STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, DIVISION OF HOTELS AND RESTAURANTS,

Petitioner,

vs.

TRAVELER'S INN,

Respondent.

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) Case No. 02-3624

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RECOMMENDED ORDER

Pursuant to notice, a formal hearing was held in this case on December 5, 2002, in Kissimmee, Florida, before T. Kent Wetherell, II, the designated Administrative Law Judge of the Division of Administrative Hearings.

APPEARANCES

For Petitioner: Charles F. Tunnicliff, Esquire

Department of Business and Professional Regulation

1940 North Monroe Street Tallahassee, Florida 32399-2202

For Respondent: Bill Slovik, General Manager

Traveler's Inn

4900 West Irlo Bronson Highway Kissimmee, Florida 34741

STATEMENT OF THE ISSUES

The issues are whether the violations cited by the Division of Hotels and Restaurants during its inspection and re-

inspection of Respondent's hotel existed, and, if so, what penalty should be imposed.

PRELIMINARY STATEMENT

On November 16, 2001, the Division of Hotels and Restaurants (Division or Petitioner) issued an Administrative Complaint against Respondent arising out of the Division's inspection and re-inspection of Respondent's hotel in August 2001 and October 2001, respectively. The administrative complaint identified three uncorrected violations: (1) the certification for the hotel's boiler had expired; (2) the hotel's fire sprinkler system had not been inspected within the prior 12 months; and (3) an advertising brochure contained a false statement regarding the travel time from the hotel to Walt Disney World and Sea World.

By letter dated February 6, 2002, Respondent contested the allegations in the administrative complaint and requested a formal administrative hearing. On September 19, 2002, the Division referred the matter to the Division of Administrative Hearings for the assignment of an administrative law judge to conduct the hearing requested by Respondent.

The hearing was held on December 5, 2002. Respondent was represented at the hearing by Bill Slovik, the general manager of the hotel at issue in this proceeding. Mr. Slovik is not an attorney, but he was authorized at the hearing to appear as the

qualified representative for Respondent. See Rule 28-106.106, Florida Administrative Code.

At the hearing, Petitioner presented the testimony of Michael Campbell, an inspector with the Division; John Norman, a boiler safety inspector with the State Fire Marshall's office; and Jo Beekman, a supervisor with the Division. Petitioner's Exhibits P1 through P4 were received into evidence. Respondent presented the testimony of Nizar Rahemtulla, the president of the corporation that owns the hotel at issue in this proceeding. Respondent's Exhibits R1 and R2 were received into evidence.

Upon the Division's request, official recognition was taken of Chapter 554, Florida Statutes; Section 509.201(2)(d), Florida Statutes; Rule 61C-1.004(12), Florida Administrative Code; and Sections 1-8 and 2-1 of the National Fire Protection Association Life Safety Code 25.

The Transcript of the hearing was filed on December 24, 2002. The Division requested and the parties were given 20 days from the date that the Transcript was filed to file their proposed recommended orders (PROs). The parties' PROs were timely filed and were given due consideration by the undersigned in preparing this Recommended Order.

FINDINGS OF FACT

Based upon the testimony and evidence received at the hearing, the following facts were established by clear and convincing evidence:

1. Parties

   
   

   1. Petitioner is the state agency responsible for regulating hotels pursuant to Part I of Chapter 509, Florida Statutes (the Act).

   2. Respondent operates the Traveler's Inn hotel on West Irlo Bronson Highway (U.S. Route 192) in Kissimmee, Florida.

2. The Hotel

   
   

   1. The hotel is near the intersection of U.S. Route 192 and State Road 535.

   2. The hotel has approximately 125 guest rooms and is three stories in height. The record does not reflect the year that the hotel was constructed.

   3. Only the first floor and half of the second floor of the hotel are currently in use.

   4. Respondent "closed" the third floor of the hotel as a result of the hotel's low occupancy rate (less than 30 percent), which is due in large part to the post-September 11 decline in the tourism industry. The record does not reflect whether the third floor rooms are in condition to be used if there was additional demand for rooms at the hotel, nor does it reflect

      whether those rooms were "closed" at the time of the Division's initial inspection in August 2001, or the re-inspection in October 2001.

3. Hotel Inspection Process Followed by the Division

   
   

   1. The Division is required to routinely inspect hotels that are subject to the Act. If violations are identified, the hotel operator is given a period of time within which to correct the violation.

   2. The correction period varies based upon the severity of the violation. The period is typically shorter for "critical" violations (those which are life-threatening or present a safety hazard) than it is for "non-critical" violations (those which do not immediately affect life safety issues and which can be fixed or corrected on a routine basis). The Division's inspectors have the authority to extend the correction period as circumstances warrant.

   3. After the expiration of the correction period, the Division re-inspects the facility to determine whether the violation has been corrected. If the violation has not been corrected and the time for doing so is not extended by the inspector, the Division initiates the administrative process to impose sanctions on the hotel's license.

4. Violations Documented at Respondent's Hotel Based Upon the Division's Inspection and Re-inspection

1. The Division conducted a routine investigation of Respondent's hotel on August 31, 2001. The inspection was conducted by Michael Campbell.

2. Mr. Campbell's inspection report documented a number of violations at Respondent's hotel, including (1) the certification for the hotel's boiler had expired; (2) the hotel's fire sprinkler system had not been inspected within the prior 12 months; (3) an advertising brochure contained a false statement regarding the travel time from the hotel to Walt Disney World and Sea World; and (4) the hotel's dock and approach walkway were not safe.

3. Based upon his report, Mr. Campbell issued a written warning to Respondent. The warning gave Respondent until October 1, 2001, to correct the cited violations.

4. Mr. Campbell performed a re-inspection of Respondent's hotel on October 3, 2001. Based upon that re-inspection,

   Mr. Campbell issued another report which documented that the four violations listed above had not been corrected. The other violations cited by Mr. Campbell in his initial inspection report had been corrected prior to the re-inspection.

5. The inspection report forms designate the sprinkler system violation and the advertising brochure violation to be "critical violations" and "of critical concern." The boiler violation is designated as a "non-critical violation." Despite the forms' characterizations of the sprinkler system and advertising brochure violations as requiring immediate correction, Mr. Campbell gave Respondent a full month to correct the violations. This suggests that Mr. Campbell did not consider the violations to pose a threat to public health, safety, or welfare, and the evidence fails to establish that any of the violations posed such a threat (although, as discussed below, the evidence does clearly and conclusively establish the violations).

6. Mr. Campbell's October 2001 report informed Respondent that the Division would be initiating the administrative process in order to assess sanctions against Respondent's license. The Division's Administrative Complaint and this proceeding followed.

7. Only the first three violations remain at issue; the violation based upon the dock and approach walkway is no longer at issue. The circumstances related to each of the violations still at issue are described below.

   1. Boiler

      
      

8. Respondent has a Lochinvar boiler which supplies hot water to the hotel. The boiler is rated at 570,000 BTU per hour (BTU/hr), which represents the maximum heat input.

9. The boiler only operates at the maximum level. Thus, whether or not the boiler is heating water to serve all 125 guest rooms or only a portion of those rooms, it is operating at 570,000 BTU/hr.

10. The boiler was first inspected by the State Fire Marshall in May 1999. The inspection was performed by John Norman.

11. Mr. Norman placed an identification tag on the boiler with a May 1999 date. However, he did not recommend that a certificate be issued for the boiler at that time because of an insufficient safety valve on the boiler.

12. Respondent fixed the safety valve and Mr. Norman re- inspected the boiler in September 1999. Based upon that re- inspection, Mr. Norman recommended that a certificate be issued.

13. The 1999 certificate was not introduced at the hearing. However, Mr. Norman testified that upon issuance, the certificate would have been valid for two years from the date that the certificate was issued, or until September 2001.

14. Neither the certificate, nor any of Mr. Norman's inspection reports were posted in the room where the boiler was

    located at the time of Mr. Campbell's inspections in August 2001 and October 2001.

15. Mr. Norman inspected the boiler again in May 2002 and a boiler certificate was issued by the State Fire Marshall on June 11, 2002. The certificate is valid until May 9, 2004.

16. Mr. Norman characterized the boiler as being in good condition, both in September 1999, and presently. He further testified that the state of the boiler at those times indicate that it would have been in good condition during the intervening period as well, which would include the times of Mr. Campbell's inspection and re-inspection.

    2. Sprinkler System

    
    

17. The fire sprinkler system in Respondent's hotel only covers the laundry room, the maintenance room, and the boiler room. The guest rooms are not covered by the sprinkler system.

18. The tag on the sprinkler system indicated that it was last inspected on August 3, 2000. Because the system is required to be inspected annually, the inspection expired on August 3, 2001.

19. Accordingly, at the time Mr. Campbell conducted his initial inspection, the fire sprinkler system's inspection had expired. The system was not inspected prior to Mr. Campbell's re-inspection, and, as of the date of the hearing, it still has not been inspected.

20. The cost to inspect the sprinkler system is between

    
    

    $800.00 and $1,000.00.

    
    

21. Respondent's owner failed to have the sprinkler system inspected because he could not afford the cost of the inspection as a result of the reduction in business at the hotel post- September 11, and because of his independent interpretation of Section 509.215, Florida Statutes, which prescribes fire safety requirements for hotels.

22. Respondent's owner relied upon the 1993 version of Section 509.215, Florida Statutes, because that was the most current version of the statute in the hotel's "library." The current version of the statute is materially the same as the 1993 version.

    3. Advertising Brochure

    
    

23. At the time of Mr. Campbell's initial inspection, Respondent had a brochure advertising its hotel which included the following statement on the front cover: "Five minutes from Walt Disney World Resort and Sea World."

24. The brochures were available at or near the hotel's front desk. The record does not reflect whether the brochures were distributed by Respondent in any other manner, e.g., mailing to prospective guests, placed in kiosks or advertising racks around the area.

25. Mr. Campbell obtained a brochure from the hotel's front desk during his August 2001 inspection. That brochure was not introduced at the hearing.

26. The brochures were printed in 1996 and, at that time, the statement on the brochure may have been accurate.1 However, as a result of the growth and additional traffic congestion in the area, Respondent's hotel is no longer five minutes from Disney or Sea World. It is now approximately 18 minutes from Sea World and a similar distance time-wise from Disney.

27. In an effort to correct the brochure in response to the August 2001 inspection report, Respondent's owner directed his staff to strike through the words "Five minutes from" on each of the brochures with a black marker. The brochure introduced by Respondent at the hearing was marked-out in that manner.

28. Division supervisor Jo Beekman confirmed at the hearing that marking-out those words on the brochure would be sufficient to address the cited violation.

29. Apparently, however, all of the brochures were not marked-out because Mr. Campbell obtained an unmodified brochure during his October 2001 re-inspection. That brochure was not introduced at the hearing, but Respondent's owner acknowledged that his staff may have "missed a few" brochures when they marked through the others.

    CONCLUSIONS OF LAW

    
    

    1. Jurisdiction and Burden of Proof

       
       

30. The Division of Administrative Hearings has jurisdiction over the parties to and subject matter of this proceeding pursuant to Sections 120.569 and 120.57(1), Florida Statutes. (All references to Sections and Chapters are to the Florida Statutes (2001), except as otherwise indicated. All references to Rules are to the current version of the Florida Administrative Code.)

31. The Division has the burden to prove the existence of the violations alleged in the Administrative Complaint by clear and convincing evidence. See Dept. of Banking & Finance v. Osborne Stern & Co., 670 So. 2d 932 (Fla. 1996).

1. Violations Cited by the Division at Respondent's Hotel

   
   

   1. Boiler

      
      

      1. Section 61C-1.004(12) provides in relevant part:

         
         

         The insurance inspector's boiler report is required annually for power boilers and high pressure/high temperature boilers and biannually for low pressure steam or vapor heating boilers and shall be posted in the boiler room.

         
         

      2. The "boiler report" referenced in the Rule appears to be the same as the certificate of compliance issued by the State Fire Marshall pursuant to Chapter 554, the Boiler Safety Act (BSA). Indeed, consistent with Rule 61C-1.004(12), Section

         554.1101(2) provides that "[t]he certificate [of compliance for the boiler] shall be posted under glass, or be similarly protected, in the room containing the boiler."

      3. Respondent argues that its boiler is exempt from the BSA because it has been operating at less than 400,000 BTU/hr due to the low occupancy of the hotel and the concomitant reduced production of hot water by the boiler. Respondent's argument is not supported by the facts established at the hearing or the law, as correctly construed.

      4. As a matter of fact, the evidence establishes that the boiler in Respondent's hotel operates at its full capacity from a heat input perspective whether it is producing hot water to serve all of the hotel's rooms or only a portion of those rooms. As a matter of law, the rating of a boiler (and, hence, the applicability of the BSA) is based upon the boiler's maximum heat input, not its output of hot water as Respondent's argument presumes. See Section 554.109(2)(a) (exempting from the BSA those boilers which have a "heat input" of less than 400,000 BTU/hr).

      5. Because the boiler in Respondent's hotel has a maximum heat input of 570,000 BTU/hr, it is not exempt from the BSA. Id. Because Respondent did not have a current certificate of compliance for its boiler posted in the boiler room, Respondent was in violation of Rule 61C-1.004(12) even though the boiler

         was technically certified at the time of Mr. Campbell's initial inspection and at all times has been in good operating

         condition.

         
         

         2. Fire Sprinkler System

         
         

      6. Although the record does not reflect the date that Respondent's hotel was constructed, the fact that the Division did not cite the hotel for failing to have a fire sprinkler system that covered the guest rooms suggests that it was constructed prior to October 1, 1983. Indeed, the Division stipulated at the hearing "that it's not necessary that [the Respondent's sprinkler system] go to the guest rooms."

      7. Accordingly, Subsection (2) of Section 509.215 applies, not Subsection (1) of that statute. Section 509.215(2) provides:

         Any public lodging establishment, as defined in this chapter, which is of three stories or more and for which the construction contract was let before October 1, 1983, shall be equipped with:

         
         

         1. A system which complies with subsection (1); or

            
            

         2. An approved sprinkler system for all interior corridors, public areas, storage rooms, closets, kitchen areas, and laundry rooms, less individual guest rooms, if the following conditions are met:

            
            

            1. There is a minimum 1-hour separation between each guest room and between each guest room and a corridor.

            2. The building is constructed of noncombustible materials.

               
               

            3. The egress conditions meet the requirements of s. 5-3 of the Life Safety Code, NFPA 101.

               
               

            4. The building has a complete automatic fire detection system which meets the requirements of NFPA-72A and NFPA-72E, including smoke detectors in each guest room individually annunciating to a panel at a supervised location.

            
            

      8. The fact that the third story of Respondent's hotel is not currently in use does not exempt the hotel from the operation of Section 509.215(2). The statute does not distinguish between occupied floors and unoccupied floors in determining whether the establishment is "three stories or more."

      9. Section 509.215(5) authorizes the State Fire Marshall to adopt rules pursuant to its authority in Chapter 633 to establish the fire safety requirements for public lodging establishments. See also Section 633.022(1)(b) (directing the establishment of uniform fire safety standards for various types of buildings, including "transient public lodging establishments"). Section 509.215(5) further provides that an establishment which is in violation of the rules of the State Fire Marshall is subject to administrative sanctions pursuant to Section 509.261.

      10. Pursuant to its authority in Chapter 633, the State Fire Marshall promulgated Rule 4A-3.012. That Rule adopts and incorporates by reference various standards of the National Fire Protection Association (NFPA), including NFPA 25. See Rule 4A- 3.012(1). And cf. Section 633.065(2) (requiring fire equipment to " be inspected, serviced, and maintained in accordance

          with . . . the applicable National Fire Protection Association standards."); Rule 4A-46.035(22) (listing NFPA 25 as one of the standards with which fire protection system contractors must comply).

      11. Chapter 2-1 of NFPA 25 provides "the minimum requirements for the routine inspection, testing and maintenance of [fire] sprinkler systems." Section 2-2.1.1 of NFPA 25 requires the sprinkler system to be inspected annually for corrosion, foreign materials, paint, physical damage, and proper orientation. Accord NFPA 25, Table 2-1 ("Summary of Sprinkler System Inspection, Testing, and Maintenance"). And cf. Rule 4A-

          46.041 (establishing the reporting requirements for inspections of fire protection systems).

      12. The inspection must be performed by an entity licensed under Chapter 633. See generally Sections 633.061 and 633.521; Rule Chapter 4A-46. The owner of the establishment where the system is installed must provide records of the inspection to

          regulatory authorities such as the Division upon request. See NFPA 25, Section 1-8.

      13. The sprinkler system in Respondent's hotel was last inspected on August 3, 2000, and therefore was required to be re-inspected on or before August 3, 2001. The evidence shows that the system had not been inspected as of the date of

          Mr. Campbell's initial inspection or as of the date of his re- inspection, and that it still had not been inspected as of the date of the hearing. Accordingly, Respondent is in violation of Chapter 2-1 of NFPA 25, which is incorporated by reference into the State Fire Marshall's rules and, as a result, Respondent is in violation of Section 509.215(5).

          3. Advertising Brochure

          
          

      14. Section 509.201(2)(d) prohibits the publication of an advertisement "that contains false or misleading statements about any public lodging establishment." Similarly, Rule 61C- 3.002(3)(a) provides:

          An advertisement or notice, designed to attract public attention or patronage, may not be published or displayed with false or misleading statements about any public lodging establishment. This applies to any type of advertisement including signs, billboards, banners, electronic displays, pamphlets, flyers, coupons, magazines, newspapers or other similar publications and displays.

      15. Respondent's brochure is clearly the type of advertisement subject to this Rule, and because the statement on the brochure regarding the proximity of Respondent's hotel to Walt Disney World and Sea World were shown to be false, the brochure violates the Rule.

2. Penalty

1. Section 509.261(1) provides:

   
   

   Any public lodging establishment . . . that has operated or is operating in violation of this chapter or the rules of the division . . . may be subject by the division to:

   
   

   1. Fines not to exceed $1,000 per offense;

      
      

   2. Mandatory attendance, at personal expense, at an educational program sponsored by the Hospitality Education Program; and

      
      

   3. The suspension, revocation, or refusal of a license issued pursuant to this chapter.

      
      

2. The Division is not seeking the suspension or revocation of Respondent's license; it is only seeking an administrative fine. Suspension or revocation of Respondent's license is not justified under the circumstances of this case.

3. The inspection report designates the sprinkler system violation and the advertising brochure violation to be "critical violations" and "of critical concern." However, the report form (DBPR Form HR 5022-014) does not appear to be incorporated by

   reference into the Division's rules, and there is no other rule (or statute) designating those violations as critical.

   Petitioner failed to prove that any of the violations in this case were critical in the sense that they "pose a significant threat to the public health, safety, or welfare." See Rule 61C- 1.0021(2). Accordingly, the provisions of Section 509.261(2) and Rule 61C-1.0021(2), which authorize the Division to assess penalties for each day that the hotel is in violation of a "critical law or rule," do not apply. Indeed, the Division has not argued for the imposition of daily fines in this case.2

4. Neither the Act nor the Division's rules identify the mitigating circumstances that may be considered by the administrative law judge. However, the Division's rules clearly contemplate the consideration of mitigating circumstances. See

   Rule 61C-1.0021(4) (providing the licensee an opportunity to "present mitigation to the division" in informal proceedings under Section 120.57(2)).

5. Respondent contends that no penalty should be imposed because of its financial situation and because it subsequently corrected all of the violations cited by the Division except for the sprinkler system. As to the sprinkler system, Respondent appears to now concede that it is required to have the system inspected because it suggests that the Recommended Order

   requires it to have the system inspected by January 31, 2003. See Respondent's PRO, at 2.

6. As discussed below, Respondent's financial situation was considered as a mitigating circumstance in determining the appropriate total fine, and the corrective action taken (or not taken) by Respondent in response to the violations was considered in determining the amount of the fine attributable to each violation. However, those circumstances do not warrant the imposition of no fine because, except for the advertising brochure which Respondent attempted to correct immediately after Mr. Campbell's initial inspection, the other violations remained uncorrected for a long period of time (nine months for the boiler) or are still uncorrected (sprinkler system). Imposition of no fine would effectively reward Respondent for that delay and would undermine the deterrent effect of the fines authorized by Section 509.261.

7. Respondent's financial situation is a result of the post-September 11 decline in tourism, and is a problem that is certainly not unique to Respondent. Nevertheless, the Division concedes in its PRO that Respondent's financial condition (in conjunction with the forthrightness of Respondent's owner in this proceeding) is a mitigating circumstance that should be considered in determining the appropriate penalty.

8. The record also contains other evidence of mitigation.

   
   

   Specifically, with respect to the advertising brochure, the record establishes that Respondent made a good faith effort to correct the deficiency cited by the Division and the Division did not find a significant number of brochures without the false statement stricken. With respect to the boiler, the evidence establishes that the boiler was technically certified at time of Mr. Campbell's August 2001 inspection, that the boiler is and at all pertinent times has been in good operating condition, and that Respondent has since had the boiler inspected and re- certified.

9. In light of those mitigating circumstances and Respondent's financial situation, a fine in the amount of

   $100.00 for the failure to have the boiler certificate posted in the boiler room and a fine in the amount of $50.00 for the false statement in the advertising brochure are appropriate.

10. With respect to the sprinkler system, the fact that the system does not cover the guest rooms is not a mitigating circumstance that would justify Respondent's failure to have the system inspected. Moreover, unlike the boiler, the record does not reflect whether the sprinkler system is in good operating condition. Accordingly, a more significant fine -- $600.00 -- is appropriate and Respondent should be required to promptly have the sprinkler system inspected.

11. Finally, it is apparent from the testimony of Respondent's owner and the creative legal interpretations of the Act by Respondent's general manager that Respondent would benefit from an educational program on the current laws and rules governing hotels (as compared to the 1993 version of the law in Respondent's "library"). Accordingly, a representative of Respondent's management should be required to attend an educational program sponsored by the Hospitality Education Program. See Section 509.261(1)(b).

RECOMMENDATION

Based upon the foregoing Findings of Fact and Conclusions of Law, it is

RECOMMENDED that the Division of Hotels and Restaurants issue a Final Order which:

1. finds that Respondent violated:

   
   

   1. Rule 61C-1.004(12), Florida Administrative Code, because it failed to have the boiler certificate posted in the boiler room; and

   2. Section 509.215(5), Florida Statutes, and the applicable NFPA standards incorporated into the State Fire Marshall's rules because Respondent failed to have the fire sprinkler system at its hotel inspected annually; and

   3. Rule 61C-3.002(3)(a), Florida Administrative Code, because its advertising brochure contained a false statement;

   and

   
   

2. imposes an administrative fine in the total amount of

   
   

   $750.00, as calculated above;

   
   

3. requires Respondent to have the fire sprinkler system inspected within 15 days of the date of the Final Order, and to provide proof thereof to the Division of Hotels and Restaurants; and

4. requires Respondent's owner and/or general manager to attend an educational program sponsored by the Hospitality Education Program within 60 days of the date of the Final Order, and to provide proof thereof to the Division of Hotels and Restaurants.

DONE AND ENTERED this 22nd day of January, 2003, in Tallahassee, Leon County, Florida.

T. KENT WETHERELL, II Administrative Law Judge

Division of Administrative Hearings The DeSoto Building

1230 Apalachee Parkway

Tallahassee, Florida 32399-3060

(850) 488-9675 SUNCOM 278-9675

Fax Filing (850) 921-6847 www.doah.state.fl.us

Filed with the Clerk of the Division of Administrative Hearings this 22nd day of January, 2003.

ENDNOTES

1/ Respondent's owner testified that five minutes was accurate in 1996, while Ms. Beekman testified that it was not accurate even then. Resolution of that factual dispute is immaterial to the outcome of this proceeding, because the relevant time frame for determining the brochure's accuracy is at the time of the Division's inspection and re-inspection, not its accuracy in 1996.

2/ In its PRO, the Division states that it "could seek $3,000 in fines in this matter" which presumably is based upon the three outstanding violations discussed in this Recommended Order and Section 509.261(1)(a) which establishes a maximum fine of

$1,000.00 per offense. Division PRO, at 4. However, the Division further states that it is only seeking $750.00 in fines. Id.

COPIES FURNISHED:

Nizar Rahemtulla 786 Resorts, Inc.

4900 West Irlo Bronson Highway Kissimmee, Florida 34741

Charles F. Tunnicliff, Esquire Department of Business and

Professional Regulation 1940 North Monroe Street

Tallahassee, Florida 32399-2202

Geoff Luebkemann, Director Division of Hotels and Restaurants Department of Business and

Professional Regulations 1940 North Monroe Street

Tallahassee, Florida 32399-0792

Hardy L. Roberts, III, General Counsel Department of Business and

Professional Regulations Northwood Centre

1940 North Monroe Street Tallahassee, Florida 32399-2202

Bill Slovik, General Manager Traveler's Inn

4900 West Irlo Bronson Highway Kissimmee, Florida 34741

NOTICE OF RIGHT TO SUBMIT EXCEPTIONS

All parties have the right to submit written exceptions within

15 days from the date of 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: 02-003624

Orders for Case No: 02-003624