611 Pennsylvania Ave., S.E. #337  Washington, D.C. 20003  (202) 780-5750

campaignforaccountability.org

November 4, 2019

BY FAX: (850) 488-3077

RE: Request for Investigation of Rep. David Scott Plakon

Dear Mr. Anderson:

Campaign for Accountability (“CfA”), a nonprofit, non-partisan government watchdog

organization, respectfully requests that the Florida Commission on Ethics (“Commission”)

investigate whether Rep. David Scott Plakon may have violated the Code of Ethics for Public

Officers and Employees, Florida Statute Chapter 112, Part III, by failing to include information

about his myriad business interests on his personal financial disclosure forms.

for insurance claim professionals and adjusters” that was a significant source of his income.

2

Rep. Plakon sold the business at the end of 2017.

Rep. Plakon appears to have run Claims Pages through an entity called Nationwide

Publishing Company, Incorporated (“Nationwide, Inc.”), which he established in 1998.

Plakon’s financial disclosures have never included Claims Pages, but every financial disclosure

he has filed since 2014 disclosed his ownership stake in Nationwide, Inc.

The stake increased

3

https://www.theclm.org/PressDetails?pressID=101; https://scottplakon.com/about-scott/; Press Release, The

Institutes Acquires CLM and Claims Pages to Deliver Enhanced Education to Risk Management and Insurance

Professionals, The Institutes, June 1, 2018, available at https://www.theinstitutes.org/about-us/media-

center/articles/institutes-acquires-clm-and-claims-pages-deliver-enhanced-education.

4

https://www.bbb.org/us/fl/deltona/profile/publishers-directory/nationwide-publishing-company-llc-0733-4002154;

Articles of Incorporation, Nationwide Publishing Company, Incorporated, Florida Secretary of State, filed May 13,

1998, available at http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=

COR%5C1998%5C0514%5CH9008973.TIF&documentNumber=P98000043246.

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from slightly more than 60 percent in 2014 to 100 percent in his most recent disclosure covering

the 2018 calendar year. In 2014, Rep. Plakon valued Nationwide, Inc. at $3.3 million, but he

reported a decreased value of $1.3 million as of December 31, 2018.

In 2016 – nearly 20 years after forming Claim Pages – Rep. Plakon set up a new entity,

Claims Pages, LLC, for which he is named as the registered agent and manager on annual forms

filed with the Florida Secretary of State.

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In 2018, Rep. Plakon appears to have transferred

In addition to Claims Pages, LLC, Rep. Plakon has failed to disclose his relationship with

several other entities. Most notably, Rep. Plakon is intricately involved with a company called

Aslan Capital, LLC (“Aslan”), a sizable real estate holding company formed in 2005.

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In 2006, Rep. Plakon was added as the manager for the company, and its business and

mailing address were the same as that of Nationwide, Inc.

and authorized person from Rep. Plakon to High Country Management Company (“High

Disclosure of Financial Interests, Form 6, filed June 13, 2016, available at

http://public.ethics.state.fl.us/Forms/2015/223307-Form6.pdf; Rep. Scott Plakon, 2014 Full and Public Disclosure of

Financial Interests, Form 6, filed June 29, 2015, available at http://public.ethics.state.fl.us/Forms/2014/223307-

Form6.pdf.

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Articles of Organization, Claims Pages, LLC, Florida Secretary of State, filed Aug. 1, 2016, available at

http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2016%5C0804%5C7

0568997.tif&documentNumber=L16000143606.

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2018 Annual Report, Claims Pages, LLC, Florida Secretary of State, filed Jan. 4, 2018, available at

Financial Interests, Form 6, filed June 20, 2018, available at http://public.ethics.state.fl.us/Forms/2017/223307-

Form6.pdf.

9

Articles of Organization, Aslan Capital, LLC, Florida Secretary of State, filed Feb. 28, 2005, available at

http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2005%5C0307%5C

H0049791.Tif&documentNumber=L05000019994.

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http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2006%5C0209%5C2

0543542.tif&documentNumber=L05000019994.

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changed the registered agent from Robert J. Hutchins to Shannon White, an employee of

Nationwide, Inc.

In 2018, Rep. Plakon was listed as the authorized person and registered agent, and the

company’s address was changed to Rep. Plakon’s home address.

In 2019, Aslan filed an

annual report, and updated its address to Rep. Plakon’s new home address.

14

On May 15, 2019,

Rep. Plakon filed an affidavit with the Seminole County Clerk of the Circuit Court stating that he

Property records from county appraisers and court clerks reveal that Aslan, Nationwide,

Inc., and High Country are interconnected. According to an affidavit filed with Volusia County

Clerk of Court in 2017, Nationwide, Inc. did business under the name High Country

Management Company. High Country/Nationwide, Inc., in turn, was the managing member of

Aslan Capital, LLC, and constituted “100% of all members, managers, officers and directors” of

Aslan. According to the affidavit:

D. Scott Plakon as President of Nationwide Publishing Company, Incorporated

LLC, a Florida Limited Liability Company is authorized by the articles of

organization to execute deeds, other documents on behalf of [Aslan Capital,

LLC], and all necessary consents have been obtained.

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Nationwide, Inc., therefore, was the owner and manager of Aslan Capital, LLC as of 2017. The

changes to Aslan’s filings with the Florida Secretary of State and the 2019 affidavit, however,

indicate this relationship may no longer be accurate.

http://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=flal-l05000019994-9a421358-2a31-

4644-906e-9f9130505d0b&transactionId=l05000019994-53678e63-4374-4098-a3e8-

5e599440a6e9&formatType=PDF.

http://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=flal-l05000019994-9a421358-2a31-

4644-906e-9f9130505d0b&transactionId=l05000019994-abd96df5-8dab-4782-aca6-

b4bbaf8bf944&formatType=PDF.

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Deltona Blvd.

Claims Pages.

directly.

property.

21

Currently, the building is

available for lease or sale.

One real estate website indicates it has been on the market for more

than 415 days, which appears to line up with the timing of the sale of Claims Pages in 2017.

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The taxable value of the property is $349,825.

24

25

Aslan also owns a building in Lake County, Florida. In 1999, Rep. Plakon and his then-

wife Suzanne Plakon, purchased a property in Tavares, Florida for $68,200.

signed the deed over to Nationwide, Inc., which, in turn, sold the property to Aslan for $120,000

in 2005.

Claims Pages can be seen on the property in the most up to date version of Google Earth.

still owns the property, and the current taxable value is $179,377.

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surrounding counties, the company has previously owned several other properties. In 2006,

https://vcpa.vcgov.org/searches.html.

Oct. 4, 2002, available at https://www.documentcloud.org/documents/6498185-Nationwide-Inc-537-Deltona-Blvd-

Deed-Sept-30-2002.html.

available at https://www.documentcloud.org/documents/6498198-Aslan-Capital-Deed-537-Deltona-Blvd-

2005.html.

https://vcpa.vcgov.org/searches.html.

Volusia County Property Appraiser, accessed at https://vcpa.vcgov.org/searches.html.

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https://www.lakecopropappr.com/property-details.aspx?AltKey=3784680.

27

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Aslan bought a single-family home in Sanford, Florida for $205,100.

Aslan sold the house in

2019 for $195,000, and Rep. Plakon signed the paperwork on behalf of Aslan.

In addition, Aslan has owned several beachfront condominiums including some

apparently in partnership with Rep. Plakon’s family members. In August 2004, Nationwide, Inc.

purchased unit 806 in an oceanfront condominium building in Daytona Beach Shores, Florida.

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Rep. Plakon’s apparent farther or uncle, Ronald Plakon,

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In 2008, Aslan, along with Ronald Plakon and Robert Plakon, purchased unit 305 in the

same building for $350,200.

In 2012, Robert Plakon deeded the property over to Ronald

Plakon and Aslan.

39

Plakon signed the paperwork on behalf of Aslan.

Plakon of $270,000 in 2017 and $116,550 in 2018, but it is unclear if the liability was related to

these real estate deals.

Court, filed July 1, 2004, available at https://www.documentcloud.org/documents/6506137-Deed-Unit-205-Ronald-

Plakon-2004.html.

March 5, 2005, available at https://www.documentcloud.org/documents/6506143-Indenture-Deed-Unit-806-Aslan-

2005.html.

Court, filed Dec. 28, 2017, available at https://www.documentcloud.org/documents/6506440-Deed-Unit-806-Aslan-

of the Circuit Court, filed May 25, 2012, available at https://www.documentcloud.org/documents/6506444-Quit-

Claim-Deed-Unit-305-Aslan-Plakon-2012.html.

Circuit Court, filed May 2, 2017, available at https://www.documentcloud.org/documents/6506445-General-

Warranty-Deed-Unit-305-Aslan-2017.html.

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Page 6

In 2009, Aslan set up another apparent real estate holding company, Lake Helen

Holdings, LLC, which shared the same business address as Nationwide Inc., 537 Deltona Blvd.

43

That same year, Lake Helen Holdings purchased a property at 186 Industrial Center Drive in

Lake Helen, Florida for $441,000, and it still owns the property.

44

Asian Capital, LLC, a Florida limited liability company, the Managing Member

of Lake Helen Holdings, LLC, a Florida limited liability company….The

Managing Member of the Company acting alone has the authority to execute all

conveyances, notes, mortgages, encumbrances and any other instrument of or

affecting the Company property and to otherwise bind the Company.

45

In April 2017, Aslan appears to have sold or transferred Lake Helen Holdings to Vincent

Wolle as the company filed an annual report listing Mr. Wolle as the registered agent and

Lake Helen Holdings took out a $405,610.58 mortgage from Aslan Capital.

In 2017, after Mr.

Wolle took over, Lake Helen Holdings transferred the mortgage to a bank.

Plakon ever listed Lake Helen Holdings or 186 Industrial Center Drive on his financial

Trilemma-3 Holdings, LLC appears to be another entity connected to Nationwide, Inc.

and Aslan. The company, formed in 2006, initially shared the 537 Deltona Blvd. address and

http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2009%5C0626%5C5

7529171.Tif&documentNumber=L09000060505.

http://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=flal-l09000060505-3b6601dd-03c4-

421c-8804-831033d5da89&transactionId=l09000060505-68007e71-fc6d-4d19-985c-

48128100ff60&formatType=PDF.

http://vcpa.vcgov.org/searches.html.

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Nov. 26, 2013, available at https://www.documentcloud.org/documents/6506479-Mortage-Aslan-Lake-Helen-

Holdings-186-Industrial.html.

Page 7

was managed by High Country Management Company and Ms. White.

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form filed with the Florida Secretary of State, in 2011 its address briefly switched to the 186

Industrial Drive, the address of Lake Helen Holdings, but it reverted to 537 Deltona Blvd in

2014.

Both its 2018 and 2019 annual reports, however, list Rep. Plakon as the controlling

party, and list his home address as the entity’s address.

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Country Management Company and Ms. White out of the 537 Deltona Blvd address.

Rep.

Plakon failed to file the 2019 annual report for Nationwide, LLC with the Florida Department of

State, and it has been administratively dissolved.

Beyond these interconnected entities, Rep. Plakon appears to have started other unrelated

businesses that he has not disclosed on his personal financial disclosures. For instance, Rep.

5942239.tif&documentNumber=L06000121112; 2014 Annual Report, Trilemma-3 Holdings, LLC, Florida

Secretary of State, filed Apr. 28, 2014, available at

http://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=flal-l06000121112-6056b9a4-2020-

4860-80c8-58e94e5a7edc&transactionId=l06000121112-d90ee497-2db1-4280-845e-

c36de5db264f&formatType=PDF.

http://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=flal-l06000121112-6056b9a4-2020-

4860-80c8-58e94e5a7edc&transactionId=l06000121112-f0f08f43-d969-47bd-80c5-

available at

http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2006%5C1221%5C

H0296741.Tif&documentNumber=L06000119933.

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http://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=EntityName&directionType=In

itial&searchNameOrder=NATIONWIDEPUBLISHING%20L060001199330&aggregateId=flal-l06000119933-

Page 8

November 27, 2017.

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company, and initially listed a business address of 537 Deltona Blvd.

In 2018, Rep. Plakon

filed an updated Articles of Organization and switched the address for the company to his home

address.

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After selling Claims Pages in 2017, Rep. Plakon appears to view ShredPro as his

principal occupation outside of politics. In July 2018, Gov. Rick Scott appointed Rep. Plakon to

in Sanford.”

According a press release, in April 2018, ShredPro signed a lease for 2,000 square feet of

industrial space in Sandford, Florida.

63

Rep. Plakon’s now-wife, Rachel Saunders, represented

ShredPro in the transaction.

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company called Plakon Investments, LLC for which he is the authorized person and registered

at

http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2017%5C1127%5C3

0040913.tif&documentNumber=L17000242182.

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filed Feb. 17, 2018, available at

http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2018%5C0220%5C0

0055401.Tif&documentNumber=L17000242182.

2018, available at https://floridapolitics.com/archives/270129-rick-scott-names-scott-plakon-to-alzheimers-disease-

advisory-committee.

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of Florida, July 28, 2018 (Nexis).

Sentinel, Oct. 3, 2018, available at https://www.orlandosentinel.com/news/seminole-county/os-ne-general-election-

house-district-29-story.html.

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Page 9

agent and which uses his home address.

house in Orange City, Florida for $74,700.

notice of commencement regarding a roof replacement for the property.

Campaign Payments to Businesses

Since 2014, Rep. Plakon’s campaign committee has paid his businesses and employees of

In 2014, Rep. Plakon’s campaign committee paid Nationwide, Inc. $1,302.84 for

“campaign services.” Additionally, between 2014 and 2017, Rep. Plakon’s campaign committee

paid his similarly named Nationwide, LLC. $18,680.74 for “campaign services,” printing

equipment, truck rental, and reimbursements. More recently, on January 4, 2017, the campaign

paid $1,200 to Lake Helen Holdings for storage. Finally, in 2017, the campaign paid Shannon

White, the registered agent for many of Rep. Plakon’s businesses and an employee of

Nationwide, Inc., $3,750 for accounting services.

and Aslan more than $1,000 in revenue while Rep. Plakon was in the State Legislature. Further,

these payments suggest Rep. Plakon intermingles his business and campaign accounts.

Requirements for Financial Disclosures

As a member of the Florida State Legislature, Rep. Plakon is required to file a Form 6,

Full and Public Disclosure of Financial Interests.

assets and liabilities in excess of $1,000 and “[i]dentify each separate source and amount of

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http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2019%5C0501%5C0

0125591.Tif&documentNumber=L19000108395.

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businesses and employees of his businesses nearly $50,000. See Expenditure Records, Scott Plakon, Florida

Secretary of State, Division of Elections, accessed at https://dos.elections.myflorida.com/campaign-

finance/expenditures/.

Center South, NAI Realvest, Apr. 25, 2018, available at https://www.thenewsfunnel.com/press-release/nai-realvest-

closes-eight-industrial-leases-60-days-sanfords-monroe-commerce-center.

https://dos.elections.myflorida.com/campaign-finance/expenditures/; https://www.linkedin.com/in/shannon-

71