Case 0:18-cv-62593-DPG Document 412 Entered on FLSD Docket 03/25/2021 Page 1 of 10

UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

CASE NO. 18-CV-62593-GAYLES

FEDERAL TRADE COMMISSION,

Plaintiff,

vs.

SIMPLE HEALTH PLANS LLC, et al.,

Defendants.
/

RECEIVER'S MOTION FOR AUTHORITY TO ENTER INTO AUCTION

CONSIGNMENT AGREEMENT WITH RM SOTHEBY'S TO SELL HEALTH
BENEFITS ONE LLC'S RIGHT, TITLE, AND INTEREST IN 2015 ROLLS-ROYCE
WRAITH AND 2013 LAND ROVER RANGE ROVER AUTOMOBILES
AND INCORPORATED MEMORANDUM OF LAW

Michael I. Goldberg, as court-appointed receiver (the “Receiver”) over defendants Simple

Health Plans LLC, Health Benefits One LLC, Health Center Management LLC, Innovative

Customer Care LLC, Simple Insurance Leads LLC, Senior Benefits One LLC, and their

subsidiaries, affiliates, successors and assigns (collectively, the “Receivership Entities”) hereby

files this Motion for Authority to Enter into Auction Consignment Agreement with RM Sotheby's

to Sell Health Benefits One LLC's Right, Title, and Interest in 2015 Rolls-Royce Wraith and 2013

Land Rover Range Rover Automobiles and Incorporated Memorandum of Law (the “Motion”). In

support of this Motion, the Receiver states as follows:

Preliminary Statement

1. The Receiver seeks authorization from this Court to enter into the necessary

contracts to consign and subsequently sell via online auction the receivership estate’s rights, title,

and interest in that certain 2015 Rolls-Royce Wraith (VIN No. SCA665C54FUX85225) (the

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“Rolls-Royce”) and 2013 Land Rover Range Rover (VIN No. SALGV2EF1DA100321) (the

“Range Rover” and together with the Rolls-Royce, the “Automobiles”). The Receiver proposes to

consign the Automobiles to RM Sotheby's. RM Sotheby's will receive the Automobiles in trust,

and act as agent for the Receiver in selling the Automobiles at its regularly scheduled end-of-

month online auction series referred to as “Open Roads Online Only Auctions”. In exchange, RM

Sotheby's will be entitled to an 5% seller's commission on the Range Rover, a 5% sales commission

on the Rolls-Royce, and reimbursement of all agreed upon fees and expenses from the receivership

estate's sales proceeds. Given that a sale will relieve the Receiver of the carrying costs needed to

maintain the Automobiles; that the Automobiles are depreciating assets; and that the proceeds of

a sale will inure to the benefit the estate's creditors, the Receiver believes consignment and sale of

the Automobiles to be in the best interest of the receivership estate.1

Background

A. The Receivership

2. On October 29, 2018, the Federal Trade Commission (the “FTC”) filed a Complaint

in the United States District Court for the Southern District of Florida against the Receivership

Entities and Steven Dorfman (“Dorfman”) (Dorfman and the Receivership Entities are collectively

referred to as, the “Defendants”), under Section 13(b) of the Federal Trade Commission Act (the

“FTC Act”), 15 U.S.C. § 53(b) and the Telemarketing and Consumer Fraud and Abuse Act, 15

U.S.C. §§ 6101-6108, alleging the Defendants violated Section 5(a) of the Federal Trade

1
RM Sotheby's takes the position that the form of its Auction Consignment Agreement is confidential and proprietary.
Thus, rather than attach a copy of the Auction Consignment Agreement, the Receiver has instead summarized the
materials terms of the agreement in this instant Motion. In addition, RM Sotheby’s has a policy of keeping buyer
identities confidential and not disclosing them to the public post-auction, which various federal courts have respected
in bankruptcy and estate auctions. Maintaining the confidentiality of RM Sotheby’s buyers and the form of its Auction
Consignment Agreement are materially important conditions of RM Sotheby’s entering into the Auction Consignment
Agreement with the Receiver.

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Commission Act, 15 U.S.C. § 45(a) and the FTC’s Telemarketing Sales Rule, 16 C.FR Part 310,

as amended [ECF No. 1].

3. On the same date, the FTC filed an Ex Parte Motion for a Temporary Restraining

Order with Asset Freeze, Appointment of a Temporary Receiver, and Other Equitable Relief, and

Order to Show Cause Why a Preliminary Injunction Should Not Issue, along with a Memorandum

in Support of the Motion for TRO [ECF No. 3].

4. On October 31, 2018, this Court entered an Ex Parte Temporary Restraining Order

with Asset Freeze, Appointment of a Temporary Receiver, and Other Equitable Relief, and Order

to Show Cause Why a Preliminary Injunction Should Not Issue (the “TRO”), which, among other

things, appointed the Receiver over the Receivership Entities with full powers of an equity receiver

[ECF No. 15].

5. The Court entered orders continuing the TRO on multiple occasions upon request

of one or more of the parties. On May 14, 2019, after the Court held an evidentiary show cause

hearing on the FTC’s request for preliminary injunctive relief, the Court entered a Preliminary

Injunction [ECF No. 139] extending the asset freeze and appointing Mr. Goldberg as permanent

receiver over the Receivership Entities.

6. Pursuant to the Preliminary Injunction, the Receiver is directed and authorized to

assume full control of the Receivership Entities; take excusive custody, control and possession of

all assets and documents of or in the possession, custody or under the control of any Receivership

Entity, including assets the Receiver has a reasonable basis to believe were purchased using funds

from any Receivership Entity’s corporate accounts. See Preliminary Injunction, p. 33.

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B. The Automobiles

7. As of the date of the TRO, a Receivership Entity, Health Benefits One, LLC

(“HBO”), held title to the Automobiles.

8. The Receiver took possession of the Automobiles immediately after the entry of

the TRO, housing them in a local air-conditioned storage facility. To the best of the Receiver's

knowledge, the Automobiles are owned by HBO free and clear of any liens. True and correct

copies of the Automobiles’ Certificates of Titles are attached hereto and incorporated herein as

Composite Exhibit A.

9. The Receiver has investigated the value of the Automobiles and has evaluated

various sale options. The Range Rover has an estimated value of approximately $15,000-$25,000

and the Rolls-Royce has an estimated value of approximately $110,000-$130,000.

10. To date, the Receiver has spent approximately $20,000 in storage and insurance

costs.

C. RM Sotheby's

11. The Receiver has determined that selling the Automobiles via an online auction

through RM Sotheby's would maximize recovery to the receivership estate due to its vast market

reach and expertise in the industry.

12. RM Sotheby's is a world-renowned auction house and a leader in the industry of

buying and selling high value collector and other cars.

13. Upon the request of the Receiver, RM Sotheby's has submitted a proposal to market

and sell the Automobiles via an online auction. The Receiver has been informed that RM Sotheby's

is conducting its next auction at the end of March 2021 and will also hold online auctions in 2021

at the end of every month thereafter.

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14. The terms of the consignment with RM Sotheby's are detailed in the Auction

Consignment Agreement, and are summarized below:

• RM Sotheby's will receive the Automobiles in trust, and in this capacity will act as

agent for the Receiver in selling the Automobiles at regularly scheduled end-of-month auction

series referred to as “Open Roads Online Only Auctions” (the “Auction”).

• The Rolls-Royce will be auctioned off with a reserve. The Range Rover will be

auctioned off without a reserve.

• RM Sotheby's will be entitled to an 5% seller's commission on the Range Rover,

and a 5% sales commission on the Rolls-Royce.

• In relation to the Auction, RM Sotheby's will provide services to the Receiver

including, but not limited to clerks, support staff, event advertising, and promotion. Any expenses

and fees incurred by RM Sotheby's, including, but not limited to the Transportation Fee2, the

Detailing Fee3, and the Marketing Fee4 will be deducted from the receivership estate's proceeds of

sale.

• RM Sotheby's will store the Automobiles at no cost until the date of Auction.

Should the Automobiles fail to be sold at Auction due to not achieving a minimum bid, then RM

Sotheby's will store the Automobiles up to an additional 30 days until they can be placed in the

next scheduled online auction.

• Buyers will also pay a buyer's premium to RM Sotheby's.

2
RM Sotheby's estimates a cost of approximately $150 - $200 per vehicle to transport the Automobiles (the
“Transportation Fee”) from Fort Lauderdale, Florida to Stuart, Florida.
3
RM Sotheby's estimates a cost of approximately $500 - $1,000 per vehicle to detail the Automobiles (the “Detail
Fee”).
4
RM Sotheby's estimates a cost of approximately $500 per vehicle to market the Automobiles (the “Marketing Fee”).

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Relief Requested

15. Based on the foregoing, the Receiver requests that this Court enter an Order: (i)

authorizing the Receiver to enter into the Auction Consignment Agreement; (ii) authorizing the

Receiver to sell the Automobiles subject to the terms set forth herein, free and clear of any and all

liens, claims and encumbrances, at an online auction conducted by RM Sotheby's; and (iii)

allowing the Receiver to set a minimum bid, and in the event necessary, sell the Automobiles

without a minimum bid should the initial auction fail to obtain the reserve price.

Memorandum of Law

16. The district court has broad powers and wide discretion to determine relief in an
th
equity receivership. SEC v. Elliott, 953 F.2d 1560, 1566 (11 Cir. 1992). These powers include

the authority to approve the sale of property of the Defendants, including HBO. Clark on Receivers

§ 482 (3rd ed. 1992) citing First National Bank v. Shedd, 121 U.S. 74, 87, 7 S.Ct. 807, 814, 30

L.Ed. 877 (1887) (A court of equity having custody and control of property has power to order a

sale of the property in its discretion).

17. 28 U.S.C. § 2004 provides that personalty sold under any order of any court of the

United States shall be sold in accordance with Section 2001 of Title 28, unless the court orders

otherwise. Pursuant to 28 U.S.C. § 2001(a), realty shall be sold at public sale within the district

where the receiver was first appointed. However, after notice and hearing, the court may order the

sale of realty at private sale upon terms and conditions approved by the court, if the court finds

that the best interests of the estate will be conserved thereby. 28 U.S.C. § 2001(b). See also Tanzer

v. Huffiness, 412 F.2d 221, 222 (3rd Cir. 1969). The Receiver believes that it is in the best interest

of the receivership estate to consign and sell the Automobiles through a licensed, qualified

auctioneer via an online platform under the terms and conditions described herein.

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18. The Automobiles, particularly the Rolls-Royce, are considered high-end used

vehicles. And while the Automobiles may command a high sales price, the market for the luxury

used vehicles is more restricted in nature. Accordingly, in an attempt to maximize the value of the

Automobiles for the benefit of the receivership estate, the Receiver seeks to consign the

Automobiles with RM Sotheby's to be marketed and sold in an international marketplace via its

online auction platform.

19. The reach of RM Sotheby's market is considerable. The Automobiles will appear

live on RM Sotheby's platform which receives approximately 300,000 views a week. RM

Sotheby's will send targeted e-blasts to its approximately 1.8 million customers around the world,

and will be soliciting interest in the Automobiles by placing classified ads in well-known

publications such as Auto Trader and through phone calls and social media platforms.

20. The Receiver will work with RM Sotheby's to ensure that the highest and best prices

are obtained for the benefit of the creditors of the receivership estate. Accordingly, the Receiver

submits that the requirement under 28 U.S.C. § 2001(a) for three independent appraisals imposes

a financial burden on the receivership estate that will only serve to limit the net funds that would

otherwise be attained for the benefit of creditors.

21. To the extent 28 U.S.C. § 2001(a) requires further publication of notice, appraisals

or other procedures, such provisions should be waived. See SEC v. Kirkland, 2009 WL 1439087,

*2 (M.D. Fla. May 22, 2009) (waving certain requirements of 28 U.S.C. § 2001 where the Court

believes the receiver had substantially complied with the requirements of the statute for the sale of

property).

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22. Based on the foregoing, the Receiver respectfully requests the authority to enter

into the Auction Consignment Agreement with RM Sotheby's to sell the Automobiles on the terms

set forth herein.

WHEREFORE, the Receiver respectfully requests the Court to enter an Order in the form

attached hereto as Exhibit B, approving the relief requested in this motion and to grant such further

relief as is just and proper.

LOCAL RULE 7.1 CERTIFICATION OF COUNSEL

Pursuant to Local Rule 7.1, undersigned counsel hereby certifies that the Receiver has

conferred with counsel for the FTC, who has no objection to the relief requested in this Motion,

and counsel for the Defendant, Steven Dorfman, who has not responded.

Dated: March 25, 2021 Respectfully submitted,

AKERMAN LLP
201 E. Las Olas Boulevard, Suite 1800
Fort Lauderdale, FL 33301-2999
Phone: (954) 463-2700
Fax: (954) 463-2224

/s/ Catherine D. Kretzschmar

Catherine D. Kretzschmar, Esq.
Florida Bar Number: 85843
Email: catherine.kretzschmar@akerman.com
Counsel for Receiver

Michael I. Goldberg, Esq.

Florida Bar Number: 886602
Email: michael.goldberg@akerman.com
Court-appointed Receiver

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served on March

25, 2021 via the Court's notice of electronic filing on all CM/ECF registered users entitled to notice

in this case as indicated on the attached Service List.

By: /s/ Catherine D. Kretzschmar

Catherine D. Kretzschmar, Esq.

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SERVICE LIST

ALDEN F. ABBOTT, General Counsel Naim S. Surgeon, Esq.

Elizabeth C. Scott, Special Bar No.: A5501502 Florida Bar No.: 101682
Joannie Wei, Special Bar No.: A5502492 naim.surgeon@akerman.com
Matthew Schiltz, Special Bar No.: A5502617 AKERMAN LLP
Federal Trade Commission Three Brickell City Centre
230 S. Dearborn Street, Suite 3030 98 Southeast Seventh Street, Suite 1100
Chicago, Illinois 60604 Miami, Florida 33131
312.960.5609; escott@ftc.gov 305.374.5600
312.960.5607; jwei@ftc.gov Counsel for Receiver
312.960.5619; mschiltz@ftc.gov
Counsel for Plaintiff, Federal Trade Commission
Catherine D. Kretzschmar, Esq.
Ryan D. O’Quinn, Esq. Florida Bar Number: 85843
Florida Bar No.: 0513857 catherine.kretzschmar@akerman.com
305.423.8553; ryan.oquinn@dlapiper.com AKERMAN LLP
Elan A. Gershoni, Esq. 201 East Las Olas Boulevard, Suite 1800
Florida Bar No.: 95969 Fort Lauderdale, FL 33301-2999
305.423.8567; elan.gershoni@dlapiper.com 954.463.2700
Jordan Allyn Ziegler, Esq. Counsel for Receiver
Florida Bar No.: 119982
305.423.8558; jordan.ziegler@us.dlapiper.com
DLA Piper LLP (US) Brian Hobbs Mallonee, Esq.
200 South Biscayne Boulevard, Suite 2500 Florida Bar Number: 160148
Miami, Florida 33131 bmallonee@stluciecriminallaw.com
Counsel for Defendant, Steven J. Dorfman legalassistant@stluciecriminallaw.com
130 S. Indian River Drive, Suite 302
Fort Pierce, FL 34950
772.464.1991
Counsel for Candida L. Girouard

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Case 0:18-cv-62593-DPG Document 412-1 Entered on FLSD Docket 03/25/2021 Page 1 of 5

COMPOSITE
EXHIBIT "A"
 A04233
Mail Lien Satisfaction to: Dept of Highway Safety and Motor Vehicles, Neil Kirkman Building, Tallahassee, FL 32399-0500
Case 0:18-cv-62593-DPG Document 412-1 Entered on FLSD Docket 03/25/2021 Page 2 of 5
Identification Number Year — Make — Body WT-L-BHP — Vessel Regis. No. — Title Number 7
:91
SALGV2EF 1DA100321 2013 LNDR UT 5137 114136015 I
Registered Owner: Date of Issue 06/06/2014
Lien Release
Interest in the described vehicle is hereby released
ix HEALTH BENEFITS ONE LLC
3325 S UNIVERSITY DR #210 By

0 DAVIE FL 33328 Title

Date
IMPORTANT INFORMATION
I. When ownership of the vehicle described herein is
transferred, the seller MUST complete in full the
Transfer of Title by Seller section at the bottom of
0 Mail To:
the certificate of title.
2. Upon sale of this vehicle, the seller must complete
LU HEALTH BENEFITS ONE LLC
the notice of sale on the reverse side of this form.
3. Remove your license plate from the vehicle.
3325 S UNIVERSITY DR #210
DAVIE FL 33328-2007 4. See the web address below for more information and
the appropriate forms required for the purchaser to
title and register the vehicle, mobile home or vessel:
cn http://www.hSmv.state.fLus/html/titlinf.html

•
- -CERTIFICATE OF TITLE--
.ttt s,

"
identifi•Palion Nuiciber Make ,7—:Bady yesyei Regis. No Title Number
tie.
• '•.• • itodse
160tilaA160321 : LNDR UT 5137 1141no 15 Interest in the described vehicle is hereby released
4-
,Prey Primary Brand Secondary Brand Use:]: . : Piey:.)s:SOP Date
. El`r
13,,cg,
„ stog,
. PRIVATE 02/21/2014
, .
- ..00benetet Statics b Vessel .Manufacturer or OH use -- - Hull Material --- Prop • Date of Issue

.7899 g)AltEs 04/28/2014 ACTUAL .05/06/2014

Registered Owner
HEALTH BENEFITS ONE LLC
3325 St- UNIVERSITY DR #210
DAVIE FL 33328

1at Lienholder
g3H3,11VJI,C110/\

NONE
01

DIVISION OF MOTORIST SERVICES TALLAHASSEE FLORIDA DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES

Clayton Boyd Walden Julie L. Jones

Director Executive Director

TRANSFER OF TITLE BY SELLER (This section must be completed at the time of sale.)
F•rknil and/or stale law require that the seller slate the milege, purchaser's norm, sell ing.price and date sold in connection with the Intusfer of owtIefehilf.
Failure to complete or providing El false Statement may result iti fines audio,- imprisonment.
iii dile I u I ii (ohe free from any liens except as noted on the face of the certificate and the motor vehicle or vessel debet ibed is hereby Irrnisferred to .

Seller Must Euler Purclutser'sNsrne,

Seller Must Enter Selling, Price: Seller Must Enter Dale Sold:
:
D'We stale that this 5 or 6 diptiI odometer now reads 1_11111,111111.100lowilhomii6.176id IIIeray• certify that M the best °low knowledge the orlontelet

1 II ACTUAL MILEAGE. El 2. is IN EXCEig, OF OS NII.:COANOW.filVilTS. Ei 3. is NOT THE ACTUAL MILEAGE.

UNDER PENALTIES OF PERJURY, I DECLARE THAT I HAVE READ THE FOREGOING DOCUMENT AND THAT THE FACTS STATED IN IT ARE TRUE.
SELLER Must CO-SELTER Most
Sign Here. Sign Here:

Print Bei Print Here,

Sell iit potle I censeNtunber. leviNe,.:

Auction Haste 1reensd'N Ober.

0:?..-214c;HAsEp.ivtost:
$150 Here: Sign Here
• ...
1'l lilt Hen e. :Print here

.EvciTicg: ppNALTY iviEciiin.RFAjay LAW. IF NOT supidulo FpR.ift44FgR WITHIN 00 DAYS AFTM.I;TAT QF PURCHASE

HSMV 82250 (REV. 10/12)

,
 Case 0:18-cv-62593-DPG Document 412-1 Entered on FLSD Docket 03/25/2021 Page 3 of 5
STATE OF FLORIDA
DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES
DIVISION OF MOTOR VEHICLES
2900 Apalachee Parkway • Neil Kirkman Building - Tallahassee, FL 32399-0620
Notice of Sale of Motor Vehicle, Mobile Home or Vessel

Section 319.22(2), Florida Statutes, requires that the seller file a Notice of Sale with the department within 30 days after the sale or transfer of the motor vehicle, vessel or
mobile home. Filing this form removes any civil liability for the operation of the sold motor vehicle, vessel or mobile home. In addition to filing this form, we suggest you
keep a copy of your bill of sale (we suggest it be notarized), certificate of title or other type of transaction document showing the vehicle was sold. Complete the information
below, tear the top portion of this document at the perforation and mail to the address above or submit to your local tax collector's office or license plate agency.

I have this day of , transferred by assignment of and delivered Florida Certificate of Title to:

Name: Purchaser(s) Purchaser's DL/ID

First MI Last

Address Selling Price $

UNDER PENALTIES OF PERJURY, I DECLARE THAT I HAVE READ THE FOREGOING DOCUMENT AND THAT THE FACTS STATED IN IT ARE TRUE.

Seller's Signature Co-Seller's Signature

NOTE: THE SUBMISSION OF THIS FORM, ACCURATELY COMPLETED, TO A TAX COLLECTOR'S OFFICE, LICENSE PLATE AGENCY OR TO THE
ADDRESS ABOVE WILL ALLOW THE TITLE CLERK TO UPDATE THE DMV DATABASE TO REFLECT THE TITLE RECORD AS "SOLD". HOWEVER,
THE OWNERSHIP STATUS WILL NOT CHANGE UNTIL THE PURCHASER APPLIES FOR AND IS ISSUED A CERTIFICATE OF TITLE.

OA*AT.f!t4!H eLximitt.EtMlett.r.Verrro that yap atedi die Liideage artar.metionw,ifb. transfer:nflommers.btat.Attme ,f6:tootatetoor pro td a]fAestia.etneht H6ti.ensulhn fins qtdiorpwrnionfpV.......

SeIigREurs 'Selling Dealde "".Tax

SelliDeaBtr'S Addres Dite•SO.R1

•; •
• .•
•.•• •..
Purdinsees.Name(03 • 'Ad diess:

/WE,STATE tHAT THIS 5 OR

•

• .•
n ••...„ • .• .;
DIGIT ODOMETER NOWREADS
n NO TENTHS) MIL;
CERTIFY THAT
. E,S, DATE READ "/ /• AND I.HEREBY:', .
THE BEST OF MY KNOWLEDGE THE ODOMETER READING •
•

CAUTION: RO.:0:cAR:61.4.0
BEFoft-F YOU
[ I; R.EF(..ECTSA(:tpAL lym.4kOn .'2t IS IN EXCESS OF ITS biEHANICAL LIMITS
(EX CE SS OF ITS MECiii•et.NICAL LIMITS 'T
.•
ri •
3. S NOT THE ACTUAEMILEAGE:
;''
WARNING ODOMETER DISCREPANCY •
. c140:ek 4.Bcix APPLIES TO 5 DIGIT ODOMETERS) • '

Purchimer Must Co-Purchaser Must

Sign Here: Sign Here*

Print here: Print Here.

Seller/Agent Most Auction Name (When Applicable):

Sign Here:

'Erin! Here: Auction License Number:

Selling Dealer's Selling Dealer's Tax

License No.: Name: Na:. Collected:

Selling Dealer's Address: Date Sold:

Purchaser's Name(s): Address:

.15

P.)
l/WE STATE THAT THIS ri 5 OR E 6 DIGIT ODOMETER NOW READS (NO TENTHS) MILES, DATE READ / / , AND I HEREBY
CERTIFY THAT TO THE BEST OF MY KNOWLEDGE THE ODOMEI ER READING:

CAUTION: READ CAREFULLY REFLECTS ACTUAL MILEAGE 2 IS IN EXCESS OF If S MECHANICAL, LIMITS 3 IS NOT THE ACTUAL MILEAGE.
BEFORE YOU (EXCESS OF EIS MECHANICAL LIMITS \YARNING - ODOMETER DISCREPANCY
CHECK A BOX • APPLIES TO 5 DIGIT ODOMETERS)
• -
Purchaser Must Co Purchaser Must
W-4 Sign Here:

Print Here: Print Here:

Seller/Agent Must:. Auction Nit te (When Applicable):

Sign Here!

Print Here: Auction License Number:

Selling Dealer's Selling Dealer's Tax Tax

License NO,: Name: No.: Collected:

is Selling Dealer's Address: Date Sold:

or Purchaser's Name(s): Address:

r5
Is
!AVE STATE THAT THIS pi •5 OR El 6 DIGIT ODOMETER NOW READS [1 (NO TENTHS) MILES, DATE READ / / ' , AND 1 liE.REBY ..: .
CERTIFY THAT TO THE BEST OF MY KNOWLEDGE THE pppmET8p.ILLEADLNdi

CAUTION: REAB•CARE.V.U14.L
. Y I. REFLECTS ACTUAL MILEAGE . IS :IN: EXCESS OE.:IT'S MECHANICAL LIMITS ' .F7 1. IS t•i0I'el-IF. ACTUAL MILEAGE.
or "ERE#ORB *OH" i• .• (EXCESS OF ITS ME(*.titi.biLE:A ELMO'S: ". :' ' ::. .: .:, WARNING 1 opomrtrg bi§cRi4j4c...,;( . i....
'' • :.'"
CIIECI(A . •:•AprLit0:'Pb..5.. DIGIT ODOMETERS) ::::.... : :.• . : : .. . •
• • •:: ::. i'' ' ':" : ...:' ""
Purchaser:1146st • 2. • . CO:T'orchnser Must:
Sign Herr. SignHere:

Pribt Fleer

• SciYeit/A.O .iiiMust "AbeBor.C•Nai(0::(When Applicable):

 Case 0:18-cv-62593-DPG Document 412-1 Entered on FLSD Docket 03/25/2021 Page 4 of 5
Mall Lien Satisfaction to: Dept of Highway Safety and Motor Vehicles, Nell Kirkman Building, Tallahassee, FL 32399-0500 # 999742935
# 618396
Identincation Number Year Make Body WT-L-BHP Vessel Regis. No. I &5 hi
8CA665C54FUX85225

Registered Owner:
2015 ROL 2D i5380

Date of Issue 12/12/2017

1294181N6um2b9e3
r

•
Lien Release
I. I I II

Interest in the described vehicle is hereby released

HEALTH BENEFITS ONE LLC By
2 OAKWOOD BLVD STE 100 Title

HOLLYWOOD, FL 33020-1955 Date

IMPORTANT INFORMATION
1. When ownership of the vehicle described herein is
transferred, the seller MUST complete in full the
Transfer of Title by Seller section at the bottom of
the certificate of title.
Nelad To: 2. Upon sale of this vehicle, the seller must complete
HEALTH BENEFITS ONE LLC the notice of sale on the reverse side of this form.
3. Remove your license plate from the vehicle.
2 OAKWOOD BLVD STE 100 See the web address below for more information and
4.
HOLLYWOOD, FL 33020-1955 the appropriate forms required for the purchaser to
title and register the vehicle, mobile home or vessel:
http://www.hsmv.state.fl.us/html/titlinf.html

•
11111t-e-'I tIt'
; ,

--- - Identification Number -- --/--- Year - Make - 1 Body WT-L-1311P Vessel Regis. No Title Number ----1
SCA665C54FUX85225 1 2015 ROL ! 2D i5380 ,129416293 ILionRMeaca
I interest in the described vehicle is hereby released

Prey Color Primary Brand _ Secondary Brand . No of Use Prey issue Date BY
, State I I Brands ,
1 NY 'ELK I 1 'PRIVATE
1
Odometer Status or Vessel Manufacturer or OH use - Hull Material - Prop --- Date of Issue
4,219 MILES 12/12/2017 ACTUAL 12/12/2017 Date

Registered Owner
HEALTH BENEFITS ONE LLC
2 OAKWOOD BLVD STE 100
HOLLYWOOD, FL 33020-1955

1st Lienholder OTHER JURISDICTION BRANDS

NONE NY—MANUF BUY BACK

DIVISION OF MOTORIST SERVICES TALLAHASSEE FLORIDA DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES

Robert R. Kynoch Terry L Rhodes

Director Executive Director

TRANSFER OF TITLE BY SELLER (This section must be completed at the time of sale.)
Federal and/or state law require that the seller state the mileage, purchaser's name, selling price and date sold in connection with the transfer of ownership. •••
Failure to complete or providing a false statement may result in fines and/or imprisonment.
This title is warranted to be free from any liens except as noted on the face of the certificate and the motor vehicle or vessel described is hereby transferred to:

Seller Must Enter Purchaser's Name: Address:

Ur.
Seller Must Enter Selling Price: Seller Must Enter Date Sold:
1/We stale that this E 5 or 6 digit odometer now reads I I Li Li I 1.LX j (no tenths) miles, date read and I hereby certify that to the best of my knowledge the odometer reading:
I. reflects ACTUAL MILEAGE. 0 2. is DI EXCESS OF ITS MECHANICAL LIMITS. 3. is NOT THE ACTUAL MILEAGE.
UNDER PENALTIES OF PERJURY, I DECLARE THAT I HAVE READ THE FOREGOING DOCUMENT AND THAT THE FACTS STATED IN IT ARE TRUE.
SELLER Must CO-SELLER Must
Sign Here: Sign Here

Print Here: Print Here.

Selling Dealer's License Number. Tax No: Tax Collected:

Auction Name: License Number:

_
PURCHASER Must CO PIJt HASER Must
Sign Here: si w; He ;

Print Here: Print Hem

— NOTICE: PENALTY IS REQUIRED BY LAW IF NOT SUBMITTED FOR TRANSFER WITHIN aq pays AFTER DATE OF PURCHASE,
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 Case 0:18-cv-62593-DPG Document 412-1 Entered
STATE OF FLORIDA on FLSD Docket 03/25/2021 Page 5 of 5
DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES
DIVISION OF MOTOR VEHICLES
2900 Apalachee Parkway • Neil Kirkman Building - Tallahassee, FL 32399-0620
Notice of Sale of Motor Vehicle, Mobile Home or Vessel
Section 319.22(2), Florida Statutes, requires that the seller file a Notice of Sale with the department within 30 days after the sale or transfer of the motor vehicle, vessel or
mobile home. Filing this form removes any civil liability for the operation of the sold motor vehicle, vessel or mobile home, hi addition to filing this form, we suggest you
keep a copy of your bill of sale (we suggest it be notarized), certificate of title or other type of transaction document showing the vehicle was sold. Complete the information
below, tear the top portion of this document at the perforation and mail to the address above or submit to your local tax collector's office or license plate agency.

I have this day of , transferred by assignment of and delivered Florida Certificate of Title to:
Name: Purchaser(s) Purchaser's DL/ID
First MI Last
Address Selling Price $
UNDER PENALTIES OF PERJURY, I DECLARE THAT I HAVE READ THE FOREGOING DOCUMENT AND THAT THE FACTS STATED IN IT ARE TRUE.

Seller's Signature Co-Seller's Signature

NOTE: THE SUBMISSION OF THIS FORM, ACCURATELY COMPLETED, TO A TAX COLLECTOR'S OFFICE, LICENSE PLATE AGENCY OR TO THE
ADDRESS ABOVE WILL ALLOW THE TITLE CLERK TO UPDATE THE DMV DATABASE TO REFLECT THE TITLE RECORD AS "SOLD". HOWEVER,
THE OWNERSHIP STATUS WILL NOT CHANGE UNTIL THE PURCHASER APPLIES FOR AND IS ISSUED A CERTIFICATE OF TITLE.

ODOMETER CF.R'FIFICATION'- Federal and state laws relaire thatiyou,*e il)gmIlestge is-claUngytion- withitMusfei.utimaie ipTaBure 0,.cornOete(ii•proviintigayS'ostatement May..reSult in Cities 01,03pippriso.m*.

Selling Dealer's Selling Dealer's Tax

License No Name: ----- - No • Collected.

Selling 1)Caler's Address: Date Sold:

Purchaser's Name(s): Address:

1/WE STATE TIIAT TI US 5 OR 6 DIGIT ODOMETER NOW READS x> (NO TENTHS) MILES, DATE READ / AND I HEREBY
CERTIFY THAT TO TIIE BEST OF MY KNOWLEDGE THE ODOMETER READING:

CAUTION: READ CAREFULLY

BEFORE YOU
1. REFLECTS AC'ILIAL MILEAGE 2. IS IN EXCESS OF ITS MECHANICAL I.INILLS
(EXCESS OF ITS MECHANICAL Limns
ri 3. IS NOT TRE ACTUAL MILEAGE.
WARNING - C)DOMETER DISCREPANCY
CHECK A BOX APPLIES TO 5 OMIT ODOMETERS)

Purchaser Must Co-Purchaser Must -

Sign Hem: Sign Here'

Print Here: Print Here•

Seller/Agent Must AuctMn Name (When Applicable).

Sign Here:

Print Here: Auction License Number:

Selling Dealer's Selling Dealer's Tax Tax

License No.: Name: No • Collected:

Selling Dealer's Address: Date Sold.

LICENSEDDEALE

Purchaser's Name(s): Address•

ITWE STATE THAT THIS

I I 5 OR 6 DIGIT ODOMETER NOW READS I-1 (NO TENTHS) MILES, DATE READ / / AND I HEREBY
CERTIFY THAT TO THE BEST OF MY KNOWLEDGE THE ODOMETER READING:

CAUTION: READ CAREFULLY

BEFORE YOU
1 REFLECTS ACTUAL MILEAGE n S IN EXCESS OF ITS MECHANICAL LIMITS
(EXCESS OF ITS MECHANICAL Limrrs
3. IS NOT THE ACTUAL MILEAGE.
WARNING - ODOMETER DISCREPANCY

5 CHECK A BOX

Purchaser Nilust
APPLIES TO 5 DIGIT ODOMETERS)

Co-Purehaser Must
Sign Here: Sign Here'

Print Here: Print Here-

C.) Seller/Agent Must Auction Name (When Applicable).

Lu
En
Sign Here:

Print Here: Auction License Number-

Selling Dealer's Selling Dealer's Tax Tax

License No.: Name: No • Collected:

Selling Dealer's Address: Date Sold'

Purchaser's Name(s): Address.

I/WE STATE THAT THIS 50K I I

6 DIGIT ODOMETER NOW READS XX (NO TENTHS) MILES, DATE READ / / AND I HEREBY

CAUTION: READ CAREFULLY

BEFORE YOU
I. REFLECTS ACTUAL MILEAGE
n 2. IS IN EXCESS OF ITS MECHANICAL LIMITS
(EXCESS OF ITS MECHANICAL LIMITS
n
CERTIFY THAT TO THE BEST OF MY KNOWLEDGE THE ODOMETER READING.

3. TS NOT THE ACTUAL MILEAGE.

WARNING - ODOMETER DISCP.EPANCY
CHECK A BOX APPLIES TO 5 DIGIT ODOMETERS)

Purchaser Most Co-Purchaser Must

Sign Hoe: Sign Here'

Print lie e Pt I Hem

Seller/Agent Must Auction Name (When Applicable);

Sign Here.

Print Here: • Auction Licease

„ blunilact•
Case 0:18-cv-62593-DPG Document 412-2 Entered on FLSD Docket 03/25/2021 Page 1 of 3

Exhibit B
Case 0:18-cv-62593-DPG Document 412-2 Entered on FLSD Docket 03/25/2021 Page 2 of 3

UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

CASE NO. 18-CV-62593-GAYLES

FEDERAL TRADE COMMISSION,

Plaintiff,

vs.

SIMPLE HEALTH PLANS LLC, et al.,

Defendants.

ORDER GRANTING RECEIVER’S MOTION FOR AUTHORITY TO ENTER INTO

AUCTION CONSIGNMENT AGREEMENT WITH RM SOTHEBY'S TO SELL
HEALTH BENEFITS ONE LLC'S RIGHT, TITLE, AND INTEREST IN 2015 ROLLS-
ROYCE WRAITH AND 2013 LAND ROVER RANGE ROVER AUTOMOBILES

This matter came before the Court without hearing upon the Motion for Authority to Enter

into Auction Consignment Agreement with RM Sotheby's to Sell Health Benefits One LLC's Right,

Title, and Interest in 2015 Rolls-Royce Wraith and 2013 Land Rover Range Rover Automobiles

and Incorporated Memorandum of Law (the “Motion”) [ECF No. ---] filed by Michael I. Goldberg,

the Court-appointed receiver1 (the “Receiver”). The Court, having reviewed the Motion, being

advised that counsel for the Plaintiff Federal Trade Commission has no objection to the relief

requested in the Motion, and that counsel for Defendant Steven Dorfman has not responded to the

Motion, and finding that the Receiver has made a sufficient and proper showing in support of the

relief requested,

IT IS ORDERED, ADJUDGED AND DECREED, as follows:

1
The Court-appointed Receiver over Defendants Simple Health Plans LLC, Health Benefits One LLC, Health Center
Management LLC, Innovative Customer Care LLC, Simple Insurance Lead LLC, Senior Benefits One LLC, and each
of their subsidiaries, affiliates, and successors (collectively, the “Receivership Entities”).

56690853;1
Case 0:18-cv-62593-DPG Document 412-2 Entered on FLSD Docket 03/25/2021 Page 3 of 3

CASE NO. 18-CV-62593-GAYLES

1. The Motion is GRANTED.

2. The Receiver is authorized to sell the Receivership Entities' interest in the 2015

Rolls-Royce Wraith with VIN No. SCA665C54FUX85225 and the 2013 Land Rover Range Rover

with VIN No. SALGV2EF1DA100321 free and clear of any and all liens, claims, and

encumbrances.

3. The Receiver is authorized to enter into an auction consignment agreement with

RM Sotheby's on the terms and conditions detailed in the Motion.

4. The Receiver is further authorized to execute any documents and take any actions

reasonably necessary to consummate the transactions contemplated therein.

5. Any resulting sales from the consignment shall stand as confirmed, without further

Order of the Court.

DONE AND ORDERED in Chambers at Miami, Florida this ___ day of

________, 2021.

__________________________________
DARRIN P. GAYLES
UNITED STATES DISTRICT COURT JUDGE