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          1997--the date she signed the application.  PRLIC reinstated her            
          disability policy.                                                          
               On August 5, 1997, PRLIC received an anonymous phone call              
          from a medical doctor informing PRLIC that petitioner intended to           
          submit a fraudulent disability claim to PRLIC.  Petitioner                  
          offered this doctor money to certify a false psychiatric                    
          diagnosis.  Petitioner stated that she had a doctor’s stationery            
          and prescription pad and would write the medical reports herself            
          if necessary.  The caller stated that petitioner was going to               
          attempt to increase her disability coverage.                                
               On August 8, 1997, petitioner applied to increase the                  
          benefit on her disability insurance.  Petitioner stated in her              
          application to increase her benefit that she earned $136,483 per            
          year, approximately $11,374 per month (after business expenses),            
          from her law practice.                                                      
               By May 19, 1998, PRLIC learned that petitioner visited Dr.             
          David Dixon on May 29, 1997, less than 2 weeks before the date              
          petitioner signed the reinstatement application, with complaints            
          of back pain and painful ambulation.  PRLIC informed her that her           
          disability policy would not have been reinstated if petitioner              
          had answered the questions on the application truthfully and                
          disclosed the May 29, 1997, doctor’s visit.                                 
               PRLIC reported petitioner’s claim as a suspected insurance             
          fraud to the California Department of Insurance (CDI).  CDI                 
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