STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

FRIENDS OF THE LAKES, INC., )

)

Petitioner, )

)

vs. ) CASE NO. 88-3056

) ISLEWORTH PARTNERS AND SOUTH ) FLORIDA WATER MANAGEMENT DISTRICT, )

)

Respondents. )

)

RECOMMENDED ORDER

Pursuant to Notice, the Division of Administrative Hearings, by its duly designated Hearing officer, Mary Clark held a hearing in the above styled case on March 7-10, 1989, in Orlando, Florida.

APPEARANCES

For Petitioner: J. Allen Cox, Esquire

105 West 5th Avenue Tallahassee, Florida 32303

For Respondent: Chris H. Bentley, Esquire

W. Douglas Beason, Esquire Rose, Sundstrom & Bentley 2548 Blairstone Pines Drive Tallahassee, Florida 32301

James K. Sturgis, Esquire South Florida Water Management District

Post Office Box 24680

West Palm Beach, Florida 33416-4680 STATEMENT OF THE ISSUES

The central issue in this proceeding is whether the South Florida Water Management District should approve Isleworth Partners' application to modify its existing surface water management permit to raise the elevation of a weir structure at holding pond BE-15, thereby retaining more surface water on site than is retained under the existing permit.

The applicant, Isleworth Partners, contends that the modification is an improvement over the existing permitted system and meets the criteria of the District.

Petitioner, Friends of the Lakes, Inc., argues that the modification is a wholly inadequate solution to multiple water quality and quantity problems created by the development, that the modification will not perform as intended,

that the existing system was not built as permitted, and that the modification does not comply with various Orange County subdivision regulations.

In a series of motion hearings and in a pre-hearing telephone conference conducted on March 6, 1989, the hearing officer ruled that the appropriateness of the original surface water management permit and other permits not timely contested are not at issue. Whether the existing surface water management system was built in accordance with the original permit is relevant only to the extent that it affects an analysis of the modification. Similarly, phosphorus loading, not addressed in the modification, is relevant only to the extent that it relates to excessive nitrate levels in the storm water discharge from ponds BE-15 and BE-16.

Isleworth Partners contests the standing of Petitioner. It also has filed a "Motion for Costs, Attorneys Fees and an Evidentiary Hearing Subsequent to the Entry of the Recommendation Order", pursuant to section 120.59(6), F.S. This motion was filed on May 23, 1989. An earlier motion for sanctions pursuant to section 120.57(1)(b)5. F.S. was filed on September 26, 1988. Consideration of that motion was deferred until the final hearing (see Order dated September 30, 1988). Because it was not raised at the final hearing, it is deemed that Isleworth Partners has abandoned the motion or intended that it be supplanted by the later section 120.59(6), F.S. motion.

PRELIMINARY STATEMENT

On June 7, 1988, Friends of the Lakes, Inc., filed a petition for a formal administrative hearing on Isleworth Partners' application no. 03248-G for modification of surface water management permit no. 48-00201-5. The governing board of the South Florida Water Management District forwarded the petition to the Division of Administrative Hearings on June 20, 1988.

After an extensive hearing on September 26, 1988, on Respondents' motion for summary disposition and various discovery motions, the petition was amended, with leave of the hearing officer, and was refiled on October 4, 1988.

The final hearing was continued twice at the request of the parties.

At the final hearing Isleworth Partners presented the testimony of James T. Shaw, P.E.; George W. Cole, P.E.; Carla Palmer, P.E., accepted as an expert in the field of environmental engineering with an emphasis on lake chemistry and lake water quality; and Ronald Rowalski, P.E., accepted as an expert in the fields of civil engineering, storm water management systems and surface water management system design and operation.

Isleworth Partners' exhibits #1-5 were received in evidence.

In support of its amended petition in opposition to the proposed modification, Friends of the Lakes, Inc., presented the testimony of John Robertson; Donald Greer; Robert Londeree; Ronald R. Potts, accepted as an expert in the field of geology and surface and ground water hydrology; Stephen Robert Miller, P.E.; and Phillip D. Sacco, accepted as an expert in the field of limnology, with specific expertise in water quality analysis, water chemistry analysis and nutrient cycling.

Friends of the Lakes, Inc., offered exhibits #1-32. Exhibits #5 and #6 (1984 and 1985 Orange County Subdivision Regulations) were excluded. Exhibit f17 (table of lake elevations) was withdrawn. Exhibit #27 (2 pages from an

environmental impact statement) was excluded. The remaining exhibits were received in evidence.

The South Florida Water Management District participated through cross examination of witnesses, but presented no witnesses nor evidence of its own.

At its request, and with concurrence by the other parties, official recognition was taken of the District's Permit Information Manual, Volume IV, Management and Storage of Surface Waters.

After the hearing and the preparation of a transcript, each party submitted a proposed recommended order. These have been considered and specific rulings on their proposed findings of fact are found in the attached appendix.

As addressed in the Statement of the Issues above, on May 23, 1989, Isleworth Partners filed a motion for costs, attorney fees and an evidentiary hearing subsequent to the entry of the recommended order. As established in the following findings of fact and conclusions of law, it is recommended that this motion be denied.

FINDINGS OF FACT

1. In 1984, the South Florida Water Management District (SFWMD) issued surface water management permit number 48-00201-5 for a 515 acre project, Isleworth Golf and Country Club, located in southwest Orange County. The permit was issued to the developer, Isleworth Partners.

   
   

2. Sometime after the permit was issued and the system was constructed, nitrate concentrations were detected in holding ponds BE-15 and 16. District staff speculated that the shallow ground water table was contaminated with residual nitrogen left from nutrient applications to a citrus grove previously on the site. They were concerned that the high nitrate ground water was seeping into the storm water storage ponds and would eventually be discharged into adjoining Lake Bessie, thereby affecting the water quality of the lake.

   
   

   Lake Bessie, along with other lakes in the region, was also experiencing rising levels.

   
   

3. On March 24, 1988, Isleworth Partners submitted to the SFWMD its application number 03248-G, to modify the existing surface water management permit, to help prevent the water quality problems from occurring in Lake Bessie, as described above, and to ameliorate and mitigate against increased lake levels in Lake Bessie. It was not intended to provide flood protection for Lake Bessie.

   
   

   The solution proposed in the modification request, as well as in water use permit applications processed at the same time, was to retain substantially more water in storage ponds BE-15 and 16, and to recycle some of the water from those ponds for use in irrigating the golf course.

   
   

4. There were no objections to the water use modifications which were processed with the surface water management permit modification, and the water use modifications were approved by the SFWMD governing board in June 1988. As they affect ponds BE-15 and 16, the water use modifications include pumping the ponds down to a new control level of 97 feet NGVD and using that water to irrigate the golf course.

   This process has already been implemented with beneficial results: the nitrate concentrations in the ponds have been reduced.

   
   

5. The surface water management modification which is the subject of the application at issue is to raise the weir structure from 101.6 to 103 feet NGVD in pond BE-15 to provide complete retention of a 10 year/24 hour storm event without discharge to Lake Bessie from the pond. The under drain system at Pond BE-15 will also be plugged to prevent the existing permitted bleed down of the pond waters into Lake Bessie. This structural modification involves simple construction work and can be completed in one or two days.

   
   

6. Ponds BE-15 and 16 are currently connected by an equalizer pipe, and will remain so. Under the modifications the ponds will be maintained (control elevation) at 97 feet NGVD through the use of existing permitted pumps. The maximum elevation of the ponds will be raised from 101.6 feet to 103 feet NGVD by the alteration of the weir. This means the waters in the ponds would have to top 103 feet to overflow and discharge, by way of an existing pipe, to the swales along Lake Bessie and thence into the lake.

   
   

7. A 10 year/24 hour storm event is the amount of rainfall that will statistically occur in a 24-hour period once every ten years, or ten times in a 100-year period. The amount of rainfall in a 10 year/24 hour storm event is roughly seven and a half inches. The modification proposed by Isleworth Partners is intended to retain the runoff from that storm. Currently, under the system as permitted, only the first inch of runoff must be retained. This is about 2.4 inches of rainfall or approximately a 3-year/1-hour storm event. Substantially more water will be retained in Ponds BE-15 and 16 under the proposed modification.

   
   

8. The staff of SFWMD recommended that the application be granted, with twelve standard limiting conditions and eight special conditions, including the following:

   
   

   * * *

   1. The permittee shall be responsible for the correction of any water quality problems that result from the construction or operation of the surface water management system.

   2. The district reserves the right to require that water quality treatment methods be incorporated into the drainage system if such measures are shown to be necessary.

      * * *

      (Isleworth Exhibit #3, p. 6)

      
      

9. John Robertson, Donald Greer and Robert Londeree reside on Lake Bessie. John Robertson and Donald Greer are members and officers of a nonprofit corporation, the Petitioner in this case, Friends of the Lakes, Inc. These residents are concerned that the level of Lake Bessie has risen in the last few years and that it is becoming polluted. Long standing docks which had been primarily dry are now frequently under water. The residents have observed milky or greenish yellow water discharging from pipes from the Isleworth development.

   
   

   These residents, who are not parties to the proceeding, concede that, if the modification works as intended, the system will be improved and the impact to Lake Bessie Will be lessened.

10. Petitioner, Friends of the Lakes, Inc., questions the reliability of the pumping system to maintain the 97.0 foot control elevation. If the ponds are maintained at a control level of 97.0 feet, the 10 year/24 hour storm water will be retained. If, however, through a series of smaller events, the level is higher than 97.0 feet, less capacity will exist, and the water will discharge sooner to Lake Bessie.

    
    

    The current permitted pump operates at 375 gallons a minute. Depending on whether the pump is operated continuously or part-time, it would take from four to twenty days to pump down the pond from a maximum 103 feet to the 97 foot level.

    
    

    The District found the pumping system to be acceptable at Isleworth because the development has a full-time maintenance staff of 35 people, of whom three work on the pumping system. A maintenance supervisor checks the pumps daily, and the developer has an agreement with a pump company to replace the pump, if needed, within four to six hours.

    
    

    The system is considered reliable and the increased pond holding capacity will insure that more water will be retained than under the existing permitted system.

    
    

11. Stephen Miller is the professional engineer whose firm prepared the application for modification and the original application for the surface water management permit. He is aware of some changes in the project as constructed which differ from his design for the original system. These changes relate specifically to grading on the golf course and not, as suggested by Petitioner, to the operation of ponds BE-15 and 16.

    
    

    Stephen Miller believes that the modifications will do exactly what they are proposed to do. The application for the modifications took into account the existing conditions which differ from the permitted construction plans.

    
    

12. Ronald R. Potts testified for Petitioner as an expert in geology and surface and ground water hydrology. He agrees that the application for modification meets all requirements of the SFWMD with the exception of a single standard condition:

    
    

    * * *

    3. The permittee shall comply with all applicable local subdivision regulations and other local requirements. In addition, the permittee shall obtain all necessary federal, state, local and special district authorizations prior to the start of any construction or alteration of works authorized by this permit

    (Isleworth Exhibit #3, P. 6.)

    
    

13. The district staff report recommending approval for the modification request was sent to Orange County for its review and comment. Orange County made no objections. Within Orange County it is the engineering department which is responsible for the implementation and interpretation of the Orange County subdivision regulations as they apply to storm water management. The SFWMD does not attempt to enforce other agencies' requirements. The Orange County Engineer, George Cole, determined that neither section 10.1.2 nor section 10.4.4(D) of the Orange County Subdivision Regulations were applicable to the modification proposed by Isleworth.

14. Section 10.1.2 requires that recharge to the Floridan Aquifer, where soils are compatible, shall be accomplished by providing for retention of the total run off generated by a 25 year frequency, 24 hour duration storm event from the developed site.

    
    

    Section 10.4.4(D) of the Orange County Subdivision Regulations requires that a pond design detain a 100 year storm event when discharge into a lake without a positive outfall is proposed.

    
    

    When the County first approved Isleworth's Planned Development, it set a specific requirement that the storm water management system retain the first inch of runoff and detain the difference between pre-development and post- development discharge for a 25 year/24 hour storm.

    
    

    "Retention" of storm water means that the water must be held on site and disposed of by some means other than discharge. "Detention" requires only that water be held back for a period of time before discharge.

    
    

15. The Isleworth property is not located in a prime recharge area, as under its soils is a highly impermeable lens, commonly called "hardpan." Lake Bessie has a positive outfall, a pipe connecting Lake Bessie with nearby Lake Down. Although the pipe was plugged with debris for a period of years, it has been cleaned out and the potential exists for outfall from Lake Bessie in flood conditions.

    
    

    The County's 100 year/24 hour detention requirement would still allow the ponds to discharge more water to Lake Bessie than the proposed 10 year/24 hour retention design, and is, therefore, less restrictive.

    
    

16. Lake Bessie presently is one of Florida's most pristine lakes with crystal clear water that is ideal for recreational purposes.

    
    

    The natural dynamic state of lakes is that over a period of time they evolve from oligotrophic, with clear water and a balanced system; to mesotrophic, with less water clarity, more nutrients, increased algae and less desirability for human use; to a eutrophic state, with even less clarity, choking vegetation, less fish and less pleasing appearance and utility. This occurs in a natural state as lakes fill in with decaying matter from the shore.

    
    

    Petitioner claims that discharge from Isleworth will hasten the death of the lake.

    
    

    Phillip Sacco testified for the Petitioner as an expert biologist and limnologist (one who studies fresh bodies of water). He performed a modeling analysis to determine the amount of phosphorus being discharged into Lake Bessie and he opined that the Isleworth development will cause Lake Bessie to change to a eutrophic state. A significant component of his analysis was his assumption that 920 acre-feet of water would be discharged into Lake Bessie as a result of the modification. (transcript pp. 557-558). The 920 acre feet is actually the total amount of water which enters Lake Bessie from the entire Lake Bessie basin, not just from the Isleworth property, and includes both surface water (2%) and ground water (98%). The analysis is discredited by the false assumption.

    
    

    Mr. Sacco also theorized that the interaction of nitrogen and phosphorus precipitated by the change in land use occasioned by the Isleworth development

    would produce deleterious effects on Lake Bessie's water quality: "Nitrogen is the dynamite; phosphorus is the fuse and the land use change of Isleworth is the match."

    
    

    The permit modification application at issue does not relate to a land use change. The change from orange groves to residential development occurred years ago and has already been permitted. In fact, the land change providing the ignition in Mr. Sacco's vivid metaphor is just as likely in the even earlier cultivation of the groves and use of nutrients in their production.

    
    

17. The single result of the modification at issue will be less water being discharged into Lake Bessie than is currently permitted from the system, thus conserving the water quality present in the lake.

    
    

18. The residents who testified are not parties to this proceeding. Although two of them established they are members and officers of Friends of the Lake, Inc., no evidence was produced regarding the corporation, its legal existence or purpose.

    
    

    CONCLUSIONS OF LAW

    
    

19. The Division of Administrative Hearings has jurisdiction in this proceeding pursuant to section 120.57(1), F.S.

    
    

20. In its Petition dated June 6, 1988, and its amended Petition dated October 3, 1988, Friends of the Lakes, Inc., relies on section 120.57(1) F.S. as the basis for requesting a formal hearing on Isleworth Partners' application for permit modification.

    
    

21. An issue as to the standing of the Petitioner to initiate the proceeding was raised early during a hearing related to discovery and other motions conducted on September 26, 1988. Although Petitioner made the requisite allegations regarding its existence, its purpose and the substantial affect on its members, it was on notice that it would be called upon to prove those allegations.

    
    

22. At the final hearing Petitioner produced no evidence of its standing to contest the proposed approval of the permit modification request. Two individuals who were not parties to the proceeding testified they are members and officers of the corporation. They did not assert that they spoke for the corporation or otherwise represented the corporation. They could be members and officers of any number of unnamed nonprofit corporations with the same nonrelevance to this proceeding. The interest of the corporation itself was not addressed and it failed to prove its standing in this proceeding. Farmworker Rights Organization, Inc. v. Department of Health and Rehabilitative Services,

    417 So. 2nd 753 (Fla. 1st DCA 1982); Florida's Home Builders Association v. Department of Labor and Employment Security, 412 So. 2nd 351 (Fla 1982).

    
    

23. Assuming that Petitioner has met its threshold burden of proving standing, Respondent, Isleworth Partners, Inc., as applicant, has the burden of proving its entitlement to the permit it seeks. Florida Department of Transportation v. J.W.C. Company, Inc., 396 So. 2nd 778 (Fla. 1st DCA 1981).

    
    

24. The permit sought here is not for the entire surface water management system, a system already permitted and built, but for a relatively simple modification to that system.

25. In contrast to an enforcement action in which the proper issue might be whether this system is working, the narrow issue here is whether the proposed activity will meet the criteria and requirements of the permitting agency. Friends of the Everglades, Inc. v. Department of Environmental Regulation, 496 So. 2nd 181 (Fla. 1st DCA 1986).

    
    

26. The applicant proved that the modification will do what is intended: retain more water on site than is currently retained, thereby reducing discharge to Lake Bessie and reducing real or potential negative water quality or quantity impact on the lake. The "reasonable assurances" required by Rule 40E-4.301, FAC, have been shown.

    
    

27. The Petitioner failed to prove that any discrepancies between the original system permit and construction of the original system relate to or impact on the design modification sought in this application.

    
    

28. Rule 40R-4.381(2), FAC, requires, among others, the following standard limiting condition to be attached to all permits, except as waived or modified:

    
    

    * * *

    1. The permittee shall comply with all applicable local subdivision regulations and other local requirements. In addition the permittee shall obtain all necessary Federal, State, local and specialized district authorizations prior to the start of any construction or alteration of works authorized by this permit.

       
       

29. Neither this, nor any other cited authority, confer on the water management district a responsibility to enforce local or other agency requirements. This provision puts the applicant on notice that a permit from the district does not automatically confer the right to proceed with its project.

    
    

30. In this case, Orange County is not a party, and whether it is properly enforcing its regulations is irrelevant.

    
    

31. Moreover, the applicant proved that the subdivision regulations which concerned the Petitioner were either not applicable or would be met or exceeded by the increase in capacity of the holding ponds.

    
    

32. Respondent, Isleworth Partners, has filed a motion for costs and fees pursuant to section 120.59(6), F.S., and has requested a separate evidentiary hearing on whether the Friends of the Lakes, Inc., John Robertson, Donald Greer and Robert Londeree participated in the proceeding for an improper purpose, and if so, what appropriate amounts should be awarded. The motion was filed on May 23, 1989, well after the final hearing.

    
    

33. A similar issue was raised much earlier in a motion under section 120.57(1)(b)5., F.S., as discussed in the Issue Statement, above.

    
    

34. Isleworth Partners failed to prove at the section 120.57(1), F.S., hearing that the Petitioner participated in this proceeding for an improper purpose as defined in section 120.59(6)(c) and (e)1. F.S.

35. Section 120.59(6), F.S., does not contemplate a separate hearing, such as that provided for in section 57.111(4)(d), F.S., also relating to the award of fees. Section 120.59(6)(d), F.S. provides:

    
    

    1. In any proceeding in which the hearing officer determines that a party participated in the proceeding for an Improper purpose, the recommended order shall so designate and shall recommend the award of costs and attorney fees.

    
    

    "The recommended order" is plainly the same recommended order emanating from the section 120.57(1), F.S. hearing, and not a separate order later issued.

    
    

36. No cases can be found construing section 120.59(6), F.S., and the commentary cited by Isleworth: Cindy L. Bartin, "Recovery of Attorney's Fees and Costs in Administrative Proceedings" 62 Fla. B.J. 41 (February 1988) acknowledges, at page 44:

    
    

    Although it is clear that the purpose of this provision is to provide a more automatic means to recover attorney's fees, the procedural mechanisms are ambiguous . At present, because of these uncertainties this mechanism does not offer an effective recovery means

    * * *

    Although ambiguous, the new provision in section 120.59 may be appropriate when the nonprevailing party has obviously participated in the proceeding to harass or cause delays or increased costs.

    
    

37. "Improper purpose" is not obvious in the record of this case. Both parties vigorously and competently pursued their claims and defenses through approximately 10 hours of preliminary hearings, countless hours of discovery and approximately 25 hours of final hearing. In their testimony at the final hearing, the residents explained the factual basis for their concerns about the activities of the developer. Significant legal issues were raised with regard to the scope of the proceeding and other matters

    
    

38. That these facts and legal issues may not ultimately be resolved in its favor does not vitiate Petitioner's participation.

    
    

39. Since the individual residents were not parties, they cannot be "nonprevailing adverse parties" and cannot be assessed costs and fees under section 120.59, F.S.

RECOMMENDATION

Based on the above it is hereby RECOMMENDED: that a final order be issued granting the application for permit modification, and denying Isleworth Partners' request for costs and attorney's fees.

DONE AND ENTERED this 17th of August, 1989, in Tallahassee, Leon County, Florida.

MARY CLARK

Hearing Officer

Division of Administrative Hearings The DeSoto Building

1230 Apalachee Parkway

Tallahassee, Florida 32399-1550

(904) 488-9675

Filed with the Clerk of the Division of Administrative Hearings this 17th day of August, 1989.

APPENDIX

Case NO. 88-3056

The following constitute specific rulings on the findings of fact proposed by the parties:

PETITIONER'S PROPOSED FINDINGS:

1-2. Adopted in part in paragraph 9. However, testimony on the dying trees was excluded as beyond the witnesses' expertise.

3-4. Adopted in part in paragraph 2, otherwise rejected as not based on competent evidenc.

1. Adopted in paragraph 3.

2. Adopted in part in paragraph 10, otherwise rejected as unsupported by the evidence. The pumps already exist and are permitted.

3. Rejected as irrelevant

4. Rejected as unnecessary

5. Rejected as inconsistent with the evidence.

6. Adopted in paragraph 12.

7. Rejeceted as unsubstantiated by competent evidence; the proposed fact is also too vague and ambiguous to properly address.

8. Rejected as unsupported by competent evidence.

9. Rejected as irrelevant, unnecessary, or unsupported by competent evidence. 14-15. Rejected as unsupported by the weight of evidence.

1. Rejected as unnecessary.

2. Rejected as contrary to the weight of evidence and irrelevant.

3. Adopted in part in paragraph 16; the contribution by the development is rejected as unsupported by competent evidence.

4. Rejected as unsupported by competent evidence.

5. Addressed in paragraph 16.

6. Rejected as contrary to the evidence.

7. Rejected as irrelevant.

8. Adopted in paragraph 16.

9. Rejected as contrary to the weight of evidence. 25-31. Rejected as irrelevant and unnecessary.

1. Rejected as testimony summarized rather than findings of fact.

2. Rejected as unecessary.

3. Rejected as unnecessary.

RESPONDENT'S PROPOSED FINDINGS: ISLEWORTH PARTNERS

1. Adopted in paragraph 1, except the finding regarding the existing system meeting district requirements is rejected as irrelevant.

2. Adopted in substance in paragraphs 2 and 3.

3-4. Adopted in substance in paragraphs 5 and 6.

1. Adopted in substance in paragraph 7.

2. Rejected as cumulative and unnecessary.

3. Adopted in part in paragraph 9, otherwise rejected as unnecessary.

4. Adopted in substance in paragraph 11.

5. Rejected as unnecessary.

6. Adopted in paragraph 12.

7. Adopted in paragraph 13.

8. Included in conclusion of law #6.

9. Adopted in paragraph 13.

14-19. Adopted in substance in paragraphs 14 and 15.

1. Rejected as unnecessary.

2. Adopted in paragraph 16.

22-25. Adopted in part in paragraph 16, otherwise rejected as unnecessary.

1. Adopted in part in paragraph 4, otherwise rejected as unnecessary.

2. Rejected as unnecessary.

28-31. Adopted in part in paragraph 9, otherwise rejected as unnecessary.

32. Adopted in paragraph 18 and in conclusion of law #2.

SOUTH FLORIDA WATER MANAGEMENT DISTRICT

1-2. Adopted in paragraph 3 and 4.

1. Adopted in paragraph 5.

2. Adopted in paragraph 7.

5-6. Adopted in paragraph 10.

1. Adopted in paragraph 11.

2. Adopted in paragraph 13.

9-10. Adopted in paragraph 14.

1. Adopted in paragraph 16, otherwise rejected as cumulative or unnecessary.

2. Adopted in part in paragraph 14.

COPIES FURNISHED:

J. Alan Cox, Esquire Bogin, Munns & Munns

105 West 5th Avenue Tallahassee, FL 32303

Chris H. Bentley, Esquire

W. Douglas Beason, Esquire Rose, Sundstrom & Bentley 2548 Blairstone Pines Drive Tallahassee, FL 32301

William Doster, Esquire

Lowndes, Drosdick, Doster, et al., PA

P.0. Box 2809 Orlando, FL 32802

James K. Sturgis, Esquire

South Florida Water Management District

P. O. Box 24680

West Palm Beach, FL 33416-4680

Docket for Case No: 88-003056

Orders for Case No: 88-003056