NO. D-1-GV THE STATE OF TEXAS IN THE DISTRICT COURT OF VS. TRAVIS COUNTY, TEXAS

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1 NO. D-1-GV THE STATE OF TEXAS IN THE DISTRICT COURT OF VS. TRAVIS COUNTY, TEXAS UNIVERSAL INSURANCE EXCHANGE and UNIVERSAL PARATRANSIT INSURANCE SERVICE, CORP. 345TH JUDICIAL DISTRICT APPLICATION TO APPROVE NOTICE AND SET CLAIM FILING DEADLINE COMES NOW, DKJ Group, Inc., Special Deputy Receiver of Universal Insurance Exchange (UIE) and Universal Paratransit Insurance Services, Corp. (Paratransit), and files this Application to Approve Notice and Set Claim Filing Deadline and in support would respectfully show the Court as follows: I. INTRODUCTION 1.1 The Special Deputy Receiver (SDR) requests approval of: (a) a procedure to provide notice of the liquidation of UIE and Paratransit; (b) the deadline by which all claims must be filed (Claims Filing Deadline); and (c) the form of the proof of claim (POC). II. BACKGROUND 2.1 On January 26, 2006, this Court entered its Agreed Order Appointing Rehabilitator and Permanent Injunction placing UIE and Paratransit in rehabilitation and appointing the Texas Commissioner of Insurance as Rehabilitator of UIE and Paratransit (Receivership Date). On April 13, 2006, the Rehabilitator designated H. Koehler Company, Inc. as the SDR. On December 20, 2007, the Rehabilitator designated DKJ Group, Inc., as the successor SDR. 9/21/2015 2:54:31 PM Velva L. Price District Clerk Travis County D-1-GV Jonathan Sanders

2 2.3 On July 2, 2007, this Court entered its Agreed Order Approving Plan of Rehabilitation for UIE and Paratransit. 2.4 On June 30, 2009, this Court entered its Order Approving Application for Order Approving Run-Off Plan (Run-Off Order). The order was appealed and on August 5, 2010 the Court of Appeals affirmed the Run-Off Order. 2.5 As provided in the Run-Off Order, UIE ceased renewing or writing new policies and processed policy claims on the insurance already underwritten, in the normal course of the policy run-off. 2.6 On June 10, 2015, this Court entered its Order Appointing Liquidator and Permanent Injunction. The order terminated the rehabilitation and placed UIE and Paratransit into liquidation (Liquidation Date). 2.7 UIE has not been determined to be insolvent, and the Commissioner of Insurance has not designated UIE an impaired insurer. If this Court subsequently finds UIE to be insolvent and the Commissioner of Insurance designates UIE an impaired insurer, the Texas Property and Casualty Insurance Guaranty Association (TPCIGA) will be responsible for statutorily-defined covered claims as set forth in TEX. INS. CODE Chapter 462. III. JURISDICTION AND AUTHORITY 3.1 This Court has exclusive jurisdiction over the subject matter of this Application pursuant to TEX. INS. CODE The SDR is authorized to file this Application pursuant to TEX. INS. CODE which provides for the notice of liquidation, and , which provides requirements for the filing of claims. 3400/Application to Approve Notice and Set Claim Filing Deadline Page 2 of 9

3 3.3 The subject matter of this Application has been referred to the Master appointed in this proceeding in accordance with Article III, Section 20 of the Order of Reference to Master entered by this Court on April 13, IV. STATUTORY REQUIREMENTS 4.1 TEX. INS. CODE specifies the categories of persons who must receive notice of liquidation, the means for providing the notice and the contents of the notice. Unless this Court otherwise directs, TEX. INS. CODE (a) requires that notice be given as follows: (a) By first class mail or electronic communication to: (i) (ii) (iii) any guaranty association that is or may become obligated as a result of the liquidation and any national association of guaranty associations; all the insurer s agents, brokers, or producers of record with current appointments or current licenses to represent the insurer, and all other agents, brokers, or producers as the liquidator deems appropriate at their last known address; all persons or entities known or reasonably expected to have claims against the insurer, at their last known address as indicated by the records of the insurer, and all state and federal agencies with an interest in the proceeding; and (b) By publication in a newspaper of general circulation in the county in which the insurer has its principal place of business and in any other locations as the Liquidator deems appropriate. 4.2 TEX. INS. CODE (b) provides that the notice must contain (or provide directions for obtaining) specified information. In summary, this information includes: (a) (b) (c) a statement that the insurer has been placed into liquidation; a statement that certain acts are stayed or enjoined; whether, and to what extent, the insurer s policies continue in effect; 3400/Application to Approve Notice and Set Claim Filing Deadline Page 3 of 9

4 (d) (e) (f) (g) (h) the coverage available by state insurance guaranty associations; the claims filing deadline, and requirements for filing a POC; the date, time, and location of any scheduled status hearings; the process for obtaining notice of matters before this Court; and any other information the SDR or this Court deems appropriate. The form of the notice that will be provided in accordance with TEX. INS. CODE (a) and (b) is attached as Exhibit A (Liquidation Notice). V. LIQUIDATION NOTICE 5.1 The SDR will provide the Liquidation Notice to the following parties: (a) Parties with Known Claims, and Parties Reasonably Expected to Have Claims: (i) Claimants with Policy and Contractual Losses To insureds, warranty, other contractual obligees, and third party claimants who reported claims that have not been resolved or for which payment was issued prior to the Liquidation Date but did not clear the estate s bank accounts prior to the Liquidation Date, any assignees or lienholders of record of such claims; and any counsel for such parties. (ii) Policyholders/Subscribers due Unearned Premium, Deductibles, Premium Deposits or Dividends To policyholders with claims for unearned premium, deductibles of premium deposits identified in UIE and Paratransit s books and records at the Receivership Date that have not been resolved or for which payment was issued prior to the Liquidation Date but did not clear the estate s bank accounts prior to the Liquidation Date. (iii) General Creditors To all vendors and service providers with unpaid invoices identified in UIE and Paratransit s books and records at the Receivership Date which remain unpaid as well as to those persons and entities as to whom payment was issued prior to the Liquidation Date but the payment did not clear the estate s bank accounts prior to the Liquidation Date. 3400/Application to Approve Notice and Set Claim Filing Deadline Page 4 of 9

5 (b) Governmental Agencies and Guaranty Associations: (i) (ii) (iii) (iv) (v) (vi) TPCIGA; National Conference of Insurance Guaranty Funds; Internal Revenue Service; United States Department of Justice; Centers for Medicare and Medicaid Services; and Texas Comptroller of Public Accounts. (c) Other Parties: (i) (ii) (iii) (iv) (v) Agents, brokers, or producers for which payment was issued prior to the Liquidation Date but did not clear the estate s bank accounts prior to the Liquidation Date; Paratransit s former owner, officers, directors and employees; Financial institutions which held UIE and Paratransit accounts; Reinsurers of UIE; and Any other parties who request, in writing, an opportunity to file a claim. 5.2 The SDR proposes to give notice of the liquidation and Claims Filing Deadline to the parties identified in Paragraph 5.1 by first class mail or . The SDR will provide notice to the parties at their last known address as shown by UIE or Paratransit s records available to the SDR, or any forwarding address provided to the SDR. 5.3 The SDR requests that this Court approve the procedure of notice and the categories of recipients as described above. 5.4 Unless otherwise permitted by this Court, TEX. INS. CODE (a)(2) requires notice by publication in a newspaper of general circulation in the county of UIE and Paratransit s principal place of business, and other locations as the SDR deems appropriate. The SDR proposes to publish a notice providing information about the claims filing process, guaranty association coverage and other matters regarding the receivership (Publication Notice). The Publication Notice will appear at least once in newspapers of general circulation in Dallas County, Texas, being the location of UIE and Paratransit s principal place of business, and in 3400/Application to Approve Notice and Set Claim Filing Deadline Page 5 of 9

6 Houston, Texas where UIE issued a substantial number of policies. Pursuant to TEX. INS. CODE (d) such notice by publication is sufficient notice to a person, if the person s address is not found in UIE or Paratransit s records or if a mailing to the person s address shown in UIE or Paratransit s records is returned as undeliverable. The SDR requests this Court approve the Publication Notice attached as Exhibit B, or a form that is substantially similar. 5.5 In order to facilitate communication with claimants and other persons, the SDR proposes to post all notices, claims filing information, POC forms, and other relevant information on the SDR s website at Links to the SDR s website are posted on the Texas Department of Insurance website. 5.6 TEX. INS. CODE requires that a POC be in a form designated by the SDR, and TEX. INS. CODE , contains requirements for the form of the POC. The SDR proposes to use the POC form attached to this Application as Exhibit C. The SDR requests this Court to approve the POC form attached as Exhibit C, or a form that is substantially similar. VI. CLAIMS 6.1 In accordance with TEX. INS. CODE , the SDR requests that this Court set a Claims Filing Deadline of February 12, 2016, requiring that all POCs be received at the address designated by the SDR on or before 11:59 p.m. C.S.T. on that date. 6.2 UIE is only licensed in the state of Texas. As UIE has not been determined to be insolvent and has not been designated an impaired insurer, TPCIGA s obligation to pay covered claims has not been triggered. If TPCIGA is subsequently triggered and if the SDR receives a POC that may have a covered claim, it will refer such claim to TPCIGA. 6.3 The SDR will process all POCs in accordance with TEX. INS. CODE and the order of this Court. 3400/Application to Approve Notice and Set Claim Filing Deadline Page 6 of 9

7 6.4 TEX. INS. CODE (b) authorizes the SDR to treat a late POC as if it was not filed late under certain circumstances. If a claimant meets those qualifications, the SDR will require an affidavit to verify the claimant s eligibility. Any POCs filed after the Claims Filing Deadline that do not qualify under TEX. INS. CODE (b) will be classified as Class 8 claims under TEX. INS. CODE (h). 6.5 In accordance with TEX. INS. CODE (h), by filing a POC, a claimant asserting a third-party claim against a policyholder of UIE, shall be deemed to have released and waived such claim up to the amount of policy limits of the insured s policy. The POC forms attached as Exhibit C contain the notice of this election of remedies as required by TEX. INS. CODE (h)(4). VII. NOTICE 7.1 The SDR has served this Application to all known parties at interest and all individuals and entities identified by the SDR in the Certificate of Service by and, as noted, by mail to certain federal agencies. 7.2 All pleadings filed in response to this Application shall be served by on the undersigned counsel and all parties shown in the attached Certificate of Service. VIII. OFFER OF PROOF 8.1 The Affidavit of the Special Deputy Receiver is attached as Exhibit D and is offered as evidence to support this Application. The SDR represents to the Court that the proposed notices, POC forms, and categories of parties for notice are in the best interests of the UIE and Paratransit estate, its policyholders, creditors, and obligations imposed by Chapter 443 of the Texas Insurance Code. 3400/Application to Approve Notice and Set Claim Filing Deadline Page 7 of 9

8 WHEREFORE, PREMISES CONSIDERED, the SDR prays that this Court: 1. Grant this Application; 2. Approve a Liquidation Notice and Publication Notice substantially in the form of the documents attached as Exhibits A and B and methods as described in this Application; 3. Approve the procedure for providing notice and the categories of recipients as described in this Application; 4. Approve a POC substantially in the form of the document attached as Exhibit C; 5. Set February 12, 2016 as the Claims Filing Deadline for the filing of POCs; and 6. Grant the SDR such other and further relief to which it may be justly entitled. Respectfully submitted, BRIAN E. RIEWE, P.C. By: /s/ Brian E. Riewe Brian E. Riewe State Bar No P.O. Box 776 Smithville, Texas Telephone: 512/ Facsimile: 512/ briewe@riewelaw.com WISENER NUNNALLY ROTH, L.L.P. Robert H. Nunnally, Jr. State Bar No Cedar Sage Drive, Suite 240 Garland, Texas Telephone: 972/ Facsimile: 972/ robert@wnrlaw.com Attorneys for DKJ Group, Inc., Special Deputy Receiver 3400/Application to Approve Notice and Set Claim Filing Deadline Page 8 of 9

9 APPLICANT'S NOTICE OF SUBMISSION Pursuant to the terms of the Order of Reference to Master entered by the District Court in this cause, the Application to Approve Notice and Set Claim Filing Deadline is hereby set for written submission before the Special Master, Tom Collins, on Monday, October 5, The Special Master has asked that the following rules be provided you: 1. Any objection must be filed with the Travis County District Clerk at least three (3) calendar days before the submission date. 2. A copy of any objection shall be served by such date on: (a) (b) The Master's Docket Clerk, Ms. Jean Sustaita, Texas Department of Insurance at specialmasterclerk@tdi.texas.gov (by ); 333 Guadalupe, Hobby Tower III, 5th Floor, Room 550, Austin, Texas (by hand delivery); or MC-305-1D, P.O. Box , Austin, Texas (by mail); and All interested parties, including those listed on the Applicant's Certificate of Service. 3. The written objection must specifically list all reasons for objection with supporting references to and discussion of statutory and case authorities. Reasons not stated in writing will not be considered orally. 4. If a matter is set for submission, an objecting party shall expeditiously coordinate with Applicant s counsel and the master s docket clerk [(512) ] to obtain an oral hearing, unless the master determines that an oral hearing is not necessary. The objecting party shall serve a Notice of Oral Hearing on applicant s counsel and all interested parties, including those listed on the Applicant s Certificate of Service. 5. Failure to file timely a written objection before the Special Master constitutes a waiver of the right to object to the Special Master's recommendation to the District Court. 6. Any Acknowledgment of Notice and Waiver to be filed by the Guaranty Association or other interested party should be filed at least three (3) calendar days before the submission or hearing date. /s/ Brian E. Riewe Brian E. Riewe 3400/Application to Approve Notice and Set Claim Filing Deadline Page 9 of 9

10 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has been served on all interested parties in accordance with the Texas Rules of Civil Procedure and TEX. INS. CODE ANN (d) this 21st day of September Mr. Tom Collins, Special Master by serving his Docket Clerk, Ms. Jean Sustaita Texas Department of Insurance 333 Guadalupe, Tower III, 5th Fl., MC-305-1D Austin, Texas specialmasterclerk@tdi.texas.gov Ms. Chayah Skye Ms. Stuart Phillips Ms. Jemmie Russell Mr. Kathy Gartner Texas Department of Insurance P.O. Box Austin, Texas chayah.skye@tdi.texas.gov Stuart.Phillips@tdi.texas.gov jemmie.russell@tdi.texas.gov kathy.gartner@tdi.texas.gov Ms. Cynthia Morales, Asst. Attorney General Attorney General's Office P.O. Box Austin, Texas Via Cynthia.Morales@texasattorneygeneral.gov Ms. Sharon Williams United States Department of Justice P.O. Box 875, Ben Franklin Station Washington, DC sharon.williams@usdoj.gov Mr. Brian E. Riewe Brian E. Riewe, P.C. P.O. Box 776 Smithville, Texas briewe@riewelaw.com Mr. Robert Nunnally Wisener * Nunnally * Roth, L.L.P. 245 Cedar Sage Dr., Suite 240 Garland, Texas robert@wnrlaw.com Mr. Bogdan Rentea (Atty for Kourosh A. Hemyari) Rentea & Associates 505 W. 12th Street #206 Austin, Texas brentea@rentealaw.com Mr. Jon E. Arsenault, General Counsel Connecticut Insurance Department P.O. Box 816 Hartford Connecticut jon.arsenault@ct.gov Ms. Arlene Knighten, Supervising Attorney Legal Services Division Louisiana Department of Insurance Post Office Box Baton Rouge, Louisiana aknighten@ldi.state.la.us Mr. Mark Haire, Director of Legal Division Mississippi Insurance Department 1001 Woolfolk State Office Building 501 North West St Jackson, Mississippi mark.haire@mid.state.ms.us Mr. Christopher Brennan, Legal Specialist NJ Department of Banking and Insurance P. O. Box 325 Trenton, New Jersey christopher.brennan@dobi.nj.gov Mr. Todd Dewey 2111 Skylark Drive Arlington, Texas goodguy222001@yahoo.com Mr. John Werner Reaud, Morgan & Quinn, L.L.P. P.O. Box Beaumont, Texas jwerner@rmqlawfirm.com 3400\ Page 1

11 Mr. Dan Lair 2 Springcrest Court Allen, Texas dlair@sbcglobal.net Mr. Edward M. Lavin (Atty-Bill Hall Jr. Trucking) Attorney at Law 8918 Tesoro Dr. #418 San Antonio, Texas elavin@satx.rr.com Mr. Harry Sivley, Jr. (Rep. for Richard W. O'Dom) Regulatory Technologies, Inc. 645 Hembree Parkway, Suite A Roswell, GA hlsregulatoryconsulting@gmail.com Mr. Stan Broome (Atty-Fletcher, Polete, et al) Broome Law Firm, PLLC 105 Decker Court, Suite 850 Irving, Texas sbroome@broomelegal.com Ms. Amber Walker Texas Property & Casualty Insurance Guaranty Association 9120 Burnet Road Austin, Texas awalker@tpciga.org slang@tpciga.org Mr. Mark A. Weitz (Atty-Annecy Investments) Weitz Morgan PLLC 100 Congress Ave., Suite 2000 Austin, Texas mweitz@weitzmorgan.com Mr. Don S. Nixon Paradise Intermediaries, Inc. 705 W. Avenue B., Suite 312 Garland, Texas donnixon@paradiseintermediaries.com /s/ Brian E. Riewe Brian E. Riewe briewe@riewelaw.com 3400\ Page 2

12 UNIVERSAL INSURANCE EXCHANGE and UNIVERSAL PARATRANSIT INSURANCE SERVICES CORP. NOTICE OF LIQUIDATION AND DEADLINE TO FILE CLAIMS CLAIM FILING DEADLINE: 11:59 P.M. CST., FEBRUARY 12, 2016 THIS NOTICE PROVIDES IMPORTANT INFORMATION REGARDING UNIVERSAL INSURANCE EXCHANGE AND UNIVERSAL PARATRANSIT INSURANCE SERVICES CORP. (UIE and Paratransit) Re: The State of Texas vs. Universal Insurance Exchange and Universal Paratransit Insurance Services, Corp.; Cause No. D-1-GV ; In the 345th Judicial District Court of Travis County, Texas (Receivership Court) UIE and Paratransit have been placed in liquidation. On June 10, 2015, the 345th District Court of Travis County, Texas entered an Order Appointing Liquidator and Permanent Injunction placing UIE and Paratransit into liquidation under Chapter 443 of the Texas Insurance Code. The Court appointed the Texas Commissioner of Insurance as Liquidator. DKJ Group, Inc. is the Special Deputy Receiver (SDR) of UIE and Paratransit. Process for obtaining notice of matters before the Receivership Court. Procedures for practice before the Receivership Court are contained in the Order of Reference to Master entered on April 13, The Master may set a status conference from time to time and they are held in Room 100 at 333 Guadalupe Street, Austin, Texas You may request to be added to the service list to receive all pleadings and notices filed in the receivership proceeding by . You can make your request to be added to the service list at Please include your name, address, phone number, fax number and address. If you are an attorney, please identify your client. UIE s policies have expired. Guaranty associations pay covered claims under UIE policies. If you have a claim under an insurance policy issued by UIE, you may have a covered claim that is payable by a state insurance guaranty association. Information regarding the Texas Property and Casualty Insurance Guaranty Association is available at Claims not paid by guaranty associations may be filed against UIE or Paratransit. You may file a Proof of Claim (POC) in the receivership for any amount due from UIE or Paratransit that is not covered, in whole or in part, by a guaranty association. POCs must be received by the SDR no later than 11:59 p.m. CST on February 12, POC forms may be obtained as follows: Download: Request by darwin@uiedallas.com Request by telephone: (214) Request by mail: P.O. Box 2385, Allen, Texas A litigation stay is in effect. Lawsuits against UIE, Paratransit and persons insured by UIE are stayed under Texas Insurance Code and Lawsuits in other states may also be stayed under applicable law in those states. Other information. More information is available on the SDR s website, including: Answers to frequently asked questions about the receivership process; Documents filed in the receivership proceeding; and Notices of hearings and status conferences. EXHIBIT A

13 UNIVERSAL INSURANCE EXCHANGE (UIE) and UNIVERSAL PARATRANSIT INSURANCE SERVICES, CORP. (Paratransit) NOTICE OF LIQUIDATION AND CLAIMS FILING DEADLINE UIE and Paratransit have been placed in receivership and are in liquidation. All policies of insurance issued by UIE have expired. The deadline for filing claims against the assets of UIE or Paratransit is 11:59 p.m. CST on February 12, See to obtain a claim form, an explanation of the claim filing process, and other important information about the receivership. To request a claim form call (214) , darwin@uiereceiver.com or mail a request to Universal Insurance Exchange c/o DKJ Group, Inc., P.O. Box 2385, Allen, Texas EXHIBIT B

14 UNIVERSAL INSURANCE EXCHANGE and UNIVERSAL PARATRANSIT INSURANCE SERVICES, CORP. CLAIM FILING INSTRUCTIONS READ CAREFULLY BEFORE COMPLETING THE PROOF OF CLAIM FORM This Proof of Claim Form must be used if you have a claim against Universal Insurance Exchange (UIE) or Universal Paratransit Insurance Services, Corp. (Paratransit). By accurately completing this form you can protect your interests, help us identify your claim, and allow us the opportunity to consider your claim properly. It is very important that you complete all the sections applicable to you and sign and return the form by the claims filing deadline, together with all documents supporting your claim. Please follow these instructions in completing the Proof of Claim: 1. Please check the box of the correct receivership estate you have a claim against. 2. Provide us with your full name, permanent address, phone numbers and address. During the course of the receivership proceeding, you must notify us in writing of any changes to your mailing address, phone numbers and address. 3. Indicate the basis of your claim (i.e., why you think you are owed money) and, if known, indicate the amount you think you are owed. 4. If the amount of your claim is unknown, you must still file the Proof of Claim by the filing deadline. Insert the word unstated in the amount column. 5. You must include sufficient documentation to support your claim. If you are involved in a lawsuit against UIE or an insured of UIE, include the case name, docket number and the court in which it is pending. 6. If you have assigned any portion of your claim, you must indicate the assignee s name and address and attach a copy of the assignment. 7. You must sign and date the Proof of Claim in front of a Notary Public. Claims filed by corporations must be signed by an authorized representative, stating the capacity of the signatory. If an attorney is signing this form on behalf of a client, a power of attorney must be attached. The Special Deputy Receiver may waive the notarization requirement regarding Proofs of Claim if good cause, as determined in the sole discretion of the Special Deputy Receiver, exists for such a waiver. 8. If you fail to adequately describe or document your claim, your claim may be disallowed. 9. Review the completed form, sign and date it, attach all required documentation and send it to us at the address indicated on the form. Failure to complete the Proof of Claim properly according to these instructions may cause your claim to be delayed or disallowed. 10. You will receive notice at the address you provided on the Proof of Claim when your claim is processed. ALL PROOF OF CLAIM FORMS MUST BE POSTMARKED ON OR BEFORE 11:59 P.M. C.S.T. FEBRUARY 12, 2016 AND MAILED TO: DKJ GROUP, INC., P.O. BOX 2385, ALLEN, TEXAS EXHIBIT C

15 PROOF OF CLAIM UNIVERSAL INSURANCE EXCHANGE in Receivership UNIVERSAL PARATRANSIT INSURANCE SERVICES, CORP. in Receivership CLAIMANT NAME: STREET ADDRESS: CITY: STATE: ZIP CODE: PHONE(s): WORK: HOME: CELL: ADDRESS: SOCIAL SECURITY NO. OR TAX ID NO.: (If represented by an attorney, please complete this section) Name of Attorney: Name of Law Firm: Street Address: City: State: Zip Code: Phone: Fax: Address: The details of my claim are as follows: A. I am claiming the amount of $. B. Describe the nature of your claim and ATTACH ALL SUPPORTING DOCUMENTS: NOTE: Failure to document your claim fully may cause it to be delayed or disallowed. EXHIBIT C Page 1 of 2

16 With the exception of the following, I alone am entitled to file this claim, and no others have an interest in this claim. (Show here the name of any persons or firms who have an interest in this claim and state what their interest is. If there are no others with an interest, write None. ). No payments have been made on the claim. No third party is liable on this debt. The sum claimed is justly owing, and there is no set-off. I declare, under penalty of perjury, that all of the statements made in this Proof of Claim and all documents attached to this form are true, complete and correct. If I am making a claim against a person insured by UIE, I understand that I am waiving any right to pursue the personal assets of that person, to the extent of the coverage and limits provided by the policy issued by the now insolvent insurer UIE. The above statements are TRUE and CORRECT. No part of the amount claimed due has been paid, and I have attached all documents and information relevant to my claim. Signature of Claimant: Printed Name of Claimant: Title of Authorized Signatory, if Claimant is Company/Corporation: SUBSCRIBED AND SWORN TO BEFORE ME, this day of Notary Public, State of Texas My Commission Expires: IMPORTANT ALL CLAIM FORMS MUST BE PRESENTED OR POSTMARKED AND MAILED ON OR BEFORE 11:59 P.M. CENTRAL STANDARD TIME, FEBRUARY 12, 2016 TO DKJ GROUP INC., PO BOX 2385, ALLEN, TEXAS EXHIBIT C Page 2 of 2

17 THE STATE OF TEXAS COUNTY OF COLLIN AFFIDAVIT OF IN SUPPORT OF APPLICATION TO APPROVE NOTICE AND SET CLAIM FILING DEADLINE BEFORE ME, the undersigned authority appeared Darwin K. Johnson, who after being duly sworn by me, states the following under oath: 1. My name is Darwin K. Johnson. I am over the age of eighteen years and competent to make this affidavit. The statements of fact set forth herein are true and correct, and are within my personal knowledge. 2. I am the President of DKJ Group, Inc., Special Deputy Receiver of Universal Insurance Exchange and Universal Paratransit Insurance Services Corp. I am duly authorized to make this certification and affidavit on behalf of the Special Deputy Receiver. 3. As a result of my duties for DKJ Group, Inc. I have knowledge of the facts stated in this Affidavit, and they are all true and correct. I have read the Application to Approve Notice and Set Claim Filing Deadline in the case styled: Cause No. D-1-GV ; The State of Texas v. Universal Insurance Exchange and universal Paratransit Insurance Services, Corp.; In the 345th Judicial District Court of Travis County, Texas (Application). I have also read the exhibits attached and incorporated into the Application by reference. I verify that all of the facts contained in the Application and this Affidavit are true and correct. 4. Further affiant sayeth not. Darwin K. Johnso resident of DKJ Group, Inc., Special Deputy Receiver of Universal Insurance Exchange and Universal Paratransit Insurance Services, Corp. SWORN TO, SUBSCRIBED, and ACKNOWLEDGED BEFORE ME, a notary public on the l $ 6""-day of.$ flf ~bay, 2015, by Darwin K. Johnson whose identity was duly established to me.,, '#t'f!t:,,,,_ LORI ANNE Hll.L ll~! ~'<% Notary Public. State of Texas ; : ;.. ~ My commission Expires ~OJ;- ~~ a~ ao19 "~it~~~.iun.. 1 EXHIBIT D