The Issue Whether the Petitioner, Bert S. McLaughlin, qualifies for licensure as an unlimited electrical contractor in the state of Florida by endorsement pursuant to Section 489.511, Florida Statutes. Whether the Resolution adopted by the Florida Electrical Contractrors' Board (Board) on July 19, 1985 and readopted in substance on March 30, 1987 and May 15, 1987 estops the Board from denying the Petitioner an unlimited electrical contractor's license by endorsement pursuant to Section 489.511, Florida Statutes.
Findings Of Fact Upon consideration of the oral and documentary evidence adduced at the hearing, the following relevant facts are found: On July 19, 1985, the Florida Electrical Contractors' Licensing Board (Board) adopted a Resolution which provides in pertinent part as follows: WHEREAS, the Florida Electrical Contractors Licensing Board has diligently compared its licensing standards with those of the unlimited electrical contractors licensed by the North Carolina State Board of Examiners of Electrical Contractors, and, WHEREAS, the Florida Electrical Contractors Licensing Board has thoroughly reviewed the examinations that North Carolina candidates for unlimited licensure must pass and found them substantially similar to or equivalent to, the Florida licensure examination, now, THEREFORE BE IT RESOLVED, that the Florida Electrical Contractors Licensing Board will, upon receipt of a properly completed application from a properly licensed unlimited North Carolina electrical contractor who has obtained licensure by the North Carolina written exam, license by endorsement in accordance with Section 489.511(9), Florida Statutes NOTICE OF CANCELLATION, this Resolution may be rescinded upon 90 days notice to North Carolina, if it is determined by the Florida Electrical Contractors Licensing Board, that the licensing standards for unlimited electrical contractors in North Carolina are no longer comparable with the licensing standards of certified electrical contractors licensed pursuant to Chapter 489, Florida Statutes The above Resolution was readopted in substance by the Board on March 30, 1987 and Nay 15, 1987. The Board made a specific finding on May 15, 1987, when it readopted the Resolution, that the North Carolina examination for unlimited electrical contractors were "substantially similar to or equivalent to, the Florida licensure examination." The Board relied on that finding, without any further finding as to equivalency of the examinations, to grant licensure by endorsement from unlimited electrical contractors licensed in North Carolina who had successfully passed the North Carolina written unlimited electrical contractors examination up until August 31, 1988. In October, 1988, the issue of the equivalency of the Florida examinations and the North Carolina examinations was raised by the Board. In December, 1988, the Board was provided current and previous examination blueprints of the North Carolina examinations by Block and Associates, who prepared the North Carolina examinations. Upon review of the examination blueprints of the North Carolina examinations, the Board determined that the North Carolina examinations were not "substantially equivalent to" the Florida examinations. This finding was based mainly on the fact that North Carolina's examinations did not contain any portion on business which the Board considered essential. From the documents reviewed by the Board, the Board was unable to make a determination as to whether the business portion of the examination was included in the North Carolina examinations at the time of its finding of equivalency on May 15, 1987. However, the Board did determine apparently based on those documents, no later than its February 1, 1989, meeting, that at the time Petitioner took the North Carolina examination on September 23, 1988 it did not contain a business portion, and thereby was not "substantially equivalent to" the Florida examination. Petitioner took and passed the examination in North Carolina for unlimited electrical contractors on September 23, 1988. On November 28, 1988, Petitioner was granted a unlimited classification licence to practice electrical contracting in the state of North Carolina. Petitioner submitted an application to the Board on December 8, 1988, for licensure as an unlimited electrical contractor in the state of Florida by endorsement based on having passed the North Carolina examination, being licensed in the state of North Carolina as an unlimited electrical contractor and practicing electrical contracting in the state of North Carolina. On December 22, 1988, the state of North Carolina was notified by Paul H. Morgan, Jr., Chairman, Florida Electrical Contractors' Licensing Board that the 90 day cancellation provision of the Resolution was in effect and the "endorsement agreement" would be cancelled effective March 22, 1989. The Board did not officially authorize the letter by Mr. Morgan. The Board's official position was that the "endorsement agreement" was of no effect. Petitioner obtained a City of Winston-Salem, North Carolina, City Privilege License, as an electrical contractor with one helper on January 5, 1989. At its February 1, 1989, meeting the Board reviewed Petitioner's application for licensure by endorsemert, and by letter dated February 28, 1989, advised Petitioner of its denial based on the criteria for issuance of his North Carolina license not being equivalent to the criteria set forth for licensure in the state of Florida at the time Petitioner received his North Carolina license. At its March 15, 1989, meeting the Board again reviewed Petitioner's application, and by letter dated March 15, 1989, advised Petitioner of its decision to uphold its denial of his application of February 1, 1989 as set out in its letter of February 28, 1989. Although not specifically addressed in the letters dated February 28, 1989 and March 15, 1989, the criteria which caused the Board concerned was the lack of North Carolina's examination being "substantially equivalent to" the Florida examination, whether the Petitioner had been engaged in electrical contracting in North Carolina immediately preceding his application for licensure by endorsement in Florida and whether North Carolina required Petitioner to show certain financial responsibility standards prior to issuance of Petitioner's electrical contractor's license in North Carolina. In its letter of February 28, 1989 the Board advised Petitioner that although it had denied his application for licensure by endorsement, it had approved his application as one for licensure by examination. The Petitioner has presently elected not to take the Florida unlimited electrical contractors' examination or the examination for licensure as an alarm system contractor. Prior to taking and passing the North Carolina electrical contractor's examination, Petitioner had been engaged in all types of electrical contracting work, including fire alarm installation, in several counties in the state of Florida, and was licensed in several Florida counties as a county master electrical contractor but not as a state certified unlimited electrical contractor. Under the present law in Florida, county master electrical contractors, who are not state certified electrical contractors or licensed to practice alarm system contracting by the state of Florida, cannot practice alarm system contracting in the state of Florida. It was Petitioner's intent at the time of taking the North Carolina examination to open an electrical contractor's business with his brother in North Carolina. Petitioner's primary reason for taking the North Carolina examination was to further this business relationship with his brother in North Carolina.. However, secondary to obtaining the North Carolina license, was licensure by endorsement in Florida. While Petitioner was aware of Florida's "endorsement agreement" with North Carolina at the time he took the North Carolina examination, there was no evidence to show that the Petitioner relied on this "endorsement agreement" to his detriment. Subsequent to obtaining his North Carolina license, Petitioner's brother died, and the North Carolina business was put on the "back burner" so to speak. Two electrical permits for electrical work was "pulled" by Petitioner in the City of Winston-Salem, North Carolina on March 6, 1989 and with the work being inspected and approved on March 8, 1989. A third electrical permit was "pulled" by Petitioner for electrical work in the City of Winston-Salem, North Carolina on March 6, 1989 but there was no evidence to show that this work was completed by Petitioner. There was no evidence to show that the North Carolina electrical contractors' examination was "substantially equivalent to" the Florida electrical contractors' examination. In fact, the Petitioner stipulated at the beginning of the hearing that he was relying entirely on Florida's "endorsement agreement" with North Carolina.
Recommendation Based upon the foregoing Findings of Fact the Conclusions of Law, the evidence of record and the candor and demeanor of the witnesses, it is, therefore RECOMMENDED that the Board enter a final order denying Petitioner's application for licensure as a unlimited electrical contractor by endorsement. DONE AND ENTERED this 20th day of September, 1989, in Tallahassee, Leon County, Florida. WILLIAM R. CAVE 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 20th day of September, 1989. APPENDIX TO RECOMMENDED ORDER IN CASE NUMBER 89-2614 The following constitutes my specific rulings pursuant to Section 120.59(2), Florida Statutes, on the proposed findings of fact submitted by the parties in this case. Specific Rulings on Proposed Findings of Fact Submitted by Petitioner Each of the following proposed findings of fact are adopted in substance as modified in the Recommended Order. The number in parentheses is the Finding of Fact which so adopts the Petitioner's proposed finding of fact: 1(1); 2(2); 3(1); 5(3); 7-8(15); 9(6); 10(7,19); 11(16); 12(18); and 15(9). Proposed findings of fact 4 and 13 are unnecessary to the conclusion reached in the Recommended Order. Proposed findings of fact 14 is rejected as not being supported by substantial competent evidence in the record. See Findings of Fact 11 and 13. Letter referred to the equivalency of criteria. Proposed findings of fact 16 and 18 are rejected as not being supported by substantial competent evidence in the record. See Findings of Fact 4 and 6. Proposed finding of fact 6 is more correctly considered as a Conclusion of Law. Although proposed finding of fact 17 is a restatement of Neely's testimony it is rejected as not being supported by substantial competent evidence in the record. See Proposed Finding of Fact 9. Specific Rulings on Proposed Findings of Fact Submitted by Respondent Each of the following proposed findings of fact are adopted in substance as modified in the Recommended Order. The number in parentheses is the Finding of Fact which so adopts the Respondent's proposed finding of fact: 1(1); 2(2); 4(4); 5(6,16); 6(8); 7(10); 8(19); 9(11); 10(12) and 11(12). Proposed finding of fact 3 is more correctly described as a Conclusion of Law. COPIES FURNISHED: Steven Meisel, Esquire 5425 St. Augustine Road Jacksonville, Florida 32207 Clark R. Jennings, Esquire Assistant Attorney General Department of Legal Affairs Suite 1603 - The Capitol Tallahassee, Florida 32399-1050 Ms. Pat Ard Executive Director Florida Board of Electrical Contractors 1940 North Monroe Street Tallahassee, Florida 32399-0792
Findings Of Fact Based upon my observation of the witnesses and their demeanor while testifying, documentary evidence received, and the entire record compiled herein, I hereby make the following relevant findings of fact: By its Administrative Complaint filed herein dated July 6, 1982, the Petitioner, Electrical Contractors Licensing Board, seeks to take disciplinary action against the Respondent, J. Hugh Smith, a registered electrical contractor, who holds license number ER 0004272. The Respondent is the President of Electric Hugh Company, Inc. Electric Hugh Company is the entity through which the Respondent engaged in the business of electrical contracting in the City of Jacksonville. On March 3, 1982, the Construction Trades Qualifying Board for the City of Jacksonville met and considered charges filed against the Respondent for failure to use certified craftsmen. A Mr. Etheridge, an employee of Respondent, was permitted to engage in electrical contracting work unsupervised by a certified craftsman without being licensed as a certified craftsman. By so doing, Respondent violated Section 950.110(a), Ordinance Code of the City of Jacksonville, Florida. 1/ For that code violation, Respondent's certificate was suspended for a period of six (6) months. (Petitioner's Exhibit 1 and testimony of John R. Bond, Executive Director -- Construction Trades Qualifying Board for the City of Jacksonville) On June 2, 1982, the Construction Trades Qualifying Board convened another meeting to consider other charges filed against Respondent based on an alleged failure (by Respondent) to pull electrical permits on four instances wherein a permit was required. At that time, Respondent's certification was revoked effective June 2, 1982, and that revocation remains in effect. The action by the Construction Trades Qualifying Board, City of Jacksonville, has been reviewed by Petitioner. By way of mitigation, Respondent opined that he considered the two years in which his license has been revoked by the City of Jacksonville as sufficient penalty for the violation. Respondent did not substantively contest the charges.
Recommendation Based on the foregoing findings of fact and conclusions of law, it is hereby RECOMMENDED that the Respondent's registered electrical contractor's license number ER 0004272 be suspended for a period of two years. DONE AND ENTERED this 17th day of April 1984 in Tallahassee, Florida. JAMES E. BRADWELL 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 17th day of April 1984.
The Issue Whether the Respondent failed to provide proof of workers' compensation coverage or exemption, and proof of having completed 14 hours of approved continuing education in response to an audit conducted by the Electrical Contractors Licensing Board for the biennium commencing September 1, 1996, and terminating on August 31, 1998, in violation of Subsection 489.533(1)(o), Florida Statutes, by violating Subsections 489.515(3) and 489.517(3), Florida Statutes, and Rule 61G6- 9.011, Florida Administrative Code, as alleged in the Amended Administrative Complaint.
Findings Of Fact The Petitioner is the State of Florida, Department of Business and Professional Regulation (DBPR), the state agency charged with regulating the practice of electrical contracting in Florida and those licensed under Chapter 489, Florida Statutes, pursuant to Section 20.165, and Chapter 455, Florida Statutes. The Respondent is, and has been at all times material to the allegations in the Amended Administrative Complaint, an electrical contractor licensed by the Electrical Contractors Licensing Board. From 1987 until 2000, the Respondent was a registered electrical contractor, holding license number ER 0010816. Since August of 2000 the Respondent has been a certified electrical contractor holding license number EC 0002356. The Respondent's practice pursuant to his registered license was a prerequisite to issuance of his certified license. All insurance and continuing education requirements for renewal of a license issued by the ECLB are set forth in Sections 489.515 and 489.517, Florida Statutes, as well as Rule 61G6-9.004, Florida Administrative Code, and are identical for certified and registered electrical contractors. In March of 1999 the ECLB conducted a random audit of the insurance and continuing education requirements established in Rule 61G6-9.004, Florida Administrative Code, for the biennium commencing September 1, 1996, and terminating August 31, 1998. The Respondent was one of the licensees randomly chosen for this audit. In response to the initial audit letter sent to the Respondent on March 17, 1999, the Respondent submitted insurance and continuing education documentation. This documentation reflects: no evidence of workers' compensation coverage or exemption for the audit period; no evidence of approved continuing education for the audit period; and no evidence of required liability insurance for the audit period. The continuing education documentation submitted by the Respondent was for the prior biennium, in February 1996. On July 19, 1999, the ECLB forwarded the Respondent a follow-up letter, indicating that he was still lacking the documents enumerated in Finding of Fact Number 5. In response to this letter, the Respondent submitted documentation of the required liability insurance and of workers' compensation for May 1, 1997 through June 22, 1999. At hearing, the Respondent produced a document similar to those previously provided to the DBPR documenting his workmen's compensation insurance from March 1, 1995 to May 1, 1997. The date of this document was the same as the date on the materials previously furnished to DBPR. The Respondent testified that his insurance agent had faxed the requested documents to DBPR and sent copies to him. He received all of the documents substantiating his insurance from May 1, 1997 until June 22, 1999. His agent presumably forwarded or faxed the same documents to DBPR. DBPR produced all the documents except the one for the period of March 1, 1995 until May 1, 1997. The Respondent provided enough information to raise a genuine question whether this document was lost by DBPR. It is concluded that it is as likely DBPR lost the record as it is the record was not sent. There was no additional documentation of the required continuing education submitted at hearing. Subsequent to the completion of the audit, the ECLB initiated a complaint with the Bureau of Consumer Services at DBPR. This complaint alleges that the Respondent failed to document required workers' compensation coverage or exemption for the entire audit period and failed to document required continuing education within the audit period. The Respondent was initially issued citations for resolution of the alleged violations herein. Each of these citations provided for a $500 administrative fine. The continuing education violation was documented as DBPR case number 2000-08338 and the workers' compensation violation was documented as 2000-05654. The Respondent chose to dispute these citations, and as a result, this matter was handled pursuant to the provisions of Section 455.225, Florida Statutes. The Respondent has failed to document completion of hours of board approved continuing education between September 1, 1996 and August 31, 1998. The Respondent failed to obtain any board approved continuing education between September 1, 1996 and August 31, 1998. In DBPR case number 2000-08338, the Petitioner incurred non-legal costs in the amount of $31.70. In DBPR case number 2000-05654, the Petitioner incurred non-legal costs in the amount of $42.47. However, this cost may not be recovered.
Recommendation Based upon the foregoing Findings of Fact and Conclusions of Law set forth herein, it is RECOMMENDED: That a final order be entered imposing an administrative fine of $500 against the Respondent for Count II of the Amended Administrative Complaint. It is further recommended that the Respondent be required to pay the non-legal costs incurred by the Petitioner in both agency cases totaling $31.70. DONE AND ENTERED this 14th day of September, 2001, in Tallahassee, Leon County, Florida. STEPHEN F. DEAN 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 14th day of September, 2001. COPIES FURNISHED: Laura P. Gaffney, Esquire Department of Business and Professional Regulation 1940 North Monroe Street, Suite 60 Tallahassee, Florida 32399-0792 David Karably Post Office Box 12 Earleton, Florida 32631 Hardy L. Roberts, III, General Counsel Department of Business and Professional Regulation 1940 North Monroe Street Tallahassee, Florida 32399-2202 Anthony B. Spivey, Executive Director Electrical Contractors Licensing Board Department of Business and Professional Regulation 1940 North Monroe Street Tallahassee, Florida 32399-0792
The Issue Whether Respondent committed the offenses alleged in the Administrative Complaint and, if so, the penalties that should be imposed.
Findings Of Fact At all times relevant to this proceeding, Respondent has been licensed by the Petitioner as an electrical contractor. Respondent holds license EC 0002526. Respondent does business as M. H. Electrical Services (M. H. Electrical) at 11512 41st Court North, Royal Palm Beach, Florida. Petitioner is the agency of the State of Florida charged with regulating the practice of construction contracting in the State of Florida pursuant to the provisions of Section 20.165, Chapter 455, and Part II of Chapter 489, Florida Statutes. On May 15, 2007, M. H. Electrical, though the Respondent, drafted a proposal for electrical services to be done on a residence being constructed by Mr. Malone. The location of the residence is 1664 88th Road North, Royal Palm Beach Acreage, Florida. The contract price totaled $5,140.00. Work on the project commenced on May 17, 2007. There were many problems with the work performed by Respondent’s company that were ultimately corrected by Mr. Malone. Respondent’s workmen installed 15 “12 gauge” wires in a 3/4 pipe underground that was inconsistent with the applicable building code. Respondent’s workmen installed a pipe running from one electrical panel to another incorrectly. Respondent’s workmen wired attic fans in a manner that overloaded an electrical panel. Respondent’s workmen installed a ground rod of only three and a half feet. The applicable building code required a ground rod of eight feet. A kick plate is a metal piece that protects electrical wires from being pierced when sheetrock is being installed. Petitioner asserted that Respondent failed to install kick plates. Respondent’s testimony established that kick plates were not necessary due to the depth of the wall studs that were utilized. Respondent’s workmen installed two wires incorrectly in the laundry room of the house. The wires were cut, which caused a fire hazard. Petitioner did not establish that Respondent’s workmen cut the wires. Respondent’s workmen failed to properly ground whirlpool tub wires for two whirlpools by failing to ground the wires to the main pipe as required by the applicable building code. The work did not progress as contemplated by Mr. Malone and by Respondent. As owner of the premises, Mr. Malone called for all inspections of the electrical work. These inspections were performed by employees of the Palm Beach County, Florida, Planning, Zoning and Building Department (the County Building Department). The following is the inspection history between May 21 and October 10, 2007: Temporary Power scheduled for May 21 was cancelled. Temporary power on May 22 passed. Rough electric on June 8 failed. Rough electric on July 9 passed. Rough electric on October 10 failed. The progress of the work was impeded for two primary reasons. First, the testimony of the Respondent, which the undersigned finds to be credible, established that on more than one occasion Mr. Malone did not have necessary materials at the building site. Second, Respondent fired the lead electrician on the subject project approximately two weeks into the project. Following communications with an employee of Florida Power and Light (FPL), Mr. Malone determined that portions of the work performed by Respondent’s employees did not meet the applicable building code. The record is not clear whether this communication occurred before or after the passed inspection on July 9. The last date on which one of Respondent’s employees worked on the project was July 23, 2007. Mr. Malone paid M. H. Electrical the full contract price on July 25, 2007. Mr. Malone and Respondent had a conversation about the communication with the FPL employee. Mr. Malone refused to tell Respondent the name of the FPL employee who stated that some of the work did not meet code. The date of this conversation was not established. Mr. Malone testified that when he paid Respondent on July 25, he believed that a list of ten items needed to be repaired. Mr. Malone further testified that he paid Respondent before these items had been repaired because he believed that Respondent would return to make all necessary repairs. The undersigned finds this testimony to be credible. As of July 25, 2007, when payment was made in full, Respondent knew or should have known that there existed on this project a list of repairs to the electrical wiring that needed to be done. After July 25, 2007, Mr. Malone made repeated efforts to contact Respondent. In response to those calls, Respondent sent an employee to the site to discuss Mr. Malone’s concerns. A locked gate prevented that employee’s entry on the building site. The date of that event was not established. On or before October 10, 2007, Mr. Malone requested another inspection from the County Building Department. That inspection failed. A failed inspection means that there were one or more deficiencies that had to be corrected before the job could progress. The inspector posted a Correction Notice, which advised that the following needed to be done before the job would be accepted: a smoke detector in the master bedroom would have to be relocated to a higher part of the ceiling; a conduit would have to be rerun (this is the deficiency described in paragraph 5 of this Recommended Order); and a ground rod would have to be replaced (this is the deficiency described in paragraph 8 of this Recommended Order). On October 11, 2007, two of Respondent’s employees went to the building site to make any needed corrections. Mr. Malone refused to let the employees on the property. Respondent did not return any of the funds paid by Mr. Malone. Respondent did not terminate the contract. Mr. Malone made all necessary electrical repairs. On April 2, 2008, the project passed final inspection.
Recommendation Based upon the foregoing Findings of Fact and Conclusions of Law, it is hereby RECOMMENDED that Petitioner enter a final order finding Respondent guilty of the violation alleged in Count I of the Administrative Complaint and not guilty of the violation in Count II. It is further RECOMMENDED that for the Count I violation, the final order issue a reprimand to Respondent and impose an administrative fine against Respondent in the amount of $1,000.00. DONE AND ENTERED this 20th day of October, 2009, in Tallahassee, Leon County, Florida. CLAUDE B. ARRINGTON 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 20th day of October, 2009.
Findings Of Fact A.P. Jerguson III is the sole shareholder of Jerguson Electric, Inc., applicant herein, and is the qualifying agent for the applicant. He has been a master electrician in Dade County since 1972 and formed his own electrical company in October, 1972. Prior to obtaining his master's license he was employed by L & M Electric Company and Lund Electric Company. While working for the latter contractor he was electrical foreman on the construction of a Holiday Inn at 79th Street Causeway in Miami. Since forming his own business Jerguson has performed all types of electrical work from equipment installation to electrical wiring. After forming Jerguson Electric he made little or no money the first two years. During the past two years the company made approximately $4,000 net profit each year after paying to the sole shareholder some $18,000 annual salary. In 1975 the applicant did approximately $66,000 in gross sales. The credit information submitted on both Jerguson and the applicant contains no adverse comments and shows both Jerguson and Jerguson Electric to pay bills promptly, have no judgments against them and to be currently solvent. Representative jobs performed by applicant are contained in Exhibit 1. These show routine wiring jobs, commercial and residential electrical work, and freezer and air-conditioning installations. These jobs varied between $500 and $8,000 in price and totaled some $60,000 over a three year period. However, as seen from the financial statement for 1975, where the total work performed amounted to some $66,000 these were representative jobs over the three year period and not all jobs performed during this three year period as the form on which they were submitted seems to indicate. At the hearing Respondent stipulated that the qualifying agents' qualifications were not in question and that the agent was denied the right to take the examination because the applicant did not show enough major jobs to demonstrate its qualification and business experience in handling large jobs. The Executive Director of the Board further testified that upon this basis the Board would deny certification of any new business organization, regardless of the expertise of its qualifying agent or agents and the financial status of the organization, simply because the new business could not show a sufficient number of jobs completed. Apparently if the qualifying agent had previously been certified by the board a new business could be certified pursuant to the provisions of Rule 21GG-2.01(2) F.A.C.
Recommendation Based on the foregoing Findings of Fact and Conclusions of Law, it is RECOMMENDED that all charges against Floyd E. Williams be DISMISSED. DONE and RECOMMENDED this 9th day of June, 1983 in Tallahassee, Florida. DONALD R. ALEXANDER Hearing Officer Division of Administrative Hearings The Oakland Building 2009 Apalachee Parkway Tallahassee, Florida 32301 (904) 488-9675 Filed with the Clerk of the Division of Administrative Hearings this 9th day of June, 1983.
