STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

LORETTA SAFF and )

EDWARD B. SAFF, )

)

Petitioners, )

)

vs. ) CASE NO. 91-2879

) DEPARTMENT OF ADMINISTRATION, ) DIVISION OF STATE EMPLOYEES' ) INSURANCE, )

)

Respondent. )

)

RECOMMENDED ORDER

On July 17, 1991, a formal administrative hearing was held in this case in Tampa, Florida, before J. Lawrence Johnston, Hearing Officer, Division of Administrative Hearings.

APPEARANCES

For Petitioners: Bernard C. Silver, Esquire

Barnett Plaza - Suite 2560

101 East Kennedy Boulevard Tampa, Florida 33602

For Respondent: John M. Carlson, Esquire

Senior Attorney

Department of Administration

438 Carlton Building Tallahassee, Florida 32399-1550

STATEMENT OF THE ISSUE

The issue in this case is whether the Respondent, the Department of Administration, Division of State Employees' Insurance, administrator of the State of Florida group health insurance policy, should pay all covered medical expenses incurred by the Petitioners for non-PPC providers on behalf of their dependent daughter that exceed $3,000 1/ maximum out-of-pocket expense stop loss provision of the policy, despite the part of the stop loss provision that subjects it to maximum payments for room and board (and some other services) supplied by non-PPC providers.

PRELIMINARY STATEMENT

On or about April 17, 1991, the Respondent referred to the Division of Administrative Hearings a January 21, 1991, letter from Loretta Saff requesting a formal administrative proceeding on the Respondent's refusal to pay all covered medical expenses incurred by the Petitioners for non-PPC providers on behalf of their dependent daughter that exceed the $1,500, or $3,000 for family

coverage, maximum out-of-pocket expense stop loss provision of the State of Florida group health insurance policy. Later, her husband, Edward B. Saff, was added as a party petitioner.

At final hearing, the Saffs were represented by counsel. They both testified, and they also presented the testimony of an insurance expert. They had Petitioners' Exhibits 1 through 5 admitted in evidence. The Respondent, also represented by counsel, called one witness--William Seaton, the Respondent's Benefits Administrator--and had Respondent's Exhibits 1 through 6 and 8 through 10 admitted in evidence.

At the conclusion of the final hearing, the Respondent ordered the preparation of a transcript of the hearing, and the parties agreed to 15 days after the filing of the transcript for filing proposed recommended orders. The transcript was filed on July 29, 1991, making proposed recommended orders due to be filed by August 12, 1991. Later, the Respondent's unopposed motion to extend the time to August 23, 1991, was granted.

After filing its Proposed Recommended Order, the Respondent filed a Motion for Leave to File Amended Proposed Recommended Order. The Petitioners filed a Motion to Strike Amended Proposed Recommended Order, characterizing the amendments as rebuttal not contemplated by the procedures for administrative adjudication. Whether the additional proposed findings in the Amended Proposed Recommended Order signify rebuttal or simple omissions from the Respondent's Proposed Recommended Order, the Petitioner's Motion to Strike Amended Proposed Recommended Order is granted.

Explicit rulings on the proposed findings of fact contained in the parties' proposed recommended orders may be found in the attached Appendix to Recommended Order, Case No. 91-2879.

FINDINGS OF FACT

1. Pertinent History of the Insurance Plan.

   
   

   1. The State of Florida offers group health insurance to its employees, including employees of the State University System, as an optional fringe benefit. Since 1978, the State has self-insured this coverage. The group health insurance coverage is administered by the Respondent, the Department of Administration, Division of State Employees' Insurance. The Respondent contracts with Blue Cross Blue Shield of Florida as a third party administrator of the insurance coverage. The State pays part of the premium required for the coverage; the balance of the premium is paid by the employee.

      
      

   2. Depending on their county of residence, state employees can choose membership in one of several approved health maintenance organizations (HMOs) in lieu of coverage under the State's health insurance plan. When an employee joins an approved health maintenance organization in lieu of the state health insurance plan, the State contributes to the cost of membership to the same extent that it contributes to an employee's insurance premium under its group health insurance plan.

      
      

   3. Since the State began to self-insure in 1978, coverage under the state group health insurance contained limits on the maximum amount the plan would pay for hospital room and board. The plan also differentiated between the amounts that would be paid under the plan for services rendered by pre-approved "preferred providers" (PPCs). From time to time through the years, the Florida

      Legislature changed the maximum amounts the plan would pay for various services, and the plan was changed accordingly. But in each version of the plan, there was a distinction made between services rendered by a PPC versus services rendered by a non-PPC.

      
      

   4. When the State began to self-insure its employee group health insurance benefit on May 1, 1978, it mailed a new, 25-page certificate of insurance to each employee covered by the plan. Whenever a change in the coverage under the state group health insurance plan was occasioned by new legislation, a revised certificate of insurance was mailed to each employee covered by the plan. This occurred in July, 1982, (a 40-page booklet), in August, 1983, (an eight-page addendum), in August, 1985, (a 13-page booklet), and in July, 1988 (a 13-page booklet).

      
      

   5. Consistent with the master group health insurance policy to which they refer, each of these certificates of insurance are clear that the maximum out- of-pocket "stop loss" feature is subject to certain limitations. In particular, all make clear that the feature is subject to a maximum payment for room and board.

      
      

   6. Each of these certificates of insurance contains language cautioning the employee that the certificate is not a contract of insurance, that the purpose of the certificate is only to summarize the insurance plan, and that the certificate does not include all covered and non-covered benefits. Each also advises that a copy of the complete contract (the master policy), and the administrative rules under which the plan is administered, could be inspected in the office of the Respondent, as well as in the employee's personnel office. Each advises employees to present questions to their agency personel office or to the Office of State Employee's Insurance.

      
      

   7. The August, 1985, certificate of insurance reflects a change in the policy to differentiate between PPC and non-PPC providers. It also clearly states that the maximum out-of-pocket stop loss feature of the policy is subject to maximum payments for room and board (and some other services) supplied by

      non-PPC providers. The July, 1988, certificate also clearly provides that the maximum out-of-pocket stop loss feature of the policy is subject to maximum payments for room and board (and some other services) supplied by non-PPC providers. Both of these certificates were entitled the "State of Florida Employees Group Health Self Insurance Plan Brochure."

      
      

   8. In addition to the certificates of insurance, Blue Cross Blue Shield also printed an abbreviated version of the July, 1988, insurance certificate called the "State of Florida Employees Group Health Self Insurance Plan Benefits." It is a seven-page document intended for distribution, along with information concerning the various available state-approved HMOs, to all new state employees, who have the opportunity to choose to enroll in the state group health plan, in one of the HMOs, or neither. It also was intended for distribution to all employees during open enrollment periods, when employees have the opportunity to change from an HMO to the state group health insurance, or vice versa, or to drop the benefit. The purpose of the "benefits" document was to give employees information on which to make that choice. Since it was anticipated that it would be mailed to many state employees who ultimately would choose against the state group health insurance plan, the information was condensed to shorten the document to save mailing costs. Only if a new employee (or an old employee during the open enrollment period) chose the insurance would the employee get mailed a certificate of insurance in the mail.

   9. Among the information contained in the July, 1988, "benefits" document was an item entitled "Maximum Out of Pocket Expense" that simply listed: "$1500 individual coverage" and "$3000 family coverage." Omitted from the "benefits" document were the limitations on the maximum out-of-pocket stop loss feature (Finding 7, above) and the language cautioning that it was not a contract (Finding 6, above). Under the heading "Exclusions and Limitations," it states: "Complete list in employee brochure." The last two pages of the document contains two lists, one entitled "Limitations," and the other entitled "Exclusions." Neither list specifies the limitations on the maximum out-of- pocket stop loss feature (Finding 7, above). On the cover of the document, it states: "This brochure replaces any other brochure or booklet printed prior to July 1, 1988, relative to the Plan and shall remain in effect until further notice."

      
      

2. The Saffs' Insurance Decision.

   
   

   1. Edward B. Saff has been a mathematics professor at the University of South Florida (USF) in Tampa, Florida, for 22 years.

      
      

   2. The Saffs did not prove that they did not receive copies of the May 1978, July, 1982, August, 1983, August, 1985, and July, 1988, certificates of insurance.

      
      

   3. The Saffs' daughter Lisa, who was born on April 24, 1970, had been diagnosed in June, 1985, as having acute lymphoblastic leukemia. She was treated at the University of South Florida through June, 1988, and seemed to have been cured.

      
      

   4. During the summer of 1988, the Saffs had occasion to consider the question whether they should obtain health insurance other than, and in addition to, their family coverage under the State employees' group health insurance. Although the Saffs did not prove that they had not received their copies of the May 1978, July, 1982, August, 1983, August, 1985, and July, 1988, certificates of insurance, they apparently did not retain them or at least did not have them readily available to consult. As a result, Dr. Saff asked his secretary to get information on the state employees' group health insurance coverage from the USF personnel office.

      
      

   5. The evidence was that the Department of Administration has made a copy of the master group health self-insurance policy, and copies of the certificate of insurance, available in all state agency personnel offices, including in the USF personnel offices, for inspection by state employees. The July, 1988, certificate of insurance states: "The agency personnel office will provide needed assistance to State officers and employees enrolling in the Plan; however, such officers or employees should take care to assure that they receive the coverage applied for and that proper deductions are made." But there was no evidence specifically what Dr. Saff told his secretary to ask of his USF personnel office.

      
      

   6. Dr. Saff's secretary did not testify, and there was no evidence from which a finding can be made as to what the secretary asked for or what the secretary was told by the USF personnel office. But the secretary returned with a copy of the abbreviated version of the July, 1988, insurance certificate (the "State of Florida Employees Group Health Self Insurance Plan Benefits.") Cf. Findings 8 and 9, above.

   7. Based exclusively on the information relayed by Dr. Saff's secretary, i.e., on the abbreviated version of the July, 1988, insurance certificate (the "State of Florida Employees Group Health Self Insurance Plan Benefits"), with its incomplete information under the heading entitled "Maximum Out of Pocket Expense," the Saffs decided that they did not need any additional health insurance coverage for their daughter Lisa. They reasoned that they could afford the maximum out of pocket expense referenced in the document. They did not seek any further information about the policy before making this decision.

      
      

3. The Saffs' Insurance Claim.

   
   

   1. In August, 1990, Lisa Saff underwent a routine gynecological examination, and a pelvic mass was discovered. The mass was removed surgically at Humana Women's Hospital in Tampa. Cancer of the ovaries was diagnosed, but at first the type of cancer was not identified. After more tests, it was determined that Lisa had suffered a recurrence of her previous cancer, but it was highly unusual for that type of cancer to recur in the ovaries. Since the physicians at Humana Women's and at USF were unfamiliar with the recurrence of the cancer in the ovaries, they recommended that Saffs seek medical care at Sloan-Kettering Hospital in New York City, where Lisa began treatment in the early part of September, 1990.

      
      

   2. Since starting treatment at Sloan-Kettering, Lisa has been under the care of Dr. Timothy Gee. She was hospitalized at Sloan-Kettering three times in 1990 and approximately twice in 1991. Fortunately, she has responded to treatment and is now on the maintenance portion of her protocol, receiving treatment as an outpatient of the hospital.

      
      

   3. Sloan-Kettering charges $700 a day for a hospital room and also charges for some other medical services in excess of the PPC fee and charge schedule under the State of Florida Group Health Self Insurance policy. In all, the Saffs have incurred $46,870 for medical treatment for Lisa for 1990. As of the date of the final hearing, they incurred $14,439 for medical treatment for Lisa for 1991. They continue to incur medical expenses for Lisa under her maintenance protocol. They have submitted claims for payment under the state group health insurance policy, including all medical expenses during both 1990 and 1991 by which their out-of-pocket expense exceeded $3000 per calendar year. 2/

      
      

4. The Respondent's Position.

1. In response to the Saffs' claims, the Respondent has taken the position that, in accordance with the master policy and the certificate of insurance, the maximum out-of-pocket stop loss feature of the policy is subject to maximum payments for room and board (and some other services) supplied by

   non-PPC providers. Cf. Finding 7, above. In accordance with that position, the Respondent has paid $18,554 of the Saffs' 1990 claims and $2,162 of the Saffs' 1991 claims. (The Saffs have paid $14,089 of the balance of their 1990 claims and $9,250 of the balance of their 1991 claims.)

   
   

   CONCLUSIONS OF LAW

   
   

2. The State of Florida Group Health Self-Insurance Plan is part of the "comprehensive package of health insurance benefits" authorized by the Legislature to be provided for state employees. Section 110.123(3), Fla. Stat. (Supp. 1990). 3/ It is administered by the Department of Administration under rules promulgated by the Department. Section 110.123(5). To implement the

   program, the Department of Administration, with prior legislative approval, determines the benefits to be provided and the contributions to be required for the state group insurance program. Section 110.123(5)(a).

   
   

3. "Final decisions concerning the existence of coverage or benefits under the state group health insurance plan shall not be delegated or deemed to have been delegated by the department." Section 110.123(5)(e). Under F.A.C. Rule 22K-1.103(23): "Personnel officers or other employees of [any agency of state government] shall not be deemed by the Department of Administration to be agents of any of the [state group insurance plans], the administrator or the Department of Administration."

   
   

4. The decision in Crown Life Ins. Co. v. McBride, 517 So. 2d 660 (Fla. 1987), held that, as an exception to the general rule, promissory estoppel can create a contract of insurance under certain circumstances. 4/ Promissory estoppel "applies to representations relating to a future act of the promisor rather than to an existing fact." Crown Life, at 661-662. "The doctrine, however, only applies where to refuse to enforce a promise, even though not supported by consideration, '"would be virtually to sanction the perpetration of fraud or would result in other injustice." (Citations omitted.)' . . . Such injustice may be found where the promisor reasonably should have expected that his affirmative representations would induce the promisee into action or forbearance substantial in nature, and where the promisee shows that such reliance thereon was to his detriment." (Citation omitted.) Crown Life, at 662.

   
   

5. In Warren v. Dept. of Admin., 554 So. 2d 568 (Fla. 5th DCA 1989), the Department of Administration was held estopped from denying coverage under the State Group Health Self-Insurance Plan. 5/ In that case, a covered employee had decided that he would undergo surgery to reverse a vasectomy only if the procedure was covered by the plan's insurance. He construed advice in the certificate of insurance to direct questions "concerning claims or claims problems" to Blue Cross and Blue Shield as advice to ask for clarification from Blue Cross and Blue Shield as to whether the procedure was covered by the plan's insurance. Following this perceived advice, the employee telephoned Blue Cross and Blue Shield and was told that the hospital costs for the procedure were covered, but not the doctor's care. To be sure, the employee telephoned again and was given the same information by another representative of Blue Cross and Blue Shield. His wife then called and also was given the same information. Based on this information, the employee underwent surgery and made a claim for the hospital costs. The Department of Administration denied the claim under the clear terms of the master policy (as well as the certificate of insurance.)

   
   

6. The Warren opinion recited the established elements of estoppel as including: (1) a representation as to a material fact that is contrary to a later-asserted position; (2) a reasonable reliance on that representation; and

   (3) a change in position detrimental to the party claiming estoppel caused by the representation and reliance thereon. Warren, at 570. It pointed out: "As applied to a state agency, the theory of estoppel is limited to those cases involving exceptional and rare circumstances where state agencies deny benefits because of mistaken statements of fact. " Warren, at 571. It also cited the Crown Life decision for the proposition that promissory estoppel may be utilized to create insurance coverage where to refuse to do so would sanction fraud or other injustice. Id. Then, the Warren court stated: "We hold that because the instant case involves such 'rare and exceptional' circumstances estoppel should be applied against the Department, assuming Blue Cross had the apparent authority to bind the Department." Id. Turning to the question of the apparent

   authority of Blue Cross and Blue Shield to bind the Department, the Warren court held that it did under the facts of that case. 6/

   
   

7. In this case, the kind of circumstances required to estop the Respondent from limiting the stop loss feature of the state group health self- insurance do not exist. Despite Section 120.58(1)(a), Fla. Stat. (1989), it probably can be inferred from the evidence that someone in the USF personnel office gave Dr. Saff's secretary a copy of the abbreviated version of the insurance certificate. But, even assuming that the USF personnel office had apparent authority to answer the Saffs' questions regarding their benefits under the policy, 7/ there was no evidence as to exactly what Dr. Saff's secretary asked of the personnel office or what information the personnel office gave to Dr. Saff's secretary (other than the abbreviated version of the insurance certificate.) It is possible that the personnel office was given to understand that the secretary or Dr. Saff was trying to decide whether to re-enroll in the plan or drop it, perhaps to join an HMO instead. Although utilization of the abbreviated version of the insurance certificate for this purpose clearly is a dangerous practice, 8/ that would not be enough in this case to work a promissory estoppel under the Crown Life decision. There was no evidence that the USF personnel office was told that the Saffs wanted to know about the stop loss feature of the plan, or why. Contrast Warren. Since the Saffs did not prove that they did not receive a copy of the July, 1988, certificate of insurance, and since they made no effort to double check the information in the seven-page abbreviated version of the certificate of insurance, their reliance on it for the purpose of determining whether to buy additional health insurance was not reasonable enough to support an estoppel. Contrast Warren.

   
   

8. The case law cited by the Saffs in support of their position in this case is distinguishable in significant respects.

   
   

   In Rucks v. Old Republic Life Ins. Co., 345 So. 2d 795 (Fla. 4th DCA 1977), the certificate of insurance issued to the insured conflicted on the point in question with the master policy, which the insured never saw. (The certificate of insurance was more beneficial to the insured.) In contrast, in the Saffs' case, the master policy and the certificate of insurance were consistent in limiting the stop loss feature of the insurance plan. The Respondent, as a matter of routine practice, would have issued a certificate of insurance to the Saffs in May, 1978, in July, 1982, in August, 1983, in August, 1985, and in July, 1988. The Saffs did not prove that they did not receive them.

   
   

   In Rucks, in addition, the act of issuing a second policy itself also contradicted the master policy on the point in question.

   
   

   In Providential Life Ins. Co. v. Clem, 403 S.W.2d 68 (Ark. 1966), and Lawrence v. Providential Life Ins. Co., 385 S.W.2d 936 (Ark. 1965), the insured never saw the master policy or any version of the insurance policy other than the insurance application form, and the insurance company was required to provide the insurance for which the insured had applied, and for which the insured had been paying premiums.

   
   

   In Lewis v. Continental Life and Accident Co., 461 P.2d 243, 36 A.L.R.3d

   529 (Idaho 1969), the insurer under a county government's group life insurance policy attempted to utilize a provision in the master policy limiting coverage to those "actively at work" on the effective date of the policy to bar recovery of a $2,000 death benefit. The court observed that, when the county government negotiated the insurance coverage, the purpose was to replace an expiring contract with another insurer, and the insurer agreed to extend coverage to "all

   employees" of the county. The county and the insurer never discussed limiting coverage to employees "actively at work." Noting that the master policy was a contract of adhesion, the court utilized promissory estoppel in "refusing to allow the insurance company to replace the original bilateral agreement with its own unilaterally drafted insurance form." Lewis, 36 A.L.R.3d at 538.

   
   

   The Lewis court also held that the master policy, particularly when read together with the handbook explaining the policy to county employees, was ambiguous as to whether annual proof of continuing disability was necessary for the policy's waiver of premium provision. In addition, the court held that the insurer waived any requirement for annual proof of disability when it notified the beneficiary that adequate proof simply of the deceased's disability would be sufficient to substantiate the claim. Lewis, 36 A.L.R.3d at 539.

   
   

9. Once, under Section 110.123(5), the Respondent decides the contractual benefits to be offered, and they are reduced to writing, the State of Florida and its employees are contracting parties. The Respondent does not have the ability to interpret contractual provisions by rule or non-rule agency policy, as it would a regulatory statute or rule under ordinary principles of administrative law. Cf., e.g., McDonald v. Dept. of Banking and Finance, 346 So. 2d 569 (Fla. 1st DCA 1977). Contractual disputes, such as the one that arose in this case, are decided under traditional contract principles.

In this case, the contract documents (the master policy and the certificate of insurance) are clear that the stop loss feature of the state employee group health self-insurance plan is subject to the maximum payments for room and board (and some other services) supplied by non-PPC providers. The questions (1) whether the seven-page abbreviated version of the certificate of insurance obtained by Dr. Saff's secretary should control over the master policy and the certificate of insurance, or (2) whether the Respondent should be estopped from limiting the stop loss feature of the plan, are determined under the law governing promissory and equitable estoppel in insurance contracts. As reflected in the foregoing Conclusions of Law, the facts of this case do not warrant the application of doctrines of promissory or equitable estoppel against the Respondent.

RECOMMENDATION

Based on the foregoing Findings of Fact and Conclusions of Law, it is recommended that the Respondent, the Department of Administration, Division of State Employees' Insurance, enter a final order (1) giving effect to the provision of the group health self-insurance plan that subjects the maximum out- of-pocket stop loss feature of the policy to maximum payments for room and board (and some other services) supplied by non-PPC providers and (2) paying $18,554 of the Saffs' 1990 claims and $2,162 of the Saffs' 1991 claims.

RECOMMENDED this 19th day of September, 1991, in Tallahassee, Florida.

J. LAWRENCE JOHNSTON 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 19th day of September, 1991.

ENDNOTES

1/ The Saffs seemed confused whether the $3,000 maximum out-of-pocket stop loss provision for family coverage or the $1,500 maximum out-of-pocket stop loss provision for individual coverage applies to them. It is clear that the former provision applies to them.

2/ See footnote 1, above.

3/ All citations to Chapter 110 of the Florida Statutes refer to the 1990 Supplement.

4/ One dissenting opinion would hold to the contrary based on the precedent of Six L's Packing Co. v. Florida Farm Bureau Mutual Ins. Co., 268 So. 2d 560 (Fla. 4th DCA 1972), cert. den., 276 So. 2d 37 (Fla. 1973).

5/ After Warren was decided, the Legislature amended Section 110.123(5)(e) to include the language quoted in Conclusion 2, above.

6/ See footnote 6, above.

7/ See Finding 6, above, for the pertinent facts on this issue; see Conclusion 2, above, for the pertinent law on this issue.

8/ Even though enrollees in the plan receive a copy of the certificate of insurance upon enrollment, the risks involved make the development of the abbreviated version for the purpose of saving postage costs appear perhaps penny wise but pound foolish.

9/ Rulings are made only on proposed findings of fact 1 through 9 contained in the Respondent's original Proposed Recommended Order. See Preliminary Statement.

APPENDIX TO RECOMMENDED ORDER

To comply with the requirements of Section 120.59(2), Fla. Stat. (1989), the following rulings are made on the parties' proposed findings of fact:

Petitioner's Proposed Findings of Fact.

1.-2. Accepted and incorporated.

1. Rejected in part. First, Dr. Saff received it, but through his secretary. Second, the "Benefits Brochure" is not "clear, unequivocal and unconditional" in that it states in part, under the heading "Exclusions and Limitations": "Complete list in employee brochure." Third, it was not proven that, under the circumstances, it was reasonable for the Saffs to rely on the "Benefits Brochure" to determine the extent of their coverage. Otherwise, accepted and incorporated.

2. Rejected as not proven.

3. First two sentences, rejected as not proven. Third sentence, accepted and incorporated.

4. Accepted and incorporated.

Respondent's Proposed Findings of Fact. 9/ 1.-9. Accepted and incorporated.

COPIES FURNISHED:

Bernard C. Silver, Esquire Barnett Plaza - Suite 2560

101 East Kennedy Boulevard Tampa, Florida 33602

John M. Carlson, Esquire Senior Attorney

Department of Administration

438 Carlton Building Tallahassee, Florida 32399-1550

John A. Pieno Secretary

Department of Administration

435 Carlton Building Tallahassee, Florida 32399-1550

Linda Stalvey, Esquire Acting General Counsel Department of Administration

435 Carlton Building Tallahassee, Florida 32399-1550

NOTICE OF RIGHT TO SUBMIT EXCEPTIONS

ALL PARTIES HAVE THE RIGHT TO SUBMIT TO THE DEPARTMENT OF ADMINISTRATION WRITTEN EXCEPTIONS TO THIS RECOMMENDED ORDER. ALL AGENCIES ALLOW EACH PARTY AT LEAST TEN DAYS IN WHICH TO SUBMIT WRITTEN EXCEPTIONS. SOME AGENCIES ALLOW A LARGER PERIOD WITHIN WHICH TO SUBMIT WRITTEN EXCEPTIONS. YOU SHOULD CONSULT WITH THE DEPARTMENT OF ADMINISTRATION CONCERNING ITS RULES ON THE DEADLINE FOR FILING EXCEPTIONS TO THIS RECOMMENDED ORDER.

Docket for Case No: 91-002879

Orders for Case No: 91-002879