STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

DUVAL MOTOR COMPANY, d/b/a )

TAMPA HONDA LAND, )

)

Petitioner, )

)

vs. ) CASE NO. 81-1743

) FLORIDA DEPARTMENT OF HIGHWAY ) SAFETY AND MOTOR VEHICLES, )

)

Respondent, )

and )

)

GLOBE AUTO IMPORTS; CROWN ) PONTIAC INC.; LINDELL MOTORS, ) INC.; and REGAL PONTIAC HONDA, ) INC., )

)

Intervenor. )

)

RECOMMENDED ORDER

Pursuant to notice the Division of Administrative Hearings, by its duly designated Hearing Officer, K. N. Ayers, held a formal hearing in the above- styled case on January 25, 26, 27 and 28, 1982, at Tampa, Florida.

APPEARANCES

For Petitioner: Baya Harrison, III, Esquire

317-1/2 East Park Avenue Tallahassee, Florida 32301

and

Henry H. Graham, Jr., Esquire 1848 Challen Avenue

Jacksonville, Florida 32205

For Licensee, Michael A. Fogarty Esquire American Honda M. Jacqueline Allee, Esquire Motor Company, Holland & Knight

Inc.: Post Office Box 1288 Tampa, Florida 33601

Roland N. Smoot, Esquire

1. Donald McCarthy, Esquire Lyon and Lyon

   800 Wilshire Boulevard, 9th Floor Los Angeles, California 90017

   For Intervenor: Karl J. Leib, Jr., Esquire

   Leib & Martinez, P.A.

   201 Alhambra Circle

   Coral Gables, Florida 33134

   and

   Joseph Jacobs, Esquire Dean Bunch, Esquire

   Ervin, Varn, Jacobs, Odom & Kitchen Post Office Drawer 1170 Tallahassee, Florida 32302

   
   

   By application dated June 9, 1981, Duval Motor Company, d/b/a Tampa Honda Land, Petitioner, seeks a license as a motor vehicle dealer at 11024 North Florida Avenue, Tampa, Florida.

   
   

   Protests to the granting of this license were received from Globe Auto Imports, Inc., located in Clearwater, Florida; Crown Pontiac, Inc., located in St. Petersburg, Florida; Lindell Motors, Inc., located in Tampa, Florida; Gateway Motors, Inc., located in Port Richey, Florida; and Regal Pontiac Honda, Inc., located in Lakeland, Florida (hereinafter referred to as Protestants).

   The case was forwarded to the Division of Administrative Hearings for hearing and American Honda Motor Company, Inc., (hereinafter Honda) was allowed to intervene as licensee in support of the application.

   
   

   At an initial prehearing conference on 6 August 1981 Motions to Dismiss were denied, a schedule for completing discovery was established, and the hearing was tentatively scheduled to commence 29 October 1981. This was memorialized by Order entered 7 August 1981. Subsequent prehearing conferences and motion hearings were held and Orders were entered 4 September, 11 September,

   8 October, 20 October and 23 October, 1981; the hearing was rescheduled several times before the January 25, 1982, date was ultimately agreed upon; and the issues were narrowed. As a result of rulings made at various prehearing conferences, the parties agreed to exclude evidence of economic impact of the application on existing dealers, Honda stipulated it was satisfied with the protesting dealers' compliance with their franchise agreements, and all parties concurred that the sole issue was whether existing dealers were providing adequate representation in northwest Hillsborough County, the primary area sought to be served by the Petitioner.

   
   

   At the hearing Petitioner called three witnesses, Honda called five witnesses, the Protestants called nine witnesses and 75 exhibits were offered into evidence. Numerous exhibits were objected to on grounds of relevance and all of these exhibits, except Exhibit 45, were admitted. However, they were admitted subject to relevancy being developed during the proceedings. Those for which relevance was not shown have been disregarded.

   
   

   Proposed findings of fact and conclusions of law submitted by the parties and not included herein were not supported by the evidence or were deemed immaterial to the conclusions reached.

   
   

   FINDINGS OF FACT

   
   

   1. The Parties

      
      

      1. Petitioner, Duval Motor Company, is a holding company operating two Ford franchises, one exclusive Honda dealership, one Isuzu dealership in Jacksonville, and one Isuzu dealership in Tallahassee. Duval Motor Company was

         founded in 1916 and its president, Walter A. McRae, has been in the automobile business some 42 years. The Duval Honda dealership in Jacksonville has been in existence for ten years; and Petitioner is fully qualified, both financially and by experience, to successfully operate the dealership requested in Tampa, Florida.

         
         

      2. Petitioner has acquired a site for the proposed dealership, to be known as Tampa Honda Land, at 11024 North Florida Avenue, Tampa, Florida. This site comprises a tract of land 200 feet wide fronting on North Florida Avenue and is

         500 feet deep. It is located in the North Florida Avenue automobile row.

         
         

      3. Honda is the exclusive distributor for Honda automobiles within the United States. It is responsible for the importation and allocation of Honda automobiles throughout the United States and for the creation and maintenance of an independent dealer network to retail and provide service facilities for these automobiles. Honda imports have increased dramatically in the United States, from 102,000 vehicles in 1975 to 375,000 vehicles in 1980. However, the demand for these vehicles during this period has exceeded the supply. This has resulted in a bonanza, as well as a frustration, to Honda dealers. The demand has been such that many of these automobiles are sold at prices exceeding the manufacturer's suggested retail price, resulting in higher profits for the dealer. Because of the finite number of Hondas imported, the dealers are allocated automobiles by Honda rather than being furnished all they request.

         The allocation system is similar to that used by other popular imports and the number of cars allocated to each dealer is determined by the dealer's rate of vehicle sales for the previous 44 days and his inventory. The more rapidly the dealer sells the cars he receives and thereby deplete's his inventory, the more cars he will get.

         
         

      4. Protestant Lindell Motors, Inc., d/b/a Lindell Honda, is located in the Dale Mabry auto row, 11 miles from Petitioner's proposed site. Lindell is the only Honda dealer in Hillsborough County and operates a dual Volkswagen-Honda dealership. In 1976 Lindell purchased the Honda dealership located in North Florida Avenue auto row and relocated it to his Volkswagen dealership site on Kennedy Avenue near Dale Mabry. Hondas sold by Lindell: 1977, 459; 1978, 609; 1979, 611; 1980, 597; and 1981, 672.

         
         

      5. Protestant Globe Honda operates an exclusive Honda dealership in Clearwater, Pinellas County, Florida, on U.S. 19 in an area in which numerous other dealerships are located. Globe is located some 28 miles from Petitioner's proposed site. Globe was a dual dealer until June 1980. Hondas sold by Globe: 1976, 166; 1977, 246; 1978, 392; 1979, 531; 1980, 729; and 1981, 1171. Globe received an additional allocation of 50 automobiles when it became an exclusive dealer in June 1980.

         
         

      6. Protestant Crown Honda is a dual dealer located at St. Petersburg, Pinellas County, Florida, and sells Pontiac, Datsun, Jaguar, Ferarri, Peugot, De Lorean, Fiat and Honda automobiles. Hondas sold by Crown: 1975, 212; 1976, 243; 1977, 292; 1978, 348; 1979, 375; 1980, 364; and 1981, 286.

         
         

      7. Gateway Motors is a dual dealer located in Port Richey, Pasco County, Florida, and sells Volkswagen and Honda automobiles. It is located some 33 miles from Petitioner's proposed site. Hondas sold by Gateway: 1979, 76; 1980, 365; and 1981, 300.

      8. Regal Honda is a dual dealer in Lakeland, Polk County, Florida, and sells Pontiac, Fiat and Honda automobiles. It is located some 31 miles from Petitioner's proposed site. Hondas sold by Regal: 1976, 42; 1977, 111; 1978, 114; 1979, 104; 1980, 127; and 1981, 157.

         
         

      9. All of these Protestants are members of an advertising group to which they contribute to pay for Honda radio and other advertising spots which are delivered to Hillsborough, Pinellas, Pasco, Polk and Manatee counties. Many of these dealers testified that because of their membership in this group and the advertising thereby generated in these five counties they considered these five counties their marketing area.

         
         

   2. The Territory

      
      

      1. Hillsborough County has a population in excess of 600,000 people and Pinellas County is of comparable population. The older section of Tampa comprises the city limits of Tampa south of Hillsborough Avenue (Interbay area) and constitutes a population center and marketing area served by the southern auto row on Dale Mabry Avenue. During the decade between 1970 and 1980 the population of the Interbay area decreased slightly from 242,369 to 225,476, while the northwest part of Hillsborough County grew from 135,587 to 233,686. While the population maps admitted into evidence do not indicate a separate population grouping in northwest Hillsborough County from the Interbay area in the sense that there is a green area of low population density between the Interbay area and northwest Hillsborough County, numerous shopping malls and residential communities have developed north of Hillsborough Avenue to serve the population in this area of Hillsborough County. In addition the University of South Florida, Busch Gardens, Busch Brewery, Schlitz Brewery, Pepsi Bottling Company, the V.A. Hospital, University Community Hospital, and other newly constructed establishments exist in northwest Hillsborough County which provide substantial employment and make it a prime retail area. The Hillsborough County Planning Commission recognizes northwest Hillsborough County as a distinct area, as does the Tampa Tribune which publishes a special newspaper supplement limited to news and advertising directed toward the northwest area. These factors have created a distinct marketing area in northwest Hillsborough County.

         
         

      2. East Hillsborough County may be described as that part of the county east of U.S. 301, which includes the communities of Brandon, Plant City and Thonotosassa. This area is much larger geographically than the northwest area of the county and the Interbay area combined, but contains less than 25 percent of the county's population.

         
         

      3. The population centers of Hillsborough and Pinellas counties are separated by Old Tampa Bay, which is crossed by three bridges and causeways. The southern two, Candy (U.S. 92) and Franklin (I-275), connect Tampa and St. Petersburg, while Courtney Campbell (S.R. 60) connects Tampa and Clearwater. The proximity of these cities to each other and the adequate connecting roads lead to a multiple market situation where people living in one city will frequently shop in another city in the Tampa Bay area. In many instances it is quicker to go from a facility near the I-275 in Tampa to a facility near the I-

         275 in St. Petersburg than to go across Tampa or St. Petersburg.

         
         

   3. Representation

      1. Honda's market penetration, or share of the total import sales, in Hillsborough County in 1981 was 11.7 percent, which is 2 percent behind its penetration in the Southeast Zone of 13.7 percent. The Southeast Zone includes Florida, South Carolina, Georgia and Tennessee. It currently ranks third behind Toyota and Datsun in market penetration.

         
         

      2. Sales into a market area from outside that market area are called "pump-in" sales. In 1981 nearly 40 percent of the Hondas sold in Hillsborough County were "pump-in" sales. The average automobile dealer generates about 50 percent of his sales within six and one-half miles of his dealership and 75 percent of his sales within ten miles of his dealership. This "geographical advantage" is enjoyed by all dealers with respect to the potential sales close to the dealership. In 1980 Lindell registered 50 percent of its sales slightly more than six and one-half miles from its dealership location and 75 percent of its sales slightly more than ten miles from its location. Globe, the largest volume seller of Hondas in the Tampa Bay area, made 50 percent of its sales to people living less than 7.5 miles from its location and 75 percent of those sales to people living within ten miles. All of Globe's sales in Hillsborough County were more than ten miles from the location of its dealership.

         
         

      3. Customers for sales and services of new automobiles in Hillsborough County, exclusive of the east portion, are served primarily at two separate locations previously described as the North Florida Avenue auto row and the Dale Mabry auto row. There are approximately 30 automobile dealers in Hillsborough County, 24 of which are in the northwest county and Interbay area. Of these 24,

         19 are located in one of these two auto rows. Location of an automobile dealership in an auto row is advantageous both to the dealer and to the customer. Presence within an auto row provides dealers with greater access to customers who come to one dealer then comparative shop at the adjacent showrooms. Such grouping is advantageous to the customers, as it facilitates their shopping for a new or used automobile by having the dealers concentrated in one area. The fact that many customers want to buy a car from a dealer reasonably close to residences or place of work to facilitate repairs and maintenance gives dealers so located a geographical advantage so far as that customer is concerned. This grouping of dealers in auto rows does not deprive them of the geographical advantage they have over dealers offering the same product because manufacturers do not generally allow two franchisees selling the same product in one auto row. Nor does the grouping of dealers materially affect the statistic that dealers sell 50 percent of their product within six and one-half miles and 75 percent within ten miles of the location of their dealership.

         
         

      4. Honda's principal competitors are Toyota, Datsun and Volkswagen. All of these manufacturers are represented by dealerships at both of these auto rows, while Honda is represented only by Lindell at the Dale Mabry auto row. In addition Ford, Chevrolet, American Motors and Dodge are represented by dealers on both auto rows.

         
         

      5. While Honda imports have increased some 350 percent, from 102,000 vehicles in 1975 to 375,000 in 1980, Lindell's sales increased approximately 30 percent in 1977 and 1978 and have remained flat since that time; Crown's sales increased 15-20 percent each year between 1975 and 1978, then slowed in 1979, and actually declined in 1980 and 1981; Gateway's sales increased some 20 percent between 1980 and 1981; and Regal's sales from 1977 to 1981 increased from 111 to 157, an increase of some 40 percent over the five-year period. Of the protesting dealers only Globe's sales showed an increase comparable to the increase of Honda imports, as Globe's percent increase over the previous year

         was 48 percent in 1977, 59 percent in 1978, 35 percent in 1979, 37 percent in

         1980 and 60 percent in 1981. In 1981 75 percent of those sales were within ten miles of the location of its dealership in Clearwater.

         
         

      6. Although Honda sales in Hillsborough County increased from 606 in 1979 to 775 in 1980, its percent of the import market in Hillsborough County still remains two percentage points below the zone level of penetration. In 1981 Lindell sold nearly as many Hondas north of Hillsborough Avenue as it sold south of Hillsborough Avenue, yet 40 percent of the sales in northwest Hillsborough Avenue were pumped in from outside Hillsborough County. High "pump-in" sales are an indication of inadequate penetration by the dealers.

         
         

   4. Availability of Automobiles

      
      

      1. Protestants contend that the reason they do not sell more Honda automobiles is because Honda does not supply them with the vehicles they need and can sell. All offered to pay in advance for an additional number of Hondas each month into the foreseeable future. Furthermore, a voluntary import restriction has been imposed on all Japanese automobile imports commencing in 1981 and continuing until 1983. This will further restrict the availability of Honda autos and create less need for an additional dealer, as there will be less cars available to the United States market.

         
         

      2. Honda contends that the allocation system allows dealers to "earn" more vehicles by expeditiously selling those received and those that do so will continue to get an increasing supply of vehicles. Protestants' contention that Globe sold more vehicles because Globe obtained a one-time additional allocation when it became an exclusive dealer in mid-1980 overlooks the yearly increases in allocated vehicles received by Globe during the period 1976 through 1979 before going exclusive. During this period Globe went from 166 vehicles in 1976 to 531 in 1979. More aggressive selling by the other Protestants would have increased their allocation of vehicles and increased Honda's penetration of the Hillsborough County market.

         
         

      3. Honda of America manufacturing company, which is 80 percent owned by Honda of America and 20 percent by Honda, Ltd.; in Japan, will commence producing Honda automobiles in the United States in 1982. First production of

         50 automobiles per day is expected to start in October or November of 1982, with full production of 600 units per day some 18 months thereafter. Thus, in 1984 production of 144,000 units is projected.

         
         

   5. Open Point in Hillsborough County

   
   

   1. Honda determined in the early 1970's that an additional open point existed in Hillsborough County. This point was not filled and, when Lindell acquired his dealership in 1976, he was told Honda did not plan to open a second point in Hillsborough County in the near future.

      
      

   2. Petitioner applied for a second dealership in Jacksonville when that point became open; however, the dealership was awarded to another applicant because Honda liked his proposal better and preferred the two points in Jacksonville be owned by different people to promote competition. Petitioner was then offered open points in St. Augustine, Florida, and Brunswick, Georgia, which he declined. When told that an open point existed in Tampa Petitioner expressed interest and submitted a proposal. Petitioner initially selected the site for the new dealership in the Dale Mabry auto row but when told by the Southeast Zone sales manager he would not recommend approval of a location that

      close to Lindell, Petitioner located a site in the North Florida Avenue row. In January 1981 Petitioner met with Honda officials in Los Angeles, California, and after presenting his proposal was told that he could have the open point in Hillsborough County. Acting upon this verbal approval, Petitioner acquired the property at 11024 North Florida Avenue and presented his formal application for the point. At about this time the voluntary moratorium on imports from Japan came into effect and Honda announced a moratorium on new points in the United States except for those already approved where applicants had expended funds in reliance upon the approval. Since Petitioner's application fitted into that category, Honda approved his franchise in Hillsborough County and his application was filed with the Department of Motor Vehicles for a license.

      
      

   3. Protestant Lindell, the closest dealer to the site of this application, acknowledges that someday Honda would be justified in opening a second point in Hillsborough County, but contends that a second point should not be opened until after the import restrictions are lifted and an adequate supply of vehicles is available for the dealers who are now selling into that market.

      
      

      CONCLUSIONS OF LAW

      
      

   4. The Division of Administrative Hearings has jurisdiction over the parties to, and the subject matter of, these proceedings.

      
      

      Section 320.642, Florida Statutes, provides:

      The department of Highway Safety

      and Motor Vehicles shall deny an applica- tion for a motor vehicle dealer license in any community or territory where the licensee's presently licensed franchised

      motor vehicle dealer or dealers have complied with the licensee's agreements and are pro- viding adequate representation in the community or territory for such licensee. The burden

      of proof in showing inadequate representation shall be on the licensee.

      
      

   5. The parties have stipulated that Honda does not charge any of the protesting dealers with failure to comply with licensee's agreements and the sole issue in this case is whether the franchised dealers serving this territory are providing adequate representation.

      
      

   6. Here we have multiple dealers (protesting dealers and others) who are selling Honda automobiles in Hillsborough County. Despite this number of dealers making sales in Hillsborough County, the market penetration of Honda in Hillsborough County remains two percentage points below the penetration in the Southeast Zone. When the facts are considered that 75 percent of a dealer's sales are normally made within a ten-mile radius of the location of his dealership, that more than one-half of the population of Hillsborough County (less east Hillsborough County) lives north of Hillsborough Avenue in northwest Hillsborough County, that Lindell Honda is located some four miles south of Hillsborough Avenue and 11 miles from the Petitioner's proposed location, that all of the other protesting dealers are located more than 15 miles from the Petitioner's proposed location, and that 40 percent of the Honda sales in northwest Hillsborough County are "pump-in" sales from outside Hillsborough County, it is not surprising that Honda market penetration in Hillsborough County is below zone penetration level.

   7. In Bill Kelly Chevrolet, Inc. v. Calvin, 322 So.2d 50 (Fla. 1st DCA 1975), the Court was faced with a multiple dealer situation where each dealer serving the metropolitan market was adequately representing the licensee in his primary area and in the metropolitan market overall the licensee was adequately represented in overall penetration, yet within the metropolitan area an identifiable area was not being adequately serviced. The Court said at p. 52:

      
      

      [W]ithin the territory described in the non-exclusive franchise agreement there remains an identifiable plot not yet cul- tivated, which could be expected to flourish if given the attention which the others in their turns received.

      
      

   8. Petitioner and Honda contend that northwest Hillsborough County constitutes such an identifiable plot which has not yet been cultivated. The fact that this area is growing, that its population is increasing faster than the population in other parts of the county, that industry exists and is increasing in this area, and that new communities have developed in this part of the county do not necessarily demonstrate that this area is uncultivated. From the evidence presented it appears that approximately the same number of Hondas was sold in 1980 and 1981 in northwest Hillsborough County as in the Interbay area. In 1981 Lindell sold 307 new Hondas north of Hillsborough Avenue of the 672 new Hondas it sold. This indicates that Hillsborough County, both the northwest and Interbay areas, are not receiving the cultivation needed to bring Honda's penetration in line with penetration in the other markets in the Southeast Zone.

      
      

   9. The fact that an auto row exists on North Florida Avenue and another one exists on Dale Mabry is evidence that the business community has concluded a separate market area exists at both places. Honda's principal competitors are located in both of these auto rows and to compete effectively with them Honda should also be represented at both auto rows.

      
      

   10. On the other hand, the population, growth and development in northwest Hillsborough County are sufficient to constitute an identifiable market area in which Honda is not adequately represented and which is not being adequately cultivated to improve Honda's market penetration. In Bill Kelly, supra, at p.

       52 the Court commented on Section 320.642, Florida Statutes, as follows:

       
       

       The purpose of s320.642, F.S. 1973,

       is to prevent powerful manufacturers from taking unfair advantage of their dealers by overloading a market area with more

       dealers than can be justified by the legiti- mate interests of the manufacturer and its dealers, existing and prospective.

       Plantation Datsun, Inc. v. Calvin,

       275 So.2d 26 (Fla. 1 DCA 1973) . Its pur- pose is not to foster combinations to prevent the introduction of dealer compe- tition which is reasonably justified in terms of market potential. Antitrust laws have proscribed such combinations in the United States since 1890 and in this state since 1915. (Citations omitted.) Assuming as we do that the legislature in enacting

       s320.642 intended "to serve the best interest of the people and the general

       welfare of the State" consistent with the pur- pose of the antitrust laws [Abood v.

       City of Jacksonville, 80 So.2d 433, 445 (Fla. 1955)], we decline to transform the non-exclusive multiple dealer area of Dade and Broward into an exclusive

       territory in which twelve existing dealers are protected from border to border

       from further competition notwithstanding their inadequate representation of Chevrolet in an identifiable part of the territory.

       
       

   11. Protestants' contention that they are unable to obtain adequate penetration of the import market in Hillsborough County because Honda will not furnish them an adequate supply of cars is without merit. These Protestants are competing on equal terms for cars with every other Honda dealer in the Southeast Zone and the penetration in the Southeast Zone is two percentage points, or 17 percent, higher than the penetration in Hillsborough County. No one contested the fairness of Honda's allocation system. Even Protestants' witnesses acknowledged the allocation system was practically identical with allocation systems used by other distributors and contained identical provisions to encourage dealers to sell cars.

       
       

   12. Here we have a situation where the residents of Hillsborough County are not given the same opportunity to purchase a Honda automobile that is given to residents of other marketing areas in the Southeast Zone. They are not given this opportunity because the dealers serving Hillsborough County do not "earn" the vehicles necessary to make Hillsborough County residents equal to other residents in the Southeast Zone. Bringing in another dealer would undoubtedly promote competition and improve the position of the residents of Hillsborough County.

       
       

   13. Any finding of fact herein made which also constitutes a conclusion of law is adopted as a conclusion of law. Any conclusion of law herein made which also constitutes a finding of fact is adopted as a finding of fact.

       
       

   14. From the foregoing it is concluded that Petitioner and licensee have shown, by a preponderance of the evidence, that Honda is not adequately represented in Hillsborough County; and the application of Duval Motors, Inc., d/b/a Tampa Honda Land for a license to operate a Honda automobile dealership at 11024 North Florida Avenue, Tampa, Florida, should be approved. It is, therefore,

   
   

   RECOMMENDED that the application of Duval Motor Company for a license to operate a Honda automobile dealership at 11024 North Florida Avenue, Tampa, Florida, be APPROVED.

   ENTERED this 25th day of February, 1982, at Tallahassee, Florida.

   
   

2. N. AYERS, Hearing Officer Division of Administrative Hearings The Oakland Building

2009 Apalachee Parkway

Tallahassee, Florida 32301

(904) 488-9675

Filed with the Clerk of the Division of Administrative Hearings this 25th day of February, 1982.

COPIES FURNISHED:

Baya Harrison, III, Esquire Karl J. Leib, Jr., Esquire 317-1/2 East Park Avenue Leib & Martinez, P.A. Tallahassee, Florida 32301 201 Alhambra Circle

Coral Gables, Florida 33134

Henry H. Graham, Jr., Esquire

1848 Challen Avenue Joseph Jacobs, Esquire

Jacksonville, Florida 32205 and

Dean Bunch, Esquire Michael A. Fogarty, Esquire Ervin, Varn, Jacobs, Odom

M. Jacqueline Allee, Esquire & Kitchen

Holland & Knight Post Office Drawer 1170

Post Office Box 1288 Tallahassee, Florida 32302 Tampa, Florida 33601

John D. Calvin, Director

Roland N. Smoot, Esquire Division of Motor Vehicles

and Department of Highway Safety

J. Donald McCarthy, Esquire and Motor Vehicles Lyon and Lyon Neil Kirkman Building

800 Wilshire Boulevard Tallahassee, Florida 32301 Los Angeles, California 90017

Chester Blakemore, Executive Director

Department of Highway Safety and Motor Vehicles

Neil Kirkman Building Tallahassee, Florida 32301

Docket for Case No: 81-001743

Orders for Case No: 81-001743