November 4, 2019
BY FAX: (850) 488-3077
Chris Anderson
Executive Director
Florida Commission on Ethics
P.O. Box 15709
Tallahassee, Florida 32317-5709
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.
Rep. Plakon’s Business Empire
Rep. Plakon is a member of the Florida House of Representatives. He represented
District 37 from 2008 to 2012, and he has represented his current seat, District 29, since 2014. 1
Before entering politics, in 1997 Rep. Plakon founded Claims Pages, an “online reference source
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. 3
Rep. Plakon appears to have run Claims Pages through an entity called Nationwide
Publishing Company, Incorporated (“Nationwide, Inc.”), which he established in 1998. 4 Rep.
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. 5 The stake increased
1

https://scottplakon.com/about-scott/.
https://www.claimspages.com/about-us/.
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/mediacenter/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.
5
Rep. Scott Plakon, 2018 Full and Public Disclosure of Financial Interests, Form 6, filed July 1, 2019, available at
http://public.ethics.state.fl.us/Forms/2018/223307-Form6.pdf; Rep. Scott Plakon, 2017 Full and Public Disclosure of
2

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

 Chris Anderson
November 4, 2019
Page 2
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. 6 In 2018, Rep. Plakon appears to have transferred
control of the company to someone else, with a new name of Short Ride, LLC. 7 Rep. Plakon did
not list Claim Pages, LLC on his 2016 or 2017 financial disclosure forms. 8
Aslan Capital, LLC
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. 9
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. 10 In 2007, Aslan changed the manager
and authorized person from Rep. Plakon to High Country Management Company (“High
Country”), another name under which Nationwide, Inc. has done business. 11 In 2009, Aslan

Financial Interests, Form 6, filed June 20, 2018, available at http://public.ethics.state.fl.us/Forms/2017/223307Form6.pdf; Rep. Scott Plakon, 2016 Full and Public Disclosure of Financial Interests, Form 6, filed June 30, 2017,
available at http://public.ethics.state.fl.us/Forms/2016/223307-Form6.pdf; Rep. Scott Plakon, 2015 Full and Public
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/2014/223307Form6.pdf.
6
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.
7
2018 Annual Report, Claims Pages, LLC, Florida Secretary of State, filed Jan. 4, 2018, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=flal-l16000143606-6655250f-b74d4290-a49f-3ea070fe9e9f&transactionId=l16000143606-cb602a7f-2518-4075-ac06feab5c424334&formatType=PDF.
8
Rep. Scott Plakon, 2016 Full and Public Disclosure of Financial Interests, Form 6, filed June 30, 2017, available at
http://public.ethics.state.fl.us/Forms/2016/223307-Form6.pdf; Rep. Scott Plakon, 2017 Full and Public Disclosure of
Financial Interests, Form 6, filed June 20, 2018, available at http://public.ethics.state.fl.us/Forms/2017/223307Form6.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.
10
2006 Annual Report, Aslan Capital, LLC, Florida Secretary of State, filed Feb. 9, 2006, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2006%5C0209%5C2
0543542.tif&documentNumber=L05000019994.
11
2007 Annual Report, Aslan Capital, LLC, Florida Secretary of State, filed May 1, 2007, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2007%5C0504%5C4
0505384.tif&documentNumber=L05000019994.

 Chris Anderson
November 4, 2019
Page 3
changed the registered agent from Robert J. Hutchins to Shannon White, an employee of
Nationwide, Inc.12
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. 13 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
was the manager of Aslan, with no mention Nationwide, Inc. or High Country. 15
Aslan Capital’s Real Estate
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
d/b/a High Country Management Company managing member of Aslan Capital,
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. 16
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.
As a real estate company, Aslan has bought and sold many properties. Currently, Aslan
owns two properties in Volusia County: commercial buildings at 537 Deltona Blvd and 849

12

2009 Annual Report, Aslan Capital, LLC, Florida Secretary of State, filed Apr. 29, 2009, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2009%5C0430%5C5
3922066.tif&documentNumber=L05000019994; https://www.linkedin.com/in/shannon-pomiber-white-3356589b/.
13
2018 Annual Report, Aslan Capital, LLC, Florida Secretary of State, filed Feb. 17, 2018, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=flal-l05000019994-9a421358-2a314644-906e-9f9130505d0b&transactionId=l05000019994-53678e63-4374-4098-a3e85e599440a6e9&formatType=PDF.
14
2019 Annual Report, Aslan Capital, LLC, Florida Secretary of State, filed Apr. 8, 2019, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=flal-l05000019994-9a421358-2a314644-906e-9f9130505d0b&transactionId=l05000019994-abd96df5-8dab-4782-aca6b4bbaf8bf944&formatType=PDF.
15
Affidavit, Scott Plakon, Seminole County Clerk of the Circuit Court & Comptroller, filed May 15, 2019, available
at https://www.documentcloud.org/documents/6497877-Affidavit-Seminole-County-Aslan-Capital-5-15-19.html.
16
Company Affidavit, Aslan Capital, LLC, Volusia County Clerk of the Circuit Court, filed May 2, 2017, available
at https://www.documentcloud.org/documents/6506513-Company-Affidavit-Unit-305-Aslan-Capital-2017.html.

 Chris Anderson
November 4, 2019
Page 4
Deltona Blvd.17 The 537 building served as an office for Nationwide, Inc. while it operated
Claims Pages.18 According to property records, in 2002 Nationwide, Inc. purchased the property
directly.19 In 2005, Nationwide, Inc. signed the deed over to Aslan, which still owns the
property.20 In 2018, Aslan installed a new roof on the building. 21 Currently, the building is
available for lease or sale.22 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. 23
The taxable value of the property is $349,825. 24
The other property, 849 Deltona Blvd, has a taxable value of $128,617 and appears to
have two commercial tenants, one of which is the district office for Florida State Rep. David
Santiago.25
Aslan also owns a building in Lake County, Florida. In 1999, Rep. Plakon and his thenwife Suzanne Plakon, purchased a property in Tavares, Florida for $68,200. 26 In 2002, they
signed the deed over to Nationwide, Inc., which, in turn, sold the property to Aslan for $120,000
in 2005.27 This building appears to have operated as an office for Claims Pages. Signs for
Claims Pages can be seen on the property in the most up to date version of Google Earth. 28 Aslan
still owns the property, and the current taxable value is $179,377. 29
While these are the only properties currently owned by Aslan in Volusia or the
surrounding counties, the company has previously owned several other properties. In 2006,

17

Property Records Search, Aslan Capital, Volusia County Property Appraiser, accessed at
https://vcpa.vcgov.org/searches.html.
18
https://www.bbb.org/us/fl/deltona/profile/publishers-directory/nationwide-publishing-company-llc-0733-4002154.
19
Deed, 537 Deltona Blvd, Nationwide Publishing Company, Inc., Volusia County Clerk of the Circuit Court, filed
Oct. 4, 2002, available at https://www.documentcloud.org/documents/6498185-Nationwide-Inc-537-Deltona-BlvdDeed-Sept-30-2002.html.
20
Deed, 537 Deltona Blvd, Aslan Capital, LLC, Volusia County Clerk of the Circuit Court, filed March 5, 2005,
available at https://www.documentcloud.org/documents/6498198-Aslan-Capital-Deed-537-Deltona-Blvd2005.html.
21
Notice of Commencement, 537 Deltona Blvd, Aslan Capital, LLC, Volusia County Clerk of the Circuit Court,
filed Oct. 15, 2018, available at https://www.documentcloud.org/documents/6498205-Notice-of-Commeccement537-Deltona-Blvd-Aslan.html.
22
https://www.xome.com/commercial-for-sale/537-Deltona-Boulevard-Deltona-FL-32725-291750412;
https://www.officespace.com/fl/deltona/2028922-537-deltona-blvd.
23
http://www.remaxcommercial.com/?p=findahome.asp&listing=true&mlsid=958&mlsnumber=506677388.
24
Final Tax Roll Values, 537 Deltona Blvd, Aslan Capital, LLC, Volusia County Property Appraiser, accessed at
https://vcpa.vcgov.org/searches.html.
25
https://public.lobbytools.com/legislators/550; Final Tax Roll Values, 849 Deltona Blvd, Aslan Capital, LLC,
Volusia County Property Appraiser, accessed at https://vcpa.vcgov.org/searches.html.
26
Property Record Card, 228 Main Street, Aslan Capital, LLC, Lake County Property Appraiser, accessed at
https://www.lakecopropappr.com/property-details.aspx?AltKey=3784680.
27
Id.
28
https://goo.gl/maps/L68yzWKGk8eUPafSA.
29
Property Record Card, 228 Main Street, Aslan Capital, LLC, Lake County Property Appraiser, accessed at
https://www.lakecopropappr.com/property-details.aspx?AltKey=3784680.

 Chris Anderson
November 4, 2019
Page 5
Aslan bought a single-family home in Sanford, Florida for $205,100. 30 Aslan sold the house in
2019 for $195,000, and Rep. Plakon signed the paperwork on behalf of Aslan. 31
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. 32
Rep. Plakon’s apparent farther or uncle, Ronald Plakon, 33 and his wife, Camille Plakon, had
purchased a different unit in the same building one month earlier. 34 Nationwide sold unit 806
less than a year later to Aslan for $505,000. 35 Aslan held the property until 2017, selling it at a
loss, for $415,000.36 Rep. Plakon signed the paperwork for the sale on behalf of Aslan. 37
In 2008, Aslan, along with Ronald Plakon and Robert Plakon, purchased unit 305 in the
same building for $350,200.38 In 2012, Robert Plakon deeded the property over to Ronald
Plakon and Aslan.39 In 2017, Aslan and Ronald Plakon sold the property for $409,000. 40 Rep.
Plakon signed the paperwork on behalf of Aslan. 41 Rep. Plakon disclosed a liability to Ronald
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.42

30

Parcel Information, 409 W Crystal Dr, Shane Ritenour, Seminole County Property Appraiser, available at
https://parceldetails.scpafl.org/ParcelDetailInfo.aspx?PID=04203050602000010.
31
Indenture, 409 W Crystal Dr, Aslan Capital, LLC, Seminole County Clerk of the Circuit Court, filed May 15,
2019, available at https://recording.seminoleclerk.org/DuProcessWebInquiry/?book=9355&page=233.
32
Deed, Unit 806, 2055 S Atlantic Ave, Nationwide Publishing Company, Inc., Volusia County Clerk of the Circuit
Court, filed Aug. 6, 2004, available at https://www.documentcloud.org/documents/6498425-Deed-Unit-806Nationwide-2004.html.
33
https://voterrecords.com/voter/19401990/ronald-plakon.
34
Deed, Unit 205, 2055 S Atlantic Ave, Ronald Plakon and Camille Plakon, Volusia County Clerk of the Circuit
Court, filed July 1, 2004, available at https://www.documentcloud.org/documents/6506137-Deed-Unit-205-RonaldPlakon-2004.html.
35
Indenture, Unit 806, 2055 S Atlantic Ave, Aslan Capital, LLC, Volusia County Clerk of the Circuit Court, filed
March 5, 2005, available at https://www.documentcloud.org/documents/6506143-Indenture-Deed-Unit-806-Aslan2005.html.
36
Deed, Unit 806, 2055 S Atlantic Ave, Liliana Otero Arce and Richard Arce, Volusia County Clerk of the Circuit
Court, filed Dec. 28, 2017, available at https://www.documentcloud.org/documents/6506440-Deed-Unit-806-AslanSale-2017.html.
37
Id.
38
Certificate of Title, Unit 305, 2055 S Atlantic Ave, Aslan Capital, LLC and Ronald Plakon and Robert Plakon,
Volusia County Clerk of the Circuit Court, filed July 10, 2008, available at
https://www.documentcloud.org/documents/6506441-Certificate-of-Title-Unit-305-Aslan-Plakons-2008.html.
39
Quit Claim Deed, Unit 305, 2055 S Atlantic Ave, Aslan Capital, LLC and Ronald Plakon, Volusia County Clerk
of the Circuit Court, filed May 25, 2012, available at https://www.documentcloud.org/documents/6506444-QuitClaim-Deed-Unit-305-Aslan-Plakon-2012.html.
40
General Warranty Deed, Unit 305, 2055 S Atlantic Ave, Karen M. D’Anniballe, Volusia County Clerk of the
Circuit Court, filed May 2, 2017, available at https://www.documentcloud.org/documents/6506445-GeneralWarranty-Deed-Unit-305-Aslan-2017.html.
41
Id.
42
Rep. Scott Plakon, 2018 Full and Public Disclosure of Financial Interests, Form 6, filed July 1, 2019, available at
http://public.ethics.state.fl.us/Forms/2018/223307-Form6.pdf; Rep. Scott Plakon, 2017 Full and Public Disclosure of
Financial Interests, Form 6, filed June 20, 2018, available at http://public.ethics.state.fl.us/Forms/2017/223307Form6.pdf.

 Chris Anderson
November 4, 2019
Page 6
Lake Helen Holdings, LLC
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
In 2013, Rep. Plakon filed an affidavit with the Volusia County, Clerk of Court stating:
[H]e is the President of Nationwide Publishing Company, Incorporated, a Florida
corporation, d/b/a High Country Management Company, the sole Manager of
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
authorized person.46 By then, 186 Industrial Center Drive was valued at $934,700. 47 In 2013,
Lake Helen Holdings took out a $405,610.58 mortgage from Aslan Capital. 48 In 2017, after Mr.
Wolle took over, Lake Helen Holdings transferred the mortgage to a bank. 49 At no time has Rep.
Plakon ever listed Lake Helen Holdings or 186 Industrial Center Drive on his financial
disclosure forms.
Trilemma-3 Holdings, LLC
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

43

Articles of Organization, Lake Helen Holdings, LLC, Florida Secretary of State, filed June 22, 2009, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2009%5C0626%5C5
7529171.Tif&documentNumber=L09000060505.
44
Property Information, 186 Industrial Center Dr., Volusia County Property Appraiser, accessed at
http://vcpa.vcgov.org/searches.html.
45
Affidavit, D. Scott Plakon, Volusia County Clerk of the Circuit Court, filed Nov. 26, 2013, available at
https://www.documentcloud.org/documents/6506478-Affidavit-Lake-Helen-Holdings-186-Industrial.html.
46
2017 Annual Report, Lake Helen Holdings, LLC, Florida Secretary of State, filed Apr. 25, 2017, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=flal-l09000060505-3b6601dd-03c4421c-8804-831033d5da89&transactionId=l09000060505-68007e71-fc6d-4d19-985c48128100ff60&formatType=PDF.
47
Property Information, 186 Industrial Center Dr., Volusia County Property Appraiser, accessed at
http://vcpa.vcgov.org/searches.html.
48
Mortgage, 186 Industrial Center Dr., Lake Helen Holdings, LLC, Volusia County Clerk of the Circuit Court, filed
Nov. 26, 2013, available at https://www.documentcloud.org/documents/6506479-Mortage-Aslan-Lake-HelenHoldings-186-Industrial.html.
49
Mortgage, 186 Industrial Center Dr., Lake Helen Holdings, LLC, Volusia County Clerk of the Circuit Court, filed
May 22, 2017, available at https://www.documentcloud.org/documents/6506480-Mortgage-186-Industrial-DriveLake-Helen-New.html.

 Chris Anderson
November 4, 2019
Page 7
was managed by High Country Management Company and Ms. White. 50 According to its annual
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
2014.51 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. 52
Nationwide Publishing Company, LLC
In 2006 Rep. Plakon set up another LLC, Nationwide Publishing Company, LLC
(“Nationwide, LLC”), the name of which mirrored the name of his main source of income:
Nationwide Publishing Company, Incorporated. 53 Nationwide, LLC was also managed by High
Country Management Company and Ms. White out of the 537 Deltona Blvd address. 54 Rep.
Plakon failed to file the 2019 annual report for Nationwide, LLC with the Florida Department of
State, and it has been administratively dissolved.55
ShredPro Secure Florida LLC
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.
Plakon filed Articles of Organization for ShredPro Secure Florida, LLC (“ShredPro”) on
50

Articles of Organization, Trilemma-3 Holdings, LLC, Florida Secretary of State, filed Dec. 20, 2006, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2006%5C1226%5C
H0298871.Tif&documentNumber=L06000121112.
51
2011 Annual Report, Trilemma-3 Holdings, LLC, Florida Secretary of State, filed Apr. 29, 2011, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2011%5C0430%5C0
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-l06000121112-6056b9a4-20204860-80c8-58e94e5a7edc&transactionId=l06000121112-d90ee497-2db1-4280-845ec36de5db264f&formatType=PDF.
52
2018 Annual Report, Trilemma-3 Holdings, LLC, Florida Secretary of State, filed Feb. 17, 2018, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=flal-l06000121112-6056b9a4-20204860-80c8-58e94e5a7edc&transactionId=l06000121112-f0f08f43-d969-47bd-80c514c279f9c771&formatType=PDF; 2019 Annual Report, Trilemma-3 Holdings, LLC, Florida Secretary of State,
filed Apr. 27, 2019, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=flal-l06000121112-6056b9a4-20204860-80c8-58e94e5a7edc&transactionId=l06000121112-100ffdfc-5b0d-433a-92f6312aa168333d&formatType=PDF.
53
Articles of Organization, Nationwide Publishing Company, LLC, Florida Secretary of State, filed Dec. 18, 2006,
available at
http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2006%5C1221%5C
H0296741.Tif&documentNumber=L06000119933.
54
Id.
55
Entity Information, Nationwide Publishing Company, LLC, Florida Secretary of State, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=EntityName&directionType=In
itial&searchNameOrder=NATIONWIDEPUBLISHING%20L060001199330&aggregateId=flal-l060001199339c5a4e80-ed0b-4f42-b737a36c9f7128b4&searchTerm=nationwide%20publishing&listNameOrder=NATIONWIDEPUBLISHING%20K7862
50.

 Chris Anderson
November 4, 2019
Page 8
November 27, 2017.56 He is listed as the authorized person and registered agent for the
company, and initially listed a business address of 537 Deltona Blvd. 57 In 2018, Rep. Plakon
filed an updated Articles of Organization and switched the address for the company to his home
address.58 In 2019, he filed an annual report that updated the address to his new home address. 59
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
serve on the Florida Alzheimer’s Disease Advisory Committee.60 A press release announcing
the appointment noted that Rep. Plakon was the CEO of ShredPro. 61 A few months later, in
October 2018, the Orlando Sentinel published an article about Rep. Plakon’s reelection
campaign, referring to him as the “chief executive officer of Shred Pro Secure LLC [sic], based
in Sanford.”62
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.64
Plakon Investments, LLC
More recently, on April 25, 2019, Rep. Plakon filed Articles of Organization for another
company called Plakon Investments, LLC for which he is the authorized person and registered

56

Articles of Organization, ShredPro Secure Florida, LLC, Florida Secretary of State, filed Nov. 27, 2017, available
at
http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2017%5C1127%5C3
0040913.tif&documentNumber=L17000242182.
57
Id.
58
Articles of Amendment to Articles of Organization, ShredPro Secure Florida, LLC, Florida Secretary of State,
filed Feb. 17, 2018, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2018%5C0220%5C0
0055401.Tif&documentNumber=L17000242182.
59
2019 Annual Report, ShredPro Secure Florida, LLC, Florida Secretary of State, filed Apr. 27, 2019, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=flal-l17000242182-8fd987d4-40804501-8c0d-dacf72f7c012&transactionId=l17000242182-901c8485-f2a2-44d4-bde07fb99978e713&formatType=PDF.
60
Jacob Ogles, Governor Taps Scott Plakon for Alzheimer’s Disease Advisory Committee, Florida Politics, July 29,
2018, available at https://floridapolitics.com/archives/270129-rick-scott-names-scott-plakon-to-alzheimers-diseaseadvisory-committee.
61
Id.; Press Release, Gov. Scott Appoints State Rep. Plakon to Alzheimer’s Disease Advisory Committee, Governor
of Florida, July 28, 2018 (Nexis).
62
Martin E. Comas, Florida House District 29: Where Scott Plakon and Tracey Kagan Stand on the Issues, Orlando
Sentinel, Oct. 3, 2018, available at https://www.orlandosentinel.com/news/seminole-county/os-ne-general-electionhouse-district-29-story.html.
63
Press Release, NAI Realvest Closes Eight Industrial Leases in 60 Days at Sanford’s Monroe Commerce Center
South, NAI Realvest, Apr. 25, 2018, available at https://www.thenewsfunnel.com/press-release/nai-realvest-closeseight-industrial-leases-60-days-sanfords-monroe-commerce-center.
64
Id.

 Chris Anderson
November 4, 2019
Page 9
agent and which uses his home address. 65 On June 17, 2019, Plakon Investments purchased a
house in Orange City, Florida for $74,700. 66 Two months later, Rep. Plakon personally filed a
notice of commencement regarding a roof replacement for the property. 67
Campaign Payments to Businesses
Since 2014, Rep. Plakon’s campaign committee has paid his businesses and employees of
his businesses more than $35,000.68 The campaign committee paid Aslan Capital $10,275,
including a 2018 payment of $4,000 to lease space at 631 Progress Way, the location of Rep.
Plakon’s other business, ShredPro Secure Florida, LLC. 69
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. 70
Rep. Plakon’s campaign paid Nationwide, Inc., Nationwide, LLC, Lake Helen Holdings,
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. 71 The form requires legislators to disclose all
assets and liabilities in excess of $1,000 and “[i]dentify each separate source and amount of
65

Articles of Organization, Plakon Investments, LLC, Florida Secretary of State, filed Apr. 25, 2019, available at
http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2019%5C0501%5C0
0125591.Tif&documentNumber=L19000108395.
66
Property Information, 227 E Fern Drive, Plakon Investments, LLC, Volusia County Property Appraiser, accessed
at http://vcpa.vcgov.org/searches.html.
67
Notice of Commencement, 227 E Fern Drive, Plakon Investments, LLC, Volusia County Clerk of the Circuit
Court, filed Aug. 26, 2019, available at https://www.documentcloud.org/documents/6506489-Notice-ofCommencement-227-E-Fern-Drive-Plakon.html.
68
Between 2007 and 2013, in support of his previous legislative stint, Rep. Plakon’s campaign account paid his
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/campaignfinance/expenditures/.
69
Id.; Press Release, NAI Realvest Closes Eight Industrial Leases in 60 Days at Sanford’s Monroe Commerce
Center South, NAI Realvest, Apr. 25, 2018, available at https://www.thenewsfunnel.com/press-release/nai-realvestcloses-eight-industrial-leases-60-days-sanfords-monroe-commerce-center.
70
Expenditure Records, Scott Plakon, Florida Secretary of State, Division of Elections, accessed at
https://dos.elections.myflorida.com/campaign-finance/expenditures/; https://www.linkedin.com/in/shannonpomiber-white-3356589b/.
71
Art. II § 8(a), Fla. Const; Full and Public Disclosure of Financial Interests, Form 6, available at
http://www.ethics.state.fl.us/Documents/Forms/Form%206_2018i.pdf?cp=2019107.

 Chris Anderson
November 4, 2019
Page 10
income which exceeded $1,000 during the year, including secondary sources of income.” 72
Members of the State Legislature can opt to file their annual federal tax returns in lieu of
completing the income section of the form.
The instructions for Form 6 detail the many assets, liabilities, and income members must
disclose. Generally, the form instructs a member to disclose any asset or liability of more than
$1,000. The asset section states that:
Assets include, but are not limited to, things like interests in real property; cash;
stocks; bonds; certificates of deposit; interests in businesses; beneficial interests in
trusts; money owed you; bank accounts; Deferred Retirement Option Program
(DROP) accounts; and the Florida Prepaid College Plan. Assets also include
investment products held in IRAs, brokerage accounts, and the Florida College
Investment Plan.73
The income section states:
Examples of income include: compensation for services, gross income from
business, gains from property dealings, interest, rents, dividends, pensions, IRA
distributions, distributive share of partnership gross income, and alimony, but not
child support. Where income is derived from a business activity you should
report the income to you, as calculated for income tax purposes, rather than the
income to the business.74
In addition, Article II, Section 8 of the Florida Constitution and Florida Statute 112.3144 both
require public officials, including state legislators, to “file full and public disclosure of their
financial interests,” but the law does not define “financial interests”.
Additionally, the Guide to the Sunshine Amendment and Code of Ethics for Public
Officers and Employees (“Guide”) instructs public officials to disclose their financial positions:
Conflicts of interest may occur when public officials are in a position to make
decisions that affect their personal financial interests. This is why public officers
and employees, as well as candidates who run for public office, are required to
publicly disclose their financial interests. The disclosure process serves to remind
officials of their obligation to put the public interest above personal
considerations. It also helps citizens to monitor the considerations of those who
spend their tax dollars and participate in public policy decisions or
administration.75

72

Id.
Id.
74
Id.
75
Guide to the Sunshine Amendment and Code of Ethics for Public Officers and Employees, Florida Commission
on Ethics, 2019, available at http://www.ethics.state.fl.us/Documents/Publications/GuideBookletInternet.pdf.
73

 Chris Anderson
November 4, 2019
Page 11
Commission Rule 34-8.005 states:
(1)

The form for disclosure of income sources shall provide for the disclosure
of the name and address of each source of income which exceeds $1,000
received by the officer or candidate or by any person for the officer’s or
candidate’s benefit and use during the previous tax year. The form also
shall provide for disclosure of the amount of income received from each
source and shall provide for the officer’s or candidate’s oath verifying the
information contained in the completed form.

(2)

A “secondary source of income” shall mean any one customer, client or
other source of income which provides in excess of 10% of the total
income of a business entity, as shown on that business entity’s most
recently filed income tax return, during the previous tax year in which a
person subject to full and public disclosure of financial interests own in
excess of five percent (5%) of the business entity’s total assets or capital
stock and from which such person derived in excess of $1,000 income
during the previous tax year.

Advisory opinions released by the Commission affirm this rule by instructing Form 6
filers to disclose as much about their financial interest as possible. 76 For instance, Opinion CEO
85-70 states:
Under Commission on Ethics Rule 34-8.05, F.A.C., if you own more than five
percent of a business entity's total assets or capital stock and derived more than
$1,000 of income from that business entity during the disclosure period, you are
required to disclose all customers, clients, or other sources of income to that
business entity which provided more than ten percent of the total income of the
business. Therefore, assuming that you own more than five percent of your
companies and receive more than $1,000 of income per year from them, you will
be required to disclose the name of each association and employer which provides
more than ten percent of the total income of each company. 77
Rep. Plakon’s Financial Disclosures
Rather than submitting his income tax returns, Rep. Plakon has filed an annual financial
disclosure Form 6 covering every calendar year from 2014 to 2018. 78 He has never filled out
76

http://www.ethics.state.fl.us/Documents/Ethics/Form%206%20Financial%20Disclosure%20Opinions.html.
CEO 85-70, Florida Commission on Ethics, Oct. 3, 1985, available at
http://www.ethics.state.fl.us/Documents/Opinions/85/CEO%2085-070.htm.
78
Rep. Scott Plakon, 2018 Full and Public Disclosure of Financial Interests, Form 6, filed July 1, 2019, available at
http://public.ethics.state.fl.us/Forms/2018/223307-Form6.pdf; Rep. Scott Plakon, 2017 Full and Public Disclosure of
Financial Interests, Form 6, filed June 20, 2018, available at http://public.ethics.state.fl.us/Forms/2017/223307Form6.pdf; Rep. Scott Plakon, 2016 Full and Public Disclosure of Financial Interests, Form 6, filed June 30, 2017,
available at http://public.ethics.state.fl.us/Forms/2016/223307-Form6.pdf; Rep. Scott Plakon, 2015 Full and Public
Disclosure of Financial Interests, Form 6, filed June 13, 2016, available at
77

 Chris Anderson
November 4, 2019
Page 12
each section of the financial disclosure form, instead submitting an attachment to each year’s
form that lists his assets and liabilities. The only sources of income Rep. Plakon has reported are
from Nationwide, Inc. and the Florida House of Representatives.
By failing to report income from all of his various entities, Rep. Plakon appears to have
violated Florida law. As the Commission’s Opinion 85-70 makes clear, if a business’s
subsidiaries constitute a certain threshold of the primary business’s income, then they must be
disclosed. As a result, even if Rep. Plakon views Aslan and Lake Helen Holdings as subsidiaries
of Nationwide, Inc., the amount of property they have owned suggests their assets should have
been disclosed, constituting a high percentage of Nationwide, Inc.’s revenue.
Additionally, Rep. Plakon’s 2018 financial disclosure doesn’t list any income from
Nationwide, Inc. indicating he may no longer be using it to control the other entities giving him
no excuse for failing to disclose income from those entities. Further, Rep. Plakon should have
disclosed his financial interests in ShredPro Secure Florida, LLC, which appears to be unrelated
to Nationwide, Inc.
2018 Financial Disclosure
In 2018, Rep. Plakon may have inaccurately omitted Aslan Capital, LLC, ShredPro
Secure Florida, LLC, and Trilemma-3 Holdings, LLC from his financial disclosure. 79 At the end
of 2018, Aslan owned three properties that today are worth a combined taxable value of
$657,819. Additionally, Aslan owned a single-family house throughout 2018, which it sold for
$195,000 in 2019. Also, in 2018, Aslan received a $4,000 payment from Rep. Plakon’s
campaign committee. These records indicate Aslan had more than $1,000 worth of economic
activity in 2018 and seemingly should have been disclosed on Rep. Plakon’s financial disclosure.
Two of Rep. Plakon’s other businesses also appear to have generated more than $1,000 in
financial activity in 2018. ShredPro signed a lease in 2018 for 2,000 square feet of commercial
space. Presumably, the company has a liability for the lease, and it had enough money in its
bank account to pay for the lease, indicating it should either be counted as an asset or a liability.
While no information is available about Trilemma-3 Holdings, LLC, it may also have been
active and, if so, should have appeared on Rep. Plakon’s financial disclosures.
2017 Financial Disclosure
In 2017, Rep. Plakon may have inaccurately omitted Aslan Capital, LLC, Lake Helen
Holdings, LLC, Claims Pages, LLC, Nationwide, LLC, and Trilemma-3 Holdings, LLC from his
financial disclosure.80 As in 2018, Aslan owned the four properties mentioned above throughout
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/2014/223307Form6.pdf.
79
Rep. Scott Plakon, 2018 Full and Public Disclosure of Financial Interests, Form 6, filed July 1, 2019, available at
http://public.ethics.state.fl.us/Forms/2018/223307-Form6.pdf.
80
Rep. Scott Plakon, 2017 Full and Public Disclosure of Financial Interests, Form 6, filed June 20, 2018, available
at http://public.ethics.state.fl.us/Forms/2017/223307-Form6.pdf.

 Chris Anderson
November 4, 2019
Page 13
2017. Aslan also sold two condominiums in 2017 for a combined value of $824,000, which
presumably should have been disclosed as income.
Lake Helen Holdings, LLC appears to have been sold at some point in 2017, which
presumably would have resulted in income for Rep. Plakon. During the year the apparent sale
took place, the company owned a property that was worth approximately $934,700.
Additionally, on January 4, 2017, Rep. Plakon’s campaign committee paid $1,200 to Lake Helen
Holdings for storage.
Rep. Plakon controlled Claims Pages, LLC throughout 2017, but it was not disclosed on
his financial disclosure. Additionally, Rep. Plakon controlled Nationwide, LLC throughout
2017, and Rep. Plakon’s campaign committee paid $500 to Nationwide, LLC on January 4,
2017. Finally, while no information is available about Trilemma-3 Holdings, LLC, it may also
have been active and, if so, should have appeared on Rep. Plakon’s financial disclosure.
2016 Financial Disclosure
In 2016, Rep. Plakon may have inaccurately omitted Aslan Capital, LLC, Lake Helen
Holdings, LLC, Claims Pages, LLC, Nationwide, LLC and Trilemma-3 Holdings, LLC from his
financial disclosure.81 In 2016, Aslan owned the four properties and two condominiums detailed
above. In 2016, Lake Helen Holdings was controlled by Rep. Plakon, and it owned the property
detailed above.
Rep. Plakon controlled Claims Pages, LLC and Nationwide, LLC throughout 2016, but
they were not disclosed on his financial disclosure. While no information is available about
Trilemma-3 Holdings, LLC, it may also have been active and, if so, should have appeared on
Rep. Plakon’s financial disclosures.
2015 Financial Disclosure
In 2015, Rep. Plakon may have inaccurately omitted Aslan Capital, LLC, Lake Helen
Holdings, LLC, Nationwide, LLC and Trilemma-3 Holdings, LLC from his financial
disclosure.82 In 2015, Aslan owned the four properties and two condominiums detailed above.
Additionally, Rep. Plakon’s campaign committee paid $3,350 to Aslan in 2015.
In 2015, Lake Helen Holdings was controlled by Rep. Plakon and owned the property
detailed above. In 2015, Rep. Plakon controlled Nationwide, LLC, and Rep. Plakon’s campaign
committee paid Nationwide, LLC $1,875 on January 30, 2015. While no information is
available about Trilemma-3 Holdings, LLC, it may also have been active and, if so, should have
appeared on Rep. Plakon’s financial disclosures.

81

Rep. Scott Plakon, 2016 Full and Public Disclosure of Financial Interests, Form 6, filed June 30, 2017, available
at http://public.ethics.state.fl.us/Forms/2016/223307-Form6.pdf.
82
Rep. Scott Plakon, 2015 Full and Public Disclosure of Financial Interests, Form 6, filed June 13, 2016, available
at http://public.ethics.state.fl.us/Forms/2015/223307-Form6.pdf.

 Chris Anderson
November 4, 2019
Page 14
2014 Financial Disclosure
In 2014, Rep. Plakon may have inaccurately omitted Aslan Capital, LLC, Lake Helen
Holdings, LLC, Nationwide, LLC and Trilemma-3 Holdings, LLC from his financial
disclosure.83 In 2014, Aslan owned the four properties and two condominiums detailed above.
Additionally, Rep. Plakon’s campaign committee paid $2,925 to Aslan in 2014. In 2014, Lake
Helen Holdings was controlled by Rep. Plakon and owned the property detailed above.
In 2014, Rep. Plakon controlled Nationwide, LLC, and Rep. Plakon’s campaign
committee paid Nationwide, LLC $17,608.58 throughout the year. While no information is
available about Trilemma-3 Holdings, LLC, it may also have been active and, if so, should have
appeared on Rep. Plakon’s financial disclosures.
Penalties
Florida law provides steep penalties for anyone who is found to have violated the Code of
Ethics including impeachment, removal or suspension from office, public censure or reprimand,
forfeiture of salary, fines of up to $10,000, and restitution of any pecuniary benefit. 84
Conclusion
Financial disclosures exist to inform the public about a government official’s financial
situation so that voters and the public can judge for themselves whether a member is acting in the
interest of the public. Rep. Plakon’s failure to disclose details about his extensive business
empire deprives the public of that knowledge.
The Commission should immediately open an investigation into these matters to
determine whether Rep. Plakon violated the law.
Sincerely,

Daniel E. Stevens
Executive Director

83

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.
84
Fla. Stat. 112.317(1).