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CAL
IFORNIA DEPARTMENT OF INSURANCE
LEGAL DIVISI
ON
Edv,ard Wu, Attorney
SBN
233946
Ang
ie Chang, Attorney
SBN
296786
300
S Spring Street, South Tower, 12
th
Floor Los Angeles, CA 90013
Telephone: (213) 346-663 I
BEFORE
THE
I
NS
UR
NCE
C
M
SS
ION
ER
OF
THE
S
TA
TE
OF
C LIFORNI
In the Matter of the Cease and Desist Order
Fi
le No. IE201800349 against:
St
ipulation and Wai
ver
LIBRE BY NEXUS, INC.,
Respondent.
TO
THE
DEPAR
T
MENT
OF
INSURANCE
OF
THE
STA
TE
OF CAL
IFORNIA:
Respondent Libre by Nexus, Inc. (herein referred to as Respondent
or
Libre ) and Lib
re s
parent company, Nexus
Serv
ices, Inc. hereby do
enter
a Sti
pu
lation and Wai
ver
to the
Cease and
Desist Order served in the above-entitled matter and does hereby stipulate as follows:
I.
Respondent ackno,vledges recei
pt
of
a copy
of
the Cease and Desist Order dated
December
11
2019;
2
Without admitting
or
agreeing that it has engaged in ,vrongdoing, Respondent
acknowledges that the allegations contained in sa
id
Cease
and
Desist, ,vould be
grounds for the Insurance Commissioner to
seek
monetary penalties against Lib
re
in the amounts specified in the Cease
and
Desist Order;
3. Although Respondent previously submitted a Request for a Hearing in this matter,
and
such request has been stayed upon the motion
of
Libre, Libre hereby
wa
ives the right to a hearing, and all other rights which may
be
accorded pursuant to Chapter
5
Part
I
Division 3, Title 2 (Sections 15000-11528, inclusive)
of
the Government
Code
of
the State
of
Ca
lifornia, and by the
Ca
lifornia Insurance
Code
and those
rights stated in t
he
Cease and Desist Order;
I