Filing # 35537831 E-Filed 12/15/2015 10:12:20 AM IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA CIVIL DIVISION OFFICE OF THE ATTORNEY GENERAL, STATE OF FLORIDA, DEPARTMENT OF LEGAL AFFAIRS, Plaintiff, v. GRAND INCENTIVES, INC., a Florida corporation, d/b/a COAST TO COAST GRAND GETAWAYS and d/b/a TAKE TWO NIGHTS, and JOSE L. MARTINEZ, an individual, Court Case Number: Defendants. COMPLAINT Plaintiff, Office of the Attorney General, State of Florida, Department of Legal Affairs (hereinafter referred to as the Attorney General ), sues Defendants, Grand Incentives, Inc., a Florida corporation, d/b/a Coast to Coast Grand Getaways and d/b/a Take Two Nights (hereinafter referred to as Grand Incentives ), and Jose L. Martinez, an individual (hereinafter referred to as Martinez and together with Grand Incentives, Defendants ), and alleges the following: Jurisdiction and Venue 1. This is an action for temporary and permanent injunctive relief, restitution, disgorgement of profits, declaratory relief, civil penalties, attorney s fees
and costs, and other statutory relief against Defendants in excess of fifteen thousand ($15,000), pursuant to the Florida Deceptive and Unfair Trade Practices Act (hereinafter referred to as FDUTPA ), Chapter 501, Part II, Florida Statutes (2015) and the Florida Sellers of Travel Act (hereinafter referred to as SOTA ), Chapter 559, Part XI, Florida Statutes (2015). 2. This Court has jurisdiction pursuant to the provisions of FDUTPA. The Attorney General seeks relief in an amount greater than fifteen thousand dollars ($15,000), exclusive of interest, costs, and attorneys fees. 3. Defendants principal place of business and residence are located in Sarasota County. The statutory violations alleged herein affect or occurred in more than one judicial circuit in the State of Florida, including the Twelfth Judicial Circuit in and for Sarasota County, Florida. Accordingly, the venue is proper in Sarasota County and in the Twelfth Judicial Circuit, pursuant to the provisions of FDUTPA, SOTA, and Sections 47.051 and 47.041 of Florida Statutes. 4. All actions material to this Complaint have occurred within four (4) years of the filing date of this action. 5. The Attorney General has conducted an investigation of the matters alleged herein, and the head of the enforcing authority, Attorney General Pamela Jo Bondi, has determined that this enforcement action serves the public interest, as required by Section 501.207(2), Florida Statutes. 2
6. All conditions precedent to this action have been performed, or have occurred. Parties 7. Plaintiff, the Attorney General, is the enforcing authority pursuant to Section 501.203(2) of FDUTPA, and is authorized to bring this action and seek injunctive and other statutory and equitable relief pursuant to FDUTPA. 8. Grand Incentives is an active for-profit Florida corporation registered with the State of Florida, Department of State, Division of Corporations, since February 3, 2006, with its principal place of business located at 7560 Commerce Court, Sarasota, FL 34243. Grand Incentives conducts and, at all times material hereto, has conducted business from within the State of Florida. 9. Grand Incentives also conducts business under at least the following fictitious names: (a) Take Two Nights and (b) Coast to Coast Grand Getaways ( CTC ). 10. Grand Incentives engages in the business of selling, servicing, and fulfilling travel-related promotional incentives, including, but not limited to, vacation certificates (collectively, Vacation Certificate(s) ), which purportedly allow consumers to obtain substantial savings on travel or lodging. Grand Incentives sells these Vacation Certificates to third-party business merchant clients, or independent distributors, for subsequent distribution to these clients current and 3
prospective customers through vacation sales presentations, promotional offers, or other venues. 11. In addition, Grand Incentives operates, services, and fulfills a travel club membership program(s) (the Travel Club ), which Grand Incentives typically operates in the name of CTC or other d/b/a s such as Take Two Nights, which purportedly provides discounted vacation packages and other travel products to Travel Club members. 12. Grand Incentives engages and, at all times material hereto, has engaged in trade or commerce as defined in Section 501.203(8), Florida Statutes, when it sells or has sold promotional travel incentives, including the Vacation Certificates, and the Travel Club membership renewals to various business merchant clients. 13. Defendant Martinez is an individual who resides and, at all times material hereto, has resided in Sarasota County, Florida. 14. Defendant Martinez is the Chief Executive Officer and owner of Grand Incentives. 15. Defendant Martinez directly participates in, manages, operates, and controls and, at all times material hereto, has managed, operated, and controlled the operations of Grand Incentives, including, but not limited to, making all operational and financial decisions for Grand Incentives. Defendant Martinez holds either a 4
direct or indirect interest in Grand Incentives, and Defendant Martinez has earned, and continues to earn, a living from Grand Incentives operation. Overview of Misconduct 16. Defendants engage in two main lines of business: (i) the sale and fulfillment of promotional travel incentives in the form of a Vacation Certificate to various business merchant clients and other independent distributors (collectively, the Distributors ); and (ii) the service, fulfillment, and renewal of its Travel Club membership program. 17. The Distributors purchase Vacation Certificates, typically in bulk quantity, from Grand Incentives. The Vacation Certificates are printed with an expiration date and a series of certificate numbers identifiable to the specific Distributor. The Distributors ultimately provide the Vacation Certificates to the consumer (end user) as an award or as an incentive for attending a presentation, or for purchasing or utilizing the Distributor s products or services. 18. Distributors purportedly create their own marketing/sales materials using these Vacation Certificates to maximize consumer traffic to their business and/or events. Upon reason and belief, Distributors expressly and/or implicitly represent to consumers that the Vacation Certificates provide complimentary or free trips to maximize the consumer turnout for a presentation of a product or service. 5
19. In actuality, use of the Vacation Certificates involves a redemption process encumbered by onerous terms and conditions, which may or may not be disclosed in the fine print of the Vacation Certificate or marketing materials. The effect of these terms and conditions is to render the Vacation Certificates practically worthless to the end user. 20. Defendants also operate the Travel Club membership program. Upon information and belief, through at least 2012, Grand Incentives both directly and indirectly (through independent distributors) marketed the Travel Club to consumers, promising substantial discounted travel opportunities, which many consumers report never obtaining. In addition, Grand Incentives purchased the travel club memberships of insolvent travel clubs, such as Cheap Trips and Travel More Now, in order to sell membership renewals or upgrades. 21. Depending on the level of membership and the purported benefits (Silver, Gold, Platinum, or Diamond) consumers paid approximately $3,500 to $8,000 initially to obtain membership. Some memberships were sold for as high as $11,500. 22. While Grand Incentives reportedly no longer sells new Travel Club memberships, Grand Incentives continues to (i) fulfill services relating to existing Travel Club memberships, (ii) actively solicit existing members to purchase upgrade packages, including but not limited to lifetime memberships or multi-year renewals, 6
and (iii) solicit payment of annual dues (a/k/a renewal fees) and solicit extensions of existing memberships, often to elderly customers, resulting in additional renewal fees, ranging from approximately $199 to $899. 23. Over the past three years, over 800 complaints have been filed with the Better Business Bureau ( BBB ) about Defendants business practices. 24. The BBB complaints relating to the travel incentive side of Defendants business allege: a. Overly restrictive terms and conditions, which make it difficult, if not impossible, to redeem Vacation Certificates; b. Significant delays in processing consumer refund requests; and c. Routine denial of travel requests due to unavailability of requested travel dates or locations. 25. While no longer selling Travel Club memberships to consumers, Grand Incentives actively and aggressively telemarkets Travel Club membership renewals to its customers using a combination of high-pressure sales tactics, misrepresentations, and outright threats. 26. The BBB complaints relating to Defendants service and fulfillment of the Travel Club program allege: a. Unauthorized and/or duplicate charges on consumers credit cards; 7
b. Misrepresentation of the true nature of additional fees to renew or upgrade Travel Club memberships and/or that these fees are mandatory, or an obligation to continue membership; c. Selling multi-year Travel Club membership renewals (sometimes up to 10 years) to seniors who did not intend to purchase and/or were no longer able to travel; and d. Routine denying of travel requests due to unavailability of requested travel dates or locations. 27. As a result of these complaints, the BBB issued an alert for Defendants businesses. 28. To date, the Attorney General s office has received over 260 complaints that allege practices similar to those reported to the BBB. A large proportion of these complaints originated from senior citizens. 29. In its 2013 tax filing, Grand Incentives indicated that it accrued, pursuant to Generally Accepted Accounting Principles ( GAAP ), over nine hundred thousand dollars ($900,000) in revenue for Forfeited Consumer Deposits, which represents about 14% of Defendants gross revenue. Department of Agriculture Licensure Requirements 30. Grand Incentives is regulated by the Department of Agriculture and Consumer Services (hereinafter referred to as DOACS ) and holds a seller of travel 8
(as defined in Section 559.927(11) of Florida Statutes) ( Seller of Travel ) license pursuant to Chapter 559, Florida Statutes. 31. DOACS requires that all Sellers of Travel operating within Florida to (1) be licensed with DOACS, (2) post a fifty-thousand-dollar ($50,000) bond, (3) and comply with disclosure requirements specifically enumerated in SOTA. 32. DOACS requires Sellers of Travel to submit specific documentation and complete a submission checklist for vacation certificates, promotional materials, and sales documents. Grand Incentives, Inc. is a Seller of Travel 33. Since 2006, Grand Incentives has submitted the required annual paperwork to DOACS relating to its Vacation Certificate business, including a form entitled Florida Department of Agriculture and Consumer Services Filing Instructions & Checklist - Sellers of Travel, Sections 559.926-559.939, Florida Statutes ( Checklist ). Grand Incentives is a Seller of Travel as defined in Section 559.927(11), Florida Statutes. provide: 34. Question 14 of the Checklist requires, in part, that the Seller of Travel A listing of the full name, address, and telephone number of each person through which the distribution and sale of vacation certificates is to be carried out, including the number of vacation certificates allocated or sold to each person 9
35. Defendants did not disclose such information to DOACS as required by Section 559.9295(2) of SOTA and deliberately denied selling Vacation Certificates and using third parties for distribution of Vacation Certificates. Grand Incentives, Inc. is a Vacation Certificate Redemption Company 36. Grand Incentives is a vacation certificate (as defined in Section 559.927(13), Florida Statutes) redemption company. A typical and illustrative example of one of Grand Incentives Vacation Certificate is attached as Exhibit A. Merchants and other Distributors acquire Vacation Certificates from Grand Incentives and use the Vacation Certificates as promotional incentives to attract consumers to their business or to a sales event with the promise of free or complimentary trips. Once the consumer receives the Vacation Certificate, the consumer must contact Grand Incentives to redeem the travel award. 37. The terms and conditions contained in the Vacation Certificate are typically in small print, and do not represent all of the terms and conditions associated with the Vacation Certificate. 38. The consumer activates the Vacation Certificate either online via the grandnavigator.com activation website or by completing the validation (registration) section of the Vacation Certificate and mailing it to Grand Incentives. The consumer may elect to pay the required fifty dollar ($50) deposit to Grand Incentives with the 10
activation of the Vacation Certificate, or may pay when making/attempting to make a reservation for traveling. 39. Following activation of the Vacation Certificate, the consumer then receives from Grand Incentives, or prints from the activation website, a vacation planning form to request their travel dates. A true and correct copy of one of Grand Incentives vacation planning forms is attached hereto as Exhibit B. On the vacation planning form, the consumer chooses three (3) different dates and destination options, subject to terms and conditions. Then the consumer submits the completed vacation planning form to Grand Incentives. 40. For Defendants Vacation Certificate titled Take Your Pick - Now Boarding Vacation Planning Form, the consumer is directed that the first travel date must be at least ninety (90) days after the activation of the Vacation Certificate, and the subsequent two dates must be at least thirty (30) days apart. 41. For the reservation to be processed, Grand Incentives must receive a refundable fifty dollars ($50) deposit, and must have received the vacation planning form at least forty-five (45) days in advance of the check-in date. 42. Buried within the terms and conditions of the Take Your Pick - Now Boarding certificate are the conditions such as Departures must be on Tuesdays, Sunday returns are not allowed, and No travel will be permitted one full week before and after Major Holidays. Also, Spring Break is listed as one of the 11
holidays, but no specific dates are listed and the actual dates of Spring Break vary widely among school systems and this restriction could potentially cover weeks, if not months. 43. Further terms and conditions include language such as: Departure and arrival airports are available from selected cities, subject to Grand Incentives, Inc., allotments and availability. Airports may be included or excluded at Grand Incentives, Inc. s discretion. 44. Additionally, the Vacation Certificates generally require redemption within a year of their receipt. 45. If consumers do not strictly abide by all of the terms and conditions in the Vacation Certificate, Grand Incentives voids the Vacation Certificate. 46. The ultimate effect of these terms and conditions is to surreptitiously invalidate at least 94% of the potential traveling days available to the consumer, effectively rendering the Vacation Certificates worthless for booking travel. 47. Even if consumers navigate through the extensive terms and conditions of the Vacation Certificates, Grand Incentives routinely rejects consumers requested travel dates and destinations based on unavailability. 48. Defendants freely admit that they could lose money on fulfilling travel requests through their Vacation Certificate programs, so both natural and planned breakage is part of the business plan for the Vacation Certificates. 12
49. Ultimately many consumers seek refunds of their deposits made according to the terms of the Vacation Certificates. Consumers subsequently complain that they cannot reach anyone at Grand Incentives, that Grand Incentives denies receiving the refund requests, or that the processing time of the refund often exceeds thirty (30) days. 50. Upon reason and belief, Defendants transferring of funds out of the country and the personal spending of business funds adversely affect the Defendants ability to fund the operational needs of Grand Incentives, including timely processing of consumer refund requests. 51. While Defendants claim to have a liberal refund policy, the accrual on Grand Incentives 2013 tax return indicates that they expect almost 1 million dollars in revenue from Forfeited Consumer Deposits. 52. Multiple sources indicate that Defendant Martinez is aware of the above-referenced problems and complaints and has deliberately chosen to ignore them. Grand Incentives, Inc. is a Fulfillment Company for its Travel Club 53. While Defendants claim to have ceased the sale of its Travel Club product in 2012, they actively and aggressively solicit Travel Club membership renewals and upgrades from its customer base of approximately eighty thousand (80,000) members. 13
54. Grand Incentives purportedly offers its customers travel fulfillment services such as travel searching and travel reservations. 55. These fulfillment services are performed by employees of Grand Incentives, and often through the d/b/a s of Coast to Coast Grand Getaways and Take Two Nights, which are owned by Grand Incentives. 56. Defendants generate revenue from the Travel Club members by aggressively selling membership renewals and/ or upgrades to customers through the use of high-pressure sales tactics, misrepresentations, and outright threats. 57. Consumer complaints received by the Attorney General s office allege that the advertised savings associated with the Travel Club membership have not materialized: consumers are repeatedly telemarketed for additional fees despite having paid for lifetime memberships and being told they would never have to pay additional fees, and requested travel dates are not available. 58. Consumer complaints also allege that regardless of whether they consent to be charged to renew or upgrade their Travel Club memberships, Defendants make unauthorized and/or duplicative charges on the consumers credit cards. 14
COUNT I VIOLATION OF FLORIDA DECEPTIVE AND UNFAIR TRADE PRACTICES ACT (FDUTPA), CHAPTER 501, PART II, FLORIDA STATUTES 59. The Attorney General incorporates and re-alleges paragraphs 1 through 58 above as if fully set forth hereinafter. 60. Section 501.204(1) of FDUTPA provides that unfair methods of competition, unconscionable acts or practices, and unfair or deceptive acts or practices in the conduct of any trade or commerce are hereby declared unlawful. 61. Provisions of FDUTPA are to be construed liberally... [t]o protect the consuming public and legitimate business enterprises from those who engage in unfair methods of competition, or unconscionable, deceptive, or unfair acts or practices in the conduct of any trade or commerce. Fla. Stat. 501.202(2). 62. At all material times, Defendants were and continue to be engaged in trade or commerce as defined in Section 501.203(8) of FDUTPA. 63. Defendants deceptive conduct includes the following: a. Making unauthorized charges on Grand Incentives customers credit cards; b. Requiring strict adherence to technical terms and conditions, which complicate the redemption process for Vacation Certificates, confuse consumers, and make it highly unlikely or impossible for consumers to travel during the stated time period; 15
c. Routinely rejecting consumers travel requests thereby delaying travel fulfillment and decreasing the number of days available for consumers to travel; d. Misleading consumers regarding the availability of requested travel dates and locations ; e. Misleading consumers regarding the status of refunds to consumers; f. Making misleading representations to Travel Club members regarding the nature of fees being paid by the members or regarding the members obligations under the Travel Club, including, but not limited to, misleading Travel Club members into paying additional fees for upgrades or other benefits despite receiving prior assurances that no additional fees would be required to maintain their memberships. 64. The representations and omissions of material facts as set forth in Paragraph 58 are likely to mislead consumers acting reasonably under the circumstances. 65. Through the actions and related business practices set forth in this Complaint, Grand Incentives is engaging in acts or practices that are likely to cause substantial injury to consumers. This substantial injury is not reasonably avoidable 16
by the consumers themselves, and is not outweighed by countervailing benefits to consumers or competition. 66. Thus, Grand Incentives is engaged in unfair or deceptive or unconscionable acts or practices in the conduct of any trade or commerce in violation of Section 501.204(1), Florida Statutes. 67. Grand Incentives willfully engaged in and continues to engage in deceptive and unfair acts and practices in that he knew or should have known that the methods, acts or practices alleged herein were and are unfair, deceptive, unconscionable and prohibited by law. 68. Grand Incentives acts and practices have injured and likely will continue to substantially injure and prejudice the public. 69. Defendants knew or should have known their travel promotion activities are unfair, deceptive or prohibited by rule. 70. Defendants have violated, and are likely to continue to violate, FDUTPA by engaging in the deceptive acts set forth above. As a result, consumers have suffered and will continue to suffer substantial injury. 71. Under FDUTPA, once corporate liability is established, an individual defendant may be individually liable if he participated directly in the deceptive practices or acts or he possessed the authority to control them. 17
72. Defendant Martinez is a controlling owner of Grand Incentives and controls the operations of Grand Incentives. He has personal knowledge and control of Grand Incentives unfair and deceptive conduct. 73. Upon information and belief, Martinez is aware of Grand Incentives business practices pursuant to consumers complaints regarding unauthorized charges to credit cards, high pressure sales tactics and misrepresentations made to consumers during sales telephone calls, and has not taken steps to stop Grand Incentives deceptive and unfair conduct. 74. A review of Grand Incentives corporate filings indicates that Defendant Martinez, during the relevant period of time up to present, has been listed as the CEO of Grand Incentives, and therefore possesses the authority to control the unfair and deceptive acts referenced above. Additionally, upon information and belief, Defendant Martinez directly participates in and controls the acts and practices of Grand Incentives business operations. Because Defendant Martinez directly controls and participates in the unfair and deceptive business practices of Grand Incentives, he can be held individually liable under FDUTPA. 75. Through the actions and related business practices set forth in this Complaint, Defendant Martinez (i) had the authority to control and/or (ii) had actual knowledge or reckless indifference to Grand Incentives (a) representations, acts, practices or omissions that are material, and that are likely to mislead consumers, 18
most of whom are senior citizens, acting reasonably under the circumstances, and (b) deceptive and unfair acts and practices, in that he knew or should have known that the methods, acts or practices alleged herein were and are unfair, deceptive, unconscionable and prohibited by law. 76. Through the actions and related business practices set forth in this Complaint, Defendant Martinez is committing acts or practices in trade or commerce that offend established public policy and are unethical, oppressive, unscrupulous or substantially injurious to consumers. 77. Through the actions and related business practices set forth in this Complaint, Defendant Martinez is engaging in acts or practices that are likely to cause substantial injury to consumers. This substantial injury is not reasonably avoidable by the consumers themselves, and is not outweighed by countervailing benefits to consumers or competition. 78. Thus, the Defendants are engaged in unfair or deceptive or unconscionable acts or practices in the conduct of any trade or commerce in violation of Section 501.204(1), Florida Statutes. 79. Unless the Defendants are temporarily and permanently enjoined from engaging further in the acts and practices complained of herein, the Defendants actions will continue to result in irreparable injury to the public for which there is no adequate remedy at law. 19
COUNT II UNFAIR AND DECEPTIVE TRADE PRACTICES: CONDUCT IN VIOLATION OF SECTION 559.9295 OF THE FLORIDA SELLERS OF TRAVEL ACT ( SOTA ) RESULTING IN VIOLATION OF FDUTPA 80. The Attorney General incorporates and re-alleges paragraphs 1 through 58 above as if fully set forth hereinafter. 81. Pursuant to Section 559.9295 of SOTA, Sellers of Travel who offer vacation certificates (as defined under SOTA) are required to append certain specified documents to their application for registration that is filed with DOACS. 82. Pursuant to Section 559.934 of SOTA, any acts, conduct, practices, omissions, failings, misrepresentations or nondisclosures which constitute a violation of SOTA also constitute a deceptive and unfair trade practice under FDUTPA and is subject to all penalties and remedies available under FDUTPA. 83. Defendants have violated Section 559.9295(14) of SOTA, by failing to submit and disclose to DOACS [a] listing of the full name, address, and telephone number of each person through which the distribution and sale of vacation certificates is to be carried out, including the number of vacation certificates allocated or sold to each such person and the name and address of a Florida registered agent for service of process. 84. Defendants violation of Section 9295(14) of SOTA is likely to mislead consumers acting reasonably under the circumstances. 20
85. Defendants acts and practices have injured and likely will continue to substantially injure and prejudice the public. 86. Defendants knew or should have known their travel promotion activities are unfair, deceptive or prohibited by rule. 87. Defendants acts, conduct, practices, omissions, failings, misrepresentations or nondisclosures have violated SOTA, and therefore have violated FDUTPA. Defendants actions are likely to continue to violate SOTA and consequently, FDUTPA, by engaging in the conduct set forth above. As a result, consumers have suffered and will continue to suffer substantial injury. COUNT III UNFAIR AND DECEPTIVE TRADE PRACTICES: CONDUCT IN VIOLATION OF SECTION 559.933 OF THE FLORIDA SELLERS OF TRAVEL ACT (SOTA) RESULTING IN VIOLATION OF FDUTPA 88. The Attorney General incorporates and re-alleges paragraphs 1 through 57 above as if fully set forth hereinafter. 89. Section 559.933 of SOTA governs vacation certificate (as defined in Section 559.927(13), Florida Statutes) cancellation and refund provisions. 90. Pursuant to Section 559.934 of SOTA, any acts, conduct, practices, omissions, failings, misrepresentations or nondisclosures which constitute a violation of SOTA also constitute a deceptive and unfair trade practice under FDUTPA and is subject to all penalties and remedies available under FDUTPA. 21
91. Grand Incentives Vacation Certificates are vacation certificates as defined in Section 559.927(13), Florida Statutes. Defendants have violated Section 559.933(2) of SOTA, by failing to refund consumer deposits within thirty (30) days of receipt of consumer s notice of cancellation. Therefore, based on Defendants violation of Section 559.933(2) of SOTA, Defendants have violated FDUTPA. Prayer for Relief WHEREFORE, the Attorney General respectfully requests that this Court: A. Grant the Attorney General temporary and permanent injunctive relief as may be necessary to avert the likelihood of continuing and future consumer harm. B. Temporarily and permanently enjoin Defendants and their officers, agents, servants, employees, attorneys and those persons in active concert or participation with them, who receive actual notice of this Court s orders from: a.) Collecting or attempting to collect, or charging consumers for goods or services, directly or indirectly, without first obtaining the consumers express verifiable authorization for the charge(s); b.) Refusing to timely refund consumer deposits paid to redeem a Vacation Certificate if the travel dates and/or destinations are unavailable, or if the consumer otherwise requests a refund; 22
c.) Transferring or otherwise moving business funds outside the United States without first satisfying consumer refund claims that have been pending for over thirty days; and d.) Processing any Travel Club membership renewals without first obtaining express verifiable authorization from the consumer. In no instance shall a Travel Club membership renewal exceed a three (3) year period. C. Assess civil penalties against Defendants pursuant to Section 501.2075 of FDUTPA, in an amount not to exceed ten thousand dollars ($10,000) per violation, or fifteen thousand dollars ($15,000) for violations involving senior citizen consumers above the age of sixty (60); D. Require disgorgement of profits and award restitution and refunds to consumers for each violation; E. Award the Attorney General reasonable attorney s fees and costs pursuant to the provisions of Section 501.2105 of FDUTPA, and as otherwise allowable by applicable statutes or law; F. Enter final judgment against Defendants, jointly and severally, for restitution, refunds, disgorgement of profits, civil penalties, costs and reasonable attorneys fees; and G. Award such other relief as the interests of justice shall require and that 23
this Honorable Court may deem just and proper. Dated this 15 th day of December, 2015. Respectfully Submitted, PAMELA JO BONDI ATTORNEY GENERAL By: /s/ Robert J. Follis Robert J. Follis Assistant Attorney General Florida Bar No.: 560200 Email: Robert.Follis@myfloridalegal.com Jennifer Hayes Pinder Assistant Attorney General Florida Bar No. 17325 Email: Jennifer.Pinder@myfloridalegal.com Office of the Attorney General Department of Legal Affairs 3507 East Frontage Road, Suite 325 Tampa, Florida 33607 Phone: (813) 287-7950 Facsimile: (813) 281-5515 Counsel for Plaintiff 24