STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

DEPARTMENT OF PROFESSIONAL ) REGULATION, BOARD OF )

CHIROPRACTIC, )

)

Petitioner, )

)

vs. ) CASE NO. 90-8103

)

THOMAS GIALLANZO, D.C. )

)

Respondent. )

)

RECOMMENDED ORDER

A hearing in this matter was held in Ft. Lauderdale, Florida, on September 24, 1991, before William R. Dorsey, the Hearing Officer assigned by the Division of Administrative Hearings.

APPEARANCES

For Petitioner: E. Renee Alsobrook, Esquire

Senior Attorney

Department of Professional Regulation 1940 North Monroe Street

Suite 60

Tallahassee, Florida 32399-0782

For Respondent: Kenneth A. Wolis, Esquire

Plaza One, 5th Floor 4601 Sheridan Street

Hollywood, Florida 33021-3401 STATEMENT OF THE ISSUE

The issue in this case is whether Dr. Giallanzo's Florida license as a chiropractic physician should be disciplined for the following violations of Chapter 460, Florida Statutes, alleged in the Amended Administrative Complaint:

COUNT I: Violation of Subsection 460.413(1)(w), Florida Statutes, by violating, Subsection 460.413(1)(bb), Florida

Statutes, by submitting to a third-party (i.e., an insurer) a claim for a service or treatment without providing a copy of that claim to the insured at the same time.

COUNT II: Voluntarily Dismissed.

COUNT III: Violation of Subsection 460.413(1)(v),

Florida Statutes, by delegating professional responsibilities to a person when the licensee knows, or has reason to know, that such person is not qualified by training, experience, or licensure to perform them.

COUNT IV: Violation of Subsection 460.413(1)(1), Florida Statutes, by making misleading, deceptive, untrue or fraudulent representations in the practice of chiropractic, or employing a trick or scheme in the practice of chiropractic.

COUNT V: Violation of Subsection 460.413(1)(g), Florida Statutes, by failing to report to the Department any person who the licensee knows has violated the chiropractic statutes or implementing rules of the department or board.

COUNT VI: Voluntarily Dismissed.

COUNT VII: Violation of Subsection 460.413(1)(i), Florida Statutes, by failing to perform a statutory or legal obligation placed upon a licensed chiropractic physician.

COUNT VIII: Violation of Subsection 460.413(1)(w), Florida Statutes, by violating a lawful order of the board or department which was previously entered in a disciplinary proceeding.

COUNT IX: Violation of Subsection 460.413(1)(i), Florida Statutes, by failing to perform a statutory or legal obligation placed upon a licensed chiropractic physician.

COUNT X: Violation of Subsection 460.413(1)(w), Florida Statutes, by violating a lawful order of the board or department which was previously entered in a disciplinary proceeding.

COUNT XI: Violation of Subsection 460.413(1)(w), Florida Statutes, by violating Section 460.411(1)(a), Florida Statutes, by practicing or attempting to practice chiropractic without an active license.

COUNT XII: Violation of Subsection 460.413(1)(w), Florida Statutes, by violating Section 455.227(1)(b), Florida Statutes, by intentionally violating a rule adopted by the board or the department.

COUNT XIII: Violation of Subsection 460.413(1)(w), Florida Statutes, by violating Section 460.411(2)(d), Florida Statutes, by knowing concealment of information about his statutory violations, in that the Respondent failed to submit a patient record when presented a patient's release authorizing its delivery to a department employee.

COUNT XIV: Violation of Subsection 460.413(1)(w), Florida Statutes, by violating Section 460.411(b), Florida Statutes in that the Respondent used or attempted to use a license to practice chiropractic which has been suspended or revoked.

PRELIMINARY STATEMENT

The Department called the following witnesses:

1. John Jorgensen Investigator

   Department of Professional Regulation

   4141 N. Andrews Avenue

   Ft. Lauderdale, Florida 33309

   
   

2. Patient 2

   (See Confidential Index)

   
   

3. Deputy William S. Garrison Deputy Sheriff

   Broward County Sheriff's Office

   
   

4. Janet Dean

   Licensed Massage Therapist

   Former employee of the Respondent

   
   

5. Teresa Tanya Chiappee, also known as Christine, an Employee of the Respondent

   
   

6. Rena Coffield Records Custodian

   Board of Chiropractic Department of Professional

   Regulation

   1940 N. Monroe Street Tallahassee, Florida 32399-0792

   
   

7. Dr. Andrew George Roberts, Jr., D.C. Chiropractic Expert

   6919 Merrill Road

   Jacksonville, Florida 32211

8. Kathe Lynch

Licensed Massage Therapist

and introduced the following exhibits:

Exhibit 1 - Respondent's response to Petitioner's Admissions (composite).

Exhibit 2 - Certified Final Order from the Board of Chiropractic in Department of Professional Regulation Case numbers 89-9848, 89-9849,

89-9850, and 99171 (composite).

Exhibit 3 - Certified Final Order from the Board of Chiropractic in Department of Professional Regulation Case number 90-16412.

Exhibit 4 - Certification that Respondent is not licensed as a massage therapist.

Exhibit 5 - Certification regarding Respondent's suspended license.

Exhibit 6 - Department of Professional Regulation subpoena and telephone logs at Respondent's chiropractic office address (composite).

Exhibit 7 - Patient Two's health insurance card.

Exhibit 8 - Health questionnaire given to Patient Two to complete and return to Respondent.

Exhibit 9 - Medical Release/Authorization executed by Patient Two to Respondent for release of records to a department employee.

Exhibit 10- Cease and Desist Agreement executed by Tanya Chiappee.

Exhibit 11- Withdrawn by the Department of Professional Regulation.

Exhibit 12- Board of Chiropractic Final Order, Department of Professional Regulation Case number 009366 (composite).

Exhibit 13- Curriculum Vitae of Dr. Roberts (composite). Exhibit 14- Respondent's Response to Petitioner's

Interrogatories (composite).

Respondent called the following witnesses:

1. Himself

   356 E. Dania Beach Blvd. Dania, Florida

2. Dr. Robert Sheldon Frankl, D.C. 6363 Taft, Suite 102

Hollywood, Florida and introduced:

Exhibit 1 - Dr. Frankl's complaint against Dr. La Russo (composite).

Exhibit 2 - Dr. Frankl's complaint against Dr. Leon (composite).

Exhibit 3 - Dr. Frankl's complaint against Dr. Vogel (composite).

Exhibit 4 - Dr. Frankl's complaint as to the review of his case by Peer Review (composite).

Exhibit 5 - Dr. Frankl's complaint regarding Peer review (composite).

Exhibit 6 - Dr. Frankl's Department of Professional Regulation Case number 95429 (composite).

Exhibit 7 - Check number 1119 for $2,000 Department of Professional Regulation Case number 99171 (composite).

Exhibit 8 - Application of Janet Dean and of Kathe Lynch dated April 22, 1990 (composite).

Exhibit 9 - Copy of judgement against Patient One.

Exhibit 10- Department of Professional Regulation notification to Respondent addressed to Pellegrino.

A transcript of the proceeding was filed. Both parties filed proposed recommended orders. Rulings on the proposed findings of fact are made in the Appendix to this Recommended Order.

FINDINGS OF FACT

1. Thomas Giallanzo is licensed as a chiropractic physician in the State of Florida, holding license number CH 5600. He practices at 356 E. Dania Beach Boulevard., Dania, Broward County, Florida 33004. The telephone number of his chiropractic office is (305) 921-2602. He operates a massage establishment, which is separately licensed, at the same location.

   
   

2. Dr. Giallanzo was disciplined previously by the Department of Professional Regulation, in Case number 93996 for violating Subsections 460.413(1) (e) and (l), Florida Statutes, which govern advertising by chiropractic physicians. He was fined $500.00 and placed on probation. The Department's Final Order was filed with the agency clerk on December 1, 1988.

3. Dr. Giallanzo was disciplined a second time by the Department in Case number 99171 for violating three statutory provisions, Subsection 460.413(1)(n), Florida Statutes, by failing to keep written chiropractic records justifying the course of treatment for a patient; Subsection 460.413(1)(s), Florida Statutes, for gross or repeated malpractice or the failure to practice chiropractic at a level of care, skill, and treatment which is recognized by a reasonably prudent chiropractic physician under similar conditions and circumstances; and Subsection 460.413(1)(w), Florida Statutes, by violating Rule 21D-17.003(3)(a), Florida Administrative Code. This discipline was imposed because from on or about December 26, 1987, Dr. Giallanzo treated a patient without obtaining a patient history, including weight, height, temperature or cause of illness; performed no x-rays; and referred the patient for peripheral vascular and cerebrovascular tests and ultrasonagraphy without justification. He failed to maintain progress notes or records justifying the need for six additional appointments for the patient. Dr. Giallanzo was fined $2,000 which was to be paid within thirty (30) days of the entry of the Final Order. Rule 21D-16.004, Florida Administrative Code. He also was placed on probation and ordered to obtain additional continuing education over and above the minimum required for renewal for his chiropractic license. That Final Order was entered September 7, 1989. Under the terms of the stipulation incorporated in the Final Order, his license was to be suspended pursuant to that Final Order if he failed to pay the fine within 30 days. Dr. Giallanzo only paid the fine more than two years later, on September 21, 1991, two days before the final hearing in this case.

   
   

4. Dr. Giallanzo was disciplined a third time by the Department of Professional Regulation in Case Numbers 89-9848, 89-9849 and 89-9850 for violations of Subsections, 460.413(1)(v), Florida Statutes, by delegating professional responsibilities to a person, when he knew or had reason to know that person was not qualified to perform those responsibilities; Subsection 460.413(1)(w), Florida Statutes, by violating provisions of Chapter 460, and any rule implementing it; and Subsection 460.413(1)(w), Florida Statutes, by sexual misconduct in the practice of chiropractic. In those cases, Dr. Giallanzo employed, from October, 1988 through about August, 1989, unlicensed persons to perform sex acts and/or massages on clients. Dr. Giallanzo was ordered by the Board of Chiropractic to pay a $2,000 fine within ninety (90) days of the filing date of the Final Order in that case. His license also was suspended from January 1, 1991 to March 31, 1991 as discipline, and following the suspension his license was placed on two (2) years probation, with conditions. This Final Order was filed December 27, 1990. Dr. Giallanzo has never paid that fine, and he never returned his license to the Board during the period of his suspension. He continued to post his license in the reception area of his office while he was suspended. Dr. Giallanzo admitted in response to Requests for Admissions that he was suspended.

   
   

5. The Respondent billed Patient One's insurance carrier without providing a copy of his bill to Patient One at the same time. Section 460.413(1)(bb), Florida Statutes, required him to do so, without regard to whether the patient specifically asked for a copy of the bill when it was submitted to the insurer. Dr. Giallanzo's attempt to re-interpret his answer to the admission at the final hearing, to claim that he sent a copy of the billing to Patient One, is rejected as unconvincing (Tr. 268).

6. Teresa Tanya Chiappee, also known as Christine, only received her apprentice massage therapist license in March 1991, although she has worked for Dr. Giallanzo since September of 1989. Prior to Ms. Chiappee's licensure as a massage therapist, she was employed by Dr. Giallanzo. The contention that she was an independent contractor is rejected. Dr. Giallanzo admitted in the response to the Request for Admissions that he was her employer, and the testimony would independently lead to this finding. Dr. Giallanzo's attempted recantation of the admission during the hearing was unconvincing (TR. 243). Dr. Giallanzo allowed her to perform massage therapy on clients when he was not physically present at his chiropractic office providing direct supervision. The massage therapy Ms. Chiappee performed was the same as that provided by licensed massage therapists in Dr. Giallanzo's office. (Tr. 96).

   
   

7. Dr. Giallanzo displayed on a wall in his office the licenses of Kathe Lynch who was a licensed massage therapists, when he did not employ her. Dr. Giallanzo never employed Kathe Lynch. Dr. Giallanzo displayed the license so that patients and members of the public could see it. The manner of display was designed to impart the erroneous belief that he currently employed licensed massage therapists at his office.

   
   

8. On February 15, 1991, Patient Two entered Dr. Giallanzo's office as part of an investigation to determine whether Dr. Giallanzo was practicing chiropractic medicine while his license was under suspension. On that date, Dr. Giallanzo obtained a copy of Patient Two's insurance card, gave Patient Two a health questionnaire to complete, and advised Patient Two to return at a later date after Dr. Giallanzo verified Patient Two's insurance coverage, which would be used to pay bills for Dr. Giallanzo's treatment of Patient Two.

   
   

9. On February 18, 1991, Patient Two returned to Respondent's office, watched Dr. Giallanzo's review the medical questionnaire he had completed, and watched Dr. Giallanzo place a telephone call to Patient Two's insurance company to verify insurance coverage. Because the line was busy, Dr. Giallanzo was unable to verify the insurance coverage. Dr. Giallanzo did not treat the patient because the coverage had not been verified. Dr. Giallanzo's contention that he called to determine whether charges for massage were covered by the insurance is rejected as less credible than that of Patient Two, who testified that he went to the office seeking chiropractic treatment, not massage.

   
   

10. On February 21, 1991, Dr. Giallanzo examined Patient Two, reviewed his medical questionnaire, performed a manipulation and massage on Patient Two, and applied electric muscle stimulation and heat packs on Patient Two.

    
    

11. Department of Professional Regulation, Investigator John Jorgensen, presented to Dr. Giallanzo a medical release for Patient Two's medical records and requested Dr. Giallanzo to turn over those records. Dr. Giallanzo has never supplied the medical records, through the time of the final hearing. Those records would be damaging to Dr. Giallanzo, for they would constitute additional proof of practice as a chiropractic physician while his license was suspended.

    
    

    CONCLUSIONS OF LAW

    
    

12. The Department has jurisdiction to prosecute this matter pursuant to Subsection 20.30, Chapter 455 and 460, Florida Statutes. The Division of Administrative Hearings has jurisdiction of this matter under Section 120.57(1), Florida Statutes.

13. As a licensed chiropractic physician Dr. Giallanzo is subject to the Department's jurisdiction.

    
    

14. Count II and VI of the Administrative Complaint were voluntarily dismissed by the Petitioner.

    
    

15. Count I. The Department has proven by clear and convincing evidence by means of admissions that Dr. Giallanzo violated Subsection 460.413(1)(bb), Florida Statutes, by failing to submit to Patient One a copy of a claim Dr. Giallanzo submitted on behalf of the patient to a third-party insurer for services or treatment provided by Dr. Giallanzo. The response to the request for admission establishes the critical fact.

    
    

16. Count III. The Department has proven by clear and convincing evidence that Dr. Giallanzo violated Subsection 460.413(1)(v), Florida Statutes, when he delegated the professional responsibilities of performing massage therapy on patients to Theresa Tanya Chiappee when he knew or should have know that she was not qualified to perform massages as chiropractic therapy because she was not a licensed message therapist, and when he was absent from his office while she performed massage therapy on his patient.

    
    

17. Count IV. The Department has proven by clear and convincing evidence that Dr. Giallanzo violated Subsection 460.413(1)(1), Florida Statutes, when he displayed the licenses of Kathe Lynch on the bulletin board in his office for public observation, at times when he did not employ her. He also displayed his own chiropractic license on the same board after it had been suspended. These acts were designed to mislead the public to believe that Dr. Giallanzo was licensed while his license was suspended, and to lead the public to believe all persons providing massage at the office were trained and licensed to do so.

    
    

18. Count V. The Department has proven by clear and convincing evidence that the Dr. Giallanzo violated Subsection 460.413(1)(g), Florida Statutes, when he failed to report the violations (i.e., unlicensed massage practice) of Tanya Chiappee. It is not clear that the statute requires a licensee to report his own violations.

    
    

19. Count VII. The Department has proven by clear and convincing evidence that Dr. Giallanzo violated Subsection 460.413(1)(i), Florida Statutes, when he failed to comply with the legal obligation imposed in the Final Order entered by the Department of Professional Regulation in Case Number 99171. He failed to pay the fine within the 30 days of the entry of the Final Order adopting the stipulated disposition of that case, but waited two years to pay the fine.

    Fines must be paid within 30 days. Rule 21D-16.004, Florida Administrative Code.

    
    

20. Count VIII. The Department has proven by clear and convincing evidence that Dr. Giallanzo also violated Subsection 460.413(1)(w), Florida Statutes, by violating a lawful Final Order of the Board of Chiropractic in Department of Professional Regulation Case Number 0099171 when he failed to pay the $2,000 fine within thirty (30) days, but waited two years to pay the fine.

21. Count IX. The Department has proven by clear and convincing evidence that Dr. Giallanzo violated Subsection 460.413(1)(i), Florida Statutes, by violating a rule of the board when he failed to comply with the Final Order in Department of Professional Regulation Case Numbers 89-9848, 89-9849, and 89- 9850. During his 90-day period of suspension, he failed to return his license to the Department of Professional Regulation, as required by Rule 21D-16.008, Florida Administrative Code.

    
    

22. Count X. The Department has proven by clear and convincing evidence that Dr. Giallanzo again violated Subsection 460.413(1)(w), Florida Statutes, by violating a lawful Final Order entered in a disciplinary proceeding because he has never paid the second $2,000.00 fine imposed in Department Case Numbers 89- 9848, 89-9849, and 89-9850.

    
    

23. Count XI. The Department has proven by clear and convincing evidence that Dr. Giallanzo violated Subsection 460.413(1)(w), Florida Statutes, by violating Subsection 460.411(1)(a), Florida Statutes, in that he practiced chiropractic medicine while his license was suspended. He reviewed a medical history questionnaire, performed a chiropractic examination and a manipulation on Patient Two during the suspension period.

    
    

24. Count XII. The Department has proven by clear and convincing evidence that Dr. Giallanzo violated Subsection 460.413(1)(w), Florida Statutes, by intentionally violating Subsection 455.227(1)(b), Florida Statutes, when he practiced chiropractic while his license was suspended and failed to pay the fine in Department of Professional Regulation Case number 89-9848, 89-9849, and 89-9859.

    
    

25. Count XIII. The Department has proven by clear and convincing evidence that Dr. Giallanzo violated Subsection 460.413(1)(w), Florida Statutes, by knowingly violating Subsection 460.411(2)(d), Florida Statutes, by failing to release the medical records of Patient Two, which he knew would demonstrate that he had practiced while his license was suspended.

    
    

26. Count XIV. The Department has proven by clear and convincing evidence that Dr. Giallanzo violated Subsection 460.413(1)(w), Florida Statutes, by violating Subsection 460.411(1)(b), Florida Statutes, by using and/or attempting to use a chiropractic license which had been suspended. In the course of rendering chiropractic treatment to Patient Two, he reviewed the medical history and health questionnaire completed by Patient Two, telephoned Patient Two's insurance carrier regarding Patient Two's coverage, performed an examination and manipulation on Patient Two. He displayed his chiropractic license in a manner such that the public could view it while it was suspended. These facts demonstrated his intent to use his license when he knew it had been suspended.

    
    

    PENALTY

    
    

27. Rule 21D-16.003, Florida Administrative Code sets forth the penalty for the Respondent's violation as follows:

    
    

    Count I: A minimum of a $1,000 fine, plus from one

    1. year probation up to revocation. (Rule 21D-16.003(1)(jj), F.A.C.)

       
       

       Count II: Voluntarily Dismissed.

       Count	III:	A minimum of a $500 fine, plus from six months of probation up to three months suspension, followed by six months of probation.
       		(Rule 21D-16.003(dd), F.A.C.)
       Count	IV:	A minimum of a $500 fine, plus from one year probation up to one year suspension followed by two years probation. (Rule 21D-6.003(1)(t), F.A.C.)
       Count	V:	A minimum of a reprimand, up to six months probation (Rule 21D-16.003(1)(o), F.A.C.)
       Count	VI:	Voluntary Dismissed.
       Count	VII:	A minimum of a reprimand, up to six months probation (Rule 21D-16.003(1)(q), F.A.C.)
       Count	VIII:	A minimum of a reprimand, up to revocation. (Rule 21D-16.003(1)(ee), F.A.C.)
       Count	IX:	A minimum of a reprimand, up to revocation. (Rule 21D-16.003(1)(q), F.A.C.)
       Count	X:	A minimum of a reprimand, up to revocation. (Rule 21D-16.003(1)(ee), F.A.C.)
       Count	XI:	A minimum of $200 per month of unlicensed practice up to revocation. (Rule 21D-16.003(1)(b), F.A.C.)
       Count	XII:	A minimum of a reprimand up to revocation. (Rule 21D-16.003(1)(ee), F.A.C.)
       Count	XIII:	A minimum of six months probation up to one year suspension followed by two years probation. (Rule 21D-16.003(1)(g), F.A.C.)
       Count	XIV:	Revocation, (Rule 21D-16.003(1)(c), F.A.C.)

       
       

28. Rule 21D-16.003(2), Florida Administrative Code,

sets forth aggravating factors to be considered in imposing a penalty. Those applicable here are:

1. the severity of the offense;

2. the danger to the public;

3. the number of specific offenses;

(e) the length of time since the date of the last violation;

1. prior discipline imposed upon the licensee;

   
   

2. the deterrent effect of the penalty imposed;

   
   

3. the effects of the penalty upon the licensee's livelihood;

4. rehabilitation efforts of the licensee;

   
   

5. failure of the licensee to correct or stop violations.

RECOMMENDATION

Based on the Respondent's failure to comply with Chapter 460, Florida Statutes, the Florida Administrative Code, and the Final Orders of the Board of Chiropractic, Dr. Giallanzo has demonstrated that his continued practice as a chiropractor poses a danger to the public because he has repeatedly failed to conform his conduct to the law. From 1987 until the present, Dr. Giallanzo has engaged in a pattern of violations of the laws governing the practice of chiropractic. These violations have included such serious violations as malpractice, sexual misconduct by massage employees in his office, improper delegation of duties and/or responsibilities to unqualified people, failure to turn over patient records and use and practice on a suspended license. The Respondent has no convincing excuse for his conduct. I find no persuasive evidence that the Department or Board is engaged in a pattern of conduct designed to harass Dr. Giallanzo. He has ignored the Final Orders of the Board of Chiropractic and the laws of Florida by his practice while under suspension and by his failure to pay the fine in Department of Professional Regulation Case Numbers 89-9848, 89-9849, and 89-9850 or offer any convincing justification for his failure.

Based on the foregoing findings of facts and conclusions of law for the twelve violations proven here, it is RECOMMENDED that the Florida Board of Chiropractic Medicine enter a Final Order imposing the following penalties for each count:

It is also recommended, should Respondent reapply for licensure as a chiropractic physician in the State of Florida, that Respondent meet all criteria for initial licensure, including passing any examinations, required at the time of the Respondent's reapplication.

DONE AND ORDERED in Tallahassee, Leon County, Florida, this 27th day of November, 1991.

WILLIAM R. DORSEY, JR.

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 27th day of November, 1991.

APPENDIX TO RECOMMENDED ORDER DOAH CASE NO. 90-8103

Rulings on findings proposed by the Department.

1. Adopted in Finding of Fact 1.

2. Adopted in Finding of Fact 2.

3. Adopted in Finding of Fact 3.

4. Adopted in Finding of Fact 4.

5. Adopted in Finding of Fact 5.

6. Adopted in Finding of Fact 6.

7. Adopted in Finding of Fact 7, except that I find insufficient evidence that Dr. Giallinzo displayed the license of Janet Dean while she was not employed. The evidence is quite weak on when she left employment, and when the license was (or remained) posted.

8. Adopted in Finding of Fact 8.

9. Adopted in Finding of Fact 9.

10. Adopted in Finding of Fact 10.

11. Adopted in Finding of Fact 11.

Rulings on findings proposed by the Respondent.

1. Adopted in Finding of Fact 1

2. Discussed in Finding of Fact 6. Last sentence rejected as unnecessary and unsupported by the evidence of Mr. Jorgensen, which I credit.

3. Rejected, see Finding of Fact 7.

4. Rejected, see Findings of Fact 8, 9 and 10.

Copies furnished:

Elizabeth Renne Alsobrook, Esquire Senior Attorney

Department of Professional Regulation

1940 North Monroe Street Suite 60

Tallahassee, Florida 32399-0792

Kenneth A. Wolis, Esquire Plaza One, 5th Floor

4601 Sheridan Street

Hollywood, Florida 33021-3401

Diane Orcutt Executive Director Board of Chiropractic

Department of Professional Regulation

1940 North Monroe Street Suite 60

Tallahassee, Florida 32399-0792

Jack McRay, General Counsel Department of Professional

Regulation

1940 North Monroe Street Suite 60

Tallahassee, Florida 32399-0792

Case No. 90-8103

NOTICE OF RIGHT TO SUBMIT

EXCEPTIONS: All parties have the right to submit written exceptions to this Recommended Order. All agencies allow each party at least 10 days in which to submit written exceptions. Some agencies allow a larger period within which to submit written exceptions. You should contact the agency that will issue the final order in this case concerning agency rules on the deadline for filing exceptions to this Recommended Order. Any exceptions to this Recommended Order should be filed with the agency that will issue the final order in this case.

Docket for Case No: 90-008103

Orders for Case No: 90-008103