STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

)

RECOMMENDED ORDER

Final hearing in these consolidated cases was held on October 8, 1987, in Melbourne, Florida, before Mary Clark, Hearing Officer of the Division of Administrative Hearings.

The parties were represented as follows:

For Petitioner: David R. Terry, Esquire

Department of Professional Regulation

130 North Monroe Street Tallahassee, Florida 32399-0750

For Respondent: James P. Beadle, Esquire

5205 Babcock Street Northeast Palm Bay, Florida 32905

BACKGROUND AND PROCEDURAL MATTERS

This proceeding arose after three administrative complaints were filed by the Department of Professional Regulation (DPR) in early May 1987, alleging that Walter L. Moyer (Moyer) violated various statutes and rules governing the practice of professional land surveying.

After Moyer requested a formal hearing, the cases were referred to the Division of Administrative Hearings and were consolidated, sua sponte, by an order entered on June 22, 1987. The administrative complaints were amended on September 4, 1987, to include all allegations in a single, three-count complaint. This amendment was approved by an order dated September 22, 1987, which, at the request of the Respondent, specifically preserved the Respondent's right against self-incrimination and the right to decline to testify on any one or all of the separate counts of the amended complaint.

At the commencement of the final hearing, Respondent moved to dismiss counts two and three of the amended complaint, arguing the following:

1. The two counts were not based on probable cause;

2. the alleged wrongs were not grounded in any violation of minimum technical standards governing the profession;

   
   

3. the Department of Professional Regulation investigator, at the time of interview, failed to advise Respondent of his right to remain silent; and

   
   

4. the investigator's notes are inadmissible as hearsay.

The motion was taken under advisement. For reasons described in the recommended conclusions of law, the motion is denied.

Two other procedural matters are addressed in the recommended conclusions of law: a) Petitioner presented the testimony of an expert witness, James E. Beadman, over the objection of Respondent, based on that expert not being included in the response to written interrogatories propounded by Respondent; and b) Respondent Moyer was permitted to testify in his own behalf in response to Count One, over the objection of Petitioner that Respondent's prior assertion of his right against self-incrimination during the discovery stages of the proceeding effectively precluded his later testimony.

DPR presented its case in chief through the testimony of eight witnesses and twelve exhibits, including a deposition of the DPR investigator, John Allan. Moyer's case was presented through his own testimony and through five exhibits. A sixth exhibit, Respondent's #3, was withdrawn as duplicative.

After the preparation of a transcript, both parties submitted proposed recommended orders. Respondent also filed separate proposed findings of fact, a memorandum of law, and objections to Petitioner's proposed recommended order.

These have been carefully considered in the preparation of this recommended order and specific rulings on each proposed finding of fact are included in the attached Appendix. Any proposed finding adopted herein is based on a consideration of the evidence in the proceeding and a weighing of any conflicts in that evidence.

ISSUE

The issues for determination are whether, as alleged in the Amended Administrative Complaint, Walter L. Moyer,

1. violated Section 472.033(1)(g) and (h) F.S. and Rule 21 HH-2.01(3)

   1. by performing a land survey in a negligent or incompetent manner, without due care and without due regard for acceptable professional standards, and

      
      

2. violated Section 472.033(1)(e), (g) and (h) F.S., and Rule 21HH- 2.01(3) and (5) FAC, by providing a false or deliberately inaccurate survey sketch to a client on two separate occasions.

FINDINGS OF FACT

1. Walter L. Moyer has been licensed by the State of Florida as a registered surveyor from approximately August 1977 until present, and holds license number LS 0002828. His address for license purposes is Palm Bay, Florida, in Brevard County.

   
   

   His practice as a surveyor has been primarily in construction-related surveys and lot surveys, with very few parcel surveys.

   THE CHILCOTT SURVEY (COUNT I)

   
   

2. In June 1984, Charles and Robin Chilcott purchased property on Grant Road, in Brevard County, consisting of approximately 1.44 acres of undeveloped land. The Chilcotts acquired the parcel with the intent to construct a home and keep their horses.

   
   

3. Shortly after purchase, the Chilcotts retained Moyer to prepare a boundary survey of the parcel. The cost of the survey was $315.00 including

   $7.50 extra cost for two concrete monuments, rather than iron rods, at the front corners, as requested by the Chilcotts. The survey was performed on July 27, 1984, and Moyer was paid. He furnished the Chilcotts several sketches of survey which he had signed and sealed.

   
   

4. In 1985, the Chilcotts hired a contractor, Casey Jones, and commenced building their house. At the request of Casey Jones, Moyer prepared both the foundation and final surveys. These two surveys were added to the boundary survey on September 26, 1985, and November 23, 1985, respectively.

   
   

   At the time that the field work on the foundation and final survey was done, Moyer detected no problems with the monumentation he had initially set in the boundary survey. He did not see any evidence that the monuments had been disturbed.

   
   

   The final survey shows the house to be 17.35 feet inside the east lot line.

   The Chilcotts wanted at least that distance because the area is zoned agricultural and they did not want the neighbor's livestock close to the house. They also understood that the county required a minimum 10-foot set-back.

   
   

5. In connection with the construction of their home, and in reliance upon Moyer's survey identifying their property's boundary, the Chilcotts installed a well and a fence and had approximately 800 feet of sod planted along the east boundary.

   
   

6. The Chilcotts have since learned that those improvements are not on their property and that their house is, in fact, only 7.25 feet from the lot line.

   
   

7. In May, 1986, David Rothery, a Florida licensed land surveyor, performed a boundary survey of the Donald Waterbury parcel adjacent to and just east of Chilcott's land on Grant Road. Rothery checked and double-checked his field measurements and still found a ten foot discrepancy in the placement of the monuments on the eastern corners of the Chilcott parcel. Those monuments were ten feet too far to the east and were, therefore, placed ten feet within the Waterbury boundaries. He did not observe any indication that the monuments had been moved, and when he placed his corners for the proper boundaries, he found no evidence that monuments had ever been there before.

   
   

   As required, the monuments placed by Moyer had his identification on them.

   Rothery put a dotted line on his survey with the notation, "Apparent survey error on adjoining property by Walter Moyer Land Surveying". Rothery also called Moyer and told him about the discrepancy.

   
   

8. On the morning of May 10, 1986, Moyer went back out to the Chilcott property and discovered that his monuments were ten feet too far to the east.

   He was in the process of moving them when he was confronted by Charles Chilcott. He told Chilcott that an error was made, that he "dropped ten feet". There was

   some discussion about possible remedies such as paying for the well and fence to be moved or buying the ten feet from Waterbury. Chilcott did not let Moyer finish moving the monuments.

   
   

   That night, Chilcott, who had never met Moyer before, but had only communicated by phone or in writing, called Moyer's house and confirmed that it was the same person he had seen moving the monuments.

   
   

9. That was the last time Chilcott spoke with Moyer. Chilcott called Moyer's house several times over the following months, but always reached Mrs. Moyer and his phone calls were not returned.

   
   

   Moyer did contact Waterbury about purchasing the ten foot strip. Waterbury was concerned about how this would affect his eventual ability to build on his lot and refused to sell. Waterbury is not pressing the Chilcotts about their encroachments; he simply expects to have the matter resolved sometime in the future.

   
   

10. By a letter dated 8/18/86, the Chilcotts requested damages of

    $2,500.00 from Moyer, including an estimate of costs to move the well, fence and a power pole and to replace sod. On September 13, 1986, another letter from Chilcott to Moyer listed the same plus additional damages, for a total demand of

    $4,025.00. In a letter to Chilcott dated August 27, 1987, Moyer offered to pay the application fee to seek a variance from the setback requirement and offered to provide a final survey and half the cost of moving the well. The letter denied that the problem was Moyer's fault and said that Moyer believes that the markers were moved between the date the survey was completed and the date of the foundation. The Chilcotts rejected that offer.

    
    

11. No evidence in this proceeding supports Moyer's contention that the Chilcotts or someone else moved the monuments he originally set in 1984. The evidence does establish a strong circumstantial basis for finding that the monuments were not moved, but were incorrectly placed by Moyer at the time that the boundary survey was completed. Setting the monuments properly is an essential component of conducting a boundary survey. Moreover, when a subsequent final survey is done, it is the duty of the surveyor to assure that the original monuments have not been disturbed during construction and site work by a contractor. Assuming that Moyer is correct in his contention that the monuments were moved after they were set by him, but before the foundation was placed, it was his duty to discover that fact. He did not, since his final survey shows that the house is 17.35 feet from the boundary, whereas the house is, in fact, approximately seven feet from the adjoining property.

    
    

12. Except when witness monuments are used, as when a tree or other obstruction sits on a boundary corner, it is a violation of standard surveying practice to place a monument other than where it is shown on the survey drawing. In this instance, the drawing is accurate; as described in the Chilcott deed, the northeast corner of their property is 600 feet from the section corner. There was no need for witness monuments here; yet the east boundary monuments are ten feet off and are 590 feet from the section corner. There is no overlap in the legal descriptions of the Waterbury and Chilcott properties to account for the overlap in monuments discovered by David Rothery, the Waterbury surveyor.

    
    

13. Surveying is a system of checking measurements. Both human and equipment errors in the profession are neither rare nor entirely common. Even the most up-to-date electronic equipment is subject to discrepancies. Checking

    and rechecking field measurements helps alleviate errors. The minimum technical standards developed by and for the profession are intended to reduce errors, although it is not clear that slavish adherence to those principles will absolutely prevent any possibility of error.

    
    

14. When errors do occur, the standard of the profession is to work with the client to resolve the problem. In some cases, this may mean the purchase of the client's property or adjoining property if the party is willing to sell. Moyer's limited offers do not meet the established standards of the profession.

    
    

    THE BURGOON-BERGER SURVEYS COUNTS II AND III

15. On August 21, 1986, Moyer signed and sealed a survey sketch of Lot 22, Block 2245, Port Malabar, Unit 44, in Brevard County Florida for Burgoon-Berger Construction Co. The survey of Lot 22 showed the drawing of an improvement within the boundaries of the lot with a notation, "FOUNDATION FF ELEV 25.86." Next to the date on the survey is the abbreviation, "FND".

    
    

16. The survey was submitted to the Palm Bay Building Department on August 26, 1986, the day before the pre-slab inspection. A pre-slab inspection is done before the slab is poured; therefore, at the time the survey was signed and sealed, the concrete slab had not yet been poured.

    
    

17. On October 20, 1986, Moyer prepared a sketch of survey of Lot 7, Block 1054, Port Malabar Unit 20, in Brevard County, Florida for Burgoon-Berger Construction Co. The survey sketch indicated an improvement within the boundaries of the lot, with the notation, "FOUNDATION FF ELEV 26.87". Next to the date on the survey is the notation "FND". The survey was submitted to the City of Palm Bay on October 28, 1986. The pre-slab inspection was done by the City on October 22, 1986. Again, the survey was signed and sealed before the slab was actually poured.

    
    

18. The notation, "FOUNDATION FF ELEV", is commonly understood to mean "foundation, finished floor elevation". "FND" is commonly understood to mean "foundation". Moyer, himself, has used both notations to signify those common usages. Foundation is generally accepted in the land surveying profession to mean something permanent and constructed, like a concrete slab, not bust the ground or wooden form boards used to guide the pouring of the slab. A survey which depicts an improvement with the note, "FOUNDATION FF ELEV", when the floor has not been finished misrepresents the status of the construction of that project.

    
    

19. Reviewing personnel at the Palm Bay Building Department rejected the surveys and alerted the City's Flood Plain Administrator. That individual, Maria Parkhurst, reported the incidents to the Department of Professional Regulation.

    
    

20. Lots 22 and 7 are both in the flood plain and slab elevation is significant, as the City must assure that federal maximum elevation requirements are met. The City requires the submission of surveys containing slab elevation data.

    
    

21. Banks also rely on foundation surveys submitted by contractors in order to determine the state of construction before the release of a foundation

    draw. That is, before the contractor is entitled to partial payment for his work, the bank needs to know if the work has been done.

    
    

22. Both Moyer and his client, Bergoon-Berger, intended the notation in these cases to mean "finished form", not "finished floor". Burgoon-Berger had Moyer perform a survey after the wooden form boards were constructed, but before the concrete slab was poured, in order to assure that the house was placed properly on the lot.

    
    

    The survey was somehow submitted prematurely to the city, whereas because Moyer and his client intended that the poured slab be re-surveyed before the sketch was submitted.

    
    

23. When the survey for Lot 7 was resubmitted to the City on October 31, 1986, the slab had been poured and, while the elevation remained the same, the size of the fireplace foundation was slightly smaller. The notation, "FOUNDATION FF ELEV" remained the same, with nothing on the face of the survey sketch to indicate that this later version was the finished floor, rather than the finished form.

    
    

24. Moyer no longer uses these abbreviations.

    
    

25. A survey is not valid until it is signed and sealed, but once it is signed and sealed, it signifies to the client and to the public at large that the information provided therein is true and accurate.

    
    

    The standard of professional land survey practice dictates that abbreviations which are not commonly accepted should be explained on the face of the drawing.

    
    

    The professional standards also dictate that even if a client asks for certain information on a survey, in anticipation that other third parties might rely on the survey the professional should either refuse to indicate improvements that do not exist yet or indicate unambiguously that the improvements are intended, but still under construction.

    
    

26. Notwithstanding Bergoon-Berger's and Moyer's intentions with regard to the two surveys at issue, Moyer failed to meet professional standards when he signed and sealed those surveys and released them to his client.

    
    

    CONCLUSIONS OF LAW

    
    

27. The Division of Administrative Hearings has jurisdiction over the parties and subject matter in these cases pursuant to Section 120.57(1) F.S., and Section 455.225(4) F.S.

    
    

28. Section 472.033(1) F.S., provides, in pertinent part:

    
    

    1. Disciplinary proceedings.--

       1. The following acts constitute grounds for which the disciplinary actions in subsection (3) may be taken:

    (e) Making or filing a report or record which the licensee knows to be false, wilfully failing to file a report or record required by state or federal

    law, wilfully impeding or obstructing such

    filing, or inducing another person to impede or obstruct such filing. Such reports or records shall include only those which are signed in the capacity of a registered land surveyor;

    1. Upon proof that the licensee is guilty of fraud or deceit, or of negligence, incompetency, or misconduct, in the practice of land surveying;

    2. Failing to perform any statutory

    or legal obligation placed upon a licensed land surveyor; violating any provision of this chapter, a rule of the board or department, or a lawful order of the board or department previously entered in a disciplinary hearing; or failing to comply with a lawfully issued subpoena of the department.

    
    

29. Respondent is alleged to have violated the following administrative rules of the Board of Professional Land Surveyors:

    
    

    21HH-2.001 Grounds for Disciplinary Proceedings.

    (3) A registered land surveyor shall not be negligent in the practice of land surveying. The term negligence set forth in Section 34(1)(g), Chapter 79-243, Laws of Florida, is herein defined as the failure by a registered land surveyor to utilize due care in performing in a land surveying capacity, to fail or have due regard for acceptable standards of land

    surveying principles, or to fail to follow minimal technical standards for land surveying promulgated by the Board pursuant to Section 36, Chapter 79-243, Laws of Florida.

    (5) A registered land surveyor shall not commit misconduct in the practice of land surveying.

    Registered land surveyors shall be guided in all their professional relations by the highest standards of integrity and shall act in professional matters for each client or employer as faithful agents or trustees.

    Misconduct in the practice of land surveying as set forth in Section 34(1)(g), Chapter 79-243, Laws of Florida, shall include but not be limited to: ...

    (b) being untruthful, deceptive, or misleading in any professional report, statement, or testimony whether or not under oath or omitting relevant and pertinent information from such report, statement or testimony when the result of

    such omission would or reasonably could lead to a fallacious conclusion on the

    part of the client or the general public...

    
    

30. Petitioner is required to prove the allegations of its Administrative Complaint in a license disciplinary case by evidence that is clear and convincing. Ferris v. Turlington, 510 So.2d 292 (Fla. 1987).

    
    

31. Clear and convincing evidence established that Moyer erred in setting the corner monuments for the Chilcott property in 1984.

    
    

    Whether he violated the minimum technical standards in the conduct of his survey is irrelevant. He is not charged with a violation of Chapter 21HH-6 F.A.C., the rules describing those standards. Rather, as provided in the description of negligence found in Rule 21HH-2.001(3) F.A.C., failure to utilize due care and failure to have due regard for acceptable standards of land surveying principles are violations separate and distinct from failure to follow minimal technical standards promulgated by the Board.

    
    

    Competent expert testimony established the acceptable standards of land surveying principles related to the setting of monuments and the duty to determine that monuments were not disturbed prior to conduct of a final survey.

    
    

32. Competent expert testimony also established acceptable standards for resolving a problem with a client when an error has been made. Moyer initially conceded his error in "dropping ten feet" and made some token attempts to resolve the problem. Those attempts do not meet the established standards. This does not mean that the client must be satisfied at any cost, no matter how unreasonable his demands may be. The evidence in this case clearly established that the Chilcotts tried to get Moyer to work with them but quickly were thwarted by his refusal to return phone calls or discuss solutions.

    
    

33. Clear and convincing evidence established that Moyer was guilty of misconduct in the signing and sealing of the foundation surveys of lots 7 and 22, for Bergoon-Berger. He omitted relevant and pertinent information when the omission reasonably could lead to a fallacious conclusion on the part of the general public, as provided in Rule 21HH-2.001(5)(b) FAC. Without an explanation of his abbreviations on the survey, the general public would be led to believe that a slab foundation had been poured at the time that the survey was signed and sealed.

    
    

34. In the preparation of this recommended order the testimony of both DPR expert witnesses, David Rothery and James Beadman, have been considered. Respondent's objection to Beadman's testimony is overruled. The Florida Rules of Civil Procedure, not the criminal procedure rules, relating to discovery are incorporated by reference in administrative proceedings pursuant to Section 120.58(1)(b), F.S. A party who has made a response to discovery that was complete at the time of response is under no obligation to include information thereafter acquired. Fla. R. Civ. P. 1.280(e).

    
    

35. Walter Moyer's testimony at hearing in defense of Count I has also been considered and weighed and Petitioner's objection to that testimony is overruled. In license discipline cases a Petitioner is entitled to assert his privilege against self-incrimination. State ex rel Vining v. Fla. Real Estate Commission, 174 So.2d 487 (Fla. 1973). He may also waive that privilege.

    Hargis v. Fla. Real Estate Commission, 174 So.2d 419 (Fla. 2nd D.C.A. 1965). In other circumstances when the issue is raised prior to final hearing, it may be

    possible to require, as in Hargis, a question-by-question assertion of the privilege during discovery. Here, the issue was not presented for determination until the final hearing. When he chose to testify in his defense to Count I, Respondent was informed that he was submitting to cross-examination on any matter related to that Count. Petitioner was not prejudiced in this case by its inability to discover in advance the substance of Respondent's testimony.

    
    

36. Respondent's motion to dismiss Counts II and III is DENIED: a) Probable cause is a matter for determination by the Board or DPR. Section 455.225(3) F.S. b) As concluded in paragraph 5, above, grounds for discipline exist other than violation of the minimum technical standards governing the profession. The promulgated definitions of negligence and misconduct are broader than simple violation of the technical standards. c) Respondent provides no authority for his assertion that a Miranda-type warning is required when a DPR investigator interviews the subject of a complaint. While "penal in nature", administrative hearings are not criminal proceedings. d) The investigator's notes were not the sole basis for any finding of fact in this Recommended Order. Ample competent, non-hearsay evidence exists to support those findings.

RECOMMENDATION

Based on the foregoing, it is hereby,

RECOMMENDED: That a final Order be issued finding Respondent guilty of Counts I, II and III of the Amended Administrative Complaint and placing him on probation for a period of two years, under such conditions as the Board may deem appropriate, including, but not limited to the participation in continuing professional education courses and the pursuit of a reasonable resolution to the Chilcott's boundary problems arising from the Respondent's negligence in performing their survey.

DONE and RECOMMENDED this 3rd day of December, 1987 in Tallahassee, Florida.

MARY CLARK

Hearing Officer

Division of Administrative Hearings The Oakland Building

2009 Apalachee Parkway

Tallahassee, Florida 32399-1550

(904) 488-9675

Filed with the Clerk of the Division of Administrative Hearings this 3rd day of December, 1987.

APPENDIX

The following constitute my specific rulings on the parties' proposed findings of fact.

Petitioner (Count I)

1. Adopted in Paragraph 1.

2. Adopted in Paragraph 2. 3-4. Adopted in Paragraph 3.

1. Incorporated in Part in Paragraph 1., as to the limitation of experience, otherwise rejected as immaterial.

2. Rejected as immaterial.

3. Adopted in Paragraph 3.

4. Adopted in part in Paragraph 3, otherwise rejected as unnecessary.

9-10. Rejected as unnecessary.

1. Adopted in Paragraph 12.

2. Rejected as unnecessary.

3. Adopted in Paragraph 4.

14-18. Adopted in Paragraph 3 and 4.

1. Adopted in Paragraph 11.

2. Adopted in Paragraph 4.

3. Adopted in Paragraph 5.

4. Adopted in Paragraph 11. 23-28. Adopted in Paragraph 7.

1. Rejected as unnecessary.

2. Adopted in Paragraph 7.

3. Adopted in part in Paragraph 8, however the accurate date is May 10, 1986, and the evidence is inconclusive as to whether Moyer spoke to either of the Chilcotts before coming back. This fact is not material.

32-33. Adopted in Paragraph 8.

34. Rejected as cumulative and unnecessary. 35-37. Adopted in substance in Paragraph 8.

1. Rejected as cumulative and unnecessary.

2. Adopted in Paragraph 9.

3. Adopted in part in Paragraph 9, otherwise rejected as unsubstantiated by competent evidence and immaterial.

4. Adopted in Paragraph 6. 42-43. Rejected as cumulative.

44. Adopted in substance in Paragraph 10. 45-47. Rejected as cumulative.

48-49. Adopted in Paragraph 12.

50-51. Rejected as cumulative and unnecessary.

1. Adopted in Paragraph 13.

2. Rejected as cumulative. 54-55. Adopted in Paragraph 14.

   
   

   (Counts II and III)

   
   

   1. Adopted in Paragraph 1.

   2. Adopted in Paragraph 15.

   3. Adopted in Paragraph 16. 4-6. Adopted in Paragraph 17.

1. Adopted in Paragraph 20.

2. Adopted in Paragraph 21.

3. Rejected as unnecessary.

4. Adopted in Paragraph 18.

5. Adopted in Paragraph 25.

6. Adopted in Paragraph 18.

7. Rejected as cumulative.

8. Adopted in substance in Paragraph 25.

9. Rejected as unnecessary.

10. Adopted in Paragraph 23.

11. Rejected as unnecessary.

12. Adopted in Paragraph 25.

    
    

    Respondent

    
    

    1. Adopted in Paragraph 1. 2-5. Addressed in Background.

1. Adopted in Paragraph 2.

2. Adopted in Paragraph 3. 8-11. Rejected as immaterial. 12-13. Adopted in Paragraph 4.

1. Adopted in Paragraph 5.

2. Adopted in Paragraph 7.

3. Adopted in part in Paragraph 7.

4. Adopted in Paragraph 7.

5. Rejected as contrary to the weight of evidence, except for the fact that the Chilcott house is 7 feet from the boundary. That fact is adopted in Paragraph 6.

19-20. Adopted in substance in Paragraph 8.

1. Adopted in Paragraphs 9, 10, and 14.

2. Adopted in Paragraph 10.

3. Rejected, except as adopted in Paragraph 10. 24-25. Rejected as unnecessary.

1. Adopted in Paragraph 11.

2. Adopted in part in Paragraph 14, otherwise rejected as unsupported by the weight of evidence.

3. Adopted in substance in Paragraph 13.

4. Rejected as immaterial. While the boundary depiction is accurate, the placement of the house is in error on the final and foundation surveys and, of course, the markers are erroneously set.

30-33. Addressed in Background.

34. Adopted in Paragraphs 15 and 17.

35-36. Adopted in part in Paragraph 22, otherwise rejected as contrary to the weight of evidence.

37-38. Rejected as immaterial.

39. Adopted in Paragraphs 19 and 22. 40-44. Rejected as immaterial.

COPIES FURNISHED:

DAVID R. TERRY, ESQUIRE

DEPARTMENT OF PROFESSIONAL REGULATION

130 NORTH MONROE STREET TALLAHASSEE, FLORIDA 32399-0750

JAMES P. BEADLE, ESQUIRE 5205 BABCOCK STREET N. E. PALM BAY, FLORIDA 32905

ALLEN R. SMITH, JR., EXECUTIVE DIRECTOR BOARD OF PROFESSIONAL LAND SURVEYORS DEPARTMENT OF PROFESSIONAL REGULATION

130 NORTH MONROE STREET TALLAHASSEE, FLORIDA 32399-0750

TOM GALLAGHER, SECRETARY

DEPARTMENT OF PROFESSIONAL REGULATION

130 NORTH MONROE STREET TALLAHASSEE, FLORIDA 32399-0750

WILLIAM O'NEIL, ESQUIRE GENERAL COUNSEL

DEPARTMENT OF PROFESSIONAL REGULATION

130 NORTH MONROE STREET TALLAHASSEE, FLORIDA 32399-0750

Docket for Case No: 87-002539

Orders for Case No: 87-002539