Findings Of Fact Wedgewood is the holder of Division of Beverage license number 62-1626, 4-COP SRX, which authorized Wedgewood to sell alcoholic beverages for consumption on the premises at retail only. Wedgewood is advertised as a resort with private villas, hotel rooms, two restaurants and a disco with live entertainment. An ad published on page 81 of Cruise Magazine, Volume 3, No. 4, however, makes no reference to any of the facilities except the appearance of an entertainment group known as The Village People. On the other hand, an ad in the November 19, 1977, issue of Florida Alive gives equal emphasis to hotel facilities, restaurant facilities and disco facilities. Wedgewood has promulgated and distributed a flyer advertising daily happy hour with special prices for alcoholic beverages. That same flyer advertises the sale of sandwiches and emphasizes that dining facilities are available nightly. Wedgewood has produced two menus. One appears to be a lunch menu which contains a soup, fifteen different sandwiches, three salads, five hot entrees, french fries, six desserts and beverages without reference to alcoholic beverages. Wedgewood has also produced a dinner menu containing appetizers, soups, five seafood entrees, five beef entrees, and two fowl entrees, with soup, salad and an assortment of desserts. The only reference to alcoholic beverages contained in the menu suggests that one's favorite after dinner drink is available. Wedgewood has two restaurants with complete facilities for serving and preparing for the requisite number of full course meals. For the period, June 15, 1977, through January 30, 1978, Wedgewood shows gross revenues of $162,685.00, composed of $22,991.00 for food sales and $139,694.00 for alcoholic beverage sales. These figures indicate that Wedgewood has derived approximately 14 percent of its total revenue from food services. One of the criteria contained in Rule 7A-3.15, Florida Administrative Code, used in determining whether or not the holder of a restaurant license is a bona fide restaurant is: The restaurant must derive at least 51 percent of its gross revenue from the sale of food and non-alcoholic beverages. The 51 percent shall be determined by taking the average monthly gross revenue of the sale of food and non-alcoholic beverages over a period of any calendar year. DABT urges that the gross receipts evidence of the approximate seven month period should be used in making a determination that the licensee is not a bona fide restaurant. However, DABT is arguing against its own regulations. Unless the revenues are analyzed over a calendar year as provided in the Rule, the percentage of revenue from the sale of food and non-alcoholic beverages may not properly be used as a criterion. Accordingly, the evidence as to the revenues will not be considered in the determination of the instant case. Wedgewood has advertised and held out to the public to be a place where meals are prepared and served, as evidenced by its comprehensive menus. The evidence shows that space is provided with adequate kitchen and dining room equipment and that there are employed sufficient numbers and kinds of employees for preparing, cooking and serving meals for guests. While Wedgewood obviously engages in the sale of alcoholic beverages, there is insufficient evidence to establish that such sale is subordinate to the sale of food. Equal advertising space is given to both functions and accordingly, it is found, as a matter of fact, that the principal business of the restaurant is to cater to and serve full course bona fide meals to the general public and the primary operation of the restaurant is for the preparation and cooking and serving of meals and not for the sale of alcoholic beverages.
The Issue Whether Respondent, Popeye’s Louisiana Kitchen (“Popeye’s”), discriminated against Petitioner, Desmond A. Lucas, in violation of the Florida Human Rights Act; and, if so, what penalty should be imposed?
Findings Of Fact Mr. Lucas is an African-American male who contends he was discriminated against by his employer, Popeye’s, while working at one of its restaurants in Pensacola, Florida. He states the basis of the discrimination to be his gender, male. At the time of the final hearing, Mr. Lucas was residing in Oveido, Florida. As noted above, Mr. Lucas did not make a live appearance at the final hearing held in this matter. Popeye’s is a corporation which, at the time of the final hearing, owned approximately 130 restaurants in the southeastern United States, four of them being in northwest Florida. Store No. 28 is located at 3411 North Pace Boulevard, Pensacola, Florida. Mr. Lucas was hired in 2011 as a cashier/drive-through operator for Popeye’s Store No. 28. He worked there until the termination of his employment on September 1, 2015. During most of his employment, Lucas was considered a good employee. He was deemed a fast learner and was especially adept at cleaning his work area. Management talked to Mr. Lucas about entering the manager training process, but he at first refused, citing the need to care for his ailing mother. Around July 2015, Mr. Lucas finally began training as a manager. Up until that time, Mr. Lucas had been a very good employee, never being written up for failing to do his job properly. Later, Mr. Lucas began to develop a bad attitude toward his primary manager and other employees. On August 24, 2015, while Mr. Lucas was in training to be a manager, he and the night manager, Mr. Abram Gordon, were tasked with closing the store once business hours ended. Mr. Gordon did not testify, but Mr. Lucas said the manager gave him no specific instructions as to how to perform the “closing” duties, saying only, “You’ll figure it out.” Mr. Lucas had been working at Store No. 28 for four years, so management expected him to have a good idea about what needed to be done. He apparently did not. By all credible accounts, Mr. Gordon and Mr. Lucas did not do a good job cleaning up the store that evening. The following morning, Ms. McPherson, the head manager of Store No. 28, came in to work to find the mess left behind from the prior night’s closing. She was very upset and set about cleaning up the area so that it would be presentable when the store opened. She then proceeded to draft a written reprimand or “write-up” against both Mr. Gordon and Mr. Lucas for failing to close the store properly. She wrote up Mr. Gordon because as the manager on duty, he was ultimately responsible for closing; Mr. Lucas was written up for failing to clean his area properly. Mr. Gordon apparently discussed the write-up with Mr. Lucas before the latter’s arrival at work that day. Although Mr. Lucas admits that he talked with Mr. Gordon before coming to work that day, he maintains they never discussed the write-up. His testimony in that regard is not credible. His demeanor and attitude upon arrival at work that day bespeak prior knowledge of the reprimand and that he had a chip on his shoulder about it. When Mr. Lucas refused to accept Ms. McPherson’s criticism that the store had not been cleaned properly, she showed him some pictures she had taken that morning. Mr. Lucas said the pictures were inaccurate and he refused to accept any responsibility for the messy storefront. Mr. Lucas, in response, showed her some pictures he had taken of the store when it had previously been left in a messy condition, apropos to nothing. That someone else had not done their job previously did not excuse Mr. Lucas’ non-performance of his duties. Ms. McPherson gave the written reprimand to Mr. Lucas, but he refused to sign it, maintaining he had done nothing wrong. Mr. Gordon on the other hand accepted his write-up without objection and signed it. Mr. Lucas noticed that Ms. McPherson’s supervisor, Ms. Bishop, had arrived at the store for a routine site visit. He quickly approached Ms. Bishop and demanded a meeting to discuss the closing dispute and the write- up. Ms. Bishop, who has extensive training and experience dealing with angry employees, told Mr. Lucas she would set up a meeting to discuss the matter with him later after he had had an opportunity to calm down. This was not satisfactory to Mr. Lucas. Mr. Lucas then demanded the telephone number of Willie Barnes, an operations specialist who was Ms. Bishop’s supervisor. That request was denied because Ms. Bishop was not prone to giving out Mr. Barnes’ personal contact information. This made Mr. Lucas even angrier, and he continued to loudly complain about the situation. One of his co-workers, Cheyenne Ford, attempted to get Mr. Lucas to calm down and stop talking so loudly. Ms. Bishop could hear Mr. Lucas’s continuing complaints, and eventually she directed Ms. McPherson to tell Mr Lucas to clock out and go home for the day. Meanwhile, Ms. Bishop asked Mr. Gordon to set up a meeting to be attended by her, Mr. Lucas, Mr. Gordon and Ms. McPherson. The meeting was scheduled for September 1, 2015. When Mr. Lucas was told by Ms. McPherson to go home, he stopped outside the store and called the Popeye’s “Employee Hotline,” a service provided by Popeye’s through its human resources department. The content of the call was reduced to writing by the individual who answered. Strangely, the writer referred to Mr. Lucas as “she” throughout the report. Apparently she mistook him for a female, although he did not sound effeminate during the final hearing (at which he appeared via telephone). The call to the Employee Hotline was not in keeping with the established order of making complaints. Mr. Lucas should have waited until after his meeting with Ms. Bishop and Ms. McPherson before calling the hotline. During the hotline call, Mr. Lucas did not make any claim of discrimination based on his gender. Ultimately, Mr. Lucas appeared at the scheduled September 1, 2015 meeting. The meeting was held in a corner of the lobby at Store No. 28 and was attended by the aforementioned persons. Mr. Lucas, after waiting several minutes for the others to arrive, was given the opportunity to state his position and to make whatever complaints he desired. The managers, in turn, explained to Mr. Lucas what shortcomings they saw in his work and behavior. The meeting seems to have been somewhat heated, but everyone was allowed to express themselves. One of the issues discussed at the meeting was Mr. Lucas’ show of disrespect for Abbas Momenzadeh, vice president of operations for Popeye’s. Mr. Momenzadeh had come into the store on several occasions to observe and ask questions of the employees, as was his normal practice. He was always friendly to employees and attempted to engage them in conversation. When he spoke to Mr. Lucas, there was no response until one of the managers chastised Mr. Lucas. He then gave a grudging “Hey” to the vice president. According to Mr. Momenzadeh, this happened on more than one occasion.3/ Mr. Lucas was given the opportunity to “change his ways” and to fall back in line with corporate guidelines. He, however, did not see any need to change his behavior or work practices and announced that he had no intention of doing so. At that, Ms. Bishop decided to terminate his employment and did so, ending the meeting. When he arose to leave, Mr. Lucas produced his telephone to the others, indicating (they believed) that he had been recording the meeting. Ms. Bishop informed Mr. Lucas that it was illegal and improper to record someone’s statements without their consent, but he just smiled and walked away, waving his phone in the air. Mr. Lucas then filed his claim of discrimination, claiming that he and other male employees were treated badly while female employees were not. He claimed that Ms. Bishop and Ms. McPherson would only train females for manager positions, passing over qualified males. He claimed that Ms. McPherson talked much more sharply to male employees than female employees, allowing females to get away with things for which males were chastised. No direct evidence as to any of those allegations was presented at final hearing by Mr. Lucas. There is absolutely no credible, believable, or competent evidence in the record to support Mr. Lucas’ claims. By way of example, when he asked Ms. Bishop to identify the managers in the four stores she supervised, she responded that nine managers were female and nine were male, numbers that do not suggest that Popeye’s discriminates on the basis of gender. Also, Mr. Gordon, who was written up at the same time and for the same reason as Mr. Lucas, is still an employee (manager) for Popeye’s. Hearsay statements from a female employee offered into evidence by Mr. Lucas were neither competent evidence nor indicative of any discrimination against males by Popeye’s or its store managers. Mr. Lucas took the position that since he had never been disciplined before this incident, discrimination was the likely reason for termination of his employment. When asked why Popeye’s had not disciplined Mr. Lucas previously, the manager just noted that “we have a lot of tolerance.” Indeed.
Recommendation Based on the foregoing Findings of Fact and Conclusions of Law, it is RECOMMENDED that a final order be entered finding that Popeye’s Louisiana Kitchen, did not discriminate against Desmond A. Lucas. DONE AND ENTERED this 9th day of March, 2017, in Tallahassee, Leon County, Florida. S R. BRUCE MCKIBBEN Administrative Law Judge Division of Administrative Hearings The DeSoto Building 1230 Apalachee Parkway Tallahassee, Florida 32399-3060 (850) 488-9675 Fax Filing (850) 921-6847 www.doah.state.fl.us Filed with the Clerk of the Division of Administrative Hearings this 9th day of March, 2017.
The Issue Whether Respondent committed the offenses set forth in the Administrative Actions in these consolidated cases, and, if so, what penalty should be imposed.
Findings Of Fact Based on the oral and documentary evidence adduced at the final hearing, and the entire record in this proceeding, the following findings of fact are made: At all times material hereto, Fowler Liquors was licensed by the Division, having been issued license number 46- 04643, Series 3-PS. The license permits Fowler Liquors to make packaged sales of beer, wine, and liquor at its convenience store located at 3450 Fowler Street in Fort Myers. In an Administrative Action dated July 11, 2002, the Division charged Samer Barghouthi, the majority owner and principal officer of Fowler Liquors, with selling alcoholic beverages to a person under the age of 21 on May 19, 2002. Fowler Liquors conceded there were no disputed issues of fact and requested that the matter be resolved in an informal hearing. In a Final Order dated October 25, 2002, the Division ordered Fowler Liquors to pay a fine of $1,000 and serve a seven-day license suspension. The Administrative Action regarding the May 19, 2002, sale arose from an incident in which 20-year-old Tony Cubello was beaten, robbed, and shot to death in the parking lot of Fowler Liquors after making a purchase in the liquor store. The murder of Mr. Cubello was the subject of articles in the Fort Myers newspaper. The Fort Myers Police Department investigated Mr. Cubello's murder and came to believe that Samer Barghouthi could identify the killers but was refusing to cooperate. The Fort Myers police requested the assistance of the Division in securing Mr. Barghouthi's cooperation. The Division commenced an investigation, interviewing young people who had known Mr. Cubello. During the course of these interviews, the Division became aware that Fowler Liquors was widely reputed as a place where underage people could buy alcoholic beverages. During its investigation, the Division also learned that the Department of Revenue had a tax warrant against Fowler Liquors, and that the City of Fort Myers had issued citations against Fowler Liquors for hours-of-sale violations. During its investigation, the Division sent an underage operative into Fowler Liquors to attempt to purchase alcoholic beverages. The operative was wearing a hidden microphone, allowing the Division's officers to hear what transpired in the liquor store. As the sale was about to be completed, a van full of construction workers pulled up outside the store. The person working behind the counter at Fowler Liquors said that there were "cops" in the van, and declined to complete the sale to the operative. On June 14, 2002, Captain Tania Pendarakis, district supervisor for the Division's Fort Myers office, met with Samer Barghouthi. She informed Mr. Barghouthi that the Division might consider filing administrative charges rather than criminal charges against Fowler Liquors, if Mr. Barghouthi would cooperate with the Fort Myers Police Department's murder investigation. During this conversation, Mr. Barghouthi assured Captain Pendarakis that he was going to start checking identifications and stop selling alcoholic beverages to underage children. The next day, June 15, 2002, David P. Green, then sixteen years old, entered Fowler Liquors early in the evening to buy beer. In the liquor store, Mr. Green recognized other people whom he knew from his high school. Mr. Green testified that it was widely known at his school that underage people could purchase alcohol at Fowler Liquors. Mr. Green purchased a twelve-pack of Budweiser Light beer. He tendered ten dollars cash to the cashier and asked if the store sold "dip," i.e., finely ground tobacco. The cashier told him no, but offered to sell Mr. Green cigarettes. The cashier did not ask Mr. Green his age, nor request any identification from Mr. Green to prove that he was at least 21 years of age. At the hearing in this matter, conducted nearly nine months after the fact, Mr. Green looked no older than sixteen. When he purchased the beer at Fowler Liquors, Mr. Green made no attempt to alter his appearance or otherwise disguise the fact that he was only sixteen years old. When Mr. Green exited Fowler Liquors, he saw a police officer parked in a police cruiser directly in front of him. Mr. Green put his twelve-pack of beer down next to a garbage can, then got into his car and drove away. Several of Mr. Green's friends were also in his car. The police officer who witnessed this scene, Officer Bradley J. Ades of the Fort Myers Police Department, testified at the hearing. Officer Ades testified that, because of the ongoing problems the police were having with Fowler Liquors, he stopped by there to check it out as part of his normal duties. As he pulled into the parking lot, he saw a "very young white male" walking out the front door of Fowler Liquors. The boy was carrying a twelve-pack of Budweiser Light beer. Officer Ades stated that he was surprised not to see the boy's father follow him out of the store, because the boy looked so young. The boy got into his car and drove away. Officer Ades followed him for a little more than one block, then pulled him over. Officer Ades interviewed Mr. Green and photographed him. Mr. Green admitted that he bought the beer in Fowler Liquors, and that he and the other boys in his car intended to drink it. Because the sale of alcohol to a minor is a misdemeanor, and he did not witness the sale, Officer Ades could not make an arrest. The next day, he forwarded to the Division the information concerning his stop of Mr. Green. Agent Brian D. Sauls of the Division contacted Mr. Green and asked him to come to the Division's offices for an interview. Mr. Green agreed. Agent Sauls conducted a photographic suspect lineup, and Mr. Green identified Samer Barghouthi as having been behind the counter at Fowler Liquors at the time he purchased the twelve-pack of Budweiser Light on June 15, 2002. The incident involving the sale to Mr. Green formed the basis of the Administrative Action that led to DOAH Case No. 03-0431. Fowler Liquors did not contest the evidence that a sale was made by Fowler Liquors to Mr. Green, an underage person, on June 15, 2002, or that Samer Barghouthi was present at the counter when the sale was made. On the evening of June 17, 2002, Justin C. Bender, then eighteen years of age, entered Fowler Liquors to buy beer. Mr. Bender testified that he had purchased alcohol at Fowler Liquors more than 40 times and had never been asked for any identification. Mr. Bender stated that he has seen friends and other people whom he knew from school inside Fowler Liquor Store. Mr. Bender also testified that he had discussions with other people about Fowler Liquors being a place where underage people could purchase alcoholic beverages. On June 17, 2002, Mr. Bender purchased a twelve-pack of Budweiser beer and a quart of Heineken beer, then left the store. Mr. Bender purchased the beer from Steve Barghouthi, the father of Samer Barghouthi. Steve Barghouthi did not ask Mr. Bender his age, nor request any identification to prove that he was at least 21 years of age. Mr. Bender had made no effort to alter his appearance or make himself look older than eighteen. On June 17, 2002, Anthony J. Smith, the chief of law enforcement for the Division, visited the Fort Myers office. He asked Captain Pendarakis to inform him of cases her office was involved in, and the subject of Fowler Liquors was discussed. After dinner that evening, Chief Smith drove by Fowler Liquors to take a look at the store. As he drove through the parking lot, Chief Smith saw Mr. Bender exiting the store with his beer. Chief Smith stopped him to determine how old he was. Mr. Bender produced a valid driver's license that showed he was eighteen years old. Chief Smith searched Mr. Bender for fake identification, but found none. Chief Smith asked Mr. Bender if he would be willing to return to Fowler Liquors and make another purchase that Chief Smith could observe. Mr. Bender agreed to do so. Chief Smith telephoned Captain Pendarakis and asked her to bring marked cash for Mr. Bender to purchase beer. Captain Pendarakis arrived with the cash. She went into Fowler Liquors to ascertain whether it would be safe for Mr. Bender to return to the store. After Captain Pendarakis determined the store was safe, Mr. Bender entered the store. Chief Smith and Captain Pendarakis watched the transaction from across the street. They had a clear view through the window of the liquor store. They observed Mr. Bender get a carton of beer, put it on the counter, pay for it, and walk out the door. After Chief Smith and Captain Pendarakis viewed the sale to Mr. Bender, they went into the store to arrest the person who had made the sale, Samer Barghouthi. Mr. Barghouthi was arrested and taken to the Lee County Jail. The incident involving the sale to Mr. Bender formed the basis of the Administrative Action that led to DOAH Case No. 03-0217. Fowler Liquors did not contest the evidence that a sale was made by Fowler Liquors to Mr. Bender, an underage person, on June 17, 2002, or that Samer Barghouthi, the licensee, had made the sale. In mitigation, counsel for Fowler Liquors argued that license revocation would be unfair because Samer Barghouthi is no longer involved in the operation of the business, having signed over his interest to his uncle, Shahir Daghara. Counsel contended that Mr. Daghara acted to remove Samer Barghouthi from the premises of Fowler Liquors as soon as he learned that Mr. Barghouthi was making sales to underage persons. This contention is not credible. The two sales that are the subject of these proceedings occurred nearly one month after the murder of Mr. Cubello, which was widely known to have occurred after Mr. Cubello purchased alcoholic beverages in Fowler Liquors. The two sales also occurred after Mr. Barghouthi had been interviewed by Captain Pendarakis about sales of alcoholic beverages to minors. Moreover, Officer Cecil Pendergrass of the Fort Myers Police Department testified that Samer Barghouthi was still working at Fowler Liquors on July 1, 2002, two weeks after his arrest for selling alcoholic beverages to Justin Bender. There is no record evidence that Mr. Barghouthi transferred his interest in the business to Mr. Daghara. At most, the Division's files indicate that at some point, Fowler Liquors represented to the Division that Mr. Daghara had taken a 49 percent interest in the business. The file also contains an undated "Current Licensee Update Data Sheet" on which Samer Barghouthi's name is crossed through, but Fowler Liquors offered no sworn testimony to explain the significance of this document. Further, even if Mr. Daghara did take over the business, there is no evidence that he took any steps to remove Mr. Barghouthi from the premises of Fowler Liquors, or did anything else to address the problem of selling alcoholic beverages to minors. Officer Pendergrass, who is the community coordinator for the area of Fort Myers that includes Fowler Liquors, also testified that he has been called to Fowler Liquors on a regular basis to deal with code enforcement problems, fights between family members, drug sales, robberies in the parking lot, and civil problems between the owners over refrigeration equipment. Officer Pendergrass testified that the police department's statistics establish that Fowler Liquors is the nucleus of criminal complaints in the area, and that in the last year, the Fort Myers Police Department has had over 300 calls for service to Fowler Liquors.
Recommendation Based on the foregoing Findings of Fact and Conclusions of Law, it is RECOMMENDED that the Department of Business and Professional Regulation, Division of Alcoholic Beverages and Tobacco enter a Final Order revoking the license of Barghouthi Enterprises, Inc., d/b/a Fowler Liquor Store. DONE AND ENTERED this 5th day of June, 2003, in Tallahassee, Leon County, Florida. LAWRENCE P. STEVENSON 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 5th day of June, 2003. COPIES FURNISHED: Michael Martinez, Esquire Department of Business and Professional Regulation 1940 North Monroe Street, Suite 60 Tallahassee, Florida 32399-2202 Captain Tania Pendarkis 4100 Center Point Drive Suite 104 Fort Myers, Florida 33916 John Kyle Shoemaker, Esquire Post Office Box 1601 Fort Myers, Florida 33902 Hardy L. Roberts, III, General Counsel Department of Business and Professional Regulation Northwood Centre 1940 North Monroe Street Tallahassee, Florida 32399-2202 Peter Williams, Director Division of Alcoholic Beverages and Tobacco Department of Business and Professional Regulation Northwood Centre 1940 North Monroe Street Tallahassee, Florida 32399-0792
The Issue The issues in these cases are whether Respondent is guilty of serving alcoholic beverages to minors and, if so, what penalty is appropriate.
Findings Of Fact Respondent holds license number 58-01997, series 2-COP, for the retail sale of alcoholic beverages. The licensed premises were located at 536 West Church Street, Orlando, Florida. Respondent abandoned the premises at the end of August, 1989. The bar owned and operated by Respondent is no longer in operation, and the license is no longer active. On at least three occasions prior to the incident in question, one or more representatives of Petitioner had warned Lester Thomas, the sole shareholder and officer of Respondent, that he or his company's employees were serving alcoholic beverages to underage persons. On one of these occasions, Mr. Thomas complained, "Every time you come around here, there are problems. You catch me." At about 11:15 p.m. on August 5, 1989, two representatives of Petitioner entered the Negril Cove bar and observed Mary Ann Carmody, age 16 years, consuming an alcoholic beverage that a companion had purchased from Respondent. At all material times on that evening, Mr. Thomas himself was tending the bar at Negril Cove. At no time was Ms. Carmody asked for any identification. Under the circumstances, Mr. Thomas permitted Ms. Carmody to consume the alcoholic beverage on the premises.
Recommendation Based on the foregoing, it is hereby recommended that the Division of Alcoholic Beverages and Tobacco enter a Final Order revoking the license of Respondent. RECOMMENDED this 23rd day of April, 1990, in Tallahassee, Florida. ROBERT E. MEALE Hearing Officer Division of Administrative Hearings The DeSoto Building 1230 Apalachee Parkway Tallahassee, FL 32399-1550 (904) 488-9675 Filed with the Clerk of the Division of Administrative Hearings this 23rd day of April, 1990. COPIES FURNISHED: Leonard Ivey, Director Division of Alcoholic Beverages and Tobacco Department of Business Regulation The Johns Building 725 South Bronough Street Tallahassee, FL 32399-1000 Stephen R. MacNamara, Secretary Department of Business Regulation The Johns Building 725 South Bronough Street Tallahassee, FL 32399-1000 Joseph A. Sole, General Counsel Department of Business Regulation The Johns Building 725 South Bronough Street Tallahassee, FL 32399-1000 Thomas A. Klein Assistant General Counsel Department of Business Regulation The Johns Building 725 South Bronough Street Tallahassee, FL 32399-1000 Jerry S. Luxenburg 1214 East Robinson Street Orlando, FL 32801
