STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

DISC VILLAGE, INC., )

)

Petitioner, )

)

vs. )

)

DEPARTMENT OF CORRECTIONS, ) CASE NO. 92-7321BID

)

Respondent, )

and )

) A LIFE RECOVERY CENTER, INC., )

)

Intervenor. )

)

RECOMMENDED ORDER

Pursuant to notice, the above matter was heard before the Division of Administrative Hearings by its duly designated Hearing Officer, Donald R. Alexander, on January 14, 1993, in Tallahassee, Florida.

APPEARANCES

For Petitioner: Ronald W. Brooks, Esquire

Rhonda S. Bennett, Esquire 863 East Park Avenue Tallahassee, Florida 32301

For Respondent: Steven S. Ferst, Esquire

2601 Blairstone Road

Tallahassee, Florida 32399-2500

For Intervenor: Rex D. Ware, Esquire

Vikki R. Shirley, Esquire Post Office Box 1794 Tallahassee, Florida 32302

STATEMENT OF THE ISSUES

The issue is whether respondent acted fraudulently, arbitrarily, illegally, or dishonestly in initially awarding the contract for Bid No. 92-JEFFERSON-5720 to intervenor and then proposing to reject all bids.

PRELIMINARY STATEMENT

This matter began on November 20, 1992, when petitioner, Disc Village, Inc., filed its formal protest to a decision by respondent, Department of Corrections, to award the contract for Bid No. 92-JEFFERSON-5720 to intervenor, A Life Recovery Center, Inc. The contract called for the implementation of a drug treatment center program at Jefferson Correctional Institution.

The matter was referred by respondent to the Division of Administrative Hearings on December 10, 1992, with a request that a hearing officer be assigned to conduct a formal hearing. By notice of hearing dated December 11, 1992, a final hearing was scheduled on December 22, 1992, in Tallahassee, Florida. At respondent's request, the final hearing was rescheduled to January 14, 1993, at the same location. On December 21, 1992, A Life Recovery Center, Inc. was authorized to intervene as a party in this cause. Intervenor supports the agency's position.

On December 14, 1992, respondent filed a motion to dismiss the formal protest on the ground it intended to withdraw its earlier proposed agency action and to reject all bids. The motion was denied by order dated December 16, 1992, for the reasons set forth in that order. In addition, petitioner was authorized to file an amended formal protest which was filed on December 21, 1992.

At final hearing, petitioner presented the testimony of Thomas L. Olk, its executive director, and Mark P. Fontaine, assistant director of the Florida Alcohol and Drug Abuse Association, Inc. Also, it offered petitioner's exhibits 1-7. All exhibits were received in evidence except exhibit 7. Respondent presented the testimony of Ronald G. Kronenberger, assistant secretary of DOR. In addition, the parties stipulated into evidence joint exhibits 1-11. Joint exhibits 8 and 9 are the depositions of Harry K. Singletary, Jr., DOC secretary, and William J. Thurber, DOC deputy secretary, respectively.

On January 13, 1993, respondent and intervenor filed motions to dismiss petitioner's bid protest. These motions were heard at the outset of the final hearing and are discussed in the conclusions of law.

The transcript of hearing (two volumes) was filed on February 1, 1993. Proposed findings of fact and conclusions of law were filed by petitioner on February 10, 1993, and by intervenor and respondent on February 11, 1993. A ruling on each proposed finding of fact is made in the Appendix attached to this Recommended Order.

FINDINGS OF FACT

Based upon all of the evidence, the following findings of fact are determined:

1. Background

   
   

   1. The operative facts giving rise to this dispute are not in dispute. On September 4, 1992, respondent, Department of Corrections (DOC), issued Invitation to Bid No. 92-JEFFERSON-5720 (ITB) inviting various vendors to submit proposals for implementing a drug treatment center program at Jefferson Correctional Institution in Jefferson County, Florida. The ITB called for the sealed bids to be filed no later than September 22, 1992, and to be evaluated by a committee composed of various DOC employees. Thereafter, the committee would make a recommendation to a DOC assistant secretary who would then make a recommendation to the secretary. The ITB called for the contract to be awarded to the vendor receiving the highest numerical score.

      
      

   2. In response to the ITB, proposals were timely submitted by petitioner, Disc Village, Inc., intervenor, A Life Recovery Center, Inc., and three other vendors. After the proposals were evaluated by the committee, petitioner was assigned a score of 84.93 points while intervenor received a score of 82.50

      points. Accordingly, the committee prepared a report recommending that the contract be awarded to petitioner. This report was forwarded to a DOC assistant secretary who recommended that the committee's recommendation be rejected and that the contract be awarded to intervenor. This recommendation was approved by the DOC secretary and on November 12, 1992, petitioner received notice that DOC intended to award the contract to intervenor. That prompted petitioner to file a protest. In its protest, petitioner raised the single ground that DOC had materially deviated from the ITB by refusing to award the contract to the bidder with the highest score and thus acted fraudulently, arbitrarily, illegally, or dishonestly.

      
      

2. The Requirements Under the ITB

   
   

   1. The ITB called for "proposals to implement a Drug Treatment Center program at Jefferson Correctional Institution." The center would be designed to treat up to seventy-two female inmates who are assessed to be in need of substance abuse treatment. When the ITB was issued, DOC had not prepared an estimated price for the range of services being solicited nor had it established a price ceiling beyond which it could not or would not fund the contract.

      
      

   2. Section 4.6 of the ITB provided that "the vendor with the highest score will be awarded the contract." This assumes, of course, that the bidder with the highest score was responsive. According to section 4.7 of the ITB, points would be awarded using the following evaluation criteria and corresponding point values:

      
      

      experience and qualifications of bidder - 25 points general substance abuse treatment - 25 points

      price - 50 points

      
      

      Criteria other than price were included to insure that the provider would be experienced and qualified. Therefore, under the express terms of the ITB, the contract would be awarded to a vendor based upon its technical skills, experience, quality of service and cost rather than on price alone. After the proposals were filed, a committee composed of DOC employees and appointed by the DOC secretary would evaluate the proposals and assign scores to each vendor.

      
      

   3. Finally, section 4.8 of the ITB provided in relevant part as follows:

      
      

      The Department reserves the right to reject all bids received in response to this request when to do so is in the Department's best interest.

      
      

      Unless it is in the "best interest" of DOC to do otherwise, the agency has consistently awarded contracts using the above evaluation criteria.

      
      

3. The Evaluation Process

   
   

   1. Both petitioner and intervenor filed responsive bids and are qualified to perform the services required under the contract. Indeed, in their requests for hearing, neither party contended that the other's bid was nonresponsive. Moreover, prior to final hearing, the agency did not contend that nonresponsiveness was an issue in this proceeding. That is to say, to the extent there may have been irregularities in either bid, the agency found them to be minor and they were waived. Therefore, any claims raised during the hearing that the bids were nonresponsive are deemed to be untimely and

      irrelevant. After the sealed bids were opened, a committee evaluated them and assigned scores of 84.93 and 82.50 to petitioner and intervenor, respectively. The other three vendors filing responses received lower scores. The manner in which the proposals were evaluated was not raised as an issue by the parties and is not in dispute. In accordance with section 4.6 of the ITB, the committee drafted a written recommendation to a DOC assistant secretary recommending that the contract be awarded to petitioner, the vendor with the highest score.

      
      

   2. After receiving the committee recommendation, the assistant secretary prepared an intraoffice memorandum to the DOC deputy secretary on October 29, 1992, in which he acknowledged that petitioner had the highest score. However, he noted that intervenor's price over the three year contract period was

      $103,000 less than the price proposed by petitioner. He also noted that by awarding the contract to intervenor, DOC would have the opportunity to use a new provider. Thus, he recommended that

      
      

      the award for drug treatment be given to A Life Recovery System as this vendor is lower in cost and will provide the department the opportunity to gain experience with additional drug treatment providers. By gaining experience with additional providers we can improve the quality of our program and obtain more competitive pricing for future contracts.

      
      

   3. This recommendation was later accepted by the DOC deputy secretary (acting on behalf of the secretary) and a letter advising the parties that the contract would be awarded to intervenor was mailed on November 12, 1992. Thereafter, petitioner's protest was filed and the matter was transmitted to the Division of Administrative Hearings (DOAH) by letter dated December 4, 1992.

      
      

   4. On December 11, 1992, or after DOAH obtained jurisdiction in this cause, DOC advised the parties by letter that:

      
      

      it has decided to withdraw the bid award to A Life Recovery Center, Inc. and reject all bids submitted.

      
      

      No reason for this action was given in the letter. However, deposition testimony of the DOC deputy secretary indicates that DOC realized it made a mistake in deviating from the terms of section 4.6 and that an award of the contract to intervenor could not be justified. Ostensibly for the purpose of correcting the mistake, but also to avoid awarding the contract to petitioner, DOC then proposed to reject all bids. At the same time, DOC filed a motion with DOAH seeking to dismiss petitioner's protest as being moot given the content of its December 11 letter. As will be discussed in the conclusions of law portion of this Recommended Order, the motion was denied but DOC was allowed to present evidence at final hearing in support of its newly adopted change in position.

      
      

4. Petitioner's Alleged Involvement in Drafting the ITB

   
   

   1. On January 13, 1993, or the day before the final hearing, DOC (and intervenor) raised for the first time the contention that petitioner was ineligible to receive the contract pursuant to the terms of Subsection 287.057(16), Florida Statutes. Basically, DOC contended that petitioner "has been involved in the drafting of the evaluation criteria used to award the contract in this case" and thus had no standing to file a protest. As the facts

      unfolded at hearing, and although not a prior concern in the bid process, DOC contended for the first time that the Florida Alcohol and Drug Abuse Association (FADAA or Association), of which petitioner is a member, influenced, either directly or indirectly, the drafting of portions of the ITB and therefore petitioner was disqualifed under subsection 287.057(16) from filing a bid and receiving a contract.

      
      

   2. The Association is a non-profit organization comprised of at least ninety drug treatment providers throughout the state. The record indicates that there may be several hundred other providers, including intervenor, who are not members of the organization. For the last twelve years, FADAA has maintained a continuing dialogue with DOC concerning drug abuse treatment for offenders in the correctional system. Most of the discussions with DOC were by FADAA's Criminal Justice Committee, a committee that works on issues dealing with adult criminal justice clients, or its Board of Directors. Petitioner's executive director is or has been a member of both the committee and the board of directors and also serves as the current president of FADAA.

      
      

   3. The nature of the discussions with DOC were very general in nature and nonspecific. They included such recommendations as DOC using specific instead of general criteria in its invitations to bid so that proposals could be scored in a competitive process, requiring bidders to be licensed by the Department of Health and Rehabilitative Services, and DOC giving preference to "community- based providers". The Association's assistant executive director was the individual who led most of the discussions and meetings with DOC personnel, all of which were open to the general public. At hearing, DOC could not point to a single provision within the ITB that was specifically influenced by discussions with FADAA. Indeed, there was no evidence that FADAA, rather than DOC personnel, was responsible for any specific language in the ITB. Rather, DOC's concern was with the number of meetings FADAA had with DOC staff, the ardor with which FADAA advocated its position, and a belief, albeit erroneous, that the ITB may have been drafted in favor of FADAA members. Therefore, it is found that petitioner did not participate in the drafting of any portion of the ITB nor did it influence any DOC employee who had that responsibility. Thus, it is eligible to file a proposal in response to the ITB.

      
      

5. Was the Process Arbitrary?

1. The initial decision to award the contract to intervenor, the vendor with the second highest score, and to ignore the provisions of section 4.6, was based largely on monetary considerations. That is, intervenor's proposal would result in $103,000 in savings over a three year period when compared to petitioner's bid. DOC also believed that intervenor could adequately deliver the required services within the financial perameters outlined in its proposal. At the same time, and even though it was not a specific criterion in the ITB, DOC concluded that by allowing a new provider such as intervenor into the arena, it would promote more competition on future contracts. This consideration was grounded on the fact that petitioner has been in business for over twenty years and currently provides services to some thirteen or fourteen DOC facilities under other contracts. Conversely, intervenor is a firm established only two years ago and has no prior experience with DOC.

   
   

2. After the initial decision was made, DOC recognized that it erred in awarding the contract to the vendor with the second highest score. In an attempt to correct that mistake, and to avoid awarding the contract to petitioner, who was entitled to receive the contract under the ITB, DOC took the position that all bids should be rejected. In taking this action, DOC relied on

   the same reasons that it used in rejecting the evaluation committee's recommendation. However, DOC contended that while these considerations could not be used to award the contract to intervenor, they could be used to trigger section 4.8 of the ITB, which allows it to reject all bids when to do so is in DOC's "best interest." According to DOC, this provision gives it the prerogative to override all other provisions in the ITB, including section 4.6, which mandates that the contract be awarded to the vendor with the highest score.

   
   

3. DOC concedes that cost savings and increased competition are not identified as criteria in the ITB and could not justify an award of the contract to intervenor. Even so, DOC considers these factors to be relevant in the context of section 4.8 and an adequate basis for rejecting all bids. But by taking the position that lower rated providers with no prior DOC experience should be used in order to promote competition, DOC was giving a competitive advantage to that class of vendors. While DOC may consider this preferential treatment to be in its "best interest", it is nonetheless an arbitrary reason and subverts the bidding process. Similarly, DOC's contention that petitioner's bid was too high must be viewed in the context of its earlier actions. More specifically, DOC did not prepare a pre-bid estimate of the cost of services or establish a price ceiling beyond which it would not award a contract. At the same time, there was no evidence that DOC could not fund the contract at the level proposed by petitioner, or that due to budget shortfalls DOC has no monies to fund the contract and no longer intends to establish a center. To the contrary, the evidence shows that after all bids are rejected, DOC still intends to award a contract for the center. In addition, there is insufficient evidence to support a finding that by rejecting all bids, and using a "negotiation" process in lieu of the bidding process, DOC could reasonably expect to achieve any material price savings. Therefore, by deviating from the clear terms of the ITB, and relying on arbitrary considerations as a reason for rejecting all bids, DOC subverted the bidding process.

   
   

   CONCLUSIONS OF LAW

   
   

4. The Division of Administrative Hearings has jurisdiction of the subject matter and the parties hereto pursuant to Subsection 120.57(1), Florida Statutes (1991).

   
   

5. As in other bid proceedings, the scope of inquiry here is "whether the agency acted fraudulently, arbitrarily, illegally, or dishonestly" in initially proposing to award the contract to the bidder with the second highest score, and then subsequently deciding to reject all bids and relet the contract.

   Department of Transportation v. Groves-Watkins Constructors, 530 So.2d 912, 914 (Fla. 1988). Thus, the undersigned is obligated to honor the rule that a public body has "wide discretion" in the bidding process and its decision, when based on an honest exercise of the discretion, should not be overturned "even if it may appear erroneous and even if reasonable persons may disagree." Id. at 913. Therefore, so long as there is substantial compliance with the bidding procedures, and no showing that the agency did not act in good faith, the agency's decision should not be overturned. Finally, as the party challenging the agency's action, petitioner must prove by a preponderance of the evidence that DOC's decision was unacceptable for one of the reasons cited in Groves- Watkins.

   
   

6. Preliminarily, three procedural matters require some discussion. The first concerns the agency's attempt, after the matter had been referred to DOAH, to reacquire jurisdiction in the case to confirm a change in its proposed agency

   action. This occurred on December 14, 1992, in the form of a motion to dismiss, and was based upon the agency's change in position from a proposed award of the contract to intervenor to a rejection of all bids. As noted in the order denying the motion:

   
   

   Once an agency refers a matter to DOAH, the referring agency shall take no action with respect to the formal proceeding except as a party litigant. Nicolitz v. Board of Opticianry, 17 F.L.W. D2569 (Fla. 1st DCA, November 24, 1992). Thus, while respondent may change its position as to how the bid dispute should be resolved after the matter has been referred to DOAH, it can do so only as a party litigant, that is, by agreement of all parties, or by offering proof in support of its new position at hearing. (Order dated December 16, 1992, pages 1-2).

   
   

   Therefore, the motion was properly denied, and the agency was required to support its change in position through proof at final hearing.

   
   

7. Second, motions to dismiss were filed by respondent and intervenor on January 13, 1993, seeking to dismiss petitioner's protest on the ground petitioner was in violation of Subsection 287.057(16), Florida Statutes. That statute provides in relevant part that "no person who . . . participates in the drafting of an invitation to bid . . . shall be eligible to contract with the agency for any contracts dealing with that specific subject matter." At hearing, petitioner unsuccessfully contended the motions were untimely. This is because the motions were in response to an initial petition (amended formal protest) served by mail on December 21, 1992, and were dispositive of the case if the allegations contained therein were true. As such, they were timely. See Rules 60Q-2.002 and 60Q-2.004(5), F.A.C. Moreover, an additional ground for rejecting a bid can be raised prior to hearing (by appropriate notice but without the need for a formal motion) if no due process violations occur. Cf. Caber Systems, Inc. v. Dept. of General Services, 530 So.2d 325 (Fla. 1st DCA 1988). Although petitioner was given the opportunity to request additional time to counter this allegation, it declined to do so. In any event, the motions required proof in support of the allegations, and under these circumstances consolidation of the jurisdictional issue with the merits of this action was appropriate.

   
   

8. Third, although the agency did not cite the responsiveness of either party's bid as being in question prior to hearing, and petitioner and intervenor did not raise this matter as an issue in their pleadings, DOC and intervenor nonetheless contend that the responsiveness of petitioner's bid is fair game. Citing Intercontinental Properties, Inc. v. State, Dept. of Health and Rehabilitative Services, 606 So.2d 380 (Fla. 3d DCA 1992), as authority, intervenor asserts that petitioner has brought its own responsiveness into issue by including a prayer for relief in its amended protest that "(the contract should) be awarded to Disc Village as the lowest qualified bidder". In Intercontinental Properties, the agency initially proposed to award the contract to the lowest bidder. Intercontinental, the second lowest bidder, then filed its protest alleging that the apparent low bidder was nonresponsive and that it was "the lowest and best responsive bidder and was entitled to the bid." Thereafter, the low bidder intervened and alleged, among other things, that the bid of Intercontinental contained irregularities. During the course of the

   hearing, and presumably over the objection of Intercontinental, the matter of Intercontinental's responsiveness was addressed. On appeal, Intercontinental argued that the responsiveness of its bid was an unpled issue and the hearing officer had erred by considering it. In rejecting this argument, the court held that "a party protesting an award to the low bidder must be prepared to show not only that the low bid was deficient, but must also show that the protestor's own bid does not suffer from the same deficiency." Id. at 384. In reaching this conclusion, the court relied upon the facts that the responsiveness of the apparent winner was in issue, the low bidder had also raised the question of responsiveness when it intervened, and Intercontinental's own formal protest had alleged that it "was the lowest and best responsive bidder." Under these circumstances, the court held that these collective considerations were sufficient to make Intercontinental's responsiveness an appropriate issue. In contrast, there is no challenge here to the responsiveness of the low bidder and thus, unlike the Intercontinental Properties case, there is no need to compare the responsiveness of the top two stakeholders. Likewise, intervenor did not raise the question of petitioner's responsiveness in its pleading, and prior to hearing, the agency did not consider this matter to be relevant. Given these distinctions between the two cases, petitioner's boilerplate language in the ad damnum clause of its amended formal protest is insufficient to trigger the right of other parties to raise a previously unpled issue. Therefore, the undersigned has deemed all evidence regarding responsiveness of both bidders to be untimely and irrelevant to a resolution of this protest.

   
   

9. The agency concedes that it acted improperly in the first instance by proposing to award the contract to the second highest bidder in clear contravention of the ITB. Thus, that action was arbitrary and in violation of the bidding procedures. In an effort to rectify that action, but to still avoid awarding the contract to the lowest qualified bidder, DOC then relied upon the broad language in section 4.8 which allows it to reject all bids when to do so is in the agency's "best interest." In doing so, DOC again relied upon the same unacceptable reasons which it used to justify its earlier action. Thus, DOC was no less arbitrary in rejecting all bids than it was in seeking to award the contract to intervenor. That is to say, if the reasons cited by DOC in choosing one vendor over another were unacceptable, in the absence of any further explanation, they are likewise unacceptable in attempting to later justify a rejection of all bids. Therefore, by taking clearly arbitrary action throughout the course of this proceeding, and ignoring the terms of its own ITB, DOC has subverted the bidding process. In light of the these conclusions, and given the fact that the evaluation committee has already determined, without dispute, that petitioner is the lowest responsive bidder under the terms of the ITB, the contract should be awarded to petitioner.

RECOMMENDATION

Based on the foregoing findings of fact and conclusions of law, it is RECOMMENDED that a final order be entered by respondent awarding the

contract for Bid No. 92-JEFFERSON-5720 to petitioner.

DONE AND ORDERED this 26th day of February, 1993, in Tallahassee, Florida.

DONALD R. ALEXANDER

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 26th day of February, 1993.

APPENDIX TO RECOMMENDED ORDER, CASE NO. 92-7321BID

Petitioner:

1. Rejected as being contrary to the evidence.

2. Partially accepted in finding of fact 9.

3. Partially accepted in finding of fact 13.

4. Partially accepted in finding of fact 3.

5. Rejected as being unnecessary.

36-46. Partially accepted in findings of fact 10-12.

1. Partially accepted in finding of fact 10.

2. Partially accepted in finding of fact 6.

Respondent:

1-4. Partially accepted in finding of fact 1. 5-6. Partially accepted in finding of fact 2. 7-9. Partially accepted in finding of fact 7.

41-52. Partially accepted in findings of fact 14 and 15.

1. Partially accepted in finding of fact 10.

2. Rejected as being contrary to the evidence.

3. Rejected as being unnecessary.

56-82. Rejected as being irrelevant and unnecessary.

1. Partially accepted in finding of fact 2.

2. Rejected as being unnecessary.

85-98. Rejected as being irrelevant and unnecessary.

1. Partially accepted in findings of fact 14 and 15.

2. Partially accepted in finding of fact 9.

3. Partially accepted in finding of fact 6. 102-103. Partially accepted in finding of fact 9. 104-106. Rejected as being unnecessary.

1. Partially accepted in findings of fact 14 and 15.

2. Partially accepted in finding of fact 9. 109-110. Rejected as being unnecessary.

1. Rejected as being irrelevant.

2. Partially accepted in finding of fact 6.

3. Partially accepted in finding of fact 12.

4. Rejected as being contrary to the evidence.

5. Partially accepted in finding of fact 7. 116-117. Rejected as being unnecessary.

1. Partially accepted in finding of fact 13.

2. Partially accepted in findings of fact 14 and 15.

120-146. Rejected to the extent they conflict with findings of fact 10-12.

Intervenor:

1. Partially accepted in finding of fact 1.

2. Partially accepted in finding of fact 2. 3-4. Partially accepted in finding of fact 6.

1. Partially accepted in finding of fact 4.

2. Partially accepted in finding of fact 6.

3. Partially accepted in finding of fact 7. 8-9. Partially accepted in finding of fact 8.

1. Partially accepted in finding of fact 2.

2. Partially accepted in finding of fact 13.

3. Rejected as being unnecessary.

4. Partially accepted in findings of fact 14 and 15. 14-23. Rejected as being irrelevant and unnecessary.

24-25. Partially accepted in findings of fact 14 and 15.

1. Partially accepted in finding of fact 8.

2. Partially accepted in findings of fact 14 and 15.

3. Partially accepted in finding of fact 9.

29-47. Rejected to the extent they conflict with findings of fact 10-12.

Note - Where proposed findings have been partially accepted, the remainder have been rejected as being irrelevant, unnecessary, subordinate, not supported by the evidence, or a conclusion of law.

COPIES FURNISHED:

Harry K. Singletary, Jr. Secretary

Department of Corrections 2601 Blairstone Road

Tallahassee, FL 32399-2500

Louis A. Vargas, Esquire General Counsel Department of Corrections 2601 Blairstone Road

Tallahassee, FL 32399-2500

Ronald W. Brooks, Esquire 863 East Park Avenue Tallahassee, FL 32301

Rex D. Ware, Esquire Vikki R. Shirley, Esquire Post Office Box 1794 Tallahassee, FL 32302

Steven S. Ferst, Esquire 2601 Blairstone Road

Tallahassee, FL 32399-2500

NOTICE OF RIGHT TO SUBMIT EXCEPTIONS

All parties have the right to submit to the Department of Corrections written exceptions to this Recommended Order. All agencies allow each party at least ten days in which to submit written exceptions. Some agencies allow a larger period within which to submit written exceptions. You should consult with the Department of Corrections concerning its rules on the deadline for filing exceptions to this Recommended Order.

Docket for Case No: 92-007321BID

Orders for Case No: 92-007321BID