STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

PAULINE SEALY COSYNS, )

)

Petitioner, )

)

vs. ) CASE NO. 88-0241F

) FLORIDA DEPARTMENT OF PROFESSIONAL ) REGULATION, DIVISION OF REAL )

ESTATE, )

)

Respondent. )

) JEAN MAXWELL, )

)

Petitioner, )

)

vs. ) CASE NO. 88-0521F

) FLORIDA DEPARTMENT OF PROFESSIONAL ) REGULATION, DIVISION OF REAL )

ESTATE, )

)

Respondent. )

)

FINAL ORDER

Pursuant to notice, this cause came before the undersigned for hearing on the Petitions of Pauline Sealy Cosyns and Jean Maxwell for awards of attorneys fees, by authority of Section 57.111, Florida Statutes. The appearances were as follows:

APPEARANCES

For Petitioners: Ken Oertel, Esquire

Oertel & Hoffman, P.A.

2700 Blair Stone Road, Suite C Tallahassee, Florida 32301

For Respondent: Lee Sims, Esquire

Department of Professional Regulation

130 North Monroe Street Tallahassee, Florida 32301

STATEMENT OF THE ISSUES

The issue to be resolved herein concerns whether the Petitioners are entitled to an award of attorney's fees in this proceeding. Embodied in that general issue are questions concerning whether the Petitioners are the prevailing parties; whether they meet the definition of "small business" parties, including the net worth amounts, enumerated in Section 57.111, Florida

Statutes, as well as whether the disciplinary proceeding against both Petitioners was "substantially justified". See Section 57.111(3)(e) , Florida Statutes.

PRELIMINARY STATEMENT

This cause arose upon the filing of a petition for Award of Attorneys Fees based upon Section 5.7.111, Florida Statutes. The petition arose out of the underlying case of Department of Professional Regulation, Division of Real Estate vs. Robert Charles Hurbanis, Pauline C. Sealy [Cosyn], John M. Parks and Jean Maxwell. DOAH Case No. 86-0140. The Petitioners Pauline Sealy Cosyns and Jean Maxwell are licensed realtors in the State of Florida.

In the Administrative Complaint in the above-mentioned licensure disciplinary case, Ms. Cosyns was charged with two counts of violations of Section 475.25(1)(b), Florida Statutes (fraud, misrepresentation and concealment, etc.) Ms. Maxwell was charged with one count of the same violation. In essence, these violations involved alleged "double-contracts" whereby sellers and buyers in real estate transactions agreed upon a purchase price, and other terms, and memorialized it in an executed contract and then, allegedly at the behest of the buyers, sellers, and Respondents in the above case, then executed a second "bogus contract". This second contract reveals a higher stated purchase price or lower down payment amount, or a combination of both situations, which was then presented to a lender. This allegedly was designed to produce an impression with the lender that a larger loan must be made as a first mortgage than would be the case if the bank were shown the original contract. By this device, the lending institution is typically induced to lend 100% of the amount of the purchase price so that the purchaser does not have to expend any of his own funds or, at least, the lender is induced to finance more of the purchase price than the lender normally would if all facts had been disclosed. It was contended that the true contracts with the true purchase price were kept on file with the real estate office, while the bogus copies were bent to the lending institutions involved for this alleged fraudulent purpose.

Upon the convening of the hearing on the merits of that case, the Administrative Complaint against Ms. Maxwell was dismissed in its entirety and a stipulation was entered between the parties to the effect that Ms. Maxwell had not violated any statutes or rules. Ms. Cosyns was prosecuted on both counts three and five of that complaint and exonerated as to each. Subsequently, the Recommended Order was adopted in its entirety by the Respondent in its final Order. Thereafter, the Petitioners filed the petition for attorneys fees.

The Petitioners produced the despositions of both Petitioners and had them admitted into evidence in this proceeding. The Petitioners called as a witness attorney Chris Bentley to testify to the reasonableness of the attorneys fees involved. Shortly prior to hearing, the Petitioners agreed to submit a complete itemized bill to the Respondent, but the Respondent had not received the complete list of charges until the morning of the hearing. Since the Respondent had had no opportunity to review the charges concerning the issue of the reasonableness of attorneys fees, and in order not to prejudice the Respondent's ability to defend concerning the issue of reasonableness of the fees, the Hearing Officer allowed the Respondent an additional period of time to review those charges and submit written argument or evidence concerning their reasonableness, if indeed the Respondent believed them to be unreasonable. The Respondent Department has filed no objection concerning the reasonableness of the attorneys fees claimed by the Petitioners nor any late-filed exhibit

demonstrating any differing position concerning the amount of a reasonable attorney's fee in each Petitioners' situation.

The Respondent submitted into evidence an investigative report of its investigator, Mr. John Harris, including the contracts at issue, as to the three counts of the complaint involved with these Petitioners, the former respondents. Additionally, Mr. Harris testified on behalf of the Respondent. The parties stipulated that the entire original record in the underlying licensure disciplinary case was admissible in this proceeding and that the Hearing Officer should take official notice of the recommended and final orders entered in that proceeding.

FINDINGS OF FACT

1. The Respondent is an agency of the State of Florida charged with licensing and regulating the practices of real estate salesmen and brokers by the various provisions of Chapter 475, Florida Statutes. Included within those duties is the duty to investigate conduct by realtors allegedly in violation of Chapter 475 and related rules and to prosecute administrative penal proceedings for which probable cause is found as a result of such investigations. At times pertinent hereto, both Ms. Maxwell and Ms. Cosyns, (then Pauline Sealey) were licensed realtors working as independent contractors for Mariner Properties, Inc. and V.I.P. Realty Inc.

   
   

2. The complete file of the underlying proceeding DOAH Case No. 86-0140, was stipulated into evidence. That file included the Administrative Complaint filed against these Respondents and the Recommended and Final Order, which Final Order adopted the Recommended Order. The findings of fact in that Recommended Order are incorporated by reference and adopted herein.

   
   

3. During the Petitioner's case, counsel for Petitioner voluntarily reduced the attorney's fees bills for both Petitioners such that Ms. Maxwell's bill is the total amount of $2,695.50 and Ms. Cosyns' bill is $17,200, rather than the original amounts submitted in the affidavit. Respondent acknowledged in its proposed Final Order that the fees and costs submitted by the Respondent were thus reasonable.

   
   

4. The testimony the Petitioners presented through depositions, transcripts of which were admitted into evidence into this proceeding, was unrefuted. That testimony demonstrates that both Ms. Cosyns and Ms. Maxwell were prevailing parties in the administrative proceeding referenced herein brought by the Respondent, Department of Professional Regulation. They were individually named as Respondents in the Administrative Complaint whereby their professional licenses were subjected to possible suspension or revocation for alleged wrong doing on their part. There is no dispute that they were exonerated in that proceeding and are thus prevailing parties within the meaning of Section 57.111, Florida Statutes. The Petitioners are also "small business parties".

   In that connection, they both were independently licensed Real Estate professionals during times pertinent to the underlying proceeding and were acting in the capacity of independent contractors for all the activities with which the administrative complaint was concerned. Each established that her net worth is below the limit provided by Section 57.111 as an element of the definition of "small business party". The reasonableness of the fees having been established in the manner found-above and the Petitioners having established that they meet the definitional requirements of prevailing small business parties, there remains to be determined the issue of whether the

   proceedings against the two Petitioners were "substantially justified", that is, whether the proceeding had a

   "reasonable basis in law and fact at the time it was initiated by a State agency." See Section 57.111(3)(e), Florida Statutes.

   
   

5. The facts concerning each Petitioner's case regarding the three counts of the Administrative Complaint relating to them are as found in the Recommended Order incorporated by reference herein. Respondent Maxwell was charged in the complaint with having worked in conjunction with an office manager, Mr. Hurbanis of V.I.P. Realty, in conspiring with him to submit a fraudulent real estate sales contract to a lending institution for purposes of financing. This allegedly involved submitting a contract to the lending institution with an inflated purchase price in order to secure one hundred percent financing, the scheme being more particularly described in that portion of the findings of fact in the Recommended Order related to Jean Maxwell.

   
   

6. In fact, Ms. Maxwell did not work in the realty office as charged in the Administrative Complaint, but rather was employed by Mariner Properties, which may have been a related company. The contract in question, although alleged to be fraudulent was, in fact, a bona fide contract which was a legitimate part of the Real Estate transaction submitted to the bank for financing purposes, about which the bank was kept fully advised. All details of the transaction were disclosed to the lender.

   
   

7. Maxwell was specifically charged with concealing the true contract from the lender in order to enhance the percentage of the purchase price that the bank would finance, done by allegedly inflating the purchase price in a second contract submitted to the bank. It was established in the disciplinary proceeding that no such concealment ever took place. In fact, Ms. Maxwell was purchasing a lot from her own employer, Mariner Properties. Two contracts were indeed prepared for the purchase of Lot 69, a single family lot on Sanibel Island. In fact, however, the difference of $42,875 and $49,500 in the stated purchase price, as depicted on the two contracts, was the result of continuing negotiations between Ms. Maxwell and the seller, who was also her employer. The difference in the two prices depicted on the contracts was the result of, in effect, a set-off to the benefit of Ms. Maxwell, representing certain employee discounts and real estate commission due from the employer and seller to Ms. Maxwell, the purchaser. As Petitioners' composite Exhibit 5 reflects, the lender involved, North First Bank of Ft. Myers, Florida, was fully apprised of all the details concerning this transaction at the time it was entered into and the loan commitment extended and closed.

   
   

8. Mr. Allan Barnes, the Assistant Vice President of North First Bank revealed, in the letter contained in this exhibit in evidence, that there was no concealment or misrepresentation of the facts to his institution by Ms. Maxwell. This letter is dated April 18, 1984. The other related letter in that exhibit, of May 2, 1984 from attorney Oertel to attorney Frederick H. Wilson of the Respondent agency, thus constitutes notice to the agency well before the complaint was filed, that no concealment or misrepresentation to the lender involved had occurred and the charges were requested to be dismissed.

   
   

9. In spite of the fact that the agency was on notice of this turn of events well before the filing of the Administrative Complaint, it proceeded to file the complaint and to prosecute it all the way up to the date of hearing, requiring Ms. Maxwell's attorney to attend the hearing to defend her interests. At the hearing, counsel for the Department acknowledged that there was no basis for prosecuting Ms. Maxwell and voluntarily dismissed the complaint as to her.

   The Respondent's witness, Investigator Harris, in his deposition taken September 11, 1984, acknowledged that he did not discuss any details concerning the investigation, with attorney Frederick Wilson, who prepared the complaint, nor did he confer with him by telephone or correspondence before the filing of the complaint. Therefore, the complaint was prepared solely on the basis of the investigative report.

   
   

10. The investigative report came into evidence as Respondent's Exhibit 1. It reveals that Mr. A. J. Davis the president of Mariner Group and Mariner Properties, who was Jean Maxwell's employer and the owner of the lot in question, signed one contract and his Executive Vice President signed the other. In spite of this, the investigative report does not reveal that the investigator conferred with either Ms. Maxwell, or the sellers concerning this transaction. He conducted a general interview of A.J. Davis concerning the alleged "problem" in his office of "double contracting," but asked him no questions and received no comment about the Jean Maxwell transaction whatever. Nor did the investigator confer with Mr. Allen Barnes or any other representative of North First Bank.

    If the investigation had been more complete and thorough, he would have learned from Mr. Barnes, if from no one else, that the bank had knowledge of both contracts and all details of the transaction underlying them and there had been no concealment or misrepresentation of the facts regarding the transaction by Ms. Maxwell. This information was learned by attorney Oertel as early as April 18, 1984 by Mr. Barnes' letter, referenced above, and it was communicated to the agency by Mr. Oertel on May 2, 1984. Nevertheless, the complaint was filed and prosecuted through to hearing.

    
    

11. Therefore, the prosecution and filing of the Administrative Complaint were clearly not substantially justified. If the Department had properly investigated the matter it would have discovered the true nature of the transaction as being a completely bona fide real estate arrangement.

    
    

12. Former Respondent, Pauline Sealy Cosyns was charged with two counts, III and V, in the Administrative Complaint at issue. One count alleged, in essence, that Ms. Sealey had engaged in a similar fraudulent contract situation regarding the sale of her residence to a Mr. and Mrs. Thomas Floyd. The evidence in that proceedings revealed no concealment of any sales contract occurred whatever with regard to the lending institution or anyone else. The facts as revealed at hearing showed Ms. Cosyns and the Floyds, through continuing negotiations after the original sales contract was entered into, amended that contract and executed a second one, in order to allow Ms. Cosyns to take back a second mortgage from the Floyds. This was necessary because Mr. Floyd, an author, was short of the necessary down payment pursuant to the terms of the original contract, because his annual royalty payment from his publishers had not been received as the time approached for closing. The second contract was executed to allow for a second mortgage in favor of the seller, Ms. Cosyns, in order to make up the amount owed by the Floyds on the purchase price agreed upon, above the first mortgage amount. The testimony and evidence in the disciplinary proceeding revealed unequivocally that the lending institution, Amerifirst Mortgage Company, was fully apprised of the situation and of the reason for the two contractual agreements. The $24,000 second mortgage in question is even depicted on the closing statement issued by that bank. There was simply no concealment and no effort to conceal any facts concerning this transaction from the lender or from anyone else.

    
    

13. The investigation conducted was deficient because the investigator failed to discuss this transaction with the lender or with the purchasers. He discussed the matter with Ms. Sealy-Cosyns and his own deposition testimony

    reveals, as does his investigative report, that he did not feel that he got a complete account of the transaction from her. She testified in her deposition, taken prior to the instant proceeding, that she indeed did not disclose all facts of the transaction to him because she was concerned that he was attempting to apprehend her in some "legal impropriety". Therefore, she was reluctant to be entirely candid. The fact remains, however, that had he conducted a complete investigation by conferring with the lender and the purchasers, he would have known immediately, long before the Administrative Complaint was filed and the matter prosecuted, that there was absolutely no basis for any probable cause finding that wrong-doing had occurred in terms of Section 475.25(1)(b), Florida Statutes. Thus, the facts concerning the prosecution as to Count III against Pauline Sealy-Cosyns, as more particularly delineated in the findings of fact in the previous Recommended Order, reveal not only that Ms. Cosyns was totally exonerated in the referenced proceeding, but that there was no substantial basis for prosecuting her as to this count at all.

    
    

14. Concerning Count V against Ms. Cosyns, it was established through the evidence at the hearing in the disciplinary case that she was merely the listing agent and did not have any part to play in the drafting of the contract nor the presenting of it to the lender. Because there was no evidence adduced to show that she had any complicity or direct involvement in any fraudulent conduct with regard to the transaction involved in Count V of the Administrative Complaint at issue she was exonerated as to that count as well. It is noteworthy here that a statement was made by counsel for the agency, appearing at pages 20 and 21 of the transcript of the proceeding involving the Administrative Complaint, which indicates that the agency, based upon its review of certain documents regarding Counts III and V, before hearing, felt that indeed there might not be a disputed issue of material fact as to Mrs. Cosyns. The agency, although acknowledging that a review of the documents caused it to have reason to believe that it was unnecessary to proceed further

    against Ms. Cosyns nevertheless did not voluntarily dismiss those counts and proceeded through hearing.

    
    

15. Be that as it may, the investigation revealed that Ms. Cosyns acknowledged that she knew that there were two contractual documents involved, but the investigation also revealed that Ms. Cosyns was only the listing agent. The selling agent was Mr. Parks. The investigation revealed through interviews with Ms. Cosyns, Mr. Parks and Mr. Hurbanis, the office Manager of V.I.P. Realty, that Ms. Cosyns, as listing agent, was merely present when the offer from the buyers was communicated to the office manager, Mr. Hurbanis, and ultimately to the sellers, the Cottrells. There was no reason for the investigator to believe that Ms. Cosyns had anything to do with the drafting of the contracts nor with the communication of them to the lending institution involved. That was done by either Mr. Parks or Mr. Hurbanis or by the buyers. The investigation (as revealed in the investigative report) does not show who communicated the contract in question to the lender. The investigation was simply incomplete. If the investigator had conferred with the buyers, the sellers and especially the lender, he could have ascertained-whether the lender was aware of all the facts concerning this transaction and whether there was any reason to believe that Ms. Cosyns had anything to do with the arrangement and the details of the transaction.

    
    

16. It was ultimately established, by unrefuted evidence at hearing, that indeed Ms. Cosyns did not have anything to do with the transaction, nor the manner in which it was disclosed to the lender. The fact that she was aware that two contracts had been prepared did not give a reasonable basis for the investigator to conclude that she had engaged in any wrong-doing. The report of

    his interviews with Ms. Cosyns, Mr. Hurbanis and Mr. Parks, as well as Donna Ross, does not indicate that he had a reasonable basis to conclude that Ms. Cosyns had engaged in any fraudulent conduct with regard to the transaction, including the conveyance of a bogus contract to the lending institution involved, nor for that matter, that Mr. Hurbanis or Mr. Parks engaged in such conduct.

    
    

17. In order to ascertain a reasonable basis for concluding whether Ms. Cosyns was involved in any wrongful conduct, he would have had to obtain more information than he did from these people or confer with the lender, the buyer or the seller, or all of these approaches, before he could have a reasonable basis to recommend to the prosecuting agency that an Administrative Complaint be filed against her concerning this transaction. In fact, he did not do so, but the Administrative Complaint was filed and prosecuted through hearing anyway, causing her to incur the above-referenced attorney's fees. It thus has not been demonstrated that there was any substantial basis for the filing and prosecution of Count V of the Administrative Complaint against Ms. Cosyn. Thus she is entitled to the attorneys fees referenced above with regard to the prosecution of the Administrative Complaint in question.

    
    

    CONCLUSIONS OF LAW

    
    

18. The Division of Administrative Hearings has jurisdiction of the subject matter of and the parties to this proceeding.

    
    

19. Section 57.111, Florida Statutes, permits the award of attorneys fees to a prevailing party if the various elements of entitlement are proven, up to the amount of $15,000. Attorneys fees up to this amount are allowed for parties who have been "prevailing small business parties" in proceedings initiated by state agencies.

    
    

20. There is no question, based upon the evidence presented and the above Findings of Fact that both Ms. Cosyns and Ms. Maxwell were "prevailing parties" in the administrative proceeding underlying this action. They were both individually named as Respondents in an Administrative Complaint alleging wrongdoing on their part. Their professional licenses were subject to suspension or revocation in the prosecution of their defense against the Department of Professional Regulation's action against them. They were successful in obtaining both a Recommended Order and a Final Order dismissing all counts of that complaint.

    
    

21. Section 57.111, Florida Statutes, also limits such fee awards to persons or entities who are "small business parties." Both Ms. Maxwell and Ms. Cosyns meet that requirement since they were both independently licensed real estate professionals, who were acting in the capacity of independent contractors as to all the activities concerning them which were the subject of the Administrative Complaint filed against them. Their personal net worth also falls within the allowance set within that statute, and they comply with Section

    57.111 as to all aspects of their businesses.

    
    

22. The only disputed portion of the statutory test for attorney's fee entitlement consists of the question of whether the proceedings brought against both Cosyns and Maxwell were "substantially justified." That term is defined in Section 57.111(3)(c) to mean that the proceeding had "a reasonable basis in law and fact at the time it was initiated by a state agency."

23. The Department was given a certain period of time after the hearing in this matter in order to take a position on the issue of the reasonableness of the amount of attorneys fees sought by petitioners. The Department ultimately made no objection as to the reasonableness of the fees sought. Thus, the petitioners offered the only evidence as to the amount of fees and the Department did not contradict it.

    
    

24. Concerning the issue of "substantial justification," Respondent Maxwell was charged, in effect, with having concealed the "real contract" from the bank in order to enhance her percentage of the purchase price that would be financed by the lender, based upon the alleged fraudulent contract. In fact, the uncontradicted evidence in the underlying proceeding showed that no concealment took place as to that transaction and that had the Department's investigator investigated it fully and conferred with the lender's representative and even the seller, the Department would have discovered the true nature of the transaction and its bona fide character. It could thus have avoided incurring the trouble and expense for itself, and especially for these petitioners, in initiating the subject proceeding.

    
    

25. Concerning the two counts involving fraudulent contracting related to Ms. Cosyns, one count alleged that she had entered into such a fraudulent contract involving the sale of her own residence to the Floyds. The evidence in the proceeding concerning the Administrative Complaint established that no fraudulent conduct with respect to any sales contract had occurred. The lending institution was aware of all the details of the transaction. In fact, Ms. Cosyns and the Floyds had amended the original sales contract simply to allow Ms. Cosyns to take back a second mortgage from Floyds as an assistance to them in being able to purchase the house. The lending institution knew of the amendment to the contract, was fully advised about it and approved it. It made the loan with full knowledge of the amendment to the contract concerning the second mortgage and naturally was not troubled by it since it was a second mortgage, with the bank having the primary lien on the property involved. The department could have determined that, had it thoroughly investigated this matter and conferred about it with the lender and its representative who was involved in the transaction, and with the sellers themselves. If it had done so, it could have obviated all the inconvenience and expense the prosecution of this proceeding caused for the petitioners and all concerned. Thus, the proceeding, as to Ms. Cosyns regarding that count of the complaint, as well as Ms. Maxwell, has not been shown to be substantially justified.

    
    

26. The other count of the complaint against Ms. Cosyns relates to the sale of property where she was a listing agent. The Department was never in possession of any information with regard to that transaction to the effect that Ms. Cosyns had anything to do with the transaction whatever. She merely acted as the listing agent. There was no evidence to show that she participated in the sale or preparation of the contract, its delivery to the lender or related negotiations in any fashion, as shown by the above Findings of Fact. Even had there been a bogus contract, which was not proven, the Department's investigation (and the evidence) only revealed the fact that Ms. Cosyn's participation was as listing agent. Thus, findings in accordance with her unrefuted testimony, and the other evidence which exonerated her as to this count, were made in the Recommended Order and adopted in the agency's Final Order. Here again, if the Department in its investigation had conferred with the other principals and agents involved in that transaction, including the lender, they would have determined at that point, long before the filing of a complaint, that Ms. Cosyns had no connection with that transaction. Thus, at the time the Department initiated the Administrative Complaint with regard to

    this transaction and Ms. Cosyns, it had no substantial basis or justification to conclude that she might have engaged in any wrongdoing.

    
    

27. In consideration of the foregoing, it must therefore be concluded that the petitions of both Ms. Maxwell and Ms. Cosyns for the recovery of attorneys fees pursuant to Section 57.111 Florida Statutes are justified and should be granted. Ms. Maxwell should be awarded attorneys fees and costs in the amount of $3,771.14. Ms. Cosyns demonstrated that she expended a combination of attorneys fees and costs in excess of $15,000 in the defense of the Administrative Complaint as to her. Therefore, she should be awarded attorneys fees and costs in the amount of $15,000, which is the maximum awardable under the statutory "cap" enumerated in Section 57.111, Florida Statutes. Accordingly, in consideration of the foregoing Findings of Fact, Conclusions of Law, and the record evidence, it is therefore,

ORDERED that Jean Maxwell be awarded attorneys fees and costs related to her defense in the proceeding described above in the amount of $3,771.14. It is, further,

ORDERED that Pauline Sealy Cosyns be awarded attorneys fees and costs for her defense of that Administrative Complaint and proceeding in the amount of

$15,000.

DONE and ENTERED this 3rd day of July, 1989, in Tallahassee, Florida.

P. MICHAEL RUFF Hearing Officer

Division of Administrative Hearings The DeSoto Building

1230 Apalachee Parkway

Tallahassee, FL 32399-1550

(904) 488-9675

FILED with the Clerk of the Division of Administrative Hearings this 3rd day of July, 1989.

COPIES FURNISHED:

Ken Oertel, Esquire Oertel & Hoffman, P.A.

2700 Blair Stone Road, Suite C Tallahassee, Florida 32301

Lee Sims, Esquire

Department of Professional Regulation 1940 North Monroe Street, Ste 60

Tallahassee, FL 32399-0729

Kenneth Easley General Counsel

Department of Professional Regulation 1940 North Monroe Street, Ste 60

Tallahassee, FL 32399-0729

Darlene F. Keller, Director Division of Real Estate

400 West Robinson Street Post Office Box 1900 Orlando, FL 32802

NOTICE OF RIGHT TO JUDICIAL REVIEW

A PARTY WHO IS ADVERSELY AFFECTED BY THIS FINAL ORDER IS ENTITLED TO JUDICIAL REVIEW PURSUANT TO SECTION 120.68, FLORIDA STATUTES. REVIEW PROCEEDINGS ARE GOVERNED BY THE FLORIDA RULES OF APPELLATE PROCEDURE. SUCH PROCEEDINGS ARE COMMENCED BY FILING ONE COPY OF A NOTICE OF APPEAL WITH THE AGENCY CLERK OF THE DIVISION OF ADMINIS- TRATIVE HEARINGS AND A SECOND COPY, ACCOMPANIED BY FILING FEES PRESCRIBED BY LAW, WITH THE DISTRICT COURT OF APPEAL, FIRST DISTRICT, OR WITH THE DISTRICT COURT OF APPEAL IN THE APPELLATE DISTRICT WHERE THE PARTY RESIDES. THE NOTICE OF APPEAL MUST BE FILED WITHIN 30 DAYS OF RENDITION OF THE ORDER TO BE REVIEWED.

Docket for Case No: 88-000241F

Orders for Case No: 88-000241F