DOB: Quesnel, Dale et al - CD-Rest-NOIF

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IN THE MATTER OF:

DALE JOSEPH QUESNEL, SR.
(CRD No. 2231152)

OVERTIME MARKETING, LLC

OVERTIME SPORTS
SOUTHEAST, LLC

OVERTIME SPORTS
SOUTHWEST, LLC

KENNETH HANSMIRE

FLORIDEL, LLC

("Respondents")

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ORDER TO CEASE AND DESIST

ORDER TO MAKE RESTITUTION

NOTICE OF INTENT TO FINE

AND

NOTICE OF RIGHT TO HEARING

DOCKET NO. CRF-15-8110-S

I. PRELIMINARY STATEMENT

1. The Banking Commissioner (“Commissioner”) is charged with the administration of Chapter 672a of the General Statutes of Connecticut, the Connecticut Uniform Securities Act (“Act”), and Sections 36b-31-2 to 36b-31-33, inclusive, of the Regulations of Connecticut State Agencies (“Regulations”) promulgated under the Act.
2. Pursuant to Section 36b-26(a) of the Act, the Commissioner, through the Securities and Business Investments Division (“Division”) of the Department of Banking, has conducted an investigation into the activities of Respondents to determine if they or any of them have violated, are violating or are about to violate provisions of the Act or Regulations (“Investigation”).
3.
As a result of the Investigation, the Commissioner has reason to believe that the Respondents have violated certain provisions of the Act.
4. As a result of the Investigation, the Commissioner has the authority to issue a cease and desist order against the Respondents pursuant to Section 36b-27(a) of the Act.
5.
As a result of the Investigation, the Commissioner has the authority to order that the Respondents make restitution pursuant to Section 36b-27(b) of the Act.
6. As a result of the Investigation, the Commissioner has the authority to impose a fine upon the Respondents pursuant to Section 36b-27(d) of the Act.

II.  RESPONDENTS

7.
Dale Joseph Quesnel, Sr. (“Quesnel”) is an individual whose mailing address last known to the Commissioner is 22 Crescent Beach Drive, Enfield, Connecticut 06082.  At various times between March 7, 1994 and January 14, 2011, Quesnel was registered as a broker-dealer agent in Connecticut.   From July 9, 1992 through approximately August 29, 2011, Quesnel was licensed with the Connecticut Insurance Department and did business as Insurance and Investment Services LLC (“IIS”), a Connecticut limited liability company with its principal place of business at 50 Freshwater Boulevard, P.O. Box 615, Enfield, Connecticut 06083.  In addition to selling insurance products, Quesnel doing business as IIS performed and sold securities research and technical analysis to broker-dealer agents.
8. Overtime Marketing, LLC (“Overtime”) is a Texas limited liability company whose address last known to the Commissioner is 4455 LBJ Freeway, Dallas, Texas 75244.  At no time were securities  issued by Overtime registered under the Act.
9. Overtime Sports Southeast, LLC (“Overtime Southeast”) is a Texas limited liability company whose address last known to the Commissioner is 4455 LBJ Freeway, Dallas, Texas 75244.  At no time were securities issued by Overtime Southeast registered under the Act.
10. Overtime Sports Southwest, LLC (“Overtime Southwest”) is a Texas limited liability company whose address last known to the Commissioner is 502 North Austin, Comanche, Texas 76442.  At no time were securities issued by Overtime Southwest registered under the Act.
11. Kenny Hansmire (“Hansmire”) is an individual whose address last known to the Commissioner is 501 North Austin Street, Comanche, Texas 76442.  Hansmire is the control person and owner of Overtime, Overtime Southeast and Overtime Southwest (the “Overtime Entities”).  During the relevant period of time, Hansmire and the Overtime Entities were, among other things, in the business of promoting an all-star football game for college athletes through the National Collegiate Athletic Association.  Hansmire has not been registered in any capacity at any time under the Act.
12. Floridel, LLC (“Floridel”) is a Florida limited liability company whose address last known to the Commissioner is 13574 Village Park Drive, Orlando, Florida 32837.  Floridel owned a taco franchise in Florida.  At no time were securities issued by Floridel registered under the Act.

III.  STATEMENT OF FACTS

13. From January 1, 2004 until January 14, 2011, Quesnel conducted broker-dealer agent activities on behalf of ING Financial Partners, Inc. (“ING”), now known as Voya Financial Advisors, Inc.
  
  
The Overtime Promissory Note Offerings
  
14. Quesnel and Hansmire first became acquainted sometime in 2008 when Hansmire, a former football player in the National Football League (“NFL”), requested that Quesnel present a financial workshop to NFL players in Texas.  After the presentation, Quesnel and Hansmire developed a business relationship, and in an effort to expand his securities brokerage business, Quesnel agreed to assist Hansmire in raising money for the Overtime Entities.  Specifically, each of the Overtime Entities issued promissory notes (the “Overtime Notes”) secured by a percentage interest in the assets of the respective issuer.  Hansmire executed the Overtime Notes on behalf of the Overtime Entities. Quesnel assisted Hansmire by offering and selling the Overtime Notes to investors.
15. From approximately February 2009 to approximately May 2012, Hansmire and Quesnel (while Quesnel was registered as a broker-dealer agent of ING), offered and sold approximately $1.9 million of the Overtime Notes from Connecticut to at least ten investors in Connecticut and other states.  The Overtime Notes were not registered in Connecticut under Section 36b-16 of the Act, nor were they exempt from registration under Section 36b-21 of the Act, nor were they the subject of a filed exemption claim or claim of covered security status.  Many of the investors in the Overtime Note offerings were Quesnel’s brokerage clients at ING.
16. Quesnel received approximately $166,000 in compensation from the Overtime Entities in connection with the offer and sale of the Overtime Notes.
17. Quesnel transacted business as an agent of each Overtime Entity in this state absent registration.
18. In connection with the Division’s Investigation into Quesnel’s activities, the Division obtained on-the-record, sworn testimony from Quesnel, wherein he represented that he did not receive compensation for offering and selling the Overtime Notes.  Such representation was false.
19. In connection with the offer and sale of the Overtime Notes, neither Hansmire, Quesnel nor the Overtime Entities provided investors with any offering document or other written disclosure describing the risks associated with investing in the Overtime Notes or their registration status.
20. While he was a broker-dealer agent of ING, Quesnel did not provide ING with prior written notice describing in detail that he was selling the Overtime Notes to investors in Connecticut and other states and whether Quesnel had or would receive compensation in connection with the transactions, as required by Section 36b-31-6e(c) of the Regulations.
  
  
The Floridel Offering
  
21. Quesnel was acquainted with the principals and owners of Floridel.  Floridel was attempting to open a chain of taco restaurants in Florida and was seeking additional funding to do so.  Specifically, Floridel issued promissory notes (the “Floridel Notes”) secured by a percentage interest in its assets.   In an apparent effort to assist Floridel raise funds, from September 2010 to approximately April 2011, Quesnel joined Floridel in offering and selling approximately $250,000 of Floridel Notes from Connecticut to at least four investors from Connecticut and other states.  The Floridel Notes were not registered in Connecticut under Section 36b-16 of the Act, nor were they exempt from registration under Section 36b-21 of the Act, nor were they the subject of a filed exemption claim or claim of covered security status.  At least one of the investors of the Floridel Notes was one of Quesnel’s ING brokerage clients.
22. Quesnel received compensation of approximately $8,000 from Floridel in connection with the offer and sale of the Floridel Notes.
23. Quesnel transacted business as an agent of issuer of Floridel in this state absent registration.
24. In connection with the Division’s Investigation into Quesnel’s activities, the Division obtained on-the-record, sworn testimony from Quesnel, wherein he represented that he did not receive compensation for offering and selling the Floridel Notes.  Such representation was false.
25. In connection with the offer and sale of the Floridel Notes, neither Quesnel nor Floridel provided the investors with any offering document or other written disclosure describing the risks associated with investing in the Floridel Notes or their registration status.
26. While he was employed as a broker-dealer agent of ING, Quesnel did not provide ING with prior written notice describing in detail that he was selling the Floridel Notes to investors in Connecticut and other states and whether Quesnel had or would receive compensation in connection with the transactions, as required by Section 36b-31-6e(c) of the Regulations.
  
  
Unregistered Investment Adviser
  
27. From approximately August 2011 to approximately December 2013, Quesnel individually and/or doing business as IIS provided research and technical analysis regarding securities to at least two Connecticut registered broker-dealer agents, who used the research and analysis to advise their clients on securities transactions.  In exchange for this investment advice, Quesnel individually and/or doing business as IIS received approximately $58,000.
28. From approximately August 2011 to approximately December 2013, Quesnel individually and/or doing business as IIS transacted business as an investment adviser by giving securities-related investment advice to at least two Connecticut registered broker-dealer agents for compensation without being registered as an investment adviser under the Act.

IV.  STATUTORY BASIS FOR ORDER TO CEASE AND DESIST,
ORDER TO MAKE RESTITUTION AND ORDER IMPOSING FINE

a.  Violation of Section 36b-16 of the Act by Quesnel, Hansmire, Overtime,
Overtime Southeast, Overtime Southwest and Floridel -
Offer and Sale of Unregistered Securities

29.  Paragraphs 1 through 28, inclusive, are incorporated and made a part hereof as if more fully set forth herein.
30.
Quesnel, Hansmire, Overtime, Overtime Southeast, Overtime Southwest, and Floridel offered and sold unregistered securities in or from Connecticut to at least one investor, as more fully described in paragraphs 14 through 21, inclusive, which securities were not registered in Connecticut under the Act.  The offer and sale of such securities absent registration constitutes a violation of Section 36b-16 of the Act, which forms a basis for an order to cease and desist to be issued against Quesnel, Hansmire, Overtime, Overtime Southeast, Overtime Southwest, and Floridel under Section 36b-27(a) of the Act, and for the imposition of a fine upon Quesnel, Hansmire, Overtime, Overtime Southeast, Overtime Southwest, and Floridel  under Section 36b-27(d) of the Act.

b.  Violation of Section 36b-6(a) of the Act by Quesnel –
Unregistered Agent of Issuer Activity

31. Paragraphs 1 through 30, inclusive, are incorporated and made a part hereof as if more fully set forth herein.
32.
Quesnel transacted business as an agent of issuer in this state on at least one occasion absent registration, as more fully described in paragraphs 14 through 23, inclusive.  Such conduct constitutes a violation of Section 36b-6(a) of the Act, which forms a basis for an order to cease and desist to be issued against Quesnel under Section 36b-27(a) of the Act, and for the imposition of a fine upon Quesnel under Section 36b-27(d) of the Act.
  
c.  Violation of Section 36b-6(b) of the Act by
Overtime, Overtime Southeast, Overtime Southwest and Floridel –
Employing an Unregistered Agent
  
33. Paragraphs 1 through 32, inclusive, are incorporated and made a part hereof as if more fully set forth herein.
34.
Overtime, Overtime Southeast, Overtime Southwest, and Floridel each employed an unregistered agent of issuer, as described more fully in paragraphs 14 through 23, inclusive.  Such conduct constitutes a violation of Section 36b-6(b) of the Act, which forms a basis for an order to cease and desist to be issued against Overtime, Overtime Southeast, Overtime Southwest, and Floridel under Section 36b-27(a) of the Act, and for the imposition of a fine upon Overtime, Overtime Southeast, Overtime Southwest, and Floridel pursuant to Section 36b-27(d) of the Act.
  
d.  Violation of Section 36b-23 of the Act by Quesnel –
Making a Statement in an Investigation that is
False or Misleading in a Material Respect
  
35. Paragraphs 1 through 34, inclusive, are incorporated and made a part hereof as if more fully set forth herein.
36.
Quesnel’s statements to the Division, as more fully described in paragraphs 18 and 24, were, at the time and in light of the circumstances under which they were made, false or misleading in a material respect, which constitutes a violation of Section 36b-23 of the Act.  Such violation forms a basis for an order to cease and desist to be issued against Quesnel under Section 36b-27(a) of the Act, and the imposition of a fine upon Quesnel under Section 36b-27(d) of the Act.

e.  Violation of Section 36b-4(a) of the Act by Quesnel, Overtime,
Overtime Southeast, Overtime Southwest, Hansmire and Floridel –
Fraud in Connection with the Offer, Sale or Purchase of any Security

37. Paragraphs 1 through 36, inclusive, are incorporated and made a part hereof as if more fully set forth herein.
38.
The conduct of Quesnel, Overtime, Overtime Southeast, Overtime Southwest, Hansmire and Floridel, as more fully described in paragraphs 14 through 25, inclusive, constitutes, in connection with the offer, sale or purchase of any security, directly or indirectly employing a device, scheme or artifice to defraud, making an untrue statement of a material fact or omitting to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading, or engaging in an act, practice or course of business which operates or would operate as a fraud or deceit upon any person.  Such conduct constitutes a violation of Section 36b-4(a) of the Act, which forms a basis for an order to cease and desist to be issued against Quesnel, Overtime, Overtime Southeast, Overtime Southwest, Hansmire and Floridel under Section 36b-27(a) of the Act, an order that Quesnel, Overtime, Overtime Southeast, Overtime Southwest, Hansmire and Floridel make restitution under Section 36b-27(b) of the Act, and for the imposition of a fine upon Quesnel, Overtime, Overtime Southeast, Overtime Southwest, Hansmire and Floridel under Section 36b-27(d) of the Act.
    
f.  Violation of Section 36b-31-6e of the Regulations by Quesnel–
Engaging in Private Securities Transactions Without
Prior Written Notice to Employing Broker-dealer (Selling Away)
         
39. Paragraphs 1 through 38, inclusive, are incorporated and made a part hereof as if more fully set forth herein.
40.
Quesnel, through his sale of the Overtime Notes and the Floridel Notes, as more fully described in paragraphs 14 through 20, inclusive, and 21 through 26, inclusive, participated in private securities transactions without providing prior written notice to his employing broker-dealer describing in detail the proposed transactions, his proposed role therein and stating whether he had received or would receive selling compensation in connection with such transactions, as more fully described in paragraph 21 and 27, in violation of Section 36b-31-6e of the Regulations.  Such violation of Section 36b-31-6e of the Regulations forms a basis for an order to cease and desist to be issued against Quesnel under Section 36b-27(a) of the Act, and for the imposition of a fine against Quesnel under Section 36b-27(d) of the Act.
        
g.  Violation of Section 36b-6(c)(1) of the Act by Quesnel–
Unregistered Investment Adviser

41. Paragraphs 1 through 40, inclusive, are incorporated and made a part hereof as if more fully set forth herein.
42.
Quesnel individually and doing business as IIS transacted business as an investment adviser in Connecticut absent registration, as more fully described in paragraphs 27 and 28.  Such conduct constitutes a violation of Section 36b-6(c)(1) of the Act, which forms a basis for an order to cease and desist to be issued against Quesnel under Section 36b-27(a) of the Act, and for the imposition of a fine upon Quesnel under Section 36b-27(d) of the Act.

V.  ORDER TO CEASE AND DESIST, ORDER TO MAKE RESTITUTION,
NOTICE OF INTENT TO FINE AND NOTICE OF RIGHT TO HEARING

WHEREAS, as a result of the Investigation, the Commissioner finds that, with respect to the activity described herein, Quesnel has committed at least one violation of Section 36b-16 of the Act, at least one violation of Section 36b-6(a) of the Act, at least one violation of Section 36b-23 of the Act, at least one violation of Section 36b-4(a) of the Act, at least one violation of Section 36b-31-6e of the Regulations, and at least one violation of Section 36b-6(c)(1) of the Act;  

WHEREAS, as a result of the Investigation, the Commissioner finds that, with respect to the activity described herein, Hansmire has committed at least one violation of Section 36b-16 of the Act and at least one violation of Section 36b-4(a) of the Act;

WHEREAS,  as a result of the Investigation, the Commissioner finds that, with respect to the activity described herein, Overtime, Overtime Southeast, Overtime Southwest and Floridel each committed at least one violation of Section 36b-16 of the Act, at least one violation of Section 36b-6(b) of the Act and at least one violation of Section 36b-4(a) of the Act; 

WHEREAS, the Commissioner further finds that the issuance of an Order to Cease and Desist, Order to Make Restitution and the imposition of a fine upon Respondents is necessary or appropriate in the public interest or for the protection of investors and consistent with the purposes fairly intended by the policies and provisions of the Act;

WHEREAS, notice is hereby given to Respondents that the Commissioner intends to impose a maximum fine not to exceed one hundred thousand dollars ($100,000) per violation upon Respondents;

WHEREAS, the Commissioner ORDERS that DALE JOSEPH QUESNEL, SR., INDIVIDUALLY AND/OR DOING BUSINESS AS INSURANCE AND INVESTMENT SERVICES LLC CEASE AND DESIST from directly or indirectly violating the provisions of the Act, including without limitation, (1) offering and selling unregistered securities; (2) acting as an unregistered agent of issuer in or from this state; (3) making a statement to the commissioner that is, at the time and in the light of the circumstances under which it is made, false or misleading in any material respect; (4) in connection with the offer, sale or purchase of any security, directly or indirectly employing a device, scheme or artifice to defraud, making an untrue statement of a material fact or omitting to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading, or engaging in an act, practice or course of business which operates or would operate as a fraud or deceit upon any person; (5) engaging in private securities transactions without prior written notice to his employing broker-dealer; and (6) acting as an unregistered investment adviser in or from this state.

WHEREAS, the Commissioner ORDERS that KENNETH HANSMIRE CEASE AND DESIST from directly or indirectly violating the provisions of the Act, including without limitation, (1) offering and selling unregistered securities; and (2) in connection with the offer, sale or purchase of any security, directly or indirectly employing a device, scheme or artifice to defraud, making an untrue statement of a material fact or omitting to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading, or engaging in an act, practice or course of business which operates or would operate as a fraud or deceit upon any person;

WHEREAS, the Commissioner ORDERS that OVERTIME MARKETING, LLC CEASE AND DESIST from directly or indirectly violating the provisions of the Act, including without limitation, (1) offering and selling unregistered securities; (2) employing an unregistered agent; and (3) in connection with the offer, sale or purchase of any security, directly or indirectly employing a device, scheme or artifice to defraud, making an untrue statement of a material fact or omitting to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading, or engaging in an act, practice or course of business which operates or would operate as a fraud or deceit upon any person;

WHEREAS, the Commissioner ORDERS that OVERTIME SPORTS SOUTHEAST, LLC CEASE AND DESIST from directly or indirectly violating the provisions of the Act, including without limitation, (1) offering and selling unregistered securities; (2) employing an unregistered agent; and (3) in connection with the offer, sale or purchase of any security, directly or indirectly employing a device, scheme or artifice to defraud, making an untrue statement of a material fact or omitting to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading, or engaging in an act, practice or course of business which operates or would operate as a fraud or deceit upon any person;

WHEREAS, the Commissioner ORDERS that OVERTIME SPORTS SOUTHWEST, LLC CEASE AND DESIST from directly or indirectly violating the provisions of the Act, including without limitation, (1) offering and selling unregistered securities; (2) employing an unregistered agent; and (3) in connection with the offer, sale or purchase of any security, directly or indirectly employing a device, scheme or artifice to defraud, making an untrue statement of a material fact or omitting to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading, or engaging in an act, practice or course of business which operates or would operate as a fraud or deceit upon any person;

WHEREAS, the Commissioner ORDERS that FLORIDEL, LLC CEASE AND DESIST from directly or indirectly violating the provisions of the Act, including without limitation, (1) offering and selling unregistered securities; (2) employing an unregistered agent; and (3) in connection with the offer, sale or purchase of any security, directly or indirectly employing a device, scheme or artifice to defraud, making an untrue statement of a material fact or omitting to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading, or engaging in an act, practice or course of business which operates or would operate as a fraud or deceit upon any person;

WHEREAS, the Commissioner ORDERS that DALE JOSEPH QUESNEL, SR., KENNETH HANSMIRE, OVERTIME MARKETING, LLC, OVERTIME SPORTS SOUTHEAST, LLC, OVERTIME SPORTS SOUTHWEST, LLC, AND FLORIDEL, LLC (“Restitution Respondents”) MAKE RESTITUTION of any sums obtained as a result of their violations of Section 36b-4(a) of the Act, plus interest at the legal rate set forth in Section 37-1 of the General Statutes of Connecticut.  Specifically, the Commissioner ORDERS that:

1.  Within thirty (30) days from the date this Order to Make Restitution becomes permanent, the Restitution Respondents shall provide the Division with a written disclosure which contains the corresponding (a) name and address of each investor who purchased, respectively, promissory notes (or similar instruments) from the Restitution Respondents between approximately February 2009 to approximately July 2013; (b) the amount collected from each investor, (c) the date of each investment, and (d) the amount of any refunds of principal or purported interest payments made to each investor;
   
2.  Within forty-five (45) days from the date this Order to Make Restitution becomes permanent, the Restitution Respondents shall reimburse each investor the amount of funds collected from the investor in connection with the promissory notes (or similar instruments) plus interest, less funds returned in the form of purported refunds of principal and purported interest payments.  Such restitution shall be made by certified check, and shall be sent by certified mail, return receipt requested, to each affected investor; and
    
3. Within ninety days (90) days from the date this Order to Make Restitution becomes permanent, the Restitution Respondents shall provide the Division with proof in the form of copies of the certified checks and the return receipts required by paragraph 2 of Section V of this Order to Cease and Desist, Order to Make Restitution, Notice of Intent to Fine and Notice of Right to Hearing that the Restitution Respondents have reimbursed each investor the amount of funds collected from the investor plus interest, less funds returned in the form of purported refunds of principal and purported interest payments, with respect to each investor who purchased a promissory note (or similar instrument) of Overtime Marketing, LLC, Overtime Sports Southeast, LLC and Overtime Sports Southwest, LLC.

THE COMMISSIONER FURTHER ORDERS THAT, pursuant to Section 36b-27 of the Act, each Respondent will be afforded an opportunity for a hearing on the allegations set forth above if a written request for a hearing is received by the Department of Banking, Securities and Business Investments Division, 260 Constitution Plaza, Hartford, Connecticut 06103-1800 within fourteen (14) days following each Respondent’s receipt of this Order.  The enclosed Appearance and Request for Hearing Form must be completed and mailed to the above address.  If any Respondent will not be represented by an attorney at the hearing, please complete the Appearance and Request for Hearing Form as “pro se”.  Once a written request for a hearing is received, the Commissioner may issue a notification of hearing and designation of hearing officer that acknowledges receipt of a request for a hearing, designates a presiding officer and sets the date of the hearing in accordance with Section 4-177 of the General Statutes of Connecticut and Section 36a-1-21 of the Regulations.  If a hearing is requested, the hearing will be held on September 1, 2015 at 10 a.m., at the Department of Banking, 260 Constitution Plaza, Hartford, Connecticut.

The hearing will be held in accordance with the provisions of Chapter 54 of the General Statutes of Connecticut.  At such hearing, each Respondent will have the right to appear and present evidence, rebuttal evidence and argument on all issues of fact and law to be considered by the Commissioner.

This Order to Cease and Desist shall remain in effect and become permanent against each Respondent who fails to request a hearing within the prescribed time period or fails to appear at any such hearing.

This Order to Make Restitution shall remain in effect and become permanent against each Respondent who fails to request a hearing within the prescribed time period or fails to appear at any such hearing.

The Commissioner may order that the maximum fine be imposed upon any Respondent who fails to request a hearing within the prescribed time period or fails to appear at any such hearing.    

Dated at Hartford, Connecticut,       ____/s/_____________
This 22nd day of June 2015.   Jorge L. Perez
    Banking Commissioner 



CERTIFICATION

I hereby certify that on this 23rd day of June 2015, the foregoing Order to Cease and Desist, Order to Make Restitution, Notice of Intent to Fine and Notice of Right to Hearing was sent by certified mail, return receipt requested, to Dale Joseph Quesnel, Sr., 22 Crescent Beach Drive, Enfield, Connecticut 06082, certified mail no. 7013 3020 0000 4226 7308; Overtime Marketing, LLC, 4455 LBJ Freeway, Dallas, Texas 75244, certified mail no. 7013 3020 0000 4226 7315; Overtime Sports Southeast, LLC, 4455 LBJ Freeway, Dallas, Texas 75244, certified mail no. 7013 3020 0000 4226 7322; Overtime Sports Southwest, LLC, 502 North Austin, Comanche, Texas 76442, certified mail no. 7013 3020 0000 4226 7339; Kenneth Hansmire, 501 N. Austin Street, Comanche, Texas 76442, certified mail no. 7013 3020 0000 4226 7346; and Floridel, LLC, 13574 Village Park Drive, Orlando, Florida 32837, certified mail no. 7013 3020 0000 4226 7353.
 

____/s/____________
Elena Zweifler
Prosecuting Attorney

                                                                     
                                        


Administrative Orders and Settlements