STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

DEPARTMENT OF PROFESSIONAL ) REGULATION, FLORIDA REAL ESTATE ) COMMISSION, )

)

Petitioner, )

)

vs. ) CASE NO. 82-2221

) 82-3278

KARL G. ROEBLING and AD DATA/ ) ORL, INC., )

)

Respondents. )

)

RECOMMENDED ORDER

This matter came on for hearing before the Division of Administrative Hearings by its duly designated Hearing Officer, Robert T. Benton, II, on May 4, 1983. The Division of Administrative Hearings received a transcript of proceedings on May 19, 1983. The record was left open for the filing of an affidavit by petitioner and for a deposition proposed to be taken of one Rod Russell. Petitioner caused an affidavit to be filed on July 26, 1983, but Mr.

Russell was never deposed. By letter dated November 9, 1983, counsel for petitioner advised that efforts to take Mr. Russell's deposition had been abandoned. Nobody appeared on behalf of Ad Data/Orl, Inc. The other parties are represented by counsel:

APPEARANCES

For Petitioner: David P. Rankin, Esquire

Freeman & Lopez, P.A.

4600 West Cypress, Suite 410

Tampa, Florida 33607

and

Frederick H. Wilsen, Esquire

400 West Robinson Street Orlando, Florida 32801

For Respondent: Donald B. Smith, Esquire Roebling 217 North Ivanhoe Boulevard

Orlando, Florida 32804

By administrative complaint filed July 14, 1982, in Case No. 82-2221, petitioner alleged that respondent Ad Data Orl, Inc., "is a licensed corporate real estate broker," that respondent Karl Roebling "is a licensed real estate broker" and that, at all pertinent times, "Roebling was the Active Firm Member for . . . Ad Data Orl, and . . . responsible for the acts and omissions of . . . Ad Data Orl's employee's [sic] and agents."

In count one, the administrative complaint filed in Case No. 82-2221 alleges that "on August 31, 1981, Richard and Claire Schauseil entered into an

advance fee rental agreement with Respondent Ad Data Orl, Inc.," but "decided to cancel the contract" and so notified "the Respondent's office" first by telephone then by written request for refund "received by the Respondents on September 28, 1981"; and that the Schauseils have not received the refund even though they were told "on or about October 14, 1982 [that] the fee would be refunded 'shortly,'" all in violation of "Subsection 475.453(1), Florida Statutes (1981) . . . Subsection 475.453(3)(b), Florida Statutes (1981), and Subsection 475[.]25(1)(e), Florida Statutes (1981)."

In count two, the administrative complaint filed in Case No. 82-2221 alleges that "in the customer commitment [sic] section of the advance fee rental contract provided by the Respondents to the Schauseils the contract requires the customer"

To use the service diligently for no less than

21 days consecutively before requesting any refund of fees paid for services and to make any request for refund in writing directed to the broker.

And that respondents' "21 day waiting period is in violation of Subsection 475.453(1), Florida Statutes. . .of Subsection 475.453(3), Florida Statutes and of Subsection 475.24(1)(e), Florida Statutes."

In count three, the administrative complaint filed in Case No. 82-2221 alleges that "the Respondents have not provided the petitioner with a copy of their [rental data] contract as required by Rule 21V-10.30, Florida Administrative Code. . .and in so doing have violated Subsection 475.25(1)(e), Florida Statutes (1981)."

By administrative complaint filed July 23, 1983, in Case No. 82-3278, petitioner made similar allegations as to the licensure of both respondents. At hearing, counsel for petitioner abandoned count one of the administrative complaint filed in Case No. 82-3278. In count two, the administrative complaint filed in Case No. 82-3278 alleges that respondents "failed to make refund as required by" Rule 21V-10.30, Florida Administrative Code, and were, therefore "guilty of fraud, dishonest dealing by trick, scheme, or device or breach of trust, all within the intent and purview of Subsection 475.24(1)(b) Florida Statutes (1979); and are further guilty of failing to account and to deliver . .

. and . . . of conversion, all within the intent and purview of Subsection 475.25(1)(d), Florida Statutes (1979)." At hearing, counsel for petitioner abandoned count two except as it related to respondents' dealings with one Mary Jill Holland.

In count three, the administrative complaint filed in Case No. 82-3278 alleges that the "form contract supplied and employed by respondents. . .fails to meet the requirements of Rule 21V-10.30]. . .as to type and size" and that the respondents "failed to furnish the DEPARTMENT OF PROFESSIONAL REGULATION. .

1. copy of the contract, or receipt agreement" in violation of the same rule.

   At hearing, counsel for petitioner abandoned count three except as it related to respondents' dealings with Mary Jill Holland.

   
   

   In count four, the administrative complaint filed in Case No. 82-3278 alleges that "on or about September 1, 1981, MARY JILL HOLLAND. . .executed a contract with AD-DATA/ORL. INC.," paid $45 for rental information, and "made a good faith attempt for 21 days to locate an apartment which she desired to rent but was unable to do so"; and that "[w]ithin 30 days of the end of that 21-day

   period, HOLLAND contacted AD-DATA/ORL INC., and demanded [a] refund" but none was paid, in violation of Sections "475.453(1)" and 475.25(1)(b) and (d), "Florida Statutes (1979)."

   
   

   The administrative complaint filed in Case No. 82-3278 on July 23, 1982, was transmitted to the Division of Administrative Hearings for hearing, pursuant to Section 120.57, Florida Statutes (1981). The Division of Administrative Hearings received this administrative complaint on December 3, 1982. By order entered December 13, 1982, Case No. 82-3278 and Case No. 82-2221 were consolidated. Final hearing was set for January 14, 1983, then continued till May 4, 1983, on respondent's motion.

   
   

   At the hearing counsel announced that they had agreed that the record should be left open for inclusion of a deposition that they contemplated taking of one Rod Russell and "an affidavit of the custodian of the records from the Department for the Board of Real Estate." (T. 2) The hearing officer ruled that "the record [be left] open for thirty days for the purpose of receiving the affidavit of the custodian of the Real Estate Commission's records, and for the purpose of receiving a copy of the deposition of Mr. Roebling's lawyer [Rod Russell]." (T. 5) At the close of the hearing, the hearing officer ruled that the time for filing "any proposed recommended order or other written submission [the parties] would like to make" would extend till "fifteen days from receipt of the transcript of the hearing or fifteen days from the filing of the last of the two exhibits for which the record has been kept open, whichever of those dates is later." (T. 63)

   
   

   By letter dated May 26, 1983, counsel for petitioner advised that he "was informed yesterday that Mr. Smith [counsel for respondent Roebling] had decided not to take [the Russell] deposition," but stated that he had noticed Mr.

   Russell for deposition himself and that he would file a "proposed recommended order within 15 days of the transmittal of the transcript of the deposition." In subsequent letters dated July 21, 1983, and September 14, 1983, petitioner's counsel recounted the difficulties he encountered in trying to set up Mr.

   Russell's deposition.

   
   

   By letter dated November 9, 1983, and received by the Division of Administrative Hearings on November 14, 1983, petitioner's counsel advised that he waived "the privilege of submitting a proposed recommended order," after stating:

   
   

   I do not intend to take the deposition of attorney Rod Russell. In the event you haven't done so already, please make a part of the record as my Petitioner's Exhibit the affidavit of Salvatore A. Carpino, [with attachment]. . .which was previously submitted to your office via cover letter of July 21, 1983 signed by Mr. Rankin.

   
   

   On November 16, 1983, respondent Roebling's counsel wrote a letter "making inquiry concerning the purpose of the affidavit" first submitted almost four months earlier. At no time has respondent sought an extension of time in which to file a proposed recommended order. In these circumstances, all parties have waived any right to submit proposed recommended orders.

   
   

   FINDINGS OF FACT

   1. At all pertinent times, respondent Karl G. Roebling was licensed by petitioner as a real estate broker, holding license number 0159045, and the parties so stipulated.

      
      

   2. In January of 1981, respondent Karl G. Roebling met William Fryar, at all pertinent times the owner of all of the stock of Best Move, Inc., which owned, in turn, all of the stock of respondent Ad Data/Orl, Inc. For a new "rental list service" business he was founding, Mr. Fryar "needed a. . .real estate broker. . .[T]he primary concern was that. . .complaints be serviced in an orderly manner." (T. 12) Mr. Roebling understood Mr. Russell, retained as counsel to Ad Data/Orl, Inc., to say that the arrangements proposed by Mr. Fryar were in conformity with Florida law. Mr. Roebling was not aware of any requirement that contract forms be sent to the Florida Real Estate Commission (T. 20), but did ask about the legality of Ad Data/Orl's contracts with customers.

      
      

   3. Mr. Roebling, who lived in Casselberry at all pertinent times, agreed to travel to the Ad Data/Orl office in Orlando and be in the office there four hours a week: from ten till noon Tuesdays and Thursdays. Beginning in late January or early February of 1981, Mr. Roebling did in fact keep these hours and more in Ad Data/Orl's Orlando office. He received compensation of $300 monthly for his efforts. On or about February 19, 1981, he signed a form affidavit of knowledge and consent for multiple certificate of a real estate broker as president of Ad Data/Orl, Inc. This document was submitted to the Board of Real Estate, as it was then known, unnotarized. By his estimate, there were "175 satisfactorily settled complaints during [his] tenure in Orlando. . .about a seven percent complaint ratio." (T. 17) He did not handle moneys himself.

      
      

   4. In May of 1981, Mr. Fryer purchased a similar business in Tampa from a Mr. Pearson. At first, he continued to operate it under an agreement with William Myers, a licensed real estate broker, but the decision was soon made "to make the Tampa operation a branch office of Ad Data/ORL," (T. 22) and Mr. Roebling obtained a branch office license to that end. Under an agreement with Mr. Fryar, Mr. Roebling visited the Tampa office three times a week on average from May or June of 1981, till early October of that year, and handled complaints there just as he did in Orlando. For his work in Tampa, he received an additional $200 monthly. His handling of complaints was in accordance with certain policies known to other Ad Data/Orl employees who assisted him, some of whom in the Tampa office were licensed real estate salespersons. Among these employees, however, "the turnover was brisk." (T. 54)

      
      

   5. By the last week in September, Ad Data/Orl had run up a bill of some eleven and a half thousand dollars at what was then the Orlando Sentinel Star, and Mr. Fryer told Mr. Roebling that "he was going to. . . 'stiff' the Sentinel Star and that other people were benefiting from the bankruptcy laws and now it was his turn." (T. 31) After several arguments with Mr. Fryer, Mr. Roebling resigned from Ad Data/Orl on October 6, 1981, and so advised petitioner by letter written the following day. Respondent's Exhibit No. 1. For about ten days before that, he was denied access to complaints and other records. In fact, Mr. Roebling never had a key to the Tampa office, even though his name and the fact that he was a real estate broker appeared on the window. At no time did he see correspondence from or deal with Mr. Schauseil or Ms. Holland. Complaints had averaged about five per week at the Tampa office, but some weeks there were none. Three days before Thanksgiving, the Tampa office of Ad Data/Orl closed.

   6. At his wife's suggestion, Richard J. Schauseil telephoned Ad Data/Orl's Tampa office on August 31, 1981, then went down, paid a $45 fee, and signed a document that read, in part, as follows:

      
      

      This receipt by Ad Data Orl, Inc. is good for rental information for FOUR MONTHS. Company will use every available source to obtain rental information one of which is local newspapers, however company is not responsible for any misinformation supplied by such sources. No warranties expressed or implied other than as stated herein are made.

      Entering into any document to occupy a rental unit will be solely through the efforts of the prospective tenant [sic] and landlord.

      Company is not responsible for any losses of any nature whatsoever. This receipt is

      non-transferable and non-assignable. Subscription to services is non-cancellable, however company reserves the right to terminate this agreement for customer abuse or misuse of services. Ad Data Orl., Inc. does not appraise, inspect or show property, however rental information will be updated on a timely basis to ensure reasonable accuracy.

      
      

      Company attempts daily contact with all cooperating landlords although customer is reminded that ALL landlords may not be available to be reached every day. Landlords who are not contacted within 72 hours of most recent prior contact will have their properties designated inactive and properties so designated are considered current.

      If the rental information provided under this contract is not current or accurate in material aspect, you may demand within 30 days

      of this contract date a return of the fee paid. If you do not obtain a rental you are entitled to receive a return not to exceed 75 percent

      of the fee paid, if you make demand within 30 days of this contract date.

      CUSTOMER COMMITMENT

      As a purchaser of Ad Data, Orl., Inc. Services I realize that locating a rental unit to suit one's particular needs may not always be accomplished immediately and I hereby agree to make a continuing bona fide effort. 1) to contact the company's above described vacancy department (238-7916 9 a.m. til[l] 6 p.m., closed Sunday) on a daily basis to obtain information on additional rental units. 2) to conscientiously attempt contact with ALL prospective landlords whose phone numbers I receive and 3) To use the service diligently for no less than 21 days consecutively before requesting any refund of fees paid for

      services and to make any request for refund in writing directed to the broker. There is a ten dollar charge to replace lost receipts.

      
      

      Exhibit A to Schauseil deposition.

      
      

      Stamped in red and signed by Mr. Schauseil was the following statement: "I HAVE BEEN TOLD THAT I MUST UTILIZE THIS SERVICE DILIGENTLY IF I EXPECT TO LOCATE A RENTAL. I WILL CALL OR VISIT THE OFFICE OF AD DATA/ORL., INC. FOR 21 DAYS IN A

      ROW OR FORFEIT ANY MONIES PAID FOR SERVICES." "[T]he Department of Professional Regulation employee responsible for reviewing rental company contracts . . .did not review nor receive the [foregoing] contract. . ." Affidavit of Mr. Carpino. 1/ Mr. Schauseil dealt with somebody who gave his name as Eric on August 31, 1981, and at various other times subsequently. After telephoning the Tampa office on 21 consecutive working days, the Schauseils wrote a letter requesting a 75 percent refund and sent it certified mail. After they got a receipt indicating the letter had been signed for by a Brian Ballweg on September 28, 1981, they telephoned and were told that Mr. Roebling would be in Wednesday to approve refunds. The Schauseils never got their refund. When they asked for Mr. Roebling's telephone number in Orlando, the information operator told them there was not one. Then as now Mr. Roebling's home number was listed in the Casselberry-Winter Park directory.

      
      

   7. At one point Eric told Mr. Schauseil that nobody who worked at Ad Data/Orl, Inc. used his real name. Mr. Roebling's denial that he was aware that any Ad Data/Orl employee used an alias has been credited, however.

      
      

   8. On or about September 1, 1981, in Ad Data/Orl's Tampa office, Mary Jill Holland signed a form contract like the one Mr. Schauseil signed, and signed the same statement stamped in red on the form. She, too, telephoned regularly, calling Ad Data/Orl's Tampa office 21 consecutive working days. She sent a certified letter requesting a refund which B. Ballweg signed for on October 1, 1981. In subsequent telephone calls, she was given the runaround but she could not remember having heard Mr. Roebling's name at any time before she was deposed in connection with the present proceedings. She never received a refund.

      
      

      CONCLUSIONS OF LAW

      
      

   9. Petitioner is authorized to ". . . suspend a license for a period not exceeding 10 years,. . .revoke a license, impose an administrative fine not to exceed $1,000 for each count or separate offense, or. . .issue a reprimand, if it finds that the licensee. . .has," Section 475.25(1), Florida Statutes (1981),

      
      

      (b) Been guilty of fraud, misrepresentation, concealment, false promises, false pretenses, dishonest dealing by trick, scheme, or device, culpable negligence, or breach of trust in any business transaction

      
      

      has violated a duty imposed upon him by law or by the terms of a listing contract, written, oral, express, or implied, in a real estate transaction; has aided, assisted, or conspired with any other person engaged in any such misconduct and in furtherance thereof; or

      1. Failed to account or deliver to any person,

         . . .at the time which has been agreed upon or is required by law or, in the absence of a fixed time, upon demand of the person entitled to such accounting and delivery, any personal property such as money, fund, deposit, check, draft,. . .or other. . .thing of value,. . . which has come into his hands and which is not his property or which he is not in law or equity entitled to retain under the circumstances. . .

         
         

      2. Violated any of the provisions of this chapter or any lawful order or rule made or issued under the provisions of this chapter. . .

      
      

      Specifically, petitioner has alleged violations of Section 475.453(1), Florida Statutes (1981), and Rule 21V-10.30, Florida Administrative Code. Both the statute and the rule pertain to furnishing rental information for a fee:

      
      

      Each broker or salesman who attempts to negotiate a rental, or who furnishes rental information to a prospective tenant, for a fee paid by the prospective tenant, shall provide such prospective tenant with a contract or receipt, which contract or receipt contains a provision for the repayment of any amount over

      25 percent of the fee to the prospective tenant if the prospective tenant does not obtain a rental. If the rental information provided by the broker or salesman to a prospective tenant is not current or accurate in any material respect, the full fee shall be repaid to the prospective tenant upon demand. A demand from the prospective tenant for the return of the fee, or any part thereof, shall be made within 30 days following the day on which the real estate broker or salesman has contracted to perform services to the prospective tenant. The contract or receipt shall also conform to the guidelines adopted by the board in order to effect disclosure of material information regarding the service to be provided to the prospective tenant.

      
      

      Section 475.453(1), Florida Statutes (1981).

      
      

      1. Any broker or salesman who attempts to negotiate a rental or who furnishes information to a prospective tenant for a fee paid by the tenant shall provide such prospective tenant with a contract or receipt agreement in writing which contract or receipt agreement must contain the following provision

         or legend in type size 10 point bold or larger:

         NOTICE

         PURSUANT TO FLORIDA LAW:

         
         

         If the rental information provided under this contract is not current or accurate in any material aspect, you may demand within 30 days of this contract date a return of your full fee paid. If you do not obtain a rental you are entitled to receive a return of 75 percent of the fee paid, if you make demand within 30 days of this contract date.

      2. Each contract or receipt agreement shall be contained on one side of one page not larger than 8 1/2 inch x 11 inches. The type size of the balance of the terms of the contract shall be in a size not smaller than 8 point type.

      Each rental data company shall furnish to the Department a copy of its contract or receipt agreement currently being utilized within 30 days of the commencing use of such agreement.

      
      

      Rule 21V-10.30, Florida Administrative Code.

      
      

      Section 475.453(2), Florida Statutes (1981), specifically authorizes promulgation of "a guideline for the form of the contract." Section 475.453(3), Florida Statutes (1981), provides, with respect to brokers who violate Subsection (1), that their real estate licenses "shall be subject to suspension or revocation."

      
      

   10. In a matter as grave as license revocation proceedings, the duty allegedly breached by the licensee must appear clearly from applicable statutes or rules or have a "substantial basis," Bowling v. Department of Insurance, 394 So.2d 165, 173 (Fla. 1st DCA 1981), in the evidence. Disciplinary licensing proceedings like the present case are potentially license revocation proceedings, even in the absence of a recommendation or revocation, since the penalty for the infraction alleged lies within the discretion of the disciplining authority, if allegations of misconduct are established at the hearing. Florida Real Estate Commission v. Webb, 367 So.2d 201 (Fla. 1979). License revocation proceedings have been said to be "'penal' in nature." State ex rel. Vining v. Florida Real Estate Commission, 201 So.2d 487, 491 (Fla. 1973); Kozerowitz v. Florida Real Estate Commission, 289 So.2d 391 (Fla. 1st DCA 1979)(reh. den. 1980).

       
       

   11. At the formal hearing, petitioner had the burden to show by clear and convincing evidence that respondent committed the acts alleged in the administrative complaint. Walker v. State, 322 So.2d 612 (Fla. 3d DCA 1975); Reid v. Florida Real Estate Commission, 188 So.2d 846 (Fla. 2d DCA 1966). See The Florida Bar v. Rayman, 238 So.2d 594 (Fla. 1970).

       
       

   12. Petitioner's allegations against the corporate respondent, to the effect that refunds demanded by the Schauseils and Ms. Holland were wrongfully withheld, were clearly established. Mr. Roebling's responsibility for their not receiving refunds is less clear, however. His testimony that he was never aware of their demands went unrefuted. But he was the sole broker and president of the firm for eight days after the Schauseils' refund demand and for five days

       after Ms. Holland's demand for refund. There is nothing inherently wrong in agreeing to work only four hours a week at an office for which one holds the only individual broker's license, or in agreeing not to handle any moneys, or in not insisting on a key to the office. But, as the sole active firm member, a broker cannot, by those expedients, insulate himself so as to avoid his responsibility to assure that the office is run in strict conformity with the licensing law and pertinent regulations.

       
       

   13. The evidence failed to establish clearly and convincingly that respondents failed to "furnish to the Department a copy of its contract or receipt Rule 21V-10.30, Florida Administrative Code. The affidavit of the departmental employee in evidence does not recite that the Department, as opposed to the affiant himself personally, failed to receive such a document; and the affidavit only addresses the document attached, without speaking to a contract with any other party or an unexecuted contract form. Neither is there a proper record basis to establish a violation of the rule's type size requirements. The pertinent documents are in evidence but no printer testified and there has been no showing otherwise as to what type size has been used.

       
       

   14. The substance of the contracts differs from what the rule requires, however. There is no indication that "Florida Law" imposes the requirements. Respondents have added conditions to refund entitlement not contemplated by the rule, viz., daily contact with their "vacancy department" and 21 consecutive days' use of respondents' "service."

RECOMMENDATION

Upon consideration of the foregoing, it is RECOMMENDED:

1. That petitioner revoke any registration certificate issued to respondent Roebling for AD DATA/ORL, INC.

   
   

2. That petitioner impose an administrative fine against respondent Roebling in the amount of two thousand dollars ($2,000.00)

DONE and ENTERED this 8th day of December, 1983, in Tallahassee, Florida.

ROBERT T. BENTON II

Hearing Officer

Division of Administrative Hearings The Oakland Building

2009 Apalachee Parkway

Tallahassee, Florida 32301

(904) 488-9675

Filed with the Clerk of the Division of Administrative Hearings this 8th day of December, 1983.

ENDNOTE

1/ This is the affidavit about which respondents' counsel inquired nearly four months after its submission. Although it does not recite that the affiant was the custodian of records, the transmittal letter makes clear that it was offered under the parties' agreement on the record at hearing, and respondents have never filed any objection to consideration of the affidavit.

COPIES FURNISHED:

David p. Rankin, Esquire Freeman & Lopez, P.A.

4600 West Cypress, Suite 410

Tampa, Florida 33607

Frederick H. Wilsen, Esquire

400 West Robinson Street Orlando, Florida 32801

Donald B. Smith, Esquire

217 North Ivanhoe Boulevard Orlando, Florida 32804

Randy Schwartz

Assistant Attorney General Department of Legal Affairs Suite 212

400 West Robinson Street Orlando, Florida 32801

Fred M. Roche, Secretary Department of Professional

Regulation

130 North Monroe Street Tallahassee, Florida 32301

Harold Huff, Executive Director Division of Real Estate

Post Office Box 1900 Orlando, Florida 32802

=================================================================

AGENCY FINAL ORDER

=================================================================

STATE OF FLORIDA

DEPARTMENT OF PROFESSIONAL REGULATION FLORIDA REAL ESTATE COMMISSION

DEPARTMENT OF PROFESSIONAL REGULATION, FLORIDA REAL ESTATE COMMISSION,

Petitioner,

vs. CASE NO. 0020810

0020811

KARL G. ROEBLING and DOAH NO. 82-2221 AD DATA/ORL INC., 82-3278

Respondent.

/

FINAL ORDER

The Florida Reel Estate Commission heard this case on January 17, 1984 to issue a Final Order.

Hearing Officer Robert T. Benton II of the Division of Administrative Hearings presided over a formal hearing on May 4, 1983. On December 8, 1983, he issued a Recommended Order, which is adopted by the Florida Real Estate Commission as to all Findings of Fact and Conclusions of Law. A copy of this Recommended Order is attached berate as Exhibit A and made a part hereof.

As to the Recommendation, after a complete review of the record the Florida Real Estate Commission hereby ORDERS that the registration of Respondent Ad Data/Orl Inc. be revoked. It is further ORDERED that Respondent Karl C. Roebling pay a $2000 administrative fine ($1000 for Count I and Count II of the Administrative Complaint) to the Department of Professional Regulation on or before the effective date of this Order. This Order shall be effective thirty

(30) days from the date of filing with the Clerk of the Department of Professional Regulation.

DONE AND ORDERED this 17th day of January 1984 in Orlando, Florida.

Brian J. Ladell, Chairman Florida Real Estate Commission

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was sent by

U.S. Mail to: Donald B. Smith, Esquire, 217 North Ivanhoe Boulevard, Orlando, Florida 32301; to Hearing Officer Robert Benton II, Division of Administrative Hearings, 2009 Apalachee Parkway, Tallahassee, Florida 32301; and to Frederick Wilsen, Staff Attorney, Dept. of Professional Regulation, Post Office Box 1900, Orlando, Florida 32302, this 27th day of January 1984.

Harold R. Huff, Director

Docket for Case No: 82-002221

Orders for Case No: 82-002221