STATE OF FLORIDA DEPARTMENT OF EDUCATION
GERARD ROBINSON, as
FILED
AUGUST 24, 2011 2:50 P.M. OFFICE OF THE AGENCY CLERK
Commissioner of Education,
Petitioner,
FLORIDA DEPARTMENT OF EDUCATION
LEADERSHIP ACADEMY (5159),
Respondent.
I
ADMINISTRATIVE COMPLAINT
Gerard Robinson, as Commissioner of Education ("Petitioner" or "Department"), files this Administrative Complaint against Leadership Academy (5159) ("Respondent" or "Leadership Academy") pursuant to§ 120.569, 120.57, 1002.39, 1002.395, 1002.42, and 1002.421, Florida Statutes ("F.S."); Rules 6A-6.03315, 6A-6.0960, and
6A-6.0970, Florida Administrative Code ("F.A.C."), and violation of the settlement agreement entered into between the parties effective November 23, 2010 ("Settlement Agreement"). Petitioner immediately suspends payment and revokes Respondent's eligibility in the John M. McKay Scholarships for Students with Disabilities Program ("McKay") and Florida Tax Credit Scholarship Program ("FTC") (collectively referred to herein as "state sponsored scholarship programs"), seeks costs and attorney fees pursuant to the Settlement Agreement, and imposes other appropriate remedies as provided by law.
Petitioner alleges:
JURISDICTION
At al1 times pertinent hereto, Respondent was a private school participating in the McKay Scholarship Program, providing services to eligible students pursuant to
Filed September 22, 2011 4:07 PM Division of Administrative Hearings
§ 1002.39, 1002.42, and 1002.421, F.S.; and Rules 6A-6.03315, 6A-6.0970, F.A.C.
At all times pertinent hereto, Respondent was a private school participating in the FTC Scholarship Program, providing services to eligible students pursuant to § l 002.395, 1002.42, and 1002.421, F.S., and Rules 6A-6.03315, and 6A-6.0960, F.A.C.
At all times pertinent hereto, Respondent has operated Leadership Academy at 2099 West Prospect Road, Tamarac, Florida; and 6700 SW 7th Street, Margate, FL 33068.
As a private school participating in the McKay and FTC Scholarship Programs, Respondent is required to continually comply with all laws relating to state sponsored scholarship programs and the general regulation of private schools. § 1002.39(8), 1002.395(8), and 1002.421(1), F.S.; Rules 6A-6.03315, 6A-6.0960 (5)(c)-(d), and
6A-6.0970(6)(c)-(d), F.A.C.
Petitioner is responsible for the implementation and operation of the McKay and FTC Scholarship Programs1. § 1002.39, 1002.395, 1002.42, and 1002.421, F.S.;
Rules 6A-6.03315, 6A-6.0960 and 6A-6.0970, F.A.C.
As part of that responsibility, 'Petitioner is required to ensure that private schools participating in the McKay and FTC Scholarship Programs continually comply with all state laws relating to general regulation of private schools. § 1002.39(6)-(7), 1002.395(9) & (11), 1002.42(2), and 1002.421(2), F.S.; Rules 6A-6.03315, 6A-6.0960(7)-(9), and
6A-6.0970(7)-(9) F.A.C.
Petitioner has the authority to immediately suspend McKay and FTC scholarship payments if Petitioner determines that there is probable cause to believe that there is an
1 For a private school that is in the McKay and FTC Scholarship Programs, Petitioner treats a violation of McKay laws/rules as a violation of FTC laws/rules. See, Paragraph 4 of this Administrative Complaint.
imminent threat to the health, safety or welfare of the students, or fraudulent activity on the part of the private school. § 120.569, 120.57, 1002.39(7)(c), and 1002.395(1 l)(c), F.S.; Rules 6A-6.0960(7)(c), and 6A-6.0970(7)(c), F.A.C.
Petitioner has the authority to revoke a private school's participation in these programs if Petitioner determines that the private school has failed to comply with the McKay and FTC Scholarship Program requirements or has otherwise engaged in unlawful activity. § 120.569, 120.57, 1002.39, 1002.39(7), F.S.; I 002.395, 1002.395(11), 1002.42, and 1002.421, F.S.; Rules 6A-6.03315, 6A-6.0960,
6A-6.0960(7), 6A-6.0970, and 6A-6.0970(7), F.A.C.
Petitioner has the authority to immediately suspend payment of scholarship program funds, revoke Respondent's participation in the McKay and FTC Scholarship Programs, and hold Respondent liable for reasonable costs and attorney's fees if
Respondent violates the terms of the Settlement Agreement. See, Settlement Agreement Paragraphs 8, 9, 12, and 14(F)-(H).
MATERIAL ALLEGATIONS
McKay Scholarship Program
The Department re-alleges paragraphs 1-9.
The McKay Scholarship Program affords a disabled student the option of attending a different public school from the one to which he is assigned, or, if he is eligible, the opportunity to receive a scholarship to defray the cost of attending a private
school of choice. Winn v. Muskateer's Academy, Inc., Recommended Order Finding of
Fact #9, DOE-2006-1243, DOAH 06-5074; See,§ l002.39, F.S.; and Rule 6A-6.0970, F.A.C.
Once awarded, a McKay scholarship remains in force until the student returns to public school, graduates, or turns 22, whichever first occurs; provided, however, that he/she does not drop out, which would render the student ineligible for the scholarship.
Id.
To participate in the McKay Scholarship Program, a private school must meet certain conditions. McKay scholarship funding is potentially available to most private schools operating lawfully in the state, for the program is designed to be inclusive in this
regard. Winn v. Muskateer's Academy, Inc., Recommended Order Finding of Pact #10,
DOE-2006-1243, DOAH 06-5074; See,§ 1002.39, 1002.42, and 1002.421, F.S.; Rules 6A-6.0970, and 6A-6.03315, F.A.C.
A private school that wants to participate in the McKay Scholarship Program must notify the Department of its interest and submit information demonstrating compliance with the eligibility requirements. This information - and other data necessary to secure the disbursement of scholarship funds - must be transmitted to the Department electronically, through forms available online to registered users, at a secure website maintained by the Department. To access this site, a private school must first obtain a unique code and establish a confidential password, both of which must be
entered correctly in order to log on to the Department's secure web page. Winn v.
Muskateer's Academy, Inc., Recommended Order Finding of Pact #11, DOE-2006-1243,
DOAH 06-5074; See,§ 1002.39, 1002.42, and 1002.421, F.S.; Rules 6A-6.0970, and 6A-6.03315, F.A.C.
If the parent ofan eligible student chooses the private school option and secures a
place for his child at the private school of choice, then the parent must notify the
Department of his decision before the child begins attending the private school. After receiving such notice, the Department verifies the student's enrollment in the private school, obtains from the private school a schedule of the tuition and fees, and receives from the student's school district a "matrix of services" reflecting the student's special educational needs. Winn v. Muskateer's Academy, Inc., Recommended Order Finding
of Fact #12, DOE-2006-1243, DOAH 06-5074; See,§ 1002.39, F.S.; and Rule 6A-6.0970, F.A.C.
The maximum amount of the McKay scholarship for a particular student is the lesser of (a) the "calculated amount" (which is roughly equal to the estimated cost of educating the student in the public school to which he is assigned) or (b) the actual amount of the private school's tuition and fees. The amount of the student's scholarship is deducted from his public school district's total funding entitlement. Winn v.
Muskateer's Academy, Inc., Recommended Order Finding of Fact #13, DOE-2006-1243,
DOAH 06-5074; See,§ 1002.39, F.S.; and Rule 6A-6.0970, F.A.C.
McKay scholarship payments are made in four equal amounts during the school year to which the scholarship applies. The payment dates are September 1, November I, February 1, and April 1. Payments are made by warrant payable to the student's parent. The Department mails each warrant to the private school of the parent's choice. The parent is required to restrictively endorse the warrant, authorizing the funds to be deposited only in the private school's account. Winn v. Muskateer's Academy, Inc., Recommended Order Finding of Fact #14, DOE-2006-1243, DOAH 06-5074;
See,§ 1002.39, andl002.421, F.S.; and Rule 6A-6.0970, F.A.C.
A student is not eligible for the McKay scholarship while the student is not having regular and direct contact with the student's private school teacher(s) at the school's physical location. Likewise, to be eligible to participate in the McKay Scholarship Program, a private school must maintain in this state a physical location where a scholarship student regularly attends classes. Thus, ahead of each payment (after the
) ,
initial payment2
the private school must verify, through the Department's secure,
password-protected website, that the student continues to be enrolled in and is attending the private school. Winn v. Muskateer's Academy, Inc., Recommended Order Finding
of Fact #15, DOE-2006-1243, DOAH 06-5074; See,§ 1002.39, 1002.39(3)(h) and (8)(d), and 1002.421, F.S.; and Rule 6A-6.0970, F.A.C.
FTC Scholarship Program
The Department re-alleges paragraphs 1-18.
The FTC Scholarship Program enables taxpayers to make private, voluntary contributions so that students who qualify for free or reduced-price school lunches under the National School Lunch Act may receive a scholarship to defray the cost of attending a private school of choice. § 1002.395, F.S.; Rule 6A-06.0960, F.A.C.
Settlement Agreement
The Department re-alleges paragraphs 1-20.
On November 23, 2010, Petitioner and Respondent entered into the Settlement Agreement to resolve Case No. DOE-2010-1983; DOAH Case No. 10-0531. The Settlement Agreement was incorporated into a Final Order of the same date.
2 The first McKay scholarship warrant is provided based on a private school's enrollment of the student for that school year. Rule 6A-6.0970(5)(c)l.-2., F.A.C.
The Settlement Agreement placed Respondent on probation until the end of the 2014-2015 school year. As part of this probation, Respondent agreed to comply with certain terms and conditions as stated therein.
Pursuant to Paragraph 5.B. of the Settlement Agreement, Respondent offered to terminate the employment of Bernita Harrison (or allow to resign, or otherwise discontinue any and all services) and not to re-employ Ms. Harrison while on probationary status. The Department accepted Respondent's offer.
Pursuant to Paragraph 7 of the Settlement Agreement, Respondent agreed to fully cooperate with any investigation regarding the facts as identified in or subsequently discovered surrounding the Administrative Complaint. Respondent agreed to grant access to all records pertaining to and subsequently discovered regarding the Administrative Complaint, facts and proceedings associated therewith, and any records resulting from the Settlement Agreement.
Pursuant to Paragraph 8 of the Settlement Agreement, should the Commissioner determine that Respondent or Shemiah Hale committed perjury regarding the facts and issues that lead to settlement of the· Administrative Complaint, Respondent shall be ineligible to participate in the McKay and FTC scholarship programs.
Pursuant to Paragraph 9 of the Settlement Agreement, should Commissioner determine that Respondent fails to comply with the Settlement Agreement, Respondent shall be subject to notice of noncompliance, termination, and/or immediate suspension of funds from the McKay Scholarship Program. Upon such action being final, neither Respondent (nor any other entity with a majority of the same corporate/board members) nor Shemiah Hale, shall apply or be deemed eligible to participate in the McKay
Scholarship Program, or any other state sponsored scholarship program, for a period of 10 years.
Petitioner Charges:
Student "A"
The Department re-alleges paragraphs 1-27.
On or about August 24, 2010, the student enrolled in Respondent's school.
On or about August 24, 2010, the student started attending Respondent's school.
On or around October 12,2010, the student stopped attending Respondent's school.
Shortly thereafter, the student's parent spoke with Bernita Harrison, who was acting on behalf of Respondent.
The student's parent instructed Bernita Harrison to withdraw the student from Respondent's school. The student withdrew from Respondent's school and did not return.
On January 4,2011, Respondent verified, or had verified, the student's continued enrollment and attendance through.the Department's secure, password-protected website.
Based on Respondent's verification, Respondent received the student's McKay scholarship warrants for February 2011 in the amount of$1,286.00.
When Respondent's school received the February 2011, McKay scholarship warrant, Respondent called, or had called, the student's parent and asked the parent to
· restrictively endorse the warrant. The parent refused to do so.
Respondent forged, or had forged, the parent's restrictive endorsement on the February 2011, McKay scholarship warrant.
On March 11,201!, Respondent verified, or had verified, the student's continued enrollment and attendance through the Department's secure, password-protected website.
Based on Respondent's verifications, Respondent received the student's McKay scholarship warrants for April 2011 in the amount of $1,286.00.
Respondent forged, or had forged, the parent's restrictive endorsement on the April 2011, McKay scholarship warrant.
COUNT 1 -- Respondent Claimed An Ineligible Student During The 2010/2011 School
Year (No Regular & Direct Contact)
The Department re-alleges paragraphs 1-40.
A student is ineligible for the McKay Scholarship Program when the student is not having regular and direct contact with the student's private school's teachers at the school's physical location. § 1002.39(3)(h), F.S.
To be eligible to participate in the McKay Scholarship Program, a private school must maintain in this state a physical location where a scholarship student regularly attends classes. § !002.39(8)(d), F.S.
Regular and direct contact is •;a program of instruction that provides for a minimum of one hundred and seventy (170) actual school instruction days with the required instructional hours (determined by grade level per state board Rule 6A-1.09512, F.A.C.) under the direct instruction of the private school teacher at the school's physical location with occasional off-site activities under the supervision of the private school teacher." Rule 6A-6.03315(1)(c), F.A.C.
A school's physical location is "the location where regular and direct contact with the private school teacher occurs and must meet applicable state and local health, safety, and welfare, laws, codes and rules." Rule 6A-6.033!5(l)(d), F.A.C.
The student did not have regular and direct contact with Respondent's teachers or school from on or about October 12, 2010, through the rest of the 2010/2011 school year. However, Respondent represented to the Department that the student was enrolled and continuously attending its school throughout the remainder of the 2010/2011 school year in order to obtain the February 2011 and April 2011 McKay scholarship warrants.
COUNT 2 -- Respondent Improperly Obtained And/Or Failed To Properly Obtain
Restrictive Endorsements Of McKay Scholarship Warrants
The Department re-alleges paragraphs 1-46.
Respondent must require a parent to restrictively endorse McKay scholarship warrants. § 1002.39(9)(f), and 1002.421(2)(f)2., F.S.
Respondent did not require Student A's parent to restrictively endorse the February 2011 and April 2011 McKay Scholarship warrants.
Respondent forged, or had forged, the restrictive endorsement of the parent(s) on the February and April 2011 McKay Scholarship warrants.
Failure to Comply with Settlement Agreement
COUNT 3 -- Failure to Adequately Train Staff
The Department re-alleges paragraphs 1-50.
Paragraph 5.A., of the Settlement Agreement states that Respondent "shall ensure that involved staff are trained and able to comply with state sponsored scholarship program requirements, including but not limited to, enrolling and re-enrolling students,
ensuring students have regular and direct contact with the LA's [school's] teachers at LA's [school's] physical location, confirming continued student enrollment and attendance, keeping student attendance and other records, and ensuring that parents restrictively endorse warrants."
Upon information and belief, Respondent violated paragraph 5.A. of the Settlement Agreement.
As stated in paragraphs 28-50 of this Administrative Complaint, Respondent represented to the Department that at least one student was enrolled and continually attending Respondent's school for at least two payment periods after the student withdrew from Respondent's school.
In addition to claiming the student, Respondent forged the parent's restrictive endorsement on at least two warrants obtained after the student withdrew from Respondent's school.
By failing to comply with these basic program requirements after execution of the Settlement Agreement, it is clear that Respondent failed to ensure that its staff were either trained or able to comply with state sponsored scholarship program requirements. Thus, Respondent violated the Settlement Agreement.
Most disturbing, claiming students no longer in attendance and forging the parent's restrictive endorsements were two of the allegations that were plead in the administrative complaint that lead to the Settlement Agreement.
In repeating the same fact pattern (that led to the Settlement Agreement), Respondent has demonstrated that these problems are not "clerical" in nature. Rather, these problems are systemic evidence that Respondent is incapable of operating at a basic
level of compliance with the law - or that Respondent is thoroughly grounded in fraudulent activity.
COUNT 4 -- Failure to Comply With Release
The Department re-alleges paragraphs 1-58.
Paragraph 5.B. of the Settlement Agreement states that upon execution of the Settlement Agreement, Respondent will "immediately terminate the employment (or allow to resign, or otherwise discontinue any and all services) of all employees who forged the restrictive endorsement on warrants, including but not limited to Bernita Harrison."3 Furthermore, Respondent will "not re-employ such persons while [Respondent] is on probationary status."
Upon information and belief, Respondent repeatedly violated Paragraph 5.B. of the Settlement Agreement.
Respondent executed the Settlement Agreement on October 4, 2010.
After October 12, 2010, Student "A's" parent spoke to Bernita Harrison and informed Bernita Harrison to withdraw the student from Respondent's school. Bernita Harrison was acting on behalf of Respondent's school at this time.
On or about February, 4,201 l, Bernita Harrison was involved in an incident with a student at Respondent's school. While the student was being restrained in a choke-type hold by another employee, Bernita Harrison beat the student with a belt. This activity was witnessed by other students. Bernita Harrison was acting on behalf of Respondent's school at this time.
3 Bernita Harrison has several aliases. Upon information and belief, she has used Bernita or Bonita for a first name, and Harrison, Gray, Prescott, Williams, Cunningham, Dunkley as a surname.
The parent spoke to "Bernita Gray," who told the parent that she was one of the administrators at Respondent's school.
On February 6, 201 I, the parent took the student to the Coral Springs Police Department to file a complaint. In the police report, the parent identifies "Bernita Gray" as the President of Respondent.
Thus, Bernita Harrison was working or acting in some capacity for Respondent after Respondent executed the Settlement Agreement.
COUNT 5 -- Failure To Cooperate
The Department re-alleges paragraphs 1-67.
Paragraph 7 of the Settlement Agreement states that Respondent "shall fully cooperate with any ... inspection, investigation, prosecution, etc., regarding the facts as identified in or subsequently discovered surrounding the Administrative Complaint."
On March 10, 2011, the Department conducted a site visit of Respondent's school. Laura Harrison, the Director of Scholarship Programs for the Office of Independent Education and Parental Choice at the Department met with Shemiah Hale to discuss the February 4, 2011, incident involving Bernita Harrison.
At the time, Shemiah Hale was Respondent's historical owner/operator. Shemiah Hale informed Laura Harrison that Bernita Harrison had been let go in accordance with the Settlement Agreement.
Shemiah Hale introduced Laura Harrison to Bernita Harrison's sister - Delphine Gray. Shemiah Hale told Laura Harrison that Delphine Gray worked at Respondent's school and was the person the parent was complaining about.
Delphine Gray stated to Laura Harrison that she was the person the parent was referring to in the complaint.
Recently, the Department obtained confirmation from the parents that the person was in fact Bernita Harrison.
Based on the complicity and statements ofShemiah Hale and Delphine Gray, two of Respondent's employees, Respondent failed to comply with Paragraph 7 of the Settlement Agreement.
Fraudulent Activity
COUNT 6 -- Sum of Funds Fraudulently Obtained
The Department re-alleges paragraphs 1-75.
As a result of Respondent's activities noted above, Respondent fraudulently obtained at least $2,572.00 in McKay Scholarship Program funds for at least one student.
Private schools are responsible for the return to the Department of all scholarship funds that are received in error, including for students that were not in attendance.
Rule 6A-6.0970(5)(d), F.A.C.4
Respondent Failed To Comply The General Regulation Of Private Schools
COUNT 7 - Failure to Comply with Background Screening
The Department re-alleges paragraphs 1-78.
As a participant in the McKay Scholarship Program, Respondent is under the continuing obligation to comply with all state laws relating to the general regulation of private schools. § 1002.421(1), F.S., Rules 6A-6.03315, and 6A-6.0970(6)(c)-(d), F.A.C.
4 Even if Respondent makes full restitution of such funds, due to the nature of Respondent's actions, the Department will still immediately suspend payments and tenninate Respondent's eligibility to participate in the McKay Scholarship Program.
One of these requirements is that a private school require each employee or contracted personnel with direct student contact, upon employment or engagement to provide services, to undergo a state and national background screening pursuant to
§ 943.0542, F.S., and deny or terminate employment if the person fails to meet the
screening standards under§ 435.04, F.S. See, § 1002.421(2)(i), F.S.
An "employee or contracted personnel with direct student contact" means any employee or contracted personnel who has unsupervised access to a scholarship student
for whom the private school is responsible. Id.
Continued employment of an employee or contracted personnel after notification that he or she has failed the background screening under this paragraph shall cause a
private school to be ineligible for participation in a scholarship program. Id.
The inability of a private school to meet the requirements of this section shall constitute a basis for the ineligibility of the private school to participate in a scholarship program as determined by the Department. § 1002.421(5), F.S.
Respondent conducted a background check on Bernita Harrison on or about February 9, 2008. The background check identifies a felony conviction of a disqualifying offense per § 435.04, F.S. (possession of cocaine with intent to deliver/sell, a violation of
§ 893.02(2)(a)4., and 893.!3(l)(a)I., F.S.).
Despite knowing this information as early as February 9, 2008, Respondent did not allege to have let Bernita Harrison go until in or around October 2010, when necessary to comply with the Settlement Agreement.
As stated herein, and upon information and belief, Bernita Harrison still works at Respondent's school, which constitutes a continued violation of§ 1002.421(2)(i), F.S.
STATUTORY/RULE VIOLATIONS
For counts 8-16, the Department re-alleges paragraphs 1-87.
COUNT 8: Respondent is in violation of§ 1002.39, 1002.395, 1002.42, and 1002.421, F.S., in that Respondent has failed to comply with laws relating to state sponsored scholarship programs and the general regulation of private schools.
COUNT 9: Respondent is in violation of§ 1002.39(5)(£), and 1002.421(2)(£)2., F.S., in that Respondent has failed to require parents to restrictively endorse McKay Scholarship Program warrants to Respondent.
COUNT 10: Respondent is in violation of§ 1002.42(2), F.S., in that Respondent has failed to properly report in the annual private school survey student enrollment by grade or special group, as well as student attendance records and reports.
COUNT 11: Respondent is in violation of§ 1002.42(2)(g), F.S., in that Respondent has submitted data for a nonexistent school or an institution providing no instruction or training, the purpose of which is to defraud the public.
COUNT 12: Respondent is in violation of§ 1002.42(3), F.S., in that Respondent has failed to maintain permanent and temporary student records.
COUNT 13: Respondent is in violation of§ 1002.42(4), F.S., in that Respondent has failed to keep student attendance records and reports.
COUNT 14: Respondent is in violation of§ 1002.39(3)(h) and (8)(d), F.S., and Rule 6A-6.03315(1)(c)-(d), F.A.C., in that Respondent claimed students who did not have regular and direct contact with the private school's teachers at the school's physical location.
COUNT 15: Respondent is in violation of §1002.421(2)-(5), F.S., in that Respondent failed to comply with background screening requirements.
COUNT 16: Respondent is in violation of§ 1002.395(8)(a), F.S., in that Respondent did not comply with all requirements for private schools participating in state school choice scholarship programs pursuant to §1002.421, F.S.
WHEREFORE, based on the foregoing and pursuant to § 120.569, 120.57, 1002.39, 1002.395, 1002.42, and 1002.421, F.S., and Rules 6A-6.03315, 6A-6.0960, and
6A-6.0970, F.A.C., Petitioner immediately suspends payment of Respondent's scholarship funds for the McKay and FTC Scholarship Programs, terminates Petitioner's eligibility to participate in the McKay and FTC Scholarship programs, seeks costs and attorneys fees pursuant to the Settlement Agreement, and and/or imposes other
appropriate remedies against Respondent provided by law.
EXECUTED on this 81/ day of [Juq ll S. f-
,J
, 2011.
Gerard Robinson, as ommissioner of Education State of Florida Department of Education
325 W. Gaines Street, Suite 1514
Tallahassee, Florida 32399-0400
(850) 245-0505
NOTICE OF RIGHT TO APPEAL
Pursuant to§ 120.569, F.S.; § 120.57, F.S.; and§ 1002.39(7), F.S., Respondent is entitled to dispute this decision through legal administrative procedures. If Respondent wishes to
do so, it must make a written request for an administrative hearing in accordance with the provisions of Chapter 28-106, F.A.C. Pursuant to§ 1002.39(7), F.S., the written request must be received by the Department's agency clerk within 15 calendar days of the date you receive this letter. The written request must be submitted to:
Lynn Abbott, Agency Clerk Department of Education
325 West Gaines Street, Room 1514
Tallahassee, Florida 32399-0400
If Respondent fails to submit the written request within 15 days of receipt of this letter, it will waive the opportunity to contest the decision through administrative proceedings and the Commissioner of Education's decision will be final, subject only to judicial review pursuant to
§ 120.68, F.S. Pursuant to§ 120.573, F.S., Respondent is advised that mediation is not available.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by certified and regular U.S. Mail to:
Dr. Claudette Giscombe 6700 SW 7th Street Margate, FL 33068
this d 1-f day of u.S.t-- , 2011.
