vs.
Respondent.
) Case No. 03-1230
Upon due notice, a disputed-fact hearing was conducted in this case on May 20, 2003, in Tallahassee, Florida, before the Division of Administrative Hearings by its duly-assigned Administrative Law Judge, Ella Jane P. Davis.
For Petitioner: D. Paul Sondel
For Respondent: Patrick D. Coleman, Esquire,
Amy H. Reisinger, Esquire
Coffman, Coleman, Andrews & Grogan, P.A. Post Office Box 40089
Whether Respondent employer is guilty of an unlawful employment practice, by failure to hire Petitioner on the basis of her color and/or national origin.
On October 28, 2002, Petitioner filed with the Florida Commission on Human Relations (Commission), a Charge of Discrimination, alleging color and national origin discrimination in Respondent's failure to hire her.
On or about March 10, 2003, a Determination of No Cause was entered by the Commission. Petitioner timely filed a Petition for Relief, alleging she had been discriminated against based upon her color and national origin. The cause was referred to the Division of Administrative Hearings on or about April 3, 2003.
By an Order entered May 2, 2003, after a telephonic hearing, D. Paul Sondel was accepted as Petitioner's Qualified Representative.
At the merits hearing on May 20, 2003, Petitioner presented the oral testimony of Diane Johnson, Anita Hayes, Gerald Buchert, Clifford Burr, and Jim Humbles, and testified on her own behalf. She had Exhibits P-1 and P-2 admitted in evidence. (TR-65, 81) Respondent presented the testimony of Diane Johnson and Gerald Buchert and had Exhibits R-1 and R-2 (TR-71, 80) admitted in evidence.
A Transcript was filed on June 11, 2003. The parties' respective Proposed Recommended Orders were timely filed, pursuant to an agreed extended time frame. Both proposals have
been considered. However, the photographs attached to Petitioner's post-hearing proposal are hereby struck because they are outside of the record, and because they were submitted to the Division without simultaneously being served on Respondent.
Respondent Advent Christian Village (Village) is an "employer" as defined in Section 760.02(7), Florida Statutes. The Village is a comprehensive retirement community, which offers a range of living options from independent living to long-term care for senior citizens who can afford them. It accommodates 750 residents and 450 employees.
Petitioner's Charge of Discrimination and Petition for Relief were based upon "color" and "national origin". Apparently, Petitioner and her qualified representative erroneously understand "color" and "race" to be synonymous. However, neither Petitioner nor anyone else testified as to her race. Petitioner is a very dark- or black-complexioned female. Petitioner testified that she was born abroad, but no national origin was specified by stipulation or by evidence. She speaks with an accent, which was not explained on the record as to national origin. The Charge of Discrimination names her country of origin as Sri Lanka.
In August 2002, Petitioner was living in New York. She received a copy of Respondent's notice for a job opening as Director of Food Service, and she applied.
Respondent notified Petitioner to prepare for a telephone interview at 9:30 a.m., on August 12, 2002. When the phone call came at 9:47 a.m., Gerald Buchert, vice president of Respondent's Programs and Services Division, asked Petitioner if she had received a videotape he had sent her about the Village. Petitioner had not received the videotape, but she decided to go ahead with the telephone interview, anyway.
Petitioner and Mr. Buchert engaged in a 45-minute phone discussion of Petitioner's qualifications. Mr. Buchert was aware from Petitioner's accent that she may have been born abroad. Nonetheless, Mr. Buchert considered Petitioner, due to her experience, credentials, and work ethic, to be a viable candidate for the position of Director of Food Service.
It is disputed whether Mr. Buchert urged Petitioner to come to the Florida facility for an in-person interview or whether she volunteered to do so. Respondent did not volunteer to pay Petitioner's way, but before Petitioner and Mr. Buchert hung-up their phones on August 12, 2002, they mutually had agreed to an in-person interview at the Village on September 11, 2002. Mr. Buchert made sure before hanging up the phone that this was a date that Respondent's full interview team would be
available. Mr. Buchert also intended to introduce Petitioner, on the date of her in-person interview, to Mr. Jim Humbles, Respondent's President and CEO. Petitioner formed the belief that Mr. Humbles would be part of the interview team.
As President and CEO, Mr. Humbles traditionally is only involved in interviews for cabinet-level positions within the Village's management hierarchy. Positions such as vice president are cabinet-level positions. The Director of Food Service position is not a cabinet-level position. It is a position within the Programs and Services Division, which is headed by vice president Buchert. Mr. Buchert was in charge of interviewing and hiring a Director of Food Service.
After the telephone interview on August 12, 2002, but on the same day, Petitioner received the video that Mr. Buchert had sent. There is no record evidence of what was contained in this video, and therefore no record evidence of how it represented "people of color" or anyone's national origin, or if it did. Petitioner never viewed it.
Through Mr. Humbles' assistant, Mr. Buchert scheduled Mr. Humbles' attendance at lunch on September 11, 2002, in the Village's cafeteria with himself and Petitioner. His assistant placed the lunch appointment on Mr. Humbles' calendar.
At some point after the lunch appointment had been placed on Mr. Humbles' calendar, he was invited to take part in
the memorial service to be held in the Village chapel on September 11, 2002, to memorialize the victims of 9/11/01's acts of terrorism. Feeling that he would be too rushed to attend both events, Mr. Humbles cancelled the lunch appointment. At the latest, this cancellation was accomplished between Mr.
Humbles' assistant and Mr. Buchert's assistant on the day before September 11, 2002.
Diane Johnson, Director of Housekeeping Services; Anita Hayes, vice president for the Village's Conference and Retreat Center; and Mr. Buchert, comprised the interview team for the Director of Food Service position. Immediately upon Petitioner's arrival at the Village on September 11, 2002, Petitioner met with the interview team in Mr. Buchert's office. Petitioner was invited to attend the memorial service for victims of 9/11/01's terrorism in the chapel with Mr. Buchert, which she did.
After attending the memorial service, as they walked across the parking lot, Mr. Buchert hailed Mr. Humbles, and introduced Petitioner to him. Mr. Humbles, who had just participated in the memorial service, was emotionally overcome. Mr. Buchert noticed nothing unusual, but Mr.Humbles admitted to possibly being uncharacteristically aloof or withdrawn in his response to Petitioner as a result of his emotions over the chapel service. The introduction of Mr. Humbles and Petitioner
and their brief conversation lasted only 20 to 30 seconds. Due to the abruptness of her meeting with Mr. Humbles, Petitioner interpreted Mr. Humbles' failure to inquire about her trip from New York and to engage in other pleasantries as a snub of her, personally, and thus, discrimination.
Petitioner then went to lunch with Mr. Buchert and the other interview team members in the Village cafeteria. She testified that she saw Mr. Humbles eating in the cafeteria while she was there, and that she considered his non-attendance at the team's table to be a rejection of her candidacy for employment based on race, color, or national origin. Mr. Humbles testified equally credibly that he did not remember being in the cafeteria that day, he only remembered he had previously cancelled his lunch attendance due only to his crowded calendar.
Petitioner testified, without refutation, that during lunch, Mr. Buchert said, ". . . in the Village is [sic.] still people who discriminated [sic.] colored people," and Petitioner changed the subject, saying, "What has [sic.] to do with the color if you have experience?" (TR 39) It is inferred that Petitioner considered Mr. Buchert's statement to be an offensive or discriminatory one.
After lunch, Petitioner was interviewed for two to three hours, by Mr. Buchert, Diane Johnson, and Anita Hayes. Mr. Buchert is a white male. The two other interviewers are
white females. There was no evidence presented of their country of origin, but it is inferred that all three interviewers are native-born Americans.
Ms. Johnson was on the interview committee because of her long history as a Village employee. Ms. Hayes was on the interview committee because there was going to be consideration of expanding food service into the Conference and Retreat Center, which she managed.
Petitioner and all the interviewers agreed that Petitioner's interview was cordial. After her interview, each of the three interviewers was satisfied that Petitioner met their threshold requirements for the job opening of Food Service Director, which included a minimum of ten years' food service experience and the ability to handle a 250-seat cafeteria and a 42-person assisted living facility.
Petitioner was one of only three applicants who were interviewed in-person for the position of Food Service Director. Mr. Clifford Burr, a white American male, was ultimately selected. The record is silent as to the race, color, national origin, and qualifications of the third applicant.
Petitioner's interview was the third one.
Petitioner's interview process was the same as the interview process for the other two applicants. The interviewers reviewed each applicant's resume before the respective interview. All
three interviewers were present for the in-person interview of each applicant. After each applicant's interview, the respective applicant was considered by the interviewers to have met the threshold job requirements.
Interviewers Johnson and Hayes did not make the decision as to which applicant should be hired, although they had input. The ultimate decision to hire Mr. Burr was made by Mr. Buchert.
Mr. Humbles was not involved in the interview or selection process for the Director of Food Service, and he did not take part in any of the three in-person interviews. He also did not direct whom Mr. Buchert should hire. It was never intended by Respondent that Mr. Humbles should have any input into the hiring process for Food Service Director. (See Finding of Fact 7.) Mr. Humbles, in fact, had no input into the decision to hire Mr. Burr.
Having observed the candor and demeanor of Mr. Burr while he testified that he did not meet Mr. Humbles until after he had been hired, that testimony is found to be credible, contrary to Petitioner's proposal that it is not credible. However, this is an insignificant and irrelevant point, inasmuch as Petitioner had met Mr. Humbles prior to her interview.
After interviewing Petitioner, who was the last applicant to be interviewed, Ms. Hayes believed both other
applicants were more qualified for the position than Petitioner. She was particularly impressed by Mr. Burr's long-term care experience, which went beyond merely managing a dining area.
Mr. Burr had over 10 years' experience in health care facilities. His experience included serving as a consultant for a corporation with numerous health care facilities, including long-term care facilities, and a total of more than 20 years in the food service industry. As a result of his experience in health care facilities, Mr. Burr had extensive knowledge regarding the dietary needs of the elderly.
Petitioner's post-hearing proposal asks why Mr. Burr's resume ends in December 2001, but Mr. Burr's testimony that he sold out his family restaurant/bakery business in a northern state for the purpose of semi-retirement in Florida is sufficient explanation of this part of his resume. Petitioner's proposal also states that Mr. Burr had no college degrees, yet Mr. Burr's resume shows: "University of Florida 1976,
Major: Food Service Management, Dietetic Assistant Program," and "Purdue University, 1978, Major: Achieving Food Service Excellence," and Mr. Buchert determined during Mr. Burr's interview that Mr. Burr was a Certified Dietary Manager.
Petitioner's resume makes no reference to any college degrees or credits. It does not list any certifications. Petitioner's resume reveals that she had excellent experience in
restaurant management and food service management, including food service management in a college environment, but it shows no experience in a long-term care facility for frail or elderly persons. Petitioner had only 13 years' experience in all types of food service.
Mr. Buchert's hiring decision was made primarily upon Mr. Burr's 20 years in the food service industry; his 10 or more years of food service in health care facilities, such as assisted living facilities, extended care facilities, and nursing homes; his consultant services to similar facilities; and the creative aspects of his former ownership and management of a family-owned café/restaurant and bake shop.
Mr. Buchert wanted to expand Respondent's food service function, and he thought Mr. Burr was better qualified for this creative task than Petitioner or the other applicant.
The three interviewers testified credibly that neither Petitioner's national origin, color, and/or race was of any concern to them. Interviewers Johnson and Hayes testified credibly that those elements did not enter into their recommendations to Mr. Buchert, and Mr. Buchert testified credibly that none of those elements had anything to do with his ultimate decision not to hire Petitioner. Mr. Buchert further articulated reasons for selecting Mr. Burr which are both legitimate and non-discriminatory.
Respondent never provided Petitioner with Exhibits P-1 and P-2, glossy promotional materials designed to encourage senior citizens to buy into/move into Respondent's facility. Exhibit P-1, is a large brochure with a separate pricing guide. Exhibit P-2 is a virtually identical smaller pamphlet. Petitioner testified that if she had seen P-1, she would never have come to Florida for an interview with Respondent because that brochure did not show enough "people of color."
Petitioner's testimony characterized Exhibit P-1 as showing only three "people of color" out of all the people pictured on its front cover, and showing no "people of color" inside. She further characterized the front cover picture of Exhibit P-1 as showing three persons with "dark or black" skin and "one from Japan or Korea." On what basis she made these assumptions, she did not say. In his testimony, Mr. Humbles guessed that there were "two to three Blacks, one Hispanic, and at least one or two Indians" on the front cover of Exhibit P-1. He, also, did not say how he reached these assumptions. Neither of these witnesses demonstrated any expertise in discerning national origin from facial features or any expertise in racial identification. Other witnesses were not asked to guess at color, race, or national origin as pictured on or in the brochure or the pamphlet. In an independent review, the undersigned counted six persons of darker skin hue than the most
predominant light skin hue of a total of 26 people on the front and back covers, combined. At most, there is only one adult with a darker skin hue pictured on the inside pages, but there is nothing on or in either exhibit that would signal whether the people photographed inside or outside the covers perceive themselves as "people of color," nor is there anything in the exhibits that designates "country of origin" for anyone pictured. There also is nothing that distinguishes employees from residents on any cover. Inside, age alone might be an indicator of resident status. No expert statistician was presented to show whether or not the number of people pictured constituted a reasonable sample of a resident population of 750 and/or an employee population of 450.
It is unrefuted that the brochure (P-1), and presumably the pamphlet (P-2), was designed by a management firm upon instructions from Mr. Humbles to "represent the community in which we live." Both P-1 and P-2 were designed to attract residents, not employees, to the Village. There is every possibility all the people pictured are professional models.
CONCLUSIONS OF LAW
The Division of Administrative Hearings has jurisdiction over the parties and subject matter of this cause, pursuant to Chapter 760, and Section 120.57(1), Florida Statutes.
Petitioner may establish a prima facie case of discrimination in three ways:(1) direct evidence of discriminatory intent; (2) statistical proof of a pattern of discrimination; or (3) circumstantial evidence that raises a rebuttable presumption of intentional discrimination under the test established in McDonnell Douglas Corp. v. Green, 41 U.S. 792, 3 S. Ct. 1817, 36 L.Ed. 2d 668, (1973). See also Longariello v. School Board of Monroe County, Florida, 987 F.Supp. 1440 (S.D. Fla. 1997); and Walker v. Nationsbank of Florida, N.A., 53 F.3d 1548 (11th Cir. 1995).
Petitioner asserts that she was subjected to hiring discrimination only because: (1) she thought Mr. Humbles was supposed to meet with her and be part of the interview team, and he was not; and (2) she felt she was rejected because
Mr. Humbles snubbed her when they were introduced and he did not eat lunch with her and the interview team. She stated that she felt Respondent should have shown her the printed promotional materials in advance because, due to Respondent's not showing them to her in advance, she was lured into expending time and money in hopes of getting a job for which she was not going to be seriously considered, based on the low percentage of "persons of color" pictured on the front cover and the absence of "persons of color" pictured inside the materials.
In fairness, the undersigned has also considered, as a third touchstone, whether or not Mr. Buchert's comment in the cafeteria, together with the printed materials, have any probative value. For instance, if Petitioner had been able to show that because Respondent caters to an entirely white, American-born pool of residents, which pool of residents also unanimously or predominantly discriminates against persons of color or persons who are not native-born Americans, then Petitioner might have proven a prima facie case of unlawful discrimination.
However, Petitioner has failed to establish a prima facie case of discrimination upon color or national origin against Respondent by either direct evidence, statistical evidence, or circumstantial evidence.
Petitioner presented no direct evidence of intentional discrimination. "Direct evidence of intentional discrimination is evidence which, if believed, establishes the existence of discriminatory intent behind the employment decision without any inference or presumption." However, "Evidence that only suggests discrimination or that is subject to more than one interpretation does not constitute direct evidence of discrimination." Chambers v. Walt Disney World Co., 132 F.Supp. 2d 1356 (M.D. Fla. 2001). See also Standard v. A.B.E.L.
Services, Inc., 161 F.3d 1318 (11th Cir. 1998), and Merritt v. Dillard Paper Co., 120 F.3d 1181 (11th Cir. 1997).
The Eleventh Circuit has narrowly defined what kind of language constitutes direct evidence of discrimination. "To amount to direct evidence, a statement must: (1) be made by a decision-maker; (2) specifically relate to the challenged employment decision; and (3) reveal blatant discriminatory animus." Chambers supra, citing Jones v. Bessemer Carraway Medical Center, 151 F.3d 1321 (11th Cir. 1998), and cases cited therein. Cf. Costa v. Desert Palace, Inc., 299 F.3d 838 (9th Cir. 2002), which attempts to align and analyze each federal circuit as to the degree(s) of animus required.
Mr. Humbles was not a decision-maker for purposes of hiring a Director of Food Service. Lack of enthusiasm by a non- decision-maker during a job candidate's informal introduction simply does not amount to clear evidence of discrimination on the basis of color or national origin.
Mr. Buchert's comment in the cafeteria to the effect that some people in the Village still discriminate, is ambiguous. Was he warning Petitioner or attempting to discern how Petitioner would deal with elderly, unenlightened residents? Was he referring to staff? Was he referring to management? There is no clarity on this issue from Petitioner's testimony, and due to her accent in repeating the comment, there is not
even the assurance that she clearly understood what was said to her. However, given all the circumstances, including a subsequent two to three-hour cordial interview of Petitioner by Mr. Buchert and his team, Petitioner's conjecture that Respondent's management had lured her to Florida to warn her that they discriminated and then did not hire her because of that discrimination is the least likely interpretation.
Moreover, Mr. Buchert's comment, either standing alone or in context, is, at most, vague commentary on inappropriate attitudes of others and does not specifically relate to his challenged employment decision or reveal any blatant discriminatory animus on his part.
"[E]vidence of facially neutral remarks from which Petitioner infers discriminatory intent" does not constitute direct evidence. See Chambers, supra, and cases cited therein. Although Petitioner may have perceived Mr. Humbles' speed and lack of warmth during their introduction and his failure to join her and the interview team for lunch as evidence of his intent to discriminate against her, Mr. Humbles was not involved in the hiring process, and he made no statements regarding Petitioner or related to filling the position for which she applied.
There is no competent statistical evidence of Respondent's hiring practices. First, on their own, the marketing materials were developed by an outside advertising
agency, not Respondent's management. Secondly, they were developed to recruit residents and are not relevant to Petitioner's claim that Respondent's workforce is not as diverse as to color and national origin as she believes it should be.
Thirdly, Petitioner has not presented any competent evidence to distinguish from among the photographed persons, which are models, which are residents, and which are employees, if any; to demonstrate their national origins; or even to quantify what skin hue constitutes a "person of color."
At the hearing, Petitioner and her qualified representative occasionally used the word "race" interchangeably with "color", but these are different concepts. For purposes of discrimination laws, "race" is usually determined upon the race an individual perceives herself to be or upon what race she holds herself out to be. Occasionally, a case may be decided upon the race an unlawfully discriminating employer perceives the employee or potential employee to be. Skin color, however, is, to a large degree, an objectively observable factor. Yet in the instant case, the only evidence consists of conflicting guesses by Petitioner and by Mr. Humbles as to what race, color, or national origin some persons in photographs may be, without any clear nexus of those persons to the Respondent's workforce. Even the undersigned's independent assessment of Petitioner's exhibits can only determine skin color, not race or national
origin. Assuming six out of 26 people on the covers are darker-skinned, there is still no nexus to Respondent's hiring practices. Even if all the elderly persons pictured inside
Petitioner's exhibits were considered "white," this factor alone does not prove those persons, or the management which hires employees to serve them, discriminated against Petitioner in this case. Petitioner has not presented any statistical evidence of the percentage of the protected classes (color and/or national origin) who reside in the region surrounding Respondent's facility (the most obvious hiring pool), the percentage of the protected classes who apply for jobs with Respondent from any and all regions, the percentage of the protected classes actually offered employment by Respondent, or the percentage of the protected classes in Respondent's 450- person workforce. Accordingly, the exhibits fall short of establishing a prima facie case based upon employment statistics. See Evans v. McClain of Georgia, Inc., 131 F.3d 957 (11th Cir. 1997), citing Brown v. American Honda Motor Co., 939 F.2d 946 (11th Cir. 1991) cert. denied 502 U.S. 1058 (1992), and holding that "Statistics without an analytic foundation are 'virtually meaningless'"; Culley v. Trak Microwave Co., 117 F.2d 1317 (M.D. Fla. 2000); and Villaneuva v. City of Ft. Pierce,
Fla. 24 F. Supp. 2d 1364 (S.D. Fla. 1998).
Assuming, arguendo, but not ruling, that the exhibits show that all the residents are white and American-born, Petitioner still has not established that this white, American- born resident population is prejudiced against Petitioner or that Respondent accommodates that resident population's prejudices by hiring only white, native-born Americans. See
Florida State University v. Sondel, 685 So. 2d 923 (Fla. 1st DCA 1997).
To establish a prima facie case of hiring discrimination based upon her color and/or national origin through circumstantial evidence, Petitioner must establish that:
(1) she was qualified and applied for the position; (2) she was rejected despite her qualifications; and (3) other equally or less qualified employees who are light-skinned and/or not born outside the United States were offered the job. Bass v. Board of County Commissioners Orange County, Florida, 256 F.3d 1095, (11th Cir. 2001). See also Durley v. APAC, Inc., 236 F.3d 651 (11th Cir. 2000). Cf. Costa, supra.
Petitioner has failed to meet the third prong of the circumstantial evidence test in that she has not established that the position she sought was filled by someone who possessed equal or less qualifications for the job. While Mr. Burr is an American-born white male, he had over 20 years in food service compared to Petitioner's 13 years, and he had over 10 years of
experience in food service for health care facilities, which she did not. He also had served as a consultant for a corporation with numerous long-term health care facilities, a category of food service in which Petitioner has no background. Mr. Burr also was a Certified Dietary Manager. As a result, Petitioner has not established a prima facie case of color and/or national origin discrimination, upon circumstantial evidence.
Assuming arguendo, but not ruling, that any of Petitioner's touchstones established a prima facie case or even is indicative that discrimination played a part in the decision not to hire Petitioner, Respondent has articulated legitimate, non-discriminatory reasons for its selection of Mr. Burr over Petitioner. "Once the plaintiff has established a prima facie case, thereby raising an inference that he was the subject of intentional . . . discrimination, the burden shifts to the defendant to rebut this inference by presenting legitimate, non- discriminatory reasons for its employment action This
intermediate burden is 'exceedingly light.'" Holifield v. Reno,
115 F.3d 1555, (11th Cir. 1997), and cases cited therein.
Mr. Buchert testified that as the ultimate decision- maker in the hiring process, he felt that he had chosen the most qualified applicant for the position. "When two applicants meet the minimum educational qualifications of a position, Title VII does not prevent an employer from preferring the applicant who
has educational qualifications which surpass the minimum requirements of the position." Sondel supra, citing Wileman v.
Frank, 979 F.2d 30 (4th Cir. 1992). The same should be true for other types of superior qualifications.
Not only did Mr. Burr have experience in long term care facilities, which Petitioner did not, Mr. Buchert expected, based on his interview and background, that Mr. Burr would be more creative than Petitioner, a trait that Mr. Buchert was looking for in a Director of Food Service.
Petitioner's interview process was the same as for the other two candidates. Mr. Humbles was not a decision-maker in filling the Director of Food Service position. The un-rebutted evidence of Mr. Buchert and Ms. Hayes established that they individually, and without input from Mr. Humbles, considered Mr. Burr to be the best of the three candidates interviewed. Ms. Johnson also testified that Mr. Humbles had no input into the selection process.
No competent evidence was presented which would establish that Respondent's reasons for not hiring Petitioner were pretextual. See Isenbergh v. Knight-Ridder Newspaper Sales, Inc., 97 F.3d 436 (11th Cir. 1996), holding that pretext must be shown with "significantly probative evidence."
While a discriminatory statement may not demonstrate animus so as to make out a prima facie case, it still may be
part of the rebuttal of a pretextual reason offered by an employer. However, herein, Mr. Buchert's cafeteria comment was not clearly discriminatory. See Chambers and Jones supra. An employer's "reason can not be a pretext for discrimination unless it is shown both that the reason was false and discrimination was the real reason." Florida State University
v. Sondel, supra, quoting St. Mary's Honor Center v. Hicks, 509
U.S. 502, 113 S. Ct 2742 (1993). That test was not met herein.
RECOMMENDED: that the Florida Commission on Human Relations enter a final order dismissing the Charge of Discrimination and Petition for Relief.
DONE AND ENTERED this 18th day of July, 2003, in Tallahassee, Leon County, Florida.
ELLA JANE P. DAVIS
Filed with the Clerk of the Division of Administrative Hearings this 18th day of July 2003.
D. Paul Sondel
Patrick D. Coleman, Esquire Amy H. Reisinger, Esquire
Coffman, Coleman, Andrews & Grogan, P.A. Post Office Box 40089
Cecil Howard, General Counsel Florida Commission on Human Relations 2009 Apalachee Parkway, Suite 100
Denise Crawford, Agency Clerk Florida Commission on Human Relations 2009 Apalachee Parkway, Suite 100
439 Granite Road, No. 5 Kerhonkson, New York 12446
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.
