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STATE OF OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES DIVISION OF FINANCE AND CORPORATE SECURITIES ANDINSURANCEDIVISON

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BEFORE THE DIRECTOR OF THE DEPARTMENT OF CONSUMER AND BUSINESS SERVICES

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In the Matter of: 8

ID-09-0027

ROBERT WARREN SPRUILL, 9 dba Brooke Auto Insurance

Services and dba Brooke Agency 10 Services Company, LLC,

ORDER TO CEASE AND DESIST, ORDER ASSESSING CIVIL PENALTY AND CONSENT TO ENTRY OF ORDER

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WHEREAS the Director of the Oregon Department of Consumer and Business

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Services has conducted an investigation of certain business activities conducted by Robert Warren Spruill, dba Brooke Auto Insurance, and dba Brooke Agency Services Company, LLC ("Spruill"), and has determined that he has violated provisions of the Oregon Consumer Identity Theft Protection Act, Oregon Revised Statutes ("ORS") 646A.6oo to 646A.628, and provisions of the Oregon Insurance Code, ORS Chapters

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Respondent.

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and

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WHEREAS Spruill waives all rights relative to an administrative hearing and judicial review thereof; NOW THEREFORE, as evidenced by the authorized signature(s) subscribed

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731 and 746; and

WHEREAS Spruill wishes to resolve and settle this matter with the Director;

25 on this Order, Robert Warrant Spruill hereby CONSENTS to entry of this Order to 26 Cease and Desist upon the Director's Findings of Fact and Conclusions of Law as Page I-CEASE AND DESIST ORDER - Robert Warren Spruill (ID-09-oo27)

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