85-002272 River Trails, Ltd. vs. South Florida Water Management District
 Status: Closed
Recommended Order on Wednesday, April 23, 1986.


View Dockets  
Summary: Developer's request to construct marina within the district denied when request failed to show it would not interfere with operation within District's control.

1STATE OF FLORIDA

4DIVISION OF ADMINISTRATIVE HEARINGS

8RIVER TRAILS, LTD., )

12)

13Petitioner, )

15)

16vs. ) Case No. 85-2272

21)

22SOUTH FLORIDA WATER MANAGEMENT )

27DISTRICT, )

29)

30Respondent. )

32_________________________________)

33RIVER TRAILS, LTD., )

37)

38Petitioner, )

40)

41vs. ) Case No. 85-3678

46)

47SOUTH FLORIDA WATER MANAGEMENT )

52DISTRICT, )

54)

55Respondent. )

57_________________________________)

58RECOMMENDED ORDER

60Pursuant to notice, the Division of Administrative Hearings,

68by its duly designated Hearing Officer, William J. Kendrick, held

78a public hearing in the above-styled cases on February 18-20,

881986, at West Palm Beach, Florida.

94APPEARANCES

95For Petitioner: Phillip S. Parsons, Esquire

101Landers, Parsons and Uhlfelder

105P.O. Box 271

108Tallahassee, Florida 32302

111For Respondent: Stanley J. Niego, Esquire

117South Florida Water Management District

122Post Office Box V

126West Palm Beach, Florida 33402

131PRELIMINARY STATEMENT

133These consolidated cases essentially raise the issue of

141whether Petitioner should be granted a right of way occupancy

151permit to construct a boat ramp and docking facility within the

162works of the Respondent.

166At final hearing Petitioner called as witnesses, Brian

174Lahey, Douglas G. Winter, Thomas L. Fratz, Gerald Ward, and

184Daniel K. Odell. Petitioner's Exhibits 2,4,7,8, and 12-21 were

196received into evidence. Respondent called as witnesses, F.E.H.

204Schiller, Robert Chamberlain, Thomas J.Schwartz, Charles A.

211Padera, Edwin Hill, Harvey Rudolf, Kevin G. Dickson, Patrick M.

221Rose, Pamela B. Reeder, Thomas L. Fratz, Stacy Meyers, and David

232A. Smith. Respondent's Exhibits 1-58, 64,66,67,69-76,78-80, 84

243and 85, were received into evidence. Respondent's Exhibits 59-61

252were received into evidence for the limited purpose of

261establishing that a law suit had been filed against Respondent

271for injuries sustained on Respondent's property, and not for

280their truth.

282A partial transcript of hearing was filed April 2,1986. The

293parties waived the requirement set forth in Rule 28-5.402,

302F.A.C., that a recommended order be entered within 30 days after

313the transcript is filed.

317Petitioner and Respondent have submitted proposed findings

324of fact and conclusions of law. The parties' proposed findings

334of fact have been addressed in the Appendix to this Recommended

345Order.

346FINDINGS OF FACT

3491. Respondent, South Florida Water Management District

356(District) is a multipurpose water management agency of the State

366of Florida. Its duties include the operation and maintenance of

376a vast network of canals which provide flood control and other

387benefits to Palm Beach County.

3922. Pertinent to this proceeding, the District is the owner

402in fee of a 600' right of way which contains a canal known as C-

41718. The tidewater reach of C-18 extends east from a control

428structure (S-46) near State Road 706 downstream for a distance of

4398,375' (1.6 miles) to the southwest fork of the Loxahatchee

450River. Of this distance, 7,322' lie upstream from a small

461bridge, which crosses the C-18 at Loxahatchee River Drive (the

471bridge) and 1,053' downstream. The canal is approximately 200'

481wide, with 200' of overbank right of way on its north and south

494sides.

495The River Trails Development

4993. Petitioner, River Trails, Ltd (River Trails) is the

508developer of a 28 acre condominium community in Palm Beach County

519known as River Walk. The River Walk development, comprised of

529347 townhouse units, is contiguous to 2,500' of the south

540overbank right of way of the C-18, approximately midway between

550S-46 and the southwest fork of the Loxahatchee River.

5594. On December 9, 1983, River Trails filed an application

569with the District for a right of way occupancy permit to

580selectively clear and regrade the C-18 right of way and to

591construct a marina facility within the right of way consisting of

602a temporary parking area, boat ramp and 3 docking facilities with

613a combined capacity of 97 boats. The District approved River

623Trails' application and issued it a permit on January 12, 1984.

634That permit provided:

637WORK PROPOSED WILL BE COMPLETED ON OR BEFORE

6451-31, 1985, otherwise, this permit is voided

652and all rights thereunder are automatically

658cancelled unless an extension to the

664construction period is applied for and

670granted.

6715. Upon receipt of the District's permit, River Trails

680began to selectively clear the bank of the canal of exotic

691vegetation, primarily Brazilian pepper, and to regrade the bank

700to a more gentle slope than its existing 12'-14' vertical drop on

712the west and 2'-3' vertical drop on the east. In the process, 28 1

726mangrove trees were damaged or destroyed.

7326. To settle a dispute which arose between Palm Beach

742County and River Trails over the destruction of the mangroves,

752River Trails agreed to plant additional mangroves and spartina

761grass along the southeasterly shoreline of the C-18. To

770consummate that agreement, River Trails requested that the

778District modify its permit to allow the selective planting of

788mangroves and spartina grass along the shoreline and in a tidal

799slough, to alter the bank slope to provide a wider intertidal

810zone to accommodate the plantings, and to move the proposed docks

821further out from the bank of the canal. The District granted

832River Trails' requested modification on June 25, 1984 subject to

842the following special conditions:

846- Construction of the boat dock facilities as

854originally permitted and modified hereunder

859is subject to the issuance of a permit from

868the DER. Prior to commencement of

874construction, the applicant shall submit a

880DER permit for the boat docking facilities.

887- Any future modification of the boat docking

895facilities by the applicant must have the

902approval of the governing board prior to

909construction.

910- Rule 40E 6.301(c), Florida Administrative

916Code, requires an applicant to give

922reasonable assurances that the proposed use

928of the works of the district "does not

936degrade the quality of the receiving body and

944meets the standards of the Florida Department

951of Environmental Regulation for the receiving

957body. The board may waive the strict

964enforcement of this provision." Neither

969issuance of the original permit nor this

976modification shall be construed as a waiver

983of this provision as it applies to the per-

992mitting activity of the DER relative to this

1000project.

1001Department of Environmental Regulation Permitting

10067. On December 22, 1983, River Trails applied with the

1016Department of Environmental Regulation (DER) for a permit and

1025water quality certification to construct its boat ramp and 97

1035slip marina. During the processing of that application, River

1044Trails requested two waivers of the 90 day time period prescribed

1055by Sections 120.60(2) and 403.0876, Florida Statutes, (180 days

1064total) in order to conduct a hydrographic survey of the area in

1076order to respond to water quality concerns raised by DER. River

1087Trails did not submit a hydrographic survey to DER, nor did it

1099offer such a survey in this proceeding.

11068. On December 20, 1984, DER advised River Trails that its

1117proposed boat ramp was exempt from permitting requirements.

1125Thereafter, on December 21, 1984, DER issued its "intent to deny"

1136the balance of River Trail's application predicated on its

1145conclusion that the project was expected to have a long and short

1157term adverse impact on the water quality and biological resources

1167of the C-18 canal and the adjacent Outstanding Florida Waters of

1178the Loxahatchee River. Specifically, DER found that degradation

1186of water quality in the project's Class II waters and the

1197adjacent Outstanding Florida Waters would likely occur due to:

1206(1) Shading from docks and walkways that

1213would likely prohibit recolonization of

1218shoreline vegetation.

1220(2) Marinas can be expected to lower water

1228quality by the accumulation of marina source

1235contaminants, including heavy metals,

1239greases, oils, detergent ,and litter.

1244(3) Increased boat traffic (97 boats), and

1251their associated wakes will result in

1257increased shoreline erosion. This additional

1262erosion can prohibit the recolonization of

1268shoreline vegetation beneficial to water

1273quality.

1274(4) The cumulative impact of this project

1281and other similar projects within the C-18

1288canal would be expected to degrade water

1295quality.

1296(5) Prop wash from outboard motor boats in

1304shallow littoral shelf areas will cause

1310turbidity problems and adversely impact

1315existing benthic communities. DER further

1320found the proposed activity contrary to the

1327public interest provisions of Chapter 253,

1333Florida Statutes, since the proposed marina

1339would substantially interfere with the

1344conservation of the Florida Manatee and the

1351destruction of natural marine habitat.

13569. River Trails declined to pursue its DER application for

1366the 97 slip facility any further. Instead, it filed an

1376application with DER for a docking facility of less than 1,000

1388square feet, accommodating 37 boats, to qualify for the exemption

1398provided by Section 403.812(2)(b), Florida Statutes. Following a

1406successful rule challenge in April 1985, River Trails received

1415its statutory exemption. The District's emerging management

1422policy.

142310. Shortly after the District approved River Trail's

1431modification on June 25, 1984, it began to receive a great deal

1443of negative comment from the public, DNR, DER, and the United

1454States Fish and Wildlife Service. These comments, of which the

1464District was not previously aware, included concerns for the

1473Loxahatchee River, the Florida manatee, and negative biological

1481and water quality assessments. Accordingly, the District's

1488Governing Board requested that its staff investigate and evaluate

1497various management options for the overall development of the 18

1507right of way.

151011. During the ensuing months the District's staff

1518solicited input from DER, DNR, the Florida Game and Fresh Water

1529Fish Commission and the United States Fish and Wildlife Service;

1539investigated the C-18; and formulated its recommendations for the

1548future management of the canal. On January 10, 1985, the

1558District's staff submitted its management plan to the Governing

1567Board. The plan recommended that the intertidal zone be widened

1577a minimum of 10 and planted in mangrove and spartina to combat

1589erosion of the canal banks by boat wakes; that the canal banks be

1602regraded to a minimum of one vertical on four horizontal slope

1613and stabilized with a combination of grasses, native trees and

1623shrubs; and that the overbank right of way be cleared of exotic

1635species and replanted with native trees and shrubs. In keeping

1645with the main goal of habitat improvement, staff recommended that

1655the cumulative linear extent of areas provided for bankfishing

1664and viewing be limited to 10 percent of the shoreline and that no

1677structure be located waterward of the mean high water line.

168712. Subsequent to its January 10, 1985, meeting the

1696District has pursued its management plan for the alteration of

1706the shoreline and berms of C-18. Since that time two permits

1717have been issued to large developers who agreed to reslope and

1728revegetate, at their expense, the banks of the C-18 in accordance

1739with the District's plan, and in exchange for the esthetic view

1750accorded by C-18. No dockage, boat ramps, or other structures

1760have been permitted.

1763River Trails' permit expires

176713. Following DER's denial of its application for a permit

1777to construct the 97 slip marina, River Trails requested that the

1788District modify its permit to reflect a 37 slip facility and

1799extend the permit for one year. River Trails subsequently

1808withdrew its request to modify the permit.

181514. On January 10, 1985, the District entered an order

1825denying River Trails' request for a one year extension of its

1836permit. The District's denial was predicated on its perceived

1845environmental sensitivity of the C-18 canal and the Loxahatchee

1854River system, and its conclusion that the project was contrary to

1865the restoration concept of the District's developing management

1873plan for the C-18. River Trails filed a timely request for

1884hearing, and the matter was referred to the Division of

1894Administrative Hearings and assigned Case No. 85-2272.

190115. On July 16, 1985 River Trails reapplied to the District

1912for approval of its modified proposal for a boat ramp and 37 slip

1925marina. The District denied River Trail's request on September

193412, 1985. Reasons for denial included adverse water quality

1943impacts, endangerment of the manatee population, increased bank

1951erosion and increased liability risks to the District associated

1960with increased boat usage of the C-18. River Trails filed a

1971timely request for hearing, and the matter was referred to the

1982Division of Administrative Hearings and assigned Case No. 85-

19913678.

1992Impacts of the River Trails Development

199816. Because of its location and physical characteristics,

2006boating activity in the C-18 has not been extensive. The canal

2017joins the Loxahatchee River on its western shore, opposite the

2027popular boating areas in the intercoastal waterway and Atlantic

2036Ocean adjacent to the River's eastern shore. Access to the canal

2047is restricted by a bridge with a 6' clearance, and its western

2059expanse is blocked by S-46. Accordingly, boating activity within

2068this 1.6 mile stretch of 18 has been generally limited to fishing

2080trips to S-46, sightseeing, and occasional water skiing.

208817. River Trails' facility will increase boating within the

2097C-18 well beyond the 37 slip capacity of its dock facility.

2108River Trails proposes to provide upland storage for the boats of

2119a all condominium unit owners, and expects a majority of owners

2130to utilize the slips or boat ramp. Accordingly, use of the

2141facility will not be limited to 37 boats but, rather, will reach

2153into the hundreds.

215618. The District's management plan for the C-18 is designed

2166to restructure the canal's present configuration to provide

2174natural habitat, reduced erosion and scenic beauty. As

2182originally designed, the C-18 had 1 on 2 side slopes throughout

2193its reach, however, erosion of the bank downstream from S-46 has

2204resulted in nearly vertical, unstable side slopes above mean high

2214water along 40 percent of its length. The overbank right of way

2226is heavily vegetated with exotic species. With the exception of

2236several areas near the downstream end of the canal, mangroves are

2247not well established along the existing shoreline due to the

2257shading effect of overhanging Brazilian pepper and a rather

2266narrow unstable intertidal zone. Currently, little use of the

2275overbank right of way is made by the public due to its dense

2288vegetation, and any view of the canal is severely impeded.

229819. Under the District's management plan the intertidal

2306zone would be expanded and planted in mangroves and spartina to

2317combat erosion from boat wakes and to provide natural habitat;

2327existing vertical banks would be recontoured to a more gentle

2337slope and stabilized with grasses and native trees; and the

2347overbanks would be cleared of exotics so that native trees could

2358prosper. To date the District has been successful in carrying

2368out its plan; however, the survival of the mangrove seedlings and

2379spartina is dependent on minimal disturbance. The introduction

2387of the boats from River Trails would increase erosion and prevent

2398the recolonization of shoreline vegetation beneficial to water

2406quality, marine habitat, and canal bank stabilization.

2413Furthermore, existing and proposed development along the C-18

2421right of way can be reasonably expected to exacerbate the erosion

2432problem if River Trails' permit is granted.

243920. River Trails' proposed marina also raises the specter

2448of adverse impacts to water quality, wildlife and habitat. The

2458C-18 is classified as a Class II surface water body, and supports

2470a diversity of aquatic life. Commonly observed species include

2479snook, mullet, mangrove snapper, pinfish, needlefish and filter

2487feeding organisms such as oysters. The endangered Florida

2495Manatee, Trichechus manatus , is also observed in the C-18 and

2505downstream in the Loxahatchee River.

251021. The Loxahatchee River is classified as outstanding

2518Florida waters (OFW) and critical habitat for the Florida

2527manatee. The river, as well as C-18 up to the S-46 control

2539structure, has also been included by the Department of Natural

2549Resources (DNR) within the Loxahatchee River Zone of the Florida 3

2560Manatee Sanctuary Act.

256322. Due to the restricted access from C-18 into the

2573Loxahatchee River, boats located at River Trails' development

2581will likely be approximately 23' in length and powered by

2591outboard motors. Such watercraft, through their introduction of

2599oils and greases, contribute to a degradation of water quality

2609however, neither party addressed the potential impacts to water

2618quality which would be occasioned by the total number of boats

2629that would utilize the boat ramp and boat slips at the proposed

2641facility. By failing to address this issue, and limiting its

2651proof to the impacts from a maximum of 97 boats, River Trails has

2664failed to give reasonable assurances that its proposed project

2673will not cause or contribute to a violation of Class II water

2685quality standards.

268723. The impact of River Trails' project upon the Florida

2697manatee is less clear than its impact upon the C-18. Although

2708designated part of the manatee sanctuary, C-18 presently offers

2717little in the way of food source for the manatee with the

2729exception of some plant materials near S-46. The grass Fla.

2739within the Loxahatchee River and the intercoastal waterway are

2748the manatee's primary food source and congregating areas;

2756however, as the mangrove and spartina plantings along the

2765intertidal zone of the canal mature, the manatee may more often.

2776venture into the canal. Whatever their frequency within the

2785narrow confines of the C-18, the numbers of boats that would be

2797introduced by River Trails would drive the manatee from the area.

2808These boats would not, however, pose a significant threat to the

2819manatee or its habitat within the Loxahatchee River since its

2829navigation channels are well marked to avoid grass flats.

2838Indeed, there has been no boat related manatee mortality in the

2849Loxahatchee River area since 1977.

285424. The District's concern regarding increased liability

2861risk is unpersuasive. Pursuant to rule the District requires

2870that an applicant for a permit to occupy right of way provide the

2883District with insurance coverage satisfactory to the District,

2891There is no suggestion that the insurance coverage tendered by

2901River Trails, and accepted by the District, was inadequate or

2911otherwise unsatisfactory.

291325. The District's decision to deny River Trail's

2921application was not inconsistent with its existing practice.

2929While the District has permitted docks and boat ramps in other

2940canals, there was no showing that those canals abutted a

2950sanctuary or were under redevelopment to improve the works of the

2961District.

2962CONCLUSIONS OF LAW

296526. The Division of Administrative Hearings has

2972jurisdiction over the parties to, and subject matter of, these

2982proceedings.

298327. River Trails contests the decision of the District to

2993deny it a one year extension of its permit number 7737, to allow

3006the construction of a boat ramp and 97 slip marina in the

3018District's Canal C-18 (Case No. 85-2272), and the District's

3027decision to deny its request to modify permit number 7737 to

3038allow the construction of a boat ramp and 37 slip marina in the

3051District's canal C-IS (Case No. 85-3678). Pertinent to these

3060proceedings are the provisions of Section 373.085, Fla Stat, and

3070Chapter 40E-6, F.A.C.

307328. Section 373.085, Fla. Stat. ,provides:

3079The governing board shall have authority to

3086prescribe the manner in which local works

3093provided by other district or by private

3100persons shall connect with and make use of

3108the works of the district, to issue permits

3116therefor, and to cancel same for

3122noncompliance with the conditions thereof, or

3128for other cause.

313129. Chapter 40E-6, F.A.C., implements a permitting system

3139regulating the use of or connection to, works of the District.

3150That chapter provides:

315340E-6.301 Conditions for Issuance of Permits

3159(1) In order to obtain a permit under this

3168chapter, an applicant must give reasonable

3174assurances that the proposed use of works of

3182the District:

3184(a) will not interfere with the

3190construction, alteration, operation, or

3194maintenance of the District.

3198* * *

3201(c) does not degrade the quality of the

3209receiving body and meets the standards of the

3217Florida Department of Environmental

3221Regulation for the receiving body. . .

3228* * *

3231(2) The following conditions and criteria

3237shall also be met:

3241(2) Unless expressly authorized by the Board

3248no permanent structure shall be constructed

3254within works of the District except bridges

3261over channels, culverts through levees,

3266lateral connections with major channels,

3271public utility lines, mains and cables, and

3278public roads.

3280* * *

328340E-6.331 Modification of Permits.

3287Applications for modification to permitted

3292uses shall be made in the same manner and

3301reviewed using the same criteria as new uses,

3309pursuant to. . . 40E-6. 301.

331530. River Trails has failed to provide reasonable

3323assurances that its proposed project will not interfere with the

3333construction, alteration and operation of works of the District.

3342The District's management program for the C-18, fully explicated

3351in this proceeding, is primarily designed to reduce erosion,

3360improve habitat, and restore the scenic qualities of this

3369waterway. Power boats associated with River Trails' project,

3377apart from the cumulative effect of other projects, will

3386substantially increase wave action along the intertidal zone of.

3395the canal and thereby increase erosion and adversely impact the

3405District's efforts to establish mangroves and other native

3413species. River Trails has further failed to provide reasonable

3422assurances that its proposed use will not degrade the water

3432quality of the C-18, a Class II waterbody.

344031. Apart from the foregoing, River Trails' request for a

3450one year extension of its permit authorizing the construction of

3460a 97 slip facility is moot. River Trails abandoned that proposal

3471and sought only authorization to modify its permit to construct a

348237 slip facility. See: Montgomery v Department of Health and

3492Rehabilitative Services , 468 So. 2d 1014 (Fla. 1st DCA 1985).

3502Based on the foregoing Findings, of Fact, and Conclusions of

3512Law, it is

3515RECOMMENDED that the District enter a Final Order

3523that:

35241. River Trails' application for an extension of permit

3533number 7737 be denied.

35372. River Trails' application for modification of permit

35457737 be denied.

35483. River Trails be authorized, until otherwise directed by

3557the District, to enter upon District property for the sole

3567purpose of maintaining the existing plantings and sodding within

3576the right of way.

3580DONE AND ENTERED this 23rd day of April, 1986 at

3590Tallahassee, Florida.

3592___________________________________

3593WILLIAM J. KENDRICK, Hearing Officer

3598Division of Administrative Hearings

3602The Oakland Building

36052009 Apalachee Parkway

3608Tallahassee, Florida 32399

3611(904) 488-9675

3613Filed with the Clerk of the

3619Division of Administrative Hearings

3623this 23rd day of April, 1986.

3629ENDNOTES

36301/ Seventeen mangrove trees were eliminated, and eleven damaged.

36392/ At hearing, River Trails expressly denied any intent or

3649desire to pursue its 97 slip facility.

36563/ The District asserted that the C-18 was also designated part

3667of the Loxahatchee Aquatic Preserve. The District's assertion

3675was not supported by the record. See: Sections 253.03 and

3685258.40, Florida Statutes.

3688COPIES FURNISHED:

3690Joseph W. Landers, Jr., Esquire;

3695Philip S. Parsons, Esquire

3699Landers, Parsons & Uhlfelder

3703Post Office Box 271

3707Tallahassee, Florida 32302

3710Stanley J. Niego, Esquire

3714South Florida Water Management

3718District

3719Post Office Drawer V

3723West Palm Beach, Florida 33402

3728APPENDIX

3729Petitioner's proposed findings of fact, consisting of 18

3737unnumbered paragraphs, have been numbered 1-13 and addressed by

3746the Recommended Order as follows:

37511. Addressed in paragraphs 2, 3, 4 and 22.

37602. Addressed in paragraph 4, Conclusions of Law.

37683. Addressed in paragraph 25.

37734. Addressed in paragraphs 6 and 10-12.

37805. Addressed in paragraph 14. Petitioner's assertion that

"3788Mr. Fratz acknowledged, however, that River Trails' project

3796was in compliance with the C-18 management plan" is rejected

3806as contrary to the evidence. While River Trails' grading

3815and planting of the right of way is consistent with the

3826District's plan, its overall project" is not consistent.

38346. Addressed in paragraph 15.

38397. Addressed in paragraphs 14 and 15.

38468. Addressed in paragraphs 21 and 25.

38539. Addressed in paragraphs 20-22.

385810. Addressed in paragraphs 20, 21, 23 and 25.

386711. Addressed in paragraph 23.

387212. Addressed in paragraph 23.

387713. Addressed in paragraphs 17, 19, and 23.

388514. Addressed in-paragraphs 22 and 23.

389115. Addressed in paragraph 21.

389616. Addressed in paragraph 24.

390117. Addressed in paragraph 24.

390618. Addressed in paragraph 19.

3911Respondent's proposed findings of fact have been addressed

3919as follows:

39211 & 2. Addressed in paragraph 1.

39283. Addressed in paragraph 2 and 18.

39354 & 5. Addressed in paragraph 21.

39426. Addressed in paragraph 3.

39477. Addressed in paragraphs 4 & 10.

39543 & 9. Addressed in paragraph 4.

396110. Addressed in paragraphs 5 & 6.

396811. Addressed in paragraph 10.

397312. Addressed in paragraphs 7-8.

397813. Addressed in paragraph 9.

398314 & 15. Addressed in paragraphs 10-12.

399016-20. Addressed in paragraphs 10-12,13-14.

399621-22. Addressed in paragraphs 9 & 15.

400323. Addressed in paragraph 12.

400824-26. Addressed in paragraphs 19-19.

401327-34. Addressed in paragraph 23.

401835. Addressed in paragraph 19.

402336. Addressed in paragraph 17.

402837-38. Not relevant.

403139. Addressed in paragraph 20.

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Date
Proceedings
PDF:
Date: 08/27/1986
Proceedings: Agency Final Order
PDF:
Date: 08/27/1986
Proceedings: Recommended Order
PDF:
Date: 04/23/1986
Proceedings: Recommended Order (hearing held , 2013). CASE CLOSED.

Case Information

Judge:
WILLIAM J. KENDRICK
Date Filed:
07/08/1985
Date Assignment:
07/12/1985
Last Docket Entry:
04/23/1986
Location:
West Palm Beach, Florida
District:
Southern
Agency:
ADOPTED IN TOTO
 

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