and FEDERAL SAFETY COMPLIANCE, INC., and possessed actual and/or constructive knowledge of all material acts and practices complained of herein. 5. Beginning in or around at least October 30, 2012, the Office of the Attorney General for the State of Florida began receiving complaints from businesses that the RESPONDENTS were engaging in unfair and deceptive trade practices by misleading businesses into believing that the RESPONDENTS were selling information packets aimed at ensuring that the businesses were in compliance with Occupational Safety and Health Act (OSHA) rules and regulations. 6. Businesses allegedly receive unsolicited OSHA rule books and labor law posters and were subsequently charged for these unwanted items. 7. According to consumers/business complainants, their companies receive repeated and unwanted telemarketing calls from a company identifying itself as either FEDERAL COMPLIANCE PUBLICATIONS, INC. or FEDERAL SAFETY COMPLIANCE, INC. 8. Unwanted packages were sent to businesses by the Respondents, FEDERAL COMPLIANCE PUBLICATIONS, INC. or FEDERAL SAFETY COMPLIANCE, INC., with neither the express nor implied consent of the businesses. 9. Within days of a businesses' receipt of the unwanted items, invoices altived of varying amounts (i.e., between $ and $269.50) demanding immediate payment for the unwanted items. 3 INJTIALSj_ ~

4 10. The Respondents, FEDERAL COMPLIANCE PUBLICATIONS, INC. and/or FEDERAL SAFETY COMPLIANCE, INC., refused to cancel the unwanted orders, as requested, and businesses were told that by signing for the unwanted items, the businesses had automatically agreed to the purchase of the items. II. When businesses challenged the RESPONDENTS' efforts to force them to pay for unwanted items, the RESPONDENTS either threatened the businesses with legal action or initiated the collection process. 12. The RESPONDENTS deny any wrongdoing and make no admission of any violation of Florida Statute 501, Part II, or any other law, statute or regulation of the State of Florida. II. NON-MONETARY TERMS AND CONDITIONS 13. The Respondents, FEDERAL SAFETY COMPLIANCE INC., FEDERAL COMPLIANCE PUBLICATIONS, INC. and JOSEPH MISHKIN, agree to refrain from violating the provisions of Chapter 50 I, Part II, of the Florida Statutes, the Florida Deceptive and Unfair Trade Practices Act, to conduct business in the State of Florida in compliance with the provisions of Chapter 501, Part II, of the Florida Statutes, the Florida Deceptive and Unfair Trade Practices Act, and to alter their business practices in the following manner: 14. The RESPONDENTS, when offering, marketing and/or selling any products in the State of Florida in furtherance of its business of soliciting, inducing and/or encouraging consumers and/or businesses in Florida and throughout the United States to use any Occupational Safety and Health Act ("OSHA") infmmation, compliance or other packets, rule books, documents, posters and/or any other OSHA-related items produced, provided and/or mailed to businesses by or on 4

5 behalf of FEDERAL SAFETY COMPLIANCE INC. AND/OR FEDERAL COMPLIANCE PUBLICATIONS, INC., shall: A. advise consumers and/or businesses, both orally and in writing, that the RESPONDENTS are not affiliated in any manner with Occupational Safety and Health Administration ("OSHA") and/or any other governmental agency; and B. within thirty (30) days of the receipt of a request by a consumer and/or business, cancel orders and/or promptly issue refunds for products sent to the respective consumer and/or business by the RESPONDENTS, absent the receipt of express written, or otherwise confim1ed, consent of the consumer and/or business. 15. The RESPONDENTS, when offering, marketing and/or selling any products in the State of Florida in furtherance of its business of soliciting, inducing and/or encouraging consumers and/or businesses in Florida and throughout the United States to use any Occupational Safety and Health Act ("OSHA") information, compliance or other packets, rule books, documents, posters and/or any other OSHA-related items produced, provided and/or mailed to businesses by or on behalf of FEDERAL SAFETY COMPLIANCE INC. AND/OR FEDERAL COMPLIANCE PUBLICATIONS, INC., shall not: A. utilize any advertising, marketing tools and/or business materials, including, but not limited to, brochures, pamphlets, flyers, newspapers, magazines, periodicals, radio, websites, telemarketing, television, Yellow Pages, letterhead, envelopes, invoices and/or contracts which suggest, or are reasonably aimed at leading consumers and/or businesses to believe, that the RESPONDENTS are affiliated in any manner with 5 INITIAL~'----

6 Occupational Safety and Health Administration ("OSHA") and/or any other governrnental agency; B. mail, send, deliver and/or provide unwanted and/or unsolicited materials to consumers and/or businesses absent receipt of express written, or otherwise confi1med, consent of the consumers and/or businesses; C. bill, invoice or otherwise attempt to collect payment from consumers and/or businesses absent receipt of express written, or otherwise confirmed, consent of consumers and/or businesses; D. provide unwanted and/or unsolicited products to consumers and/or businesses and thereafter charge consumers and/or businesses for the unwanted and/or unsolicited products based solely upon the fact that the consumers and/or businesses signed for the unwanted and/or unsolicited products. Neither consumers nor businesses may be charged for unwanted and/or unsolicited products by the RESPONDENTS absent receipt of express written, or otherwise confirmed, consent of consumers and/or businesses; E. repeatedly call consumers and/or businesses which have expressed a lack of interest in purchasing the products being offered by the RESPONDENTS. Specifically, once a consumer and/or business has expressed a lack of interest in purchasing the products being offered by the RESPONDENTS, the RESPONDENTS may not thereafter contact that consumer and/or business for a period of no less than one (1) year; and F. contact any consumer and/or ~usiness which it knows, or reasonably should have known, is on a "No-Call Registry". 6

7 III. MONETARY TERMS AND CONDITIONS 16. The Respondents, FEDERAL SAFETY COMPLIANCE INC., FEDERAL COMPLIANCE PUBLICATIONS, INC. and JOSEPH MISHKIN, shall make a charitable contribution made payable to "SENIORS vs. CRIME" in the amount of FIFTEEN THOUSAND DOLLARS AND ZERO CENTS ($15,000.00) for educational, investigative and crime prevention programs for the benefit of senior citizens and the community as a whole as senior citizens were among the consumer complainants in this matter. 17. The RESPONDENTS agree to pay the above-referenced charitable donation m the amount of FIFTEEN THOUSAND DOLLARS AND ZERO CENTS ($15,000.00) in ten (10) equal monthly payments in the amount of One Thousand Five Hundred Dollars and Zero Cents ($1,500.00). 18. The RESPONDENTS shall ensure that each of the ten (1 0) installment payments described more fully in Paragraph 17 above is received by the Office of the Attorney General on or before the loth day of each month. 19. Payments due under this AVC shall be delivered to Carol E. A. DeGraffenreidt, Esquire, Consumer Protection Division, Office of the Attorney General, 1515 N. Flagler Drive, Suite 900, West Palm Beach, Florida Payment of the first installment in the amount of One Thousand Five Hundred Dollars and Zero Cents ($1,500.00) shall be due on the 10 1 h day of the month immediately following the date upon which the instant A VC has been fully executed by all required Parties hereto (i.e., the date upon which the last required signatory affixes a signature to the instant A VC). 7 INITIALS~ 7

8 21. The Respondents, FEDERAL SAFETY COMPLIANCE INC., FEDERAL COMPLIANCE PUBLICATIONS, INC. and JOSEPH MISHKIN, agree to resolve the complaints of each of the below businesses which presented complaints against the Respondents, FEDERAL SAFETY COMPLIANCE INC., FEDERAL COMPLIANCE PUBLICATIONS, INC. and JOSEPH MISHKIN, to various governmental entities, including, but not limited to, the Office of the Attorney General for the State of Florida and which allege that their restitution claims against FEDERAL SAFETY COMPLIANCE INC., FEDERAL COMPLIANCE PUBLICATIONS, INC. and JOSEPH MISHKIN remain unresolved. 22. The below complaints which total One Thousand Sixty-Seven Dollars and Ninety-Seven Cents ($1,067.97) shall be resolved in full within thirty (30) days of the date upon which this document is fully executed by all required Parties. PENDING BUSINESS-CONSUMER COMPLAINTS AND TOTALS Kevin Drury 5961 South 1 08th Place Hales Corner, WI $ Jessica Flock 207 South 1st Street Laramie, WY $ Grant Lawrence 6445 Carlisle Pike Mechanicsburg, P A I 7050 $ Bobby Robinson 4740 Highway 14 P.O. Box 352 Elmore, AL INITIALS 9~ /

9 $ Jennifer Baker Amalgam Way Rancho Cordova, CA $ "Resolved" shall mean: 1) full payment of a businesses' complaint; 2) partial payment of a businesses' complaint, accompanied by a fom1al Release and/or other document signed by an authorized representative of the respective business stating that a partial payment has been accepted in full accord and satisfaction of the businesses' complaint and that no further reliefwill be sought from the RESPONDENTS with respect to the businesses' complaint; 3) charge-backs to the businesses' credit card; and/or 4) any other altemative means of complaint resolution approved by the Office of the Attomey General which was made to a business in satisfaction of its complaint against any named RESPONDENTS herein. 24. At the end of the above-referenced 3 0-day period, the RESPONDENTS agree to present to the Office of the Attomey General a notarized statement attesting to the fact that the businesses' complaints referenced above in Paragraph 20 have been resolved and which further provides a clear, explanation as to the manner in which each complaint was resolved. IV. PENALTIES 25. Provided that the RESPONDENTS comply with the terms of this AVC, no civil penalties shall be sought against them or imposed hereunder for any conduct arising prior to the date of the execution of this A VC. However, in the event that the RESPONDENTS fail to comply with the terms and conditions of this A VC, then such action is by statute prima facie evidence of a violation of Chapter 50 I, Part II, Florida Statutes as to the RESPONDENTS, and the RESPONDENTS 9 INITIALS~

10 agree to be liable for their failure to comply and to be subject to any and all civil penalties and sanctions authorized by law. 26. In the event that the RESPONDENTS fail to make any payment(s) required by the terms of this A VC within the time period provided by the A VC, then such non-payment shall constitute a material breach and default of the tetms of the A VC. 27. The RESPONDENTS moreover consent to venue and jurisdiction for the entry of a Final Judgment, or any other proceeding necessary to enforce the terms of the AVC, within the Fifteenth Judicial Circuit Court, in and for Palm Beach County, Florida. VII. MISCELLANEOUS TERMS 28. The Respondents FEDERAL SAFETY COMPLIANCE INC., FEDERAL COMPLIANCE PUBLICATIONS, INC. and JOSEPH MISHKIN, shall further ensure that all of the tetms and conditions of this A VC are known to its representatives, agents, employees, managers, officers, directors, independent contractors and/or any other persons making sales solicitations on its behalf. The obligations imposed by this A VC are continuing in nature and shall apply to the RESPONDENTS' 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 the RESPONDENTS. 29. The RESPONDENTS 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 fmth in this A VC. 10 INITIALS

11 30. The RESPONDENTS agree to preserve and retain all relevant business and financial records relating to the acts and practices at issue in this A VC and other information reasonably sufficient to establish compliance with the provisions of this A VC for two (2) years from the date of this A VC, and shall provide reasonable access to such documents and infonnation to the Department upon request. 31. Nothing herein shall be constmed as a general waiver of any private right, cause of action, or remedy of any private person against the Respondents, FEDERAL SAFETY COMPLIANCE INC., FEDERAL COMPLIANCE PUBLICATIONS, INC. and/or JOSEPH MISHKIN. Similarly, nothing contained herein shall waive the right of any RESPONDENT to assert lawful defenses in response to a consumer complaint. 32. Upon entry of this A VC, confirmation that all consumer restitution has been resolved and payment of all funds required by this A VC, the Office of the Attorney General for the State of Florida agrees to close its civil investigation into the activities of the Respondents, FEDERAL SAFETY COMPLIANCE INC., FEDERAL COMPLIANCE PUBLICATIONS, INC. and JOSEPH MISHKIN. 33. Notwithstanding any other provision of this AVC, the Patties acknowledge that any future violations of either this A VC or Florida law by the RESPONDENTS may subject the RESPONDENTS to additional and unrelated civil penalties and sanctions, as provided by law. 34. In the event that the Respondents, FEDERAL SAFETY COMPLIANCE INC., FEDERAL COMPLIANCE PUBLICATIONS, INC. and JOSEPH MISHKIN, violate any of the terms and conditions of this A VC, they shall pay reasonable attorney's fees and/or investigative costs which arise from the future violation. II

12 Although the Parties jointly participated in the negotiation of the tenns articulated in this AVC, no provision herein shall be constmed for or against either Party on the grounds that any one Party was more heavily involved in the preparation of the AVC and/or its terms. 42. The Pa1ties agree that all notices required hereunder shall be sufficient if given as provided below: AS TO THE ATTORNEY GENERAL: Carol E. A. DeGraffenreidt Assistant Attorney General - Economic Crimes 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 RESPONDENTS: Joseph Mishkin 1835 East Hallandale Beach Boulevard, Suite 329 Hallandale, FL VI. EFFECTIVE DATE 43. 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 oflegal Affairs shall be established by the signature of the Division Director of the Consumer Protection Division. The receipt by the Department of Legal Affairs of any monies pursuant to the A VC does not constitute acceptance of the A VC by the Department of Legal Affairs, and any monies received shall be returned to RESPONDENTS in the event that this A VC is not accepted and fully executed by the Department oflegal Affairs. 12 INITIAL~

13 IN WITNESS WHEREOF, the Respondents, FEDERAL SAFETY COMPLIANCE INC., FEDERAL COMPLIANCE PUBLICATIONS, INC. and JOSEPH MISHKIN, have caused this Assurance ofvoluntary Compliance to be executed by an authorized representative, as a true act and deed, in the county and state listed below, as of the date affixed thereon. PARTIES' SIGNATURES ON FOLLOWING PAGES 13 INITIAL~

14 JOSEPH MISHKIN Agreed to and signed this _.:L_ day of :::J'\../'1 ~, 2014, by the below-stated person who stated and affirmed as follows: BY MY SIGNATURE I hereby affinn that my signature below binds me both personally and individually to the terms and conditions of this Assurance ofvoluntary Compliance. By: JffSEPH MISHKIN, INDIVIDUALLY STATE OF FLORIDA ) COUNTY OFDt--OLt?O..J) BEFORE ME, this _ j :. day o~ la L ~, 2014, an officer duly authorized to take acknowledgments in the State of Florida, personally appeared JOSEPH MISHKIN who acknowledged before me that he executed the foregoing instrument for the purposes therein stated. Personally known or Produced Identification V(check one) Type ofldentification Produced: FL, 0 \ l->. 14 INITIALS~

15 . FEDERAL SAFETY COMPLIANCE INC. Agreed to and signed this ~ day of ~ V Ud, 20 14, 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 a Principal, Owner and/or Officer of FEDERAL SAFETY COMPLIANCE INC. and that by my signature I am binding FEDERAL SAFETY COMPLIANCE INC. to the terms and conditions of this A VC. By: t4_~ JOijii>H MISHKIN Principal, Owner and/or Officer FEDERAL SAFETY COMPLIANCE INC. STATE OF F~ORIDA COUNTY OF J:::>\---OU.)rA J BEFORE ME, this 1 day of~!a L.Lj, 2014, an officer duly authorized to take acknowledgments in the State of Florida, personally appeared JOSEPH MISHKIN who acknowledged before me that he executed the foregoing instrument for the purposes therein stated. 1' -;;~ -;;~.. /~o\ :x ~;;\ LIND SUE MIDYETTE t ~ l j MY COMMISSION #FF :. I '\~. ~ ~ 'o:r '#.J'--I=*PIRES.July (print, type Or Stamp comm ~~Mt'Yi~ 153 FlorldaNotaryServic;.com name ofnotary Public) Personally known or Produced Identification t/ (check one) Type ofldentification Produced: F l-, (), L i 15

16 .. FEDERAL COMPLIANCE PUBLICATIONS, INC. Agreed to and signed this ~y of -;:f v J-:1, 2014, by the below-stated person who stated and affirmed as follows: BY MY SIGNATURE I hereby affitm that I am acting in my capacity and within my authority as a Principal, Owner and/or Officer offederal COMPLIANCE PUBLICATIONS, INC. and that by my signature I am binding FEDERAL COMPLIANCE PUBLICATIONS, INC. to the terms and conditions of this A VC. By: Jo,& Ji MISHKIN " Principal, Owner and/or Officer FEDERAL SAFETY COMPLIANCE INC. STATE OF FLORIDA J) COUNTY OFD \--0 u...2a ~ ) BEFORE ME, this ;:;i=:; day of ~ la,.ll:), 2014, an officer duly authorized to take acknowledgments in the State offlorida, personally appeared JOSEPH MISHKIN who acknowledged before me that he executed the foregoing instrument for the Personally knowx or Produced Identification (check one). Type ofldentification Produced: F L, D.L-' 16 INITIALS

$,_-=-----=-------.!1:~/l '-{ Andrew Nathan Cove, Esquire G 1 Counsel for the Respondents Florida Bar No. 562122 225 S.$

17 ,_-=-----= !1:~/l '-{ Andrew Nathan Cove, Esquire G 1 Counsel for the Respondents Florida Bar No S. 21 st Avenue Hollywood, FL Telephone No Facsimile No Electronic Mail Address: anc0',covelav..com 17 INITIALS _

. _A_n_d_re_w_N --at~h-m-c~ov_e_,-es~q~u~ir-e------~~~~~tlf Courtsel for the Respondents Florida Bar No. 562122 225 S.

18 . _A_n_d_re_w_N --at~h-m-c~ov_e_,-es~q~u~ir-e------~~~~~tlf Courtsel for the Respondents Florida Bar No S. 21' 1 Avenue Hollywood, FL Telephone No Facsimile No Electronic Mail Address: anc@covelaw.com 17

FOR THE ATTORNEY GENERAL'S OFFICE 1515 North Flagler Drive, Suite 900 West Palm

: (561) 837-51 09 E lectronic mail: carol.degraffenreidt@mytloridalegal.

Protection Division 1515 North Flagler Drive, Suite 900 West Palm Beach, Florida,

19 FOR THE ATTORNEY GENERAL'S OFFICE 1515 North Flagler Drive, Suite 900 West Palm Beach, Florida, Telephone No.: (561) Facsimile No.: (561) E lectronic mail: carol.degraffenreidt@mytloridalegal.com Accepted this 0 day of 3""vt ) 6/ '2014 ~ South Florida Bureau Chief Consumer Protection Division 1515 North Flagler Drive, Suite 900 West Palm Beach, Florida, Telephone No.: (561) Facsimile No.: (561) Electronic mail: katherine.kiziah@myfl oridalegal.com 18 INITIALS

20 FOR THE ATTORNEY GENERAL'S OFFICE ~~1'-f--- arole. A. e a e9 tat ~ ssistant Attorney Gfoneral Office of the Attomey General Florida Bar No North Flagler Drive, Suite 900 West Palm Beach, Flolida, Telephone No.: (561) Facsimile No.: (561) Electronic mail: carol.degraffenreidt@myfloridalegal.com Accepted this 6) day of ;::::rt1 }&\ ~~ '2014 South Florida Bureau Chief Consumer Protection Division 1515 North Flagler Drive, Suite 900 West Palm Beach, Florida, Telephone No.: (561) Facsimile No.: (561) Electronic mail: katherine.kiziah@myfloridalegal.com 18

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STATE OF FLORIDA OFFICE OF THE ATTORNEY GENERAL DEPARTMENT OF LEGAL AFFAIRS IN THE INVESTIGATION OF: AGENCY FILE NO. L13-3-1123 SECURITY NETWORKS, LLC, RESPONDENT. --------------------------~/ ASSURANCE