STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

PITNEY BOWES, INC., )

)

Petitioner, )

)

vs. ) CASE NO. 93-4192BID

)

DEPARTMENT OF LABOR AND )

EMPLOYMENT SECURITY, )

)

Respondent, )

and )

)

ADVANCED BUSINESS SYSTEMS, )

)

Intervenor. )

)

RECOMMENDED ORDER

This case was heard by Eleanor M. Hunter, the Hearing Officer designated by the Division of Administrative Hearings, on October 13, 1993, in Tallahassee, Florida.

APPEARANCES

For Petitioner: Trisa J. Thompson, Attorney-At-Law

Rachel A. Sens, Attorney-At-Law 815 Connecticut Avenue, Northwest Washington, D.C. 20006-4004

For Respondent: Edward A. Dion, Attorney-At-Law

Assistant General Counsel

Department of Labor and Employment Security 2012 Capital Circle, S.E.

307 Hartman Building Tallahassee, Florida 32399-2189

For Intervenor: Michael L. Rich, Attorney-At-Law

Cathleen M. DeMarco, Attorney-At-Law 5360 Maple Avenue

Morristown, New Jersey 07963 STATEMENT OF THE ISSUES

The issue is whether Petitioner's response to Invitation to Bid No. 93-066- OR was responsive or unresponsive.

PRELIMINARY STATEMENT

On June 3, 1993, Respondent Department of Labor and Employment Security ("the Department"), issued its Invitation to Bid ("ITB") for the lease and/or purchase of certain mailing equipment, which included mailing machines, meters, scales, and an accounting system. Prior to issuance of the ITB, the Department staff met with representatives of the prospective bidders to review the ITB. On July 7, 1993, the Department posted notice of its intent to award the bid to Advanced Business Systems. Pitney Bowes timely filed its notice of intent to protest and its formal written protest with the Department. In an amended petition, Pitney Bowes alleged that the Department should have awarded Bid No.

93-066-OR to Pitney Bowes for the following reasons:

1. Pitney Bowes was the lowest responsive, responsible bidder;

2. Pitney Bowes' equipment meets the

   disputed specification related to collecting usage information from each meter;

3. Neither Pitney Bowes or ABS could meet a Department's interpretation of the specification to require collecting 16 digit usage information in the meter; and

4. the absence of UL documentation in the ABS bid.

A Notice of Hearing was issued on July 30, 1993, setting the formal hearing for August 13, 1993. Following two Motions for Continuance, one filed by the Department and one by Pitney Bowes, the formal hearing was held on October 13, 1993.

At the formal hearing, Pitney Bowes presented the testimony of Jacquelyn Collins, Oradelle Rollins, Diane Matthews, Jimmy Hall, John Vavra, Larry Snow, Jan Berryman, and Jerome Dilworth. Pitney Bowes' exhibits 1 - 11 were received in evidence.

The Department presented the testimony of Monty Mills, and exhibits 1-3, which were received in evidence. Advanced Business Systems' one exhibit was received in evidence.

A transcript of the formal hearing was filed with the Division of Administrative Hearings on October 27, 1993. Proposed findings of fact and conclusions of law were filed on November 8, 1993. Rulings on each of the proposed findings are in the Appendix to this Recommended Order.

FINDINGS OF FACT

1. In June 1993, the Department of Labor and Employment Security ("the Department") issued Invitation to Bid ("ITB") No. 93-066-OR for mailing machines, meters, scales and an accounting system.

   
   

2. Petitioner Pitney Bowes, Inc. ("Pitney Bowes") and Intervenor Advanced Business Systems ("ABS") submitted timely offers in response to the Department's ITB.

   
   

3. The Pitney Bowes' total offer price was $386,970, with a year of free meter rental, parts and maintenance. ABS' total offer price was $572,729.

4. On June 23, 1993, the Department's Chief for Purchasing, telephoned the Pitney Bowes' sales representative, and requested a meeting the following morning with the full Bid Evaluation Board.

   
   

5. On June 24, 1993, Pitney Bowes' representatives met with the Bid Evaluation Board, and were informed by the Bureau Chief that Pitney Bowes was the lower of the two bidders. The meeting was held for Pitney Bowes to clarify the capabilities of the Pitney Bowes' equipment. Pitney Bowes' representatives assured the Board that its equipment met the requirements of the ITB.

   
   

6. On June 25, 1993, the Department posted a bid tabulation notice that it intended to award the contract to Pitney Bowes, the lowest bidder, pending verification that the specifications were met. On that same day, the Purchasing Agent responsible for this procurement, telefaxed the following requested clarifications to Pitney Bowes:

   
   

   1. Please provide model numbers for each class of mailing machines for outright purchase.

   2. Please provide the volume for each model for each class.

   3. If your company has installed a mail management system using 16 digits for the model numbers that you bid, please provide references and telephone numbers.

      
      

7. In its response to the request for clarifications, Pitney Bowes listed E200 and E680 Mail Machines, Star Post and Star 90 Scale Accounting Systems, and the A900 Electronic Postage by Phone Meters. Pitney Bowes also included a narrative explanation of the systems' volumes in terms of speed and number of pieces of mail, and a statement that software for the system was so new that there were no available references for a mail management system using the software.

   
   

8. In a letter dated July 1, 1993, Pitney Bowes offered to substitute its more expensive Star 150 Scale Accounting System at no additional cost and listed four references for that system.

   
   

9. ABS also received the June 25th telefaxed request for clarifications. In its response ABS gave its model numbers, volumes and two references, and also sent questions soon afterwards regarding Pitney Bowes. The questions were as follows:

   
   

   Where in the nation does Pitney Bowes have a system that will transfer data from remote sites over phone lines to a central personal computer for the collection, and reporting of postage data by individual site locations?

   
   

   Can Pitney Bowes poll individual site locations to determine postage usage?

   
   

   Does Pitney Bowes have brochures or technical data to support the equipment bid?

   Is the equipment bid standard, current production, available equipment with a history of usage in the open market of six months or longer?

   
   

10. In a certified letter dated July 7, 1993, the Department notified Pitney Bowes that it intended to revise the prior bid tabulation notice, posting instead on July 9th, a notice of intent to award the bid to ABS. The notice gives, as justification for not making the award to the lowest bidder, "Vendor does not meet specifications".

    
    

11. Three of the bid specification requirements listed in the ITB were as follows:

    
    

    -mailing machines and meter heads located in remote and central locations must have the capability to interface with a centralized mail management via modems to an existing PC located in Tallahassee. Machine must be capable of collecting usage information from each meter including but not limited to account summaries, station summaries and operator summaries

    -machine provided at any location must be capable of processing a minimum of 10 accounts up to 16 digits per account

    -machine must be UL approval. Documentation must be provided with the bid. (Emphasis added.)

    
    

    Substantial disagreement exists among the parties over the meaning of the word "Machine" at the beginning of the sentence starting on line 5 in the first specification above. In fact, the members of the evaluation committee differed in their understanding of the term. If "machine" refers to mailing machines, none of which collect usage information from meters, then neither Pitney Bowes' nor ABS' bid is responsive. At a Pre-Bid Conference, the Department clarified "machine" to mean mail machine and meter. None of the prospective bidders, including Pitney Bowes and ABS objected to that interpretation at the time.

    However, the Pitney Bowes equipment has its accounting system in the weighing scales and the ABS system has a separate piece of equipment connected by cable to the meter to provide the accounting capabilities required in the specifications.

    
    

12. ABS and Pitney Bowes included references in their original bids. When asked to provide additional references with "a mail management system using 16 digits for the model numbers ... bid", Pitney Bowes did not and ABS did. No one in the Department is known to have checked ABS' references and, if they had, they would have found that the ABS' references listed do not have systems with the capabilities requested.

    
    

    Pitney Bowes' Bid

    
    

13. The Star 90 and Starpost accounting systems bid by Pitney Bowes collect account summaries, station summaries, and operator summaries. The accounting system is located in the weighing scales.

14. Pitney Bowes proposed to use its A900 postage meter, with its Starpost and Star 90 accounting systems. The accounting systems expand the meter's accounting capabilities, by increasing account numbers to a maximum of 16 digits.

    
    

15. Pitney Bowes' failure to list any reference in response to the clarifications request caused at least one member of the evaluation committee to determine that the bid was not responsive.

    
    

16. The chairman of the Department's procurement task force also questioned, due to the absence of references whether Pitney Bowes' software could meet the specifications. In particular, he was concerned that Pitney Bowes equipment was not able to interface via modem to a centralized computer mail management system. He understood the ITB to require mailing machines and meters to collect usage information. Although another member of the committee understood the ITB's reference to a "machine" that could collect usage information to mean the mail management system. An earlier draft of the ITB supports the latter interpretation, but the final version of the ITB does not.

    
    

17. Nothing in the specifications specifically precluded having an accounting system in the scales, as proposed by Pitney Bowes. However, because the accounting system is in the scales, the Pitney Bowes equipment requires a dedicated computer at each of the remote sites to transmit data to a central computer in Tallahassee. By contrast, the ABS accounting system has the capability to interface with the Tallahassee computer by having a modem connected to it. There are 84 remote sites in the Department's Division of Labor Employment and Training. It was not clear how many total remote sites the Department has, but the number exceeds 100.

    
    

18. The ITB does not specifically prohibit a bidder from bidding equipment that would later require personal computers to link to a mail management system. In fact, the Department has personal computers ("PC") at most of its sites throughout the state.

    
    

19. In an effort to reassure the Department after its representative was unable to give references concerning a 16 digit mail management system using solely a modem to transfer data, Pitney Bowes offered to substitute different, more expensive equipment for the price quoted and to provide references for that operational system.

    
    

20. Pitney Bowes' representative conceded that the bid information included no documentation that stated its equipment had the capability to interface with a centralized mail management system via modem. On the basis of their belief that the Pitney Bowes system could not interface with a centralized computer via modem, the Bid Evaluation Committee unanimously found Pitney Bowes' bid nonresponsive, despite its representatives' statements to the contrary. In the absence of documentation, the Committee's conclusion was not unreasonable or arbitrary.

    
    

    Advanced Business Systems' Bid

    
    

21. The equipment bid by ABS was manufactured by Ascom Hasler. ABS forwarded the ITB to Ascom Hasler to select the equipment it would include in the bid.

22. ABS bid the 1201 and 2201 mailing machines for sale, 1441 TMS postage meter for lease, and models 10057, 1010L, 1030L and MPS electronic scales for purchase. The bid was in compliance with United States Postal Service requirements that meters can only be leased not sold. The accounting system bid by ABS was Ascom Hasler's AMS 20 modified to produce operator summaries. Ascom Hasler's national sales director testified that the meter bid, model 1441 TMS, stores data on postage amount, possibly the number of pieces of mail, and has the capability to down load postage from the Postal Service using a modem. The modified AMS 20 operates functionally as an adjunct to the meter, having no independent use, to keep up to 16 digit information on 10 accounts at each location, and station and operator summaries. With mailing machines, postage meters and the modified AMS 20 accounting system at each remote site, data from the meters and the accounting system can be transmitted to the central computer making it a complete mail management system with the addition of modems at each site, a receiving modem in Tallahassee, and software for the Tallahassee central computer. The AMS 20 is physically a separate piece of equipment and is not a postage meter subject to approval and lease-only requirements of the United States Postal Service. The AMS 20 is an extension of the meter and functionally a part of the meter, having no independent function.

    
    

23. ABS provided documentation of the capabilities of the AMS 20 as modified in a letter submitted with its bid. ABS did not provide clear documentation that the electrical equipment in its bid had Underwriter's Laboratories ("UL") approval, although the equipment is and was at the time of the bid, UL approved.

    
    

24. The UL approvals were faxed to the President of ABS from Ascom Hasler the day before the bids were delivered. He personally compiled the bid, technical brochures, and UL letter and delivered them to the Department.

    
    

25. The faxed copies of UL approvals submitted were poorly reproduced, but did not appear to reference the model numbers of the equipment in the ABS bid. Nevertheless, the evaluation board unanimously decided to accept the ABS bid.

    
    

    The Bidding Process

    
    

26. One member of the evaluation board considered the notice of intent to award the bid to Pitney Bowes as a method for making contents of the bids public. After the notice of intent, ABS representatives discussed Pitney Bowes' bid with evaluation board members Hall and Berryman. In these conversations and in questions transmitted to board members ABS raised questions regarding the capabilities of Pitney Bowes' mailing equipment.

    
    

27. The failure of Pitney Bowes to list references in response to the telefax of June 25 and the fact that the accounting system for the models bid is in the weighing scales are the factors which led the evaluation committee to conclude unanimously that Pitney Bowes' equipment did not meet the specifications.

    
    

28. ABS' references were provided, but apparently not checked by the Department staff, although the Department never before had contracted with ABS for mailing equipment. The Department previously had purchased supplies from ABS and has some Ascom Hasler equipment in a few offices. If the Department had contacted ABS' references, it would have found that ABS had no 1441 TMS meter with a modified AMS 20 accounting system meeting the requested specifications in operation.

    CONCLUSIONS OF LAW

    
    

29. The Division of Administrative Hearings has jurisdiction over this case pursuant to Subsection 120.57(1).

    
    

30. One test in bid cases is whether the purposes of the competitive bidding process have been subverted by fraud or collusion, as a result of an agency acting arbitrarily, illegally or dishonestly. Department of Transportation v. Groves-Watkins Contractor, 530 So.2d 912 (Fla. 1988).

    
    

31. Pitney Bowes is favored as the low bidder, if its bid is responsive in all material aspect. Intercontinental Properties v. DHRS, 606 So.2d 380 (Fla. 3d DCA 1992).

    
    

32. In addition to the issues related to the ITB specifications, Pitney Bowes alleges irregularities in the bid process, including the following: (1) the Department's notice of intent to award to Pitney Bowes had the effect of making bids public to allow ABS to review and advise the Department concerning Pitney Bowes' bid; (2) that the Department concluded that Pitney Bowes' equipment could not interface via modem with a centralized, computer mail management system because Pitney Bowes could not give references for its systems, although having references for a currently operational mail management system was not a specification in the ITB; and (3) that no one on the Department staff and evaluation committee checked ABS' references, even though the Department had never before contracted with ABS for such services.

    
    

33. Subsection 119.07(3)(0), Florida Statutes, provides that materials submitted in response to an ITB become public documents after the posting of a notice of intent to award the bid.

    
    

34. After the notice of intent to award the bid to Pitney Bowes was posted, contacts between Ascom Hasler employees and Department staff, and ABS review of the Pitney Bowes bid are permitted by Subsection 119.07(3)(0), Florida Statutes and existing case law. In E. M. Watkins & Co., Inc. v. Board of Regents, 414 So.2d 583 (Fla. 1980), the court's recitation of the facts includes a statement that a competitor's complaint to agency staff resulted in a reversal of the agency's initial preliminary decision and an award to the complaining competitor. The contacts are not evidence of fraud or collusion, and is not illegal.

    
    

35. Pitney Bowes' failure to document to the Department that its equipment was capable of interfacing via modem with a central mail system, and the failure, in fact, to require solely a modem and the supplementary software and computer upgrades associated with the use of a modem to link to a central system is competent evidence which supports the Department's conclusion that the Pitney Bowes' bid was nonresponsive. Even if Pitney Bowes' equipment can function in an identical manner as that bid by ABS, the Department may require that accounting function occur in a particular piece of equipment in the system configuration to facilitate its long range plans for a more comprehensive, centralized system.

    
    

36. The Department's interpretation of the ITB as requiring accounting functions as an integral component of the meter is a material, fundamental element of the ITB. ABS documented, in its original bid submission, that the system it bid could perform the accounting functions of the ITB. In addition, ADS demonstrated at hearing that the Department reasonably concluded that the modified ATMS 20 accounting system is functionally a part of the meter.

37. Because the ITB specification regarding the accounting functions is a material, fundamental element of the requirements, the equipment cannot be substituted, as proposed by Pitney Bowes, because the substitution would correct more than a technical inadequacy of the bid. The Department is prohibited from accepting Pitney Bowes offer of more expensive equipment for which it could provide references. The practice of amending bids to offer more expensive items to gain an advantage or benefit over competitors was rejected in Harry Pepper & Associates v. City of Cape Coral, 352 So.2d 1190 (Fla. 2d DCA 1977).

    
    

38. ABS failed to show at hearing that it met the UL documentation requirement of the ITB. The failure to do so has been corrected by testimony that the equipment was, as required, UL approved. In addition, no material advantage was gained by ABS' submission of an erroneous or unclear copy of a faxed UL letter.

    
    

39. Pitney Bowes has the burden of proof in this bid protest and has not shown that the submission of an unclear or erroneous UL letter covering different Ascom Hasler equipment gave any advantage or benefit to ABS. Absent such a showing the omission must be treated as a minor, technical irregularity. Harry Pepper & Associates, supra.

    
    

40. Some members of the Department staff based their decision on Pitney Bowes' lack of references and ABS' references for systems which were not that requested. The erroneous conclusions do not alter the fact that, despite the issue of references, the ABS documentation in the original bid submission and the system configuration requirements provide competent, substantial evidence to support the award to ABS. In addition, the failure to check references for a new supplier was not shown to be applicable in this case, because, although limited, the Department previously has done business with ABS and has in use Ascom Hasler equipment.

RECOMMENDATION

Based on the foregoing Findings of Fact and Conclusions of Law, it is RECOMMENDED that the Department of Labor and Employment Security enter a

final order awarding Bid No. 93-066-OR to Advanced Business Systems over the protest of Pitney Bowes, Inc.

DONE AND ENTERED this 13th day of December, 1993, in Tallahassee, Leon County, Florida.

ELEANOR M. HUNTER

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 13th day of December, 1993.

APPENDIX TO RECOMMENDED ORDER, CASE NO. 93-4192BID

To comply with the requirements of Section 120.59(2), Fla. Stat. (1991), the following rulings are made on the parties' proposed findings of fact:

Petitioner's Proposed Findings of Fact.

1. Subordinate to Finding of Fact 1 and 2.

2. Accepted in Finding of Fact 1.

3. Subordinate to Conclusions of Law.

4. Subordinate to Finding of Fact 11.

5. Accepted in Finding of Fact 11.

6. Accepted in Finding of Fact 12.

7. Accepted in Finding of Fact 12.

8. Accepted in Finding of Fact 12.

9. Accepted in Finding of Fact 12.

10. Accepted in Finding of Fact 17.

11. Accepted in Finding of Fact 17.

12. Accepted in Finding of Fact 18 and 19.

13. Accepted in Finding of Fact 18 and 19.

14. Subordinate to Finding of Fact 2.

15. Accepted in Finding of Fact 2.

16. Subordinate to Finding of Fact 4, but not all voting members

17. Subordinate to Finding of Fact 4, but not all voting members

18. Subordinate to Finding of Fact 21.

19. Accepted in Finding of Fact 16.

20. Accepted in Finding of Fact 16.

21. Accepted in Finding of Fact 5.

22. Accepted in Finding of Fact 5.

23. Accepted in Finding of Fact 3 and 5.

24. Accepted in Finding of Fact 6.

25. Accepted as to one member, in Findings of Fact 26.

26. Subordinate to Finding of Fact 26.

27. Clear as to Vavra, not as to Snow in Finding of Fact 26.

28. Accepted in Finding of Fact 26.

29. Accepted in Finding of Fact 10.

30. Accepted in Finding of Fact 26.

31. Accepted in Finding of Fact 6.

32. Accepted in Finding of Fact 9.

33. Accepted in Findings of Fact 28.

34. Accepted in Finding of Fact 28.

35. Accepted in Finding of Fact 28.

36. Accepted in Findings of Fact 7, 18 and 19.

37. Accepted in relevant part for members specified in Findings of Fact 16.

38. Accepted in Finding of Fact 18.

39. Rejected, based on ITB language, in Finding of Fact 11.

40. Accepted in relevant part in Finding of Fact 15.

41. Accepted in Preliminary Statement and subordinate to Finding of Fact 12.

42. Accepted in Finding of Fact 3.

43. Accepted in Finding of Fact 14.

44. Accepted in Finding of Fact 13.

45. Accepted in Finding of Fact 13.

46. Accepted in Findings of Fact 13 and 14.

47. Accepted in Finding of Fact 13.

48. Accepted in Finding of Fact 14.

49. Accepted in Finding of Fact 14.

50. Accepted in Finding of Fact 13.

51. Accepted in Finding of Fact 3.

52. Subordinate to Findings of Fact 23, 24, and 25.

53. Subordinate to Findings of Fact 23, 24, and 25.

54. Subordinate to Findings of Fact 23, 24, and 25.

55. Subordinate to Findings of Fact 23, 24, and 25. 56(a)-(g) Rejected in Findings of Fact 22.

Respondent's Proposed Findings of Fact.

1. Accepted in Conclusions of Law.

2. Accepted in Preliminary Statement and Finding of Fact 2.

3. Accepted in Preliminary Statement and Findings of Fact 5 and 15.

4. Accepted in Preliminary Statement and Finding of Fact 5 and 16.

5. Accepted in Preliminary Statement and Finding of Fact 21.

6. Subordinate to Findings of Fact 2 and 9.

7. Accepted in Preliminary Statement and Findings of Fact 5 and 17.

8. Accepted in Preliminary Statement.

9. Accepted in Preliminary Statement and Findings of Fact 5 and 18.

10. Accepted in Finding of Fact 13.

11. Subordinate to Preliminary Statement.

12. Accepted in Findings of Fact 1 and 11.

13. Accepted in Findings of Fact 1 and 11 except "with a minimum of difficulty" was not in specification.

14. Subordinate to Finding of Fact 11.

15. Subordinate to Finding of Fact 11.

16. Subordinate to Preliminary Statement.

17. Subordinate to Preliminary Statement.

18. Accepted in Finding of Fact 11.

19. Accepted in Finding of Fact 11.

20. Accepted in Finding of Fact 11.

21. Subordinate to Preliminary Statement and Finding of Fact 11.

22. Subordinate to Preliminary Statement and Finding of Fact 11.

23. Accepted in Finding of Fact 11.

24. Accepted in Finding of Fact 2.

25. Accepted in Finding of Fact 7.

26. Accepted in Finding of Fact 13.

27. Accepted in Finding of Fact 20.

28. Accepted in Finding of Fact 22.

29. Accepted in Finding of Fact 6.

30. Subordinate to Finding of Fact 6.

31. Accepted in Finding of Fact 5.

32. Accepted in Findings of Fact 6 and 9.

33. Accepted in Findings of Fact 6 and 9.

34. Subordinate to Findings of Fact 6 and 9.

35. Accepted in Findings of Fact 6 and 9.

36. Accepted in Finding of Fact 7.

37. Accepted in Finding of Fact 9.

38. Accepted in Finding of Fact 8.

39. Accepted in Finding of Fact 10.

40. Issue not reached.

41. Accepted in Finding of Fact 20.

42. Accepted in Finding of Fact 20.

43. Accepted in Findings of Fact 17 and 20.

44. Subordinate to Finding of Fact 17.

45. Subordinate to Finding of Fact 17.

46. Accepted in Finding of Fact 25.

47. Accepted in Finding of Fact 22.

48. Accepted in Finding of Fact 22.

49. Accepted except the word "every" in Findings of Fact

    22 and 26.

50. Rejected in Findings of Fact 22.

51. Accepted in Finding of Fact 22.

52. Accepted in Finding of Fact 22.

53. Subordinate to Finding of Fact 22.

54. Subordinate to Finding of Fact 22.

55. Rejected first sentence in Finding of Fact 11.

56. Subordinate to Finding of Fact 22.

57. Accepted in Finding of Fact 24.

58. Accepted in Finding of Fact 25.

59. Issue not reached.

60. Issue not reached.

61. Issue not reached.

62. Subordinate to Findings of Fact 7 and 13.

63. Accepted in Finding of Fact 9.

64. Issue not reached.

65. Issue not reached.

66. Accepted in Finding of Fact 26.

67. Accepted in Finding of Fact 26.

68. Accepted in Finding of Fact 10.

69. Accepted in Finding of Fact 10.

70. Accepted in Finding of Fact 12.

71. Accepted in Findings of Fact 12.

COPIES FURNISHED:

Trisa J. Thompson, Esquire SEYFARTH, SHAW, FAIRWEATHER

& GERALDSON

Suite 500

815 Connecticut Avenue, N.W. Washington, D.C. 20006-4004

Edward A. Dion, Esquire Department of Labor and

Employment Security Hartman Building, Suite 307 2012 Capital Circle, S.E.

Tallahassee, Florida 32399-2189

Cathleen DeMarco, Esquire 5360 Maple Avenue Morristown, New Jersey 07963

(Attorney for Advanced Business Systems)

Shirley Gooding, Secretary

303 Hartman Building

2012 Capital Circle Southeast Tallahassee, Florida 32399-2152

Cecilia Renn

Chief Legal Counsel

307 Hartman Building

2012 Capital Circle, Southeast, Tallahassee, Florida 32399-2152

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 ten 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: 93-004192BID

Orders for Case No: 93-004192BID