The Issue Whether Respondent committed the offenses set forth in Administrative Complaint and, if so, what penalties should be imposed?
Findings Of Fact Respondent holds Florida Education Certificate No. 460644, covering the areas of Educational Leadership and Social Science. The license is valid through June 30, 2001. At all times material to this proceeding, Respondent was employed as a substitute teacher at Marathon High School in the Monroe County School District. On or about November 26, 1996, Respondent submitted an application for renewal of a Professional Florida Educator's Certificate to Petitioner's Bureau of Teacher Certification. On the application, Respondent checked "no" in response to the following question: Have you ever been convicted of a crime, found guilty, or entered a plea of nolo contendre or had adjudication withheld in a criminal proceeding; or are there any criminal charges now pending against you. Failure to answer this question accurately could cause denial of certification. By indictment of the grand jury convened in Pickens County, South Carolina, on June 22, 1995, Respondent was charged with "Assault and Battery of a High and Aggravated Nature" and with the offense of "Disturbing Schools." Respondent pled guilty to the charge of Disturbing Schools and the lesser charge of "Simple Assault and Battery" on March 18, 1996. He received a sentence of a $200 fine and a suspended 90 days jail sentence. On or about October 6, 2000, Petitioner submitted its First Request for Admissions to Respondent. Respondent failed to answer, admit, or deny the truth of the matters asserted in the request; namely, that Respondent submitted the application for renewal of a Professional Florida Educator's Certificate in the manner and form described in paragraph 3, above, and that he pled guilty to the criminal charges described in paragraph 4, above. Pursuant to Rule 1.370(b), Fla. R. Civ. P., the truth of the matters asserted in the request is conclusively established.
Recommendation Based upon the findings of fact and conclusions of law, it is RECOMMENDED that a final order be entered revoking Respondent's teaching certificate for a period of three years. DONE AND ENTERED this 22nd day of December, 2000, in Tallahassee, Leon County, Florida. DON W. DAVIS 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 December, 2000. COPIES FURNISHED: William B. Graham, Esquire Graham, Moody & Sox, P.A. 215 South Monroe Street, Suite 600 Tallahassee, Florida 32301 Costa Lempesis 1334 Bryjo Place Charleston, South Carolina 29407 Kathleen M. Richards, Executive Director Education Practices Commission Department of Education 224-E Florida Education Center 325 West Gaines Street Tallahassee, Florida 32399-0400 Michael H. Olenick, General Counsel Department of Education The Capitol, Suite 1701 Tallahassee, Florida 32399-0400 Jerry W. Whitmore, Chief Bureau of Educator Standards Department of Education 325 West Gaines Street, Suite 614 Tallahassee, Florida 32399-0400
The Issue Whether Respondent committed the violations alleged in the Administrative Complaint. If so, what disciplinary action should be taken against her.
Findings Of Fact Based upon the evidence adduced at hearing and the record as a whole, the following Findings of Fact are made: Respondent held Florida teacher's certificate number 681506, covering the areas of Pre-K through Grade 3, which was valid until June 30, 1995. On or about November 4, 1986, Respondent was charged with battery by information filed in Dade County Court Case No. 86-79409. On December 29, 1986, following a non-jury trial, Respondent was found guilty as charged. Adjudication of guilt was withheld and Respondent was ordered to pay $77.00 in court costs. In 1990, Respondent submitted an Application for Florida Educator's Certificate to the Bureau of Teacher Certification of the Department of Education (Bureau). On the application, she checked "no" in response to the following question: Have you ever been convicted of a crime, found guilty, or entered a plea of nolo contendre (no contest) even if adjudication was withheld? Your answer to this question will be checked against local, state and federal records. Failure to answer this question accurately could cause denial of certification. Please Check One: Yes No If yes, you must give complete details for each charge. As Respondent was aware, her negative response to this question was untrue inasmuch as, in 1986, she had been found guilty of the crime of battery in Dade County Court Case No. 86-79409. In 1992, Respondent submitted another Application for Florida Educator's Certificate to the Bureau. On the application, knowing that her response was false, she answered "no" in response to the following question: Yes No Have you ever been convicted, found guilty, or entered a plea of nolo contendre (no contest) to a crime other than a traffic violation? A YES or NO answer is required by Florida Law. If you check the YES box, you must give the information requested for each charge In 1993, Respondent submitted a third Application for Florida Educator's Certificate to the Bureau. On the application, she knowingly gave false information by checking "no" in response to the following question: Yes No Have you ever been convicted, found guilty, entered a plea of nolo contendre (no contest), or had adjudication withheld in a criminal offense other than a minor traffic violation (DUI is NOT a minor traffic violation); or are there any criminal charges now pending against you? SEALED or EXPUNGED records must be reported pursuant to s.943.058, F.S. Failure to answer this question accurately could cause denial of certification. A YES or NO answer is required by Florida Law. If you check the YES box, you must give the information requested for each charge. On February 7, 1994, while working as a teacher at Golden Glades Elementary School, a public school located in Dade County, Respondent was involved in an altercation with a student, C.K., in the doorway to Respondent's classroom.2
Recommendation Based on the foregoing Findings of Fact and Conclusions of Law, it is RECOMMENDED that the Commission issue a final order: (1) finding Respondent guilty of the violations of subsection (1) of Section 231.28, Florida Statutes, alleged in the Administrative Complaint, as amended, concerning her falsification of the 1990, 1992, and 1993 certification applications she submitted to the Bureau; (2) barring Respondent from applying for certification for a period of three years for having committed these violations; and (3) dismissing the remaining counts of the Administrative Complaint, as amended. DONE AND ENTERED this 29th day of July, 1997, in Tallahassee, Leon County, Florida. STUART M. LERNER Administrative Law Judge Division of Administrative Hearings The DeSoto Building 1230 Apalachee Parkway Tallahassee, Florida 32399-3060 (904) 488-9675 SUNCOM 278-9675 Fax Filing (904) 921-6847 Filed with the Clerk of the Division of Administrative Hearings this 29th day of July, 1997.
Findings Of Fact Pertinent to this case, respondent, Ugene Adkins (Adkins), has been employed by petitioner, School Board of Dade County, Florida (Board), since September 1985, as an auto mechanics instructor, and assigned to Robert Morgan Vocational Technical Institute. Commencing with the 1985-86 school year, Adkins received an annual contract from the Board, pursuant to Section 231.36(1)(a), Florida Statutes, for five consecutive years, based upon one-year temporary nondegreed vocational certificates issued by the Department of Education. His fifth temporary certificate expired on June 30, 1990, and he was not thereafter eligible for continued certification and employment, under the law as it had existed from the inception of his employment, absent successful completion of all portions of the Florida Teacher Certification Examination (FTCE). 1/ See Section 231.17(2)(g), Florida Statutes (1989). Adkins was well aware of the foregoing requirement, and took the FTCE on several occasions during the term of his employment; however, he never successfully passed the writing portion of the examination. Unbeknownst to Adkins or the Board's certification office, Section 231.1725, Florida Statutes (1990), became law on July 3, 1990, retroactive to June 29, 1990. That law effectively exempted nondegreed teachers of vocational programs from the certification requirements of Section 231.17, Florida Statutes, and provided that the school boards would establish the qualifications for such teachers. In establishing such qualifications, the new law did not mandate taking or successfully completing the FTCE, and the Board's rule, 6Gx13- 4-1.007, passed the afternoon of July 25, 1990, which established the qualifications for such teachers, likewise did not require taking or successfully completing the FTCE. By memorandum, dated July 12, 1990, the Board's certification office, unaware of any changes in existent law, notified Adkins that he had not yet provided proof of his eligibility for continued employment during the 1990-91 school year, and to do so would require, among other things, evidence that he had met the test requirements for certification by the Department of Education that applied to his position. The memorandum concluded: IT IS YOUR RESPONSIBILITY TO ENSURE THAT THE REQUIRED INFORMATION IS RECEIVED BY THE DADE COUNTY CERTIFICATION OFFICE ON OR BEFORE JULY 27, 1990, FOR YOU TO BE CONSIDERED FOR CONTINUED EMPLOYMENT FOR THE 1990-91 SCHOOL YEAR. On the morning of July 25, 1990, Adkins, likewise unaware of any changes in existent law, presented to the Board's certification clerk an FTCE report, which he had altered to reflect that he had passed the writing portion of such examination, for the purpose of gaining continued employment with the Board. As a consequence of such misrepresentation, the clerk issued Adkins a clearance of employment form for the 1990-91 school year, based on her assumption that Adkins had passed all portions of the FTCE, and was therefore eligible for certification by the Department of Education. At hearing, the Board contended that, notwithstanding the enactment of Section 231.1725, Florida Statutes, and the existence of its Rule 6Gx13-4-1.007, Adkins' failure to successfully complete all parts of the FTCE, and therefore qualify for certification by the Department of Education under prior law, precluded his reemployment for the 1990-91 school year. To support this position, the Board points to Section 231.17(7), Florida Statutes (1990), which provides: PRIOR APPLICATION. -- Those persons who applied for initial regular or temporary certification under the law preceding July 1, 1990, shall be governed by the law and rules in effect at the time of application for issuance of the initial certificate. Based on such provision, the Board concludes that, notwithstanding the absence of any present need to satisfy FTCE requirements to qualify for employment as a nondegreed teacher of vocational education, Adkins' failure to pass all portions of the FTCE, and therefore qualify for certification by the Department of Education under prior law, precluded his reemployment. Such conclusion is, however, contrary to the express language of Section 231.1725, Florida Statutes, which expressly reposes the authority and obligation to establish the qualifications for such teachers in the school boards, notwithstanding the provisions of Section 231.17 or any other provision of law to the contrary. Notwithstanding the Board's erroneous interpretation of existent law, the proof demonstrates that it firmly held such conviction, and that had it known Adkins had not passed the writing portion of the FTCE, and was therefore not eligible for certification by the Department of Education under prior law, it would not have reemployed him for the 1990-91 school year. Adkins' falsification of the FTCE report to gain reemployment is common knowledge among the faculty and administration at Robert Morgan Vocational Technical Institute, and has rendered him untrustworthy in the opinion of the Board. Under such circumstances, Adkins, through his dishonesty, has seriously impaired his effectiveness in the school system.
Recommendation Based on the foregoing findings of fact and conclusions of law, it is RECOMMENDED that a final order be entered which sustains Adkins' suspension without pay, and which dismisses him from employment with the Board. DONE AND ENTERED in Tallahassee, Leon County, Florida, this 20th day of June 1991. WILLIAM J. KENDRICK 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 21st day of June 1991.
Findings Of Fact At all times pertinent to the issues involved in this case, Respondent, Bruce M. Williams, held Florida teacher certificate number 414669 authorizing him to serve as a substitute teacher. On March 21, 1984, after a trial by bury in the County Court of Alachua County, Florida, on Case No. 83-4274-MM-A , Respondent was found guilty of the offense of trespass after warning. On April 30, 1984, the Judge of the County Court entered a Judgement of Guilt and placed the Respondent on one year's probation with the stipulation that, among other things, he not go onto the University of Florida campus unless his probation officer gave him prior permission. This judicial determination of guilt. It was the culmination of a series of events involving the Respondent and his repeated entrances onto property owned by the University for which he was repeatedly warned and directed not to return. Respondent contends that he had legitimate reasons to be on the University property each of the times in question and contests the use of these reports branding them a violation of his rights. He overlooks the fact that the conviction came after several instances of unauthorized entrance and that the conviction was based on proven violations. Nonetheless, it appears that on December 30, 1982, Respondent was observed by Kenneth E. Solomon, an investigator with the University police department, in the parking lot of Diamond Village, a University married students' housing area not open to the public. Mr. Solomon attempted to identify the Respondent who was at first reluctant to identify himself but who finally agreed and indicated that his wife was inside doing their laundry. Since this is an area reserved for university students and their families, Mr. Solomon issued a warning to Respondent not to trespass on University property and thereafter filled out and filed a report of the incident. Thereafter, on March 15, 1983, Keith B. Reddick, who was at that time an officer with the University police was called to University Hospital (Shands), where he was met by a Mrs. Fugate and a guard who had Respondent in custody. Mrs. Fugate advised at that time that Respondent had previously been at the hospital on March 7 with no legitimate reason for being in the area. On that occasion, when asked why he was there, Respondent indicated he had been given permission to be there by a member of the medical school faculty, Dr. Cruz. Dr. Cruz categorically denies ever having given Respondent permission to be where he was. In fact, she met him only once when he stopped her and asked her about the possibility of a job with the hospital. At that time she told him there were none available except for fellowships for which an applicant had to be a physician already. Nonetheless, he gave her a resume and she believes he indicated he was involved in research. With this one exception, she has had no contact with him and never gave him authority to work with patients in her department or be there for any reason. On this latter occasion, when asked what he was doing there, Respondent replied that he had become lost while looking for a laboratory. He also said he was looking for a doctor friend whose name he could not remember and as a chemistry major, was working on his thesis. On this occasion, Officer Reddick took Respondent to the police station, showed him a map of the campus, told him where he could and could not go on the campus by pointing to the map areas, and told him not to return again to the university unless on official business or for public functions. The following day, on March 16, 1983, Respondent was observed in the Shands Hospital cafeteria by Officer Rogers of the University police. When asked for his identification and reason for being there, Respondent indicated he had paid a bill in the laboratory, so Rogers let him go. When Rogers checked the story out, however, he found that the bill which was alleged to have been for unauthorized use of the hospital copying machine, had in reality been paid three hours before the Respondent was contacted. Rogers again saw Respondent on March 29, 1983 in the hub area of the University book store on campus. Rogers had been notified by Reddick that Respondent was on campus and when he had approached the Respondent, Respondent walked off and into the book store. Rogers and three other officers contacted Respondent in the book store where Respondent indicated he had met with a Mrs. Greene, a University affirmative actions officer and upon receiving that explanation, the officers let him go. Respondent was again identified on July 6, 1983, by officer Edward Miles who observed him in an off-limits gynecological area on the 4th floor of the University hospital. When Miles arrived at the scene, a contract security officer was talking with Respondent. This officer had seen Respondent in the area and had asked for identification in response to which request, Respondent showed a student identification card which was no longer valid since Respondent was no longer a student. Asked what business he had in this particular area, Respondent indicated he was looking for work but when, after 30 minutes, he could not verify this story, Officer Miles placed Respondent under arrest and took him to campus police headquarters. From all of the above, it is clear that though Respondent may have felt he had a legitimate basis for being on the campus and, in fact, may have had when he went to speak with Mrs. Green and went to pay the bill at the hospital, he stretched these occasions into several unauthorized occasions even after he had been warned with full knowledge that his presence on the campus was not authorized. The conviction in County Court was not contested at the time and on the basis of the above evidence, appears to have been warranted. On July 8, 1983, an arrest warrant was issued out of the Circuit Court for the 8th Judicial Circuit in Alachua County alleging sexual battery in violation of Section 794.011, Florida Statutes. This warrant contained allegations that Respondent had committed a sexual battery against his 9-year- old stepdaughter. However, Respondent was tried on a reduced charge of lewd and lascivious assault upon a child and at his trial he entered a plea of no contest. Respondent was found guilty and sentenced to 10 years probation the terms of which required him to undergo mental health counseling among other requirements. Respondent continues to deny his commission of the offenses to which he pleaded no contest at the trial. However, in a statement he made at the time of his arrest, he admitted several factors which contradict that. He admitted that he had a very physical relationship with his stepdaughter; that he appeared nude in front of her many times; and that he would be in bed with her laying on top of him while both were nude with the child's mother there as well. He also admitted having French kissed his stepdaughter (she indicates he taught her how to do this) but denies having any sexual intercourse with her. Respondent contends that these charges are all a plot to deprive him of the close relationship with his family, instituted by someone unnamed and unidentified. The fact remains that Respondent is delinquent in his probation and has made little progress in the required mental health counseling because of his continued belief that he has done nothing wrong but is the victim of this conspiratorial plot. Sometime in or around February 1984, Respondent entered the restaurant owned and operated by Mrs. Vlahopous, in Gainesville, and asked to speak with her daughter, Alex, who apparently had come to the blood center at which he worked. At this point Respondent identified himself as "Dr. Bruce. When she asked him for his office address and phone number since Alex was not there, he said he didn't have an office, but he wrote his name and phone number on one of her cards for her. After Mrs. Vlahopous thought about this over night, she went to the blood bank where Respondent had said he worked and asked for Dr. Williams. At this point she was told by blood bank personnel that Williams was not a doctor, had been fired, and would be rejected if he came there again. Be that as it may, Sharron A. Sturdevant, an official of the blood bank where Respondent had been working, does recall that at times Respondent was referred to as Dr. Bruce at the center. This was, however, only a term of affection or friendliness and was not in any way intended to authorize him to hold himself out to the public as a doctor. Respondent did work for the City of Gainesville in a conservation project in May and June of 1984 but he was terminated because he had not listed his full police record on the application form. This termination was a matter of necessity under city personnel policies which required termination of anyone who intentionally falsified an application form. It had nothing to do with Respondent's performance or anything that took place while he was employed by the city. Mr. John Middleton, Principal of Ft. Clarke Middle School, knew Respondent as a paraprofessional at the alternative school when Mr. Middleton was principal there and Respondent was employed for approximately a month and a half. While Respondent was working at the alternative school he was working as aide to another teacher. He was apparently unable to accept the fact, however, that when a teacher and a paraprofessional (aide) are in the same classroom, it is the teacher who always is in charge. Respondent was discharged from his employment at the alternative school because of an incident where it was alleged he had usurped the authority of and changed the orders of the teacher for whom he was working, in front of the class. The investigation report, which Mr. Middleton received from the teacher and students who observed the incident indicated that the Respondent was loud and boisterous at the time of the incident. Since these students at the alternative school were emotionally handicapped to start with, a fact which Respondent knew, his misconduct was even more serious than it would have been in a normal situation. These students need calm more than noise. In the situation here, Respondent's actions served only to upset them. Mr. Middleton had observed that prior to this incident, Respondent's dealings with the students aggravated rather than helped them. As a result, this incident was only one factor in the decision to terminate Respondent from employment and after the incident took place, Mr. Middleton wrote an unsatisfactory performance report on the Respondent. Based on his personal observation of the Respondent, and what he now knows of Respondent's criminal record, Mr. Middleton is convinced that a teacher with this record could not be effective in the classroom. His effectiveness would be definitely reduced by his misconduct and his conduct would not set a positive example for students. In his opinion, students should not be exposed to anyone with criminal convictions. These sentiments are reinforced by Mr. Wilford A. Griffin, a career service specialist with the Alachua County School Board, who first met Respondent when Respondent left Newberry High School seeking a place in the Alachua County system. Respondent had been terminated at Newberry High School because of some problem with his certification which had nothing to do with performance or misconduct. After the alternative school termination referenced above, Respondent was placed at Eastside High School but was terminated there because of his difficulties with teachers similar to those he had at the alternative school. As an aide, he disagreed openly with teachers in the classroom and in this case, the teacher complained that he would not follow directions and would not do what the teacher wanted done. In all cases, Mr. Griffin counseled with the Respondent about the problem. Respondent obviously felt that the complaining teacher was demeaning him. He felt that he was being helpful and had been rebuffed. Based on his experience with this Respondent, Mr. Griffin would never again try to place him within the school system. Considering Respondent's record in and out of the classroom, Mr. Griffin could not recommend Respondent for employment in the school system. He believes Respondent could not be an effective teacher because of his inability to understand the ramifications of his actions. This does not even consider the convictions which merely aggravate the situation even more. There is no evidence to counter these professional opinions of Respondent's fitness to teach and they are accepted and adopted as fact.
Findings Of Fact On or before July 29, 1969, respondent applied for a type four teacher's certificate, which was issued to him on October 29, 1969. Thereafter, while he was employed as a teacher by the Duval County School Board, he did course work nights at the Continuing Education Center, affiliated with Florida Agricultural and Mechanical University (FAMU), which eventuated in the award of a master's degree on August 30, 1971. On January 31, 1972, respondent applied for a type two teacher's certificate, in order to be eligible for an assistant principal's job, and because his master's degree satisfied the educational prerequisite for upgrading his teacher's certificate. In applying for type two teacher's certificate, respondent filled out an application form. On the form was the question, "Have you ever been arrested or involved in a criminal offense other than a minor traffic violation?" Respondent answered this question in the negative by checking a blank after the word "No." On July 7, 1972, a type two teacher's certificate was issued to respondent. On May 6, 1969, respondent was convicted of an offense under Section 832.05, Florida Statutes (1975), because of a check he drew to the order of FAMU in the amount of thirty dollars ($30.00). According to court records, respondent pleaded guilty to this charge by mail, although at the hearing he had no recollection of the offense or of the disposition of the charges. Respondent did remember the six bad check charges of which he was found guilty in the spring of 1971. These cases, too, arose because he drew checks to the order of FAMU, two in the amount of forty-eight dollars ($48.00) and four in the amount of fifty-seven dollars ($57.00). These checks were all written the same quarter and delivered to individual professors at FAMU. At the time respondent wrote the 1971 checks, he knew he had insufficient funds on deposit to cover them, but he reasonably believed he would be able to cover the checks before they cleared. They all bounced and they all resulted in convictions and fines under Section 832.05, Florida Statutes (1975), half on pleas of nolo contendere and half on pleas of guilty. Respondent eventually made good on all the checks written to FAMU's order. Respondent testified that he believed the 1971 bad check proceedings had been civil, rather than criminal, at the time he filled out the application form for a type two teacher's certificate. The evidence as a whole established, however, that respondent deliberately concealed the fact of the bad check convictions. On January 22, 1976, respondent filled out an application form for employment by the City of Jacksonville On this form appears the question, "Have you ever been arrested, taken into custody, held for investigation or questioning, charged with driving while intoxicated, or charged with an offense with any law enforcing agency? (Excepting minor traffic violations)." Respondent placed and "X" in a box beside the word "YES," and amplified his answer, in pertinent part, as follows: "I wrote Fla. A&M University a check and had to make restitution." (emphasis supplied) In 1975, respondent took a leave of absence from teaching, in order to do work at the University of Florida towards a Ph.D. degree. Before he left Jacksonville for Gainesville, he rented a typewriter from McDavid Typewriter Service, paying two weeks' rent in advance. On two occasions, he called Mr. McDavid from Gainesville to assure him that he would return the typewriter, once he had retrieved it from the typist working on his dissertation. After a warrant for his arrest issued, respondent returned the typewriter on October 31, 1975, slightly more than five months after he had rented it. Respondent paid Mr. McDavid two hundred twenty-seven dollars ($227.00) for back rent and to cover the cost of fixing the carriage on the typewriter. Criminal proceedings resulted in an order, entered January 26, 1976, withholding adjudication of guilt and placing defendant on probation, upon respondent's plea of nolo contendere to an amended information charging attempted grand larceny of the typewriter. For the latter part of respondent's probationary period, he was supervised by Joe M. Kiser, a probation officer. Mr. Kiser expressed confidence in respondent, and predicted no future skirmishes with the law. Because of respondent's exemplary behavior while on probation, Judge Black terminated his probation almost four months before the date on which probation was originally scheduled to end. During the school year 1975-76, respondent worked under Mr. Nathaniel Davis, then principal at Ribault Junior High School. Respondent supervised another teacher and an aide and did a marvelous job. The students were respectful and felt respondent would listen to them. He set an excellent example for the students, while he was in their presence. He was able to improve the behavior of truants and other students who posed disciplinary problems. In the course of the school year, in Mr. Davis' opinion, respondent changed for the better because he had learned a lesson. Mr. Davis would want respondent teaching under him. Mr. Ted Montgomery, currently principal of Ribault Junior High School, met respondent on August 23, 1976, and is respondent's supervisor. Respondent counsels students who have dropped out of school or on the verge of doing so. He tries to establish links between the school and the students' homes. He is hard working and does a good job. He gives to students of his own time. Mr. Montgomery wants respondent to continue teaching under him.
Recommendation Upon consideration of the foregoing, it is recommended that respondent be reprimanded. DONE and ENTERED this 7th day of April, 1977, in Tallahassee, Florida. Hearings ROBERT T. BENTON, II Hearing Officer Division of Administrative Room 530 Carlton Building 2009 Apalachee Parkway Tallahassee, Florida 32304 (904) 488-9675 COPIES FURNISHED: Mr. Ronald C. LaFace, Esquire Post Office Box 1572 Tallahassee, Florida 32304 Mr. Haldane Taylor, Esq. 605 Florida Theatre Building 128 East Forsyth Street Jacksonville, Florida 32202 Mr. Tom Benton Professional Practices Council 319 West Jefferson Street Tallahassee, Florida 32304 ===========================================================
