Pursuant to notice, the Division of Administrative Hearings, by its duly designated Hearing Officer, W. Matthew Stevenson, held a formal hearing in this case on January 16 and 17, 1986 in Tampa, Florida.
For Petitioner: James H. Gillis, Esquire
For Respondent: Elizabeth Ann Goodale, Esquire (Phyllis Reeves) 14320 Indian Rocks Road
One Urban Centre, Suite 750 4830 W. Kennedy Boulevard Tampa, Florida 33609
The issue for determination at the final hearing was whether the Respondents committed the allegations contained in the Administrative Complaints.
The two Respondents were charged in identical Administrative Complaints filed on March 6, 1985 and May 10, 1985. Both Respondents disputed the factual allegations contained in the Administrative Complaints and requested a formal hearing pursuant to Section 120.57(1), Florida Statutes (1983). The cases were consolidated for the purpose of conducting the formal hearing.
Although there are three case numbers, there are only two Administrative Complaints. Division of Administrative Hearings Case Nos. 85-1008 and 85-1138 concern identical Administrative Complaints, however, each was forwarded to the Division of Administrative Hearings separately and they were assigned different case numbers.
This cause came on for final hearing on January 16 and 17, 1986. The Petitioner presented the testimony of 9 witnesses. In addition, Petitioner's Exhibits 1, 9, 15-17, 19-29, 31-40, 53-55, 57-58, 61-69 and 77-79 were offered and duly admitted into evidence. The Respondent, Annette J. Ruffin, testified on her own behalf. In addition, Respondent, Annette J. Ruffin, Exhibits 1-28 were offered and duly admitted into evidence. The Petitioner submitted posthearing Proposed Findings of Fact. A ruling has been made on each proposed finding of fact in the appendix to this Recommended Order.
Based upon my observation of the witnesses and their demeanor while testifying, the documentary evidence received and the entire record compiled herein, I hereby make the following findings of fact:
Phyllis I. Reaves is now and was at all times material to these proceedings, a licensed real estate salesman in the State of Florida having been issued license number 0351816.
Annette J. Ruffin is now and was at all times material to these proceedings, a licensed real estate broker having been issued license number 0076385.
From May 2, 1983 to October 18, 1984, Respondent Phyllis
I. Reaves was licensed and operating as a real estate salesman in the employ of Respondent Annette J. Ruffin, as broker, c/o International Investment Development Center, Belleair, Florida or Century 21 A Little Bit Country, Brandon, Florida.
At all time material hereto, Respondent Phyllis I. Reaves was a licensed mortgage broker in the State of Florida.
DOAH CASE NO. 85-1008/1138.
COUNT I
No evidence was presented concerning the allegations in Count I..
COUNT II
No evidence was presented concerning the factual allegations of Count II.
COUNT III
No evidence was presented concerning the allegations of Count III.
COUNT IV
On June 10, 1983, Respondent Reaves entered into a real estate sales contract with Emmett K. Singleton, as seller to purchase certain real estate through the use of a land trust.
The sales contract listed a total purchase price of
$67,000. C-21 A Little Bit Country was listed on the contract as escrow agent of the binder deposit.
The property had an existing first mortgage of approximately $33,854. Respondent Reaves agreed to assume the new mortgage and requested that Mr. Singleton obtain a second mortgage in the principal amount of $26,400. Reaves agreed to assume this second mortgage amount while allowing Mr. Singleton to keep the proceeds. Mr. Singleton agreed that the balance of the sales price would be paid via a purchase money mortgage to Respondent Reaves in the principal amount of $9,643.99.
Respondent Phyllis I. Reaves executed a Hold Harmless and Indemnity Agreement which read as follows:
"Phyllis Reaves does agree to hold Emmett
K. Singleton harmless and does idemnify him against any future liability or losses related to the mortgage on subject property
at 1912 Hastings Drive, Clearwater, Florida."
The sales transaction closed on July 7, 1983, and Respondent Reaves received a real estate brokerage commission in the amount of $1,955. The contract provided that the "listing agent agrees to pay C-21 A Little Bit Country cooperating agent 3.5% of the total purchase price on closing."
The purchase money mortgage note was actually signed by Michael R. Fisher, as trustee, and not by Respondent Reaves.
Respondent Reaves requested that Mr. Singleton give her the mortgage payment booklets and she would assume and pay off the existing and second mortgages.
Singleton trusted Reaves and relied upon her statements that she would do as she promised.
Respondent Reaves failed to assume and pay the notes and mortgages and thereby caused the seller to become delinquent with the lenders.
After closing, Respondent Reaves, acting as the owner, obtained tenants for the property and collected rental payments. Respondent Reaves solicited and obtained $3,000 in connection with a lease/option agreement. The lease/option agreement provided that the sales price of the home would be $78,000 in three years. The rent would remain at $495 per month for three
(3) years. The agreement further provided that $3,000 per year would be paid for three (3) years which would reflect a total down payment of $9,000. This down payment was considered the "option consideration." The agreement provided that one third of the option money would be returned if the option were not exercised. The tenants paid Respondent Reaves a total of $3,000 of the option consideration. The renters became concerned when they began to receive notices from Freedom Mortgage Company stating that certain mortgages on the home were overdue. The renters did not exercise the option to buy the home. The renter requested, but did not receive, $1,000 of the $3,000 option consideration back from Respondent Reaves.
COUNT V
On July 6, 1983, Respondent Reaves entered into a real estate sales contract with Stephen B. Barnes, as seller, to purchase certain real estate through the use of a land trust. The property was not listed", but a broker from Tam-Bay Realty approached Barnes and stated that he had a buyer.
The purchase and sale agreement provided for a total purchase price of $91,000. The agreement listed "C-21 A Little Bit Country" as escrow-agent for the binder deposit. In addition, the purchase and sales agreement provided that:
"Listing agent Tam-Bay agrees to pay C-21 A Little Bit Country cooperating agent 3.5% of the total purchase price on closing."
The seller agreed that he would allow Respondent Reaves to assume the existing mortgage of approximately $52,990. Mr. Barnes then agreed to obtain a second mortgage in the amount of
$18,925. The seller agreed that the balance of the sales price would be paid via a purchase money mortgage in the principal amount of $16,670.91 to be paid by Respondent Reaves. In addition, Mr. Barnes obtained a home improvement loan in the amount of $4,900. According to the agreements between Respondent Reaves and Mr. Barnes, Mr. Barnes was to keep the money obtained by the second mortgage and the home improvement loan. Respondent Reaves agreed to assume the existing mortgage, the second mortgage and the home improvement loan.
Respondent Reaves advised Mr. Barnes to state to the lender that the purpose of the loans were for home improvements.
Respondent Reaves executed a hold harmless and indemnity agreement which stated as follows:
"Phyllis Reaves does agree to hold Stephen.
B. Barnes harmless and does indemnify him against any future liability or losses related to the mortgages on property at 13222 - 88 Place North, Seminole, Florida."
The sales transaction closed on August 10, 1983, and Respondent Reaves received a real estate brokerage commission in the amount of $2,513.45 and a mortgage brokerage fee of $946.25.
Respondent Reaves failed to assume and pay the notes and mortgages and thereby caused the seller to become delinquent with the lenders.
COUNT VI
On September 3, 1983 Respondent Reaves entered into a real estate sales contract with Floyd and Christine Erwin, as sellers, to purchase certain real estate through the use of a land trust. The contract concerned Floyd and Christine Erwins' home located at 2805 Candlewood Drive in Clearwater, Florida.
The purchase and sale agreement provided for a total purchase price of $53,000. The agreement listed C-21 A Little Bit Country as escrow agent for the binder deposit. The agreement further provided that the "listing agent agrees to pay C-21 A Little Bit Country cooperating agent 3.5% of the total purchase price on closing."
Respondent Reaves agreed to assume the existing mortgages of $16,766.29 and $17,457.94. In addition, the sellers
agreed to obtain a new mortgage in the principal amount of $4,900 and a $1,500 personal loan. Upon the advice of Respondent Reaves, the sellers stated to the lender that the purpose of the loans were for home improvements. Respondent Reaves and the sellers agreed that the sellers would keep the money obtained by the loans and that Respondent Reaves would assume the mortgages and make all of the required loan payments. The sellers agreed that the balance of the sales price was to be paid via a purchase money mortgage, payable by Respondent Reaves, in the principal amount of $12,375.77.
Respondent Reaves executed a hold harmless and indemnity agreement which stated as follows:
"Phyllis Reaves does agree to hold Floyd S. Erwin and Christine E. Erwin harmless and does indemnify them against any future liability or losses related to mortgages
or liens on the subject property at 2805 Candlewood Drive, Clearwater, Florida."
Floyd and Christine Erwin's home was listed with a broker, and the Erwins understood that Reaves was not their agent. Respondent Reaves told the Erwins that she was representing "some investors." The purchase money mortgage note was actually signed by "Michael R. Fisher, as trustee and not personally."
Respondent Reaves made some payments on the purchase money mortgage note which was signed by Michael Fisher.
The sales transaction closed on September 23, 1983, and Respondent Reaves received a real estate brokerage commission in the amount of $1,555.50.
Respondent Reaves failed to assume and pay the mortgages and notes.
Respondent Reaves has not made the payments due on the mortgages and notes and has caused the Erwins to become delinquent with their lenders.
COUNT VII
The evidence presented concerning Count VII consisted solely of documentary evidence. For reasons enumerated in the Conclusions of Law section, infra, the documents alone are insufficient to establish the basis of any offense. Therefore, a discussion of those documents would serve no useful purpose.
COUNT VIII
On October 16, 1983, Respondent Reaves entered into a real estate sales contract with Patricia and William Willis as sellers, to purchase certain real estate through the use of land trust. The contract concerned the Willis' home located at 417 North Missouri Avenue, Clearwater, Florida.
The purchase and sale agreement provided for a total purchase price of $54,000. The agreement listed C-21 A Little Bit Country as escrow agent for the binder deposit. The agreement further provided that the listing agent ". . .
agrees to pay C-21 A Little Bit Country cooperating agent 3.5% of the total purchase price on closing."
Respondent Reaves and the Willis' agreed that Respondent would assume the existing mortgage of $15,396.52. The sellers agreed to obtain the new mortgage in the principal amount of $34,100. The sellers agreed that the balance of the sales price would be paid via a purchase money mortgage in the principal amount of $8,898.45 to be paid by Respondent Reaves. Respondent Reaves agreed to assume the existing mortgage and the new mortgage in the amount of $34,100 and make all of the required loan payments.
Respondent Reaves advised the Willis' to state to the lender that the purpose of the $34,100 mortgage loan was for home improvements. The Willis' applied for the loan but refused to state that the purpose of the loan was for home improvements.
Respondent Reaves executed a hold harmless agreement which stated as follows:
"Phyllis Reaves does agree to hold Patricia
L. Carrah, a/k/a Patricia L. Willis and William Willis harmless and does idemnify them against any future liability for losses related to any mortgages or liens on the subject property "
The sales transaction closed on November 23, 1983 and Respondent Phyllis Reaves received a real estate brokerage commission in the amount of $3,213 and a mortgage brokerage fee of $2,216.
Respondent Reaves failed to assume the notes and mortgages and thereby caused the sellers to become delinquent with their lenders.
COUNT IX
No evidence was presented concerning the allegations of Count IX.
COUNT X
No evidence was presented concerning the allegations of Count X.
COUNT XI
No evidence was presented concerning the factual allegations of Count XI.
COUNT XII
No evidence was presented concerning the factual allegations of Count XII.
COUNT XIII
No evidence was presented concerning the factual allegations of Count XIII.
No evidence was presented concerning the factual allegations of Count XIV.
COUNT XV
on January 13, 1984, Respondent Reaves entered into a real estate sales contract with Clifford and Virginia Miner, as sellers, to purchase certain real estate through the use of a land trust. The contract concerned the Miner's home located at 1247 Burma Avenue, Clearwater, Florida.
The purchase and sale agreement provided for a total purchase price of $62,000. The agreement listed "C-21 A Little Bit Country" as escrow agent for the binder deposit. In addition, the agreement provided that the listing agent ". . . agrees to pay C-21 A Little Bit Country cooperating agent 3.5% of the total purchase price on closing."
Respondent Reaves and the sellers agreed that Respondent Reaves would assume the existing mortgage of
$34,424.82. Respondent Reaves advised the sellers to obtain a
$20,000 second mortgage that she would also assume. The sellers were to obtain the mortgage and keep the money as their equity, and Respondent Reaves was to assume the mortgage and make the payments. The sellers agreed that the balance of the sales price
was to be paid via a purchase money mortgage in the principal amount of $6,865.33, payable by Respondent Reaves. Respondent Reaves promised the sellers that she would make all the required loan payments and assume the mortgages.
Respondent Reaves executed a hold harmless agreement which stated as follows:
"Phyllis Reaves does agree to hold Clifford
S. Miner and Virginia N. Miner, his wife, harmless and does idemnify them against any future liability or losses related to any mortgages or liens on the subject property
. . . ."
The purchase money mortgage note was actually signed by Michael R. Fisher, "as trustee and not personally."
Respondent Reaves told Mr. Miner that the hold harmless agreement provided additional assurance that she would personally assume all of the mortgage and loans.
The sales transaction closed on January 31, 1984, and Respondent Phyllis Reaves received a real estate brokerage commission in the amount of $1,823.25 and a mortgage brokerage fee of $949.48.
Respondent Reaves failed to assume and pay the notes and caused the Miners to become delinquent with their lenders, requiring them to "catch up" on the delinquent loan.
COUNTS XVI, XVII AND XVIII.
The evidence presented concerning Count XVI, XVII and XVIII consisted solely of documentary evidence. For reasons enumerated in the Conclusions of Law section of this Recommended Order, the documents alone are insufficient to establish the basis of any offense. Therefore, a discussion of those documents would serve no useful purpose.
COUNT XIX
During the later part of 1984, an investigator, representing the Department of Professional Regulation, went to speak to Mrs. Ruffin at her "Little Bit of Country" office concerning this case. The investigator requested that he be provided with the records from all of Respondent Reaves' transactions. Respondent Ruffin stated that she was unaware of the particular real estate transactions in question, but that she would check and provide the records at a later date because she
was in the process of moving the location of her office. After subpoena was served, Respondent's counsel provided one of the documents in question.
COUNT XX
Respondent Ruffin employed Respondent Reaves as a salesman. Respondent Ruffin thought of Respondent Reaves as "an independent contractor." Respondent Reaves decided on her own hours and took care of her own transportation. Respondent Ruffin and Respondent Reaves were on an 85%-15% split fee arrangement. Respondent Ruffin knew that Reaves was interested in "buying a lot of property." Respondent Ruffin was basically aware of the method that Respondent Reaves was using to obtain property. Respondent Ruffin did not feel that the method was wrong, however, she did ask Respondent Reaves to leave employment after she received many calls complaining about Respondent Reaves and information that Respondent was in a "tight financial situation." Respondent Ruffin admitted that she had very little time to provide assistance or guidance to Respondent Reaves.
DOAH CASE NO. 85-2454 COUNT I
There was no evidence presented concerning the factual allegations of Count I.
COUNT II
There was no evidence concerning the factual allegations of Count II.
COUNT III
On October 2, 1984, an investigator, representing the Department of Professional Regulation, went to speak with Respondent Ruffin at her office. The investigator requested certain records relating to Respondent Reaves' transactions concerning the charges herein. Respondent Ruffin stated that she was unaware of the particular real estate transactions in question, but that she would check and provide the records at a later date because she was then in the process of moving her office. After a subpoena was served, Respondent Ruffin's attorney provided one of the documents in question.
COUNT IV
There was no evidence presented concerning the factual allegations of Count IV of DOAH Case No. 85-2454.
CONCLUSIONS OF LAW
The Division of Administrative Hearings has jurisdiction of the parties to, and the subject matter of, this cause pursuant to Section 120.57(1), Florida Statutes (1983).
The burden of proof is on the Petitioner. In a matter as grave as license revocation proceedings, the duty allegedly breached by the licensee must appear clearly from applicable statutes or rules and have a substantial basis in the evidence. Bowling V. Department of Insurance, 394 So.2d 165, 173 (Fla. 1st DCA (1981). Disciplinary license proceedings like the present case are potentially license revocation proceedings, even in the absence of a recommendation of revocation, since the penalty for the infraction lies within the discretion of the disciplining authority if allegations of misconduct are established. Florida Real Estate Commission V. Webb, 367 So.2d 201 (Fla. 1979). The Petitioner must prove all of the essential elements of the charges contained in the Administrative Complaints by clear and convincing evidence.
Section 475.25, Florida Statutes (1983) provides in pertinent part that:
"(1) The [Florida Real Estate Commission]
. . . may suspend a license or permit for a period not exceeding 10 years; may revoke a license or permit; may impose an administrative fine not to exceed $1,000 for each
count or separate offense; and may issue a reprimand, or any or all of the foregoing, if it finds that the licensee . . .:
(b) Has been guilty of fraud, misrepresentation concealment, false promises, false
pretenses, dishonest dealing by trick, scheme, or device, culpable negligence, or breach of trust in any business transaction . . ."
In addition, Rule 21V-14.12, F.A.C. provides in pertinent part that:
"Brokers records. A broker who received a deposit such as defined herein shall preserve and make available to the department or its authorized representative, all deposit slips and statements of account rendered by the bank or trust powers, in which said deposit is placed, together with all agreements between
the parties respecting the transaction, particularly the deposit, and all contracts, agreements, instructions and directions to or with the said depository
. . .all such books and accounts shall be subject to inspection by the department or
its authorized representative at all reasonable times during regular business hours."
RESPONDENT PHYLLIS I. REAVES
In Counts I - XVIII, of DOAH Case No. 85-1008/1138, and Counts I and II of DOAH Case No. 85-2454, Respondent Reaves is charged with a violation of Section 475.25(1)(b), Florida Statutes (1983). No evidence was presented as to Counts I, II, III, IV, V, XI, XII, XIII and XIV of DOAH Case No. 85-1008/1138 and Counts I and II of DOAH Case No. 85-2454. Therefore, those counts were not proven and must be dismissed without further consideration.
In the remaining counts of DOAH Case No. 85-1008/1183, Respondent Reaves' modus operandi remained the same. Respondent Reaves sought to acquire a substantial amount of real estate while paying little or no money down and incurring little or no personal obligation. To achieve this end, Respondent Reaves approached the home owners material to this proceeding with a seemingly attractive proposal. Respondent Reaves in each instance offered to purchase the homes offered for sale by the parties herein involved. Each home was already encumbered by an existing mortgage. The sellers were advised by Respondent Reaves to borrow additional money which would serve as fund for the payment of costs, commission and some equity to the sellers. The sellers happily pocketed the money obtained from the additional loans, minus costs and commissions. In addition, the sellers were asked to "take back" a third mortgage, which would be a purchase money mortgage, payable by Respondent Reaves.
Respondent Reaves promised the sellers that she would personally
assume the existing mortgage(s), and the new second or third mortgage(s). Respondent Reaves also assured the sellers that she would be responsible for paying the purchase money mortgage. In each instance, Respondent Reaves' binder deposit on the contract consisted of a promissory note which would be credited at closing.
The "real" transaction that occurred was quite different from that promised by Respondent Reaves. The sellers actually transferred the title of the property to a land trust with Michael R. Fisher, as Trustee and the sellers as beneficiaries. See generally, Section 689.071, Florida Statutes (1983). The trust agreements provided that the sellers, as beneficiaries could make contracts or deeds for the sale of the
property. The trustee was empowered to convey title of the property upon the direction of the sellers. The trustee received no renumeration for his services. Next, the sellers executed assignments wherein they assigned and transferred their beneficial interest in the property held subject to the trust agreement to Respondent Reaves.
Respondent Reaves method of acquiring property was not in and of itself illegal, and was indeed sophisticated. A land trust may be used to avoid possible acceleration of existing mortgages because a due on sale clause cannot be enforced when real property title is put into an inter vivos trust. Ownership transfer is off of the public records when a land trust is used and the lender would have difficulty learning of the sale. However, Respondent Reaves in each instance orally promised the sellers that she would personally assume the existing and newly applied for loans and mortgages. But, Respondent Reaves was not responsible for paying the purchase money mortgage note because the note was signed by the trustee, Michael R. Fisher. The indemnity agreements signed by Respondent Reaves were of little significance. Despite the "clarity of the written documents reflecting the true nature of these transactions, the sellers were uniformly assured by Reaves that she would be personally liable for the purchase money mortgage notes. Respondent Reaves promised each seller that she would assume the existing and new mortgages but the result was the same in each case --the sellers discovered that the debts were delinquent or in default and still in their names with no attempt made by anyone to assume them. Respondent Reaves knew at the time that she promised to assume the mortgages that she had no real intention of doing so and she knew, despite her promises and assurances to the contrary, that she would not be personally responsible for the purchase money mortgage. It is equally clear that Respondent Reaves exploited the sellers confidence and trust in her by virtue of her position as a licensed real estate professional and that, but for their faith in her promises, the sellers would not have entered into these transactions.
While the legal documents in this case clearly show that a land trust was utilized, the documents only tell half of the story. The other half of the story consists of Respondent Reaves inducing the sellers to enter into these risky transactions by her knowingly false verbal assurances and promises that she would be ultimately, personally and legally responsible for satisfying all of the mortgages and loans associated with the various sales. In addition, Respondent Reaves advised several of the sellers to lie to certain lenders in applying for the new mortgages and loans. For these misdeeds, Respondent Reaves as a licensed member of the real estate profession is responsible. Respondent Reaves can find no solace
in the fact that each contract contained a statement that "Reeves is a licensed real estate salesperson and is investing for her own account." (emphasis added) In each sale, Respondent Reaves obtained a financial benefit directly related to her license -- a real estate commission. Further, it is equally clear that a registered real estate broker or salesman may be disciplined under Section 475.25(1)(b) for dishonest conduct of business affairs for his own account, as well as for conduct in transactions in which his only interest is as a broker or salesman. See Sellars V. Florida Real Estate Commission, 380 So.2d 1052, 1054 (Fla. 1st DCA 1979).
Certainly, the general rule is that the mere nonperformance of a promise does not establish fraud or the lack of intent to perform. See Brod v. Jernigan 188 So.2d 575 (Fla. 2nd DCA 1966). However, the Florida courts recognize an exception where the promise to perform a material matter in the future is made without any intention of performing or made with the positive intention not to perform. Further, a party's secret, undisclosed intent not to carry out the promise may be inferred from the circumstances Home Seeker's Realty Co. v. Menear, 135 So.2d 402 (Fla. 1981); Vance v. Indian Hammock Hunting and Riding Club, 403 So. 2d 1367 (Fla. 4th DCA 1981). The evidence established that Respondent Reaves engaged in a pattern and practice which clearly showed that she had no intention of fulfilling the promises at the time of the making of the promises or anytime thereafter. The Petitioner has established by clear and convincing evidence that Respondent Reaves is guilty of fraud, misrepresentation, false promises, false pretenses, dishonest dealing by trick or scheme, and breach of trust in a business transaction as alleged, in Counts IV, V, VI, VIII and XV of the Administrative Complaint (DOAH Case No. 85-1008/1138) Factual allegations contained in the foregoing Counts, but not discussed herein, were not proven.
RESPONDENT ANNETTE J. RUFFIN_
The Petitioner established by clear and convincing evidence that Respondent Ruffin failed to properly supervise, direct and control the business activities of Respondent Reaves. When approached by a DPR investigator, Respondent Ruffin was unaware of the many transactions that Respondent Reaves had entered into, although Ruffin was listed as escrow agent on all of the contracts and her company received commissions from the closing of the sales. In light of the economic benefit accruing to Respondent Ruffin's firm, her claim that the transactions of Respondent Reaves were personal and of no concern to her professionally is without merit. Respondent Ruffin admitted that she had no time to supervise Respondent Reaves and that she was basically unaware of what Respondent Reaves was doing until she
began receiving complaints and decided to terminate Respondent Reaves employment. A broker has a clear legal duty to supervise the operations of the salesmen working under the authority of his registration. Dryer v Florida Real Estate Commission, 370 So.2d
95 (Fla. 5th DCA 1979). The Respondent is guilty of culpable negligence as alleged in Count XX of the Administrative Complaint (DOAH Case No. 85-1008/1138).
The Petitioner failed to establish by clear and convincing evidence that Respondent Ruffin failed to provide for inspection business records allegedly maintained in connection with the real estate transactions herein involved. Petitioner failed to establish that any such records were, in fact, maintained by Respondent Ruffin. After a search for the documents, Respondent Ruffin did provide a copy of at least one
$500.00.
DONE and ORDERED this 27th day of March, 1986, in Tallahassee, Florida.
W. MATTHEW STEVENSON, Hearing Officer Division of Administrative Hearings The Oakland Building
Filed with the Clerk of the Division of Administrative Hearings this 27th day of March, 1986.
James H. Gillis, Esquire Division of Real Estate Post Office Box 1900 Orlando, Florida 32801
E. A. Goodale, Esquire 14320 Indian Rocks Road Largo, Florida 33540
Salvatore A. Carpino, General Counsel Department of Professional
