99-002493 The Pines Of Punta Gorda, Inc. vs. Seltzer Management Group, Inc., And Florida Housing Finance Corporation
 Status: Closed
Recommended Order on Thursday, September 16, 1999.

View Dockets  
Summary: Threshold check of applications for mortgage funds exceeded permissible scope when it included an analysis of construction-period financing, which properly occurs in final underwriting when the developer can provide explanatory information to underwriter.




14INC., )


17Petitioner, )


20vs. ) Case No. 99-2493





33Respondent. )



38Robert E. Meale, Administrative Law Judge of the Division of

48Administrative Hearings, conducted the final hearing in

55Tallahassee, Florida, on September 13, 1999.


62For Petitioner: Robert S. Cohen

67Robert S. Cohen, P.A.

711435 East Piedmont Drive

75Suite 201-B

77Tallahassee, Florida 32312

80For Respondent: Maureen McCarthy Daughton

85Nabors, Giblin & Nickerson, P.A.

90Post Office Box 11008

94Tallahassee, Florida 32302-1008


101The issue is whet her Respondent improperly rejected

109Petitioner's application during the threshold check of

116applications for bond funds in the Multifamily Mortgage Revenue

125Bond Program. The case requires the identification of the

134requirements of a threshold check.


141By Petition for Formal Administrative Proceedings dated

148March 30, 1999, Petitioner requested a recommended order

156determining that, during the threshold check, Respondent

163improperly rejected Petitioner's application to participate in

170the Multifamily Mortgage Revenue Bond Program.

176On June 3, 1999, Respondent transmitted the petition and

185file to the Division of Administrative Hearings and requested

194that an Administrative Law Judge conduct a hearing on the

204relevant issues. By Notice of Hearing dated June 22, 1999, the

215Administrative Law Judge set the final hearing for September 13,


226At the hearing, Petitioner voluntarily dismissed the portion

234of its petition directed against Selzer Management Group, Inc.

243At the hearing, Petitioner called two witnesses. Respondent

251called two witnesses. The parties jointly offered 11 exhibits,

260which were admitted.

263Respondent ordered a transcript. However, after inquiring

270of the parties as to the status of the allocation of mortgage

282funds for 1999, the Administrative Law Judge directed the parties

292to file any proposed recommended orders by noon, September 16,

3021999, even though the court reporter would not have filed the

313transcript by that date.


3201. Respondent is a public corporation generally responsible

328for the administration of the programs previously administered by

337the Florida Housing Finance Agency. Among these programs is the

347Multifamily Mortgage Revenue Bond Program (Program). This case

355involves Petitioner's application for an allocation of mortgage

363funds for 1999.

3662. The Program provides construction and permanent mortgage

374loans to developers of rental housing. Respondent offers

382submarket interest rates if the developers reserve rental units

391for lower-income tenants. As is relevant to this case,

400Respondent funds the loans through the sale of tax-exempt

409mortgage revenue bonds.

4123. The allocation process is competitive because the demand

421for mortgage funds exceeds their supply. The allocation process

430consists of several parts. Respondent's staff first conducts a

439completeness review. Respondent's staff assigns each application

446that passes the completeness review to an independent

454underwriter, which conducts a threshold check. Respondent's

461staff comparatively ranks the applications that pass the

469threshold check, and the staff submits the rankings to

478Respondent's Board of Directors. After finalizing the rankings,

486the Board sends the applications within the funding range to

496final credit underwriting, at which point credit underwriters

504closely examine each application. The underwriters make funding

512recommendations to the Board, which accepts, rejects, or modifies

521the recommendations in making the final funding decisions.

5294. According to the 1999 Developer's Handbook (Handbook,

537which is Joint Exhibit 1), the first event in the closing

548schedule is the real estate closing. Joint Exhibit 1, p. F-3.

559After the real estate closing, Respondent and other parties

568negotiate the bond prices and mortgage interest rates. The final

578event in the closing schedule is the bond closing, at which point

590Respondent delivers the bonds to the bond purchasers in exchange

600for the bond proceeds, which Respondent lends in the form of a

612mortgage loan to the developer.

6175. The Handbook also reprints Chapter 67-21, Florida

625Administrative Code. Rule 67-21.008(12), all references to Rules

633are to the Florida Administrative Code, provides that the

642developer shall, "prior to the requested date for funding,"

651provide Respondent with, among other things, a commitment for

660mortgagee title insurance subject only to the standard exceptions

669and evidence as to the status of liens so as to reflect only

682those liens that Respondent has permitted to remain recorded

691against the mortgaged property.

6956. At the start of the application process, Respondent

704supplied each prospective applicant with the Handbook. The

712Handbook lists numerous evaluation criteria that apply to the

721overall process by which Respondent decides which applications to

730fund. These criteria, of course, include "[e]vidence of economic

739feasibility of the Development and repayment of the loan." Joint

749Exhibit 1, p. B-3. However, this case involves only the

759threshold check, which is clearly both preliminary to, and less

769comprehensive than, final credit underwriting.

7747. In a general discussion of the preliminary reviews that

784precede final credit underwriting, the Handbook warns that the

793completeness review is "quantitative" and the threshold check is

"802qualitative." Joint Exhibit 1, p. E-1. The Handbook adds:

"811Credit Underwriters will be looking at each Application for

820thoroughness and quality of information." Id.

8268. Part H of the Handbook addresses credit underwriting and

836identifies nine factors, such as the value of the security,

846feasibility, costs, and marketability, that are part of the

"855Credit Underwriting review." Although Part H mentions the

863threshold check, the text is not explicit as to whether "Credit

874Underwriting review" is meant to include the threshold check.

8839. A close reading of the penultimate paragraph on page H-1

894of the Handbook suggests that "Credit Underwriting review," as

903used on page H-1, does not include the threshold review. This

914paragraph of the Handbook notes that developers may be required

924to submit additional documentation during final credit

931underwriting. As noted below in the discussion of the rules,

941developers are prohibited from providing additional documentation

948during the threshold check. Given this important distinction

956between these two stages in the credit-underwriting process, the

965final sentence of the penultimate paragraph reveals that "Credit

974Underwriting reviews" are limited to final credit underwriting.

982The sentence states: "The time required for completing Credit

991Underwriting reviews is directly related to the completeness and

1000timing of submission of required items to the Credit

1009Underwriter." The Administrative Law Judge thus determines that

1017the identification of these nine underwriting criteria stated on

1026page H-1 of the Handbook apply only to final credit underwriting.

103710. However, the Handbook clearly addresses the threshold

1045check at pages H-3 and H-4. These pages list 25 items applicable

1057to the threshold check. These items include statements of the

1067experience of the attorney and consultant, preliminary plans and

1076specifications, a preliminary site plan, evidence of site

1084control, a survey, a statement of permitting status, evidence of

1094infrastructure availability and concurrency, and general

1100construction contracts. Among the items with more direct

1108financial impact are "[15 -]year Pro Formas: sources and uses,

1118and income, expense and occupancy projection; a "[c]over letter

1127outlining terms of financing requested"; and a "[s]yndication

1135commitment letter outlining participants and the basic terms of

1144the agreement, if Housing Credits are required during

1152construction phase."

115411. Several of the rules contained in the Handbook apply to

1165the threshold check. Most importantly, Rule 67-21.002(63)

1172defines the "threshold check" as the "required documentation

1180verification and review" by the underwriter before the Board may

1190submit an application to final credit underwriting.

119712. Rule 67-21.003(5) provides that the Board shall rank

1206applications that receive a "satisfactory" threshold check, but

1214the rule fails to specify what is necessary to earn

"1224satisfactory" threshold check. Rule 67-21.003(8) refers to a

"1232favorable" threshold check, but also fails to specify what is

1242necessary to earn a "favorable" threshold check.

124913. Rule 67-21.014 explains the credit underwriting

1256procedures. Rule 67-21.014(1) describes the threshold check, and

1264Rule 67-21.014(2) describes final credit underwriting. Rule 67-

127221.014(1)(b) requires that a prerequisite to final credit

1280underwriting is a "positive recommendation as to compliance with

1289the Threshold Check," but the rule does not specify what is

1300necessary to comply with the threshold check. By contrast, Rule

131067-21.014(2)(b) identifies clearly the overriding criterion of

1317final credit underwriting: "The Credit Underwriter shall review

1325the proposed financing structure to determine whether the Loan is


133614. Rule 67-21.003(1) adopts by reference the application

1344form, which also addresses the threshold review. The front page

1354of the application cautions: "If the necessary backup

1362information is not accurately provided the Credit Underwriter

1370will not unable to process your application during the Threshold

1380Check." The front page of the application adds that applicants

1390may not supplement their applications during the completeness

1398review conducted by Respondent's staff or the threshold check

1407conducted by the underwriters.

141115. Page 13 of the application states:

1418III. Development Financing: Please respond

1423to the requested information below. Attach

1429and label the appropriate exhibits. Failure

1435to respond to the requested information and

1442provide the necessary backup information will

1448result in the determination that the

1454application is incomplete during the Florida

1460Housing's Staff Application Review. If the

1466necessary backup information is not

1471accurately provided the Credit Underwriter

1476will be unable to process your application

1483during the Threshold Check. All information

1489must be clear and directly related to your

1497proposed development. No additional

1501information can be received by Florida

1507Housing and the Credit Underwriter during the

1514Application Review and Threshold Check.

1519A. Financing Cover Letter: Include a

1525letter describing any anticipated sources of

1531financing other than Bonds for the proposed

1538development. This letter must include all

1544information available at the time of

1550application submission (such as interest

1555rates and any terms associated with these

1562sources of financing). The letter must also

1569include how the applicant intends to fund


1577The letter can be found behind Exhibit __.

1585B. Sources and Uses of Funds: Include

1592sources and uses of funds consistent with all

1600intended financing. The Sources and Uses of

1607Funds must be prepared in a format similar to

1616the one found behind this Application.

1622The Sources and Uses of Funds for the

1630proposed development can be found behind

1636Exhibit __.

1638C. Fifteen year income, expense, and

1644occupancy projection: Include a fifteen year

1650income, expense, and occupancy projection

1655consistent with all financing commitments.

1660It must demonstrate that the development

1666meets debt service coverage requirements

1671based on current interest rates. Please use

1678a format similar to the one found behind this


1688The fifteen year income, expense and

1694occupancy projection can be found behind

1700Exhibit __.

170216. The suggested forms for reporting the sources and uses

1712of funds and 15-year income, expense, and occupancy projections

1721are contained in the Handbook. The two forms are detailed. By

1732contrast, the Handbook contains no suggested form for the

1741financing cover letter.

174417. For sources of funds, the suggested form list s

1754Respondent's loan, any tax credit equity, any deferred

1762developer's fee, and any developer cash, as well as "other"

1772sources. For uses of funds, the suggested form lists various

1782acquisition costs, actual construction costs, general development

1789costs, financial costs, and other development costs. The 15-year

1798income, expense, and occupancy projection form is even more

1807detailed, containing over 100 line items.

181318. Petitioner's application contains a financing cover

1820letter, sources and uses of funds, and 15-year income, expense,

1830and occupancy projections.

183319. Petitioner's financing cover letter states in its


1842[Petitioner] (borrower) credit enhancer will

1847be [Respondent's] Guarantee Program.

1851The borrower's anticipated source of funds

1857will be tax-exempt bonds through

1862[Respondent's] Bond insurance prior to


1868The borrower plans to syndicate tax credits

1875as additional sources of funds.

1880The Pines development shall receive a Fair

1887Share Impact Fee contribution from the City

1894of Punta Gorda within the construction time


1902The Pines project "does not" anticipate other

1909sources of financing other than tax exempt

1916bonds, tax credit funds and a fair share

1924impact fee contribution.

1927We appreciate your consideration in this


193420. Petitioner used the suggested form for sources and uses

1944of funds. For sources of funds, Petitioner's completed form

1953shows $12,375,800 from Respondent's loan; $7,400,000 from tax

1965credit equity; $1,299,266 from the deferral of the developer fee;

1977$347,904 from developer cash; and $559,800 from Charlotte County

1988in the form of an impact-fee contribution. For uses of funds,

1999Petitioner's completed form shows a total of $21,982,770.

200921. Petitioner's application also included a letter dated

2017January 19, 1999, from Midland Equity Corporation to Petitioner.

2026The letter constitutes a firm commitment from Midland Equity to

2036purchase the project's tax credits, through the purchase of

2045partnership interests, in three installments of $4,440,000,

2054$1,480,000, and $1,480,000, respectively. The letter describes

2065the due dates of the installments as follows:

2073First Installment: At the later of: (i)

2080admission of the Investment Partnership to

2086the Operating Partnership; or (ii) closing of

2093the construction loan and Project land


2100Second Installment: Within thirty (30) days

2106of the later of: (i) completion of the

2114Project; or (ii) receipt by the Investment

2121Partnership of the cost and credit

2127certification from the independent


2132Third Installment: Within thirty (30) days

2138of the later of: (i) closing of the

2146permanent loan; or (ii) receipt of the Form

21548609; or (iii) 90% physical occupancy for

2161ninety (90) consecutive days; or (iv) 1.10

2168Debt Service Coverage for ninety (90) days.

217522. The commitment letter elaborates:

2180With respect to the Second Installment,

2186completion of the Project shall mean receipt

2193of permanent certificates of occupancy or

2199temporary certificates of occupancy with

2204conditions/requirements for receiving the

2208permanent certificates satisfactory to the

2213Investment Partnership.

221523. Petitioner's application contained a copy of an

2223agreement between Petitioner, as owner, and a general contractor.

2232The contract is for $13,328,435 and calls for the payment of 95

2246percent of the total contract price upon the substantial

2255completion of work. The value of the five percent retainage is

2266thus $666,421. Substantial completion is the date on which the

2277Building Department issues a certificate of occupancy for each


228724. City of Punta Gorda Ordinance 946-89 provides th at a

2298landowner shall pay impact fees. The ordinance authorizes

2306landowners to pay the impact fee not later than the issuance of a

2319certificate of occupancy.

232225. In conducting the threshold check, the underwriter

2330completed a "threshold review checklist." This form states that

2339the "threshold check" is the "review and verification of this

2349information by the Credit Underwriter . . .." The form adds:

"2360The following items must be satisfactorily addressed." In

2368explanation, the form states: "'Satisfactory' means that the

2376Applicant has met the minimum threshold requirements pursuant to

2385the Application but the items will be further reviewed and

2395analyzed during Final Credit Underwriting."

240026. The underwriter noted that Petitioner's application

2407satisfied each of the 25 items required on pages H-3 and H-4 of

2420the Handbook, except for the cover letter outlining the terms of

2431the requested financing. As for this item, the underwriter

2440noted: "The financing cover letter does not explain how the

2450construction period will be funded. Based on the other

2459information in the application, [the underwriter] calculates a

2467$1,375,546 construction period funding gap."

247427. In determining that Petitioner's application contained

2481a construction period financing gap, the underwriter constructed

2489a table entitled "Construction Period Funding Analysis."

249628. For uses of funds, the underwriter inserted $21,982,770

2507for total development costs. The underwriter obtained this

2515figure from the uses and sources of funds that accompanied

2525Petitioner's application.

252729. For "construction sources of funds," the underwriter

2535listed six items totaling $20,607,224, leaving a "construction

2545funding gap" of $1,375,545. The six items were Respondent's loan

2557of $12,375,800; the first installment of $4,440,000 from the

2570syndicator of the tax credits; the deferred developer fee of

2580$1,299,288; developer cash of $347,904; Charlotte County's impact

2591fee contribution of $559,800; and an additional developer fee

2601available for deferral of $1,584,454. As to the failure to

2613include the second installment, the underwriter noted that the

"2622second capital contribution is not paid until both construction

2631and the final cost certification are complete."

263830. This was the first time that Respondent required a

2648threshold check in the Program. Respondent arranged for several

2657underwriters to conduct threshold checks. The underwriter who

2665performed the threshold check of Petitioner's application

2672testified at the hearing. His testimony was credible and

2681established him as a capable credit underwriter with experience

2690in projects of the type proposed in Petitioner's application.

269931. However, the underwriter was limited in his ability to

2709explain the source of the requirements of the threshold check.

2719Rather than rely on the available documentation, he explained

2728that he relied on conversations with Respondent's staff and

2737mostly common sense. As noted below, there is good reason why

2748the underwriter did not rely on documentation of the contents of

2759the threshold check.

276232. The underwr iter did not clearly explain the objective

2772of the threshold review, again understandably. However, he

2780explained in detail his reasoning in determining that

2788Petitioner's application left a construction-period financing gap

2795of $1.375 million. He was not asked how this analysis differs

2806from the construction financing analysis that presumably is part

2815of final credit underwriting, but the available record permits no

2825finding of such a difference.

283033. After examining the record, the Administrative Law

2838Judge is unable to define adequately the scope of review entailed

2849by the threshold review. Clearly, the threshold review requires

2858more than the completeness review, but less than final credit

2868underwriting. Although it is impossible to specify much more

2877about what the threshold review requires, it is possible to find

2888that nothing in this record informed Petitioner that its

2897application would undergo a construction-period financing

2903analysis, of the type performed by the underwriter in this case,

2914during the threshold check, rather than during final credit


292434. The finding that the analysis that resulted in the

2934rejection of Petitioner's application exceeded the scope of the

2943threshold check eliminates the necessity of findings concerning

2951Petitioner's challenge to the conclusions of the underwriter who

2960performed this analysis.

296335. In light of the adverse finding on the scope of the

2975threshold check, Respondent would argue in the alternative that

2984this Recommended Order should proceed to analyze the conclusions

2993of the underwriter in the construction-period financing analysis.

300136. However, the record does not permit a finding that

3011Petitioner's application does or does not provide adequate

3019assurance that Petitioner would be able to deliver a lien-free

3029project at the bond/mortgage closing, as is Petitioner's clear

3038obligation. There are some complicated timing questions in terms

3047of projecting, relative to the bond closing, the receipt of the

3058second installment from the tax-credit syndicator, the payment of

3067all of the impact fees, and the payment of the retainage allowed

3079under the general contractor's contract. The second installment

3087alone would eliminate the gap found by the underwriter, as would

3098the impact fees and retainage together.

310437. The inability to make this finding at this time

3114reinforces the prematurity of the analysis conducted by the

3123underwriter. The process permits the developer to add new or

3133explanatory information during final credit underwriting, but not

3141the threshold check. A process as complicated and important as

3151matching, prior to bond/mortgage closing, sources and uses of

3160funds should be deferred until the stage in the process--i.e.,

3170final credit underwriting--at which the underwriter can obtain

3178additional information from the developer. Given the state of

3187the present record, this process must await final credit

3196underwriting because nothing adequately informed Petitioner that

3203his application would be subjected to construction-period

3210financing analysis during the threshold check.

321638. The 1999 allocation cycle is nearly complete. In

3225August 1999, the Board reviewed the underwriters' funding

3233recommendations and ordered the allocation of $162 million in

3242mortgage funds, which, when added to a $5 million carryover from

32531998, results in a total allocation of $167 million. Respondent

3263has allocated all of this amount, except for about $8 or $9


327639. However, the projects that have already been allocated

3285funds must close by September 30, 1999, or the funds revert to

3297the state pool, from which Respondent may make additional

3306allocations at its November 1999 meeting. If mortgage funds

3315become available due to unclosed deals, the Board will reconsider

3325approximately 10 to 12 applications that were not initially

3334funded, but which passed the threshold check. If Respondent

3343issues a final order consistent with this Recommended Order,

3352Respondent's Board would rank Petitioner's application among

3359these unfunded 10 to 12 applications.

336540. It is unclear whether the 10 to 12 remaining

3375applications have already undergone final credit underwriting.

3382Clearly, Petitioner's application has not yet undergone final

3390credit underwriting. The construction-period financing issues

3396prematurely raised during the threshold check nonetheless require

3404analysis during final credit underwriting. If the other 10 to 12

3415applications have already undergone final credit underwriting,

3422and given the imminent year-end deadline on the 1999 allocation,

3432Respondent should consider allowing Petitioner, at its financial

3440risk, to apply for final credit underwriting, prior to the

3450November 1999 meeting at which Respondent's Board will consider

3459this Recommended Order.


346541. The Division of Administrative Hearings has

3472jurisdiction over the subject matter. Sections 120.57(1) and

3480420.504(2), Florida Statutes. (All references to Sections are to

3489Florida Statutes.)

349142. As the applicant, Petitioner bears the burden of proof.

3501Department of Transportation v. J. W. C. Company, Inc. , 396 So.

35122d 778 (Fla. 1st DCA 1981).

351843. Section 420.58(1) authorizes Respondent to adopt rules

3526for the evaluation and competitive ranking of applications for


353644. Petitioner has proved that Respondent improperly

3543rejected Petitioner's application during the threshold check.

3550Respondent has described the threshold check in several rules,

3559including the application form, and the Handbook, but has not

3569sufficiently described the threshold check so as to allow an

3579underwriter performing a threshold check to conduct a

3587construction-period financing analysis of the type that resulted

3595in the rejection of Petitioner's application during the threshold



3606It is

3608RECOMMENDED that the Florida Housing Finance Corporation

3615enter a final order determining that Petitioner's application has

3624passed the threshold check, directing that Respondent incorporate

3632any additional information obtained by any additional review

3640process undertaken pursuant to the recommendation contained in

3648Paragraph 40 above, and directing that (subject to the outcome of

3659final credit underwriting) Respondent reconsider Petitioner's

3665application among the 10 to 12 remaining applications for any

3675mortgage funds that remain in the Program after the September 30,

36861999, closing deadline passes.

3690DONE AND ENTERED this 16th day of September, 1999, in

3700Tallahassee, Leon County, Florida.



3708Administrative Law Judge

3711Division of Administrative Hearings

3715The DeSoto Building

37181230 Apalachee Parkway

3721Tallahassee, Florida 32399-3060

3724(850) 488-9675 SUNCOM 278-9675

3728Fax Filing (850) 921-6847


3733Filed with the Clerk of the

3739Division of Administrative Hearings

3743this 16th day of September, 1999.


3751Brad Baker, Executive Director

3755Florida Housing Finance Corporation

3759227 North Bronough Street, Suite 5000

3765Tallahassee, Florida 32399-1329

3768Stephen M. Donelan, General Counsel

3773Florida Housing Finance Corporation

3777227 North Bronough Street, Suite 5000

3783Tallahassee, Florida 32399-1329

3786Robert S. Cohen

3789Robert S. Cohen, P.A.

37931435 East Piedmont Drive

3797Suite 201-B

3799Tallahassee, Florida 32312

3802Maureen McCarthy Daughton

3805Nabors, Giblin & Nickerson, P.A.

3810Post Office Box 11008

3814Tallahassee, Florida 32302-1008


3823All parties have the right to submit written exceptions within 15

3834days from the date of this Recommended Order. Any exceptions to

3845this Recommended Order must be filed with the agency that will

3856issue the final order in this case.

Select the PDF icon to view the document.
Date: 11/02/1999
Proceedings: Final Order filed.
Date: 11/01/1999
Proceedings: Agency Final Order
Date: 11/01/1999
Proceedings: Recommended Order
Date: 10/06/1999
Proceedings: Letter to Cari L. Roth from Ann Cole sent out. (RE: transmitting hearing transcript)
Date: 09/27/1999
Proceedings: Notice of Filing; DOAH Court Reporter Final Hearing Transcript filed.
Date: 09/16/1999
Proceedings: Recommended Order sent out. CASE CLOSED. Hearing held 9/13/99.
Date: 09/16/1999
Proceedings: Respondent Florida Housing Finance Corporations Proposed Recommended Order filed.
Date: 09/16/1999
Proceedings: (Petitioner) Proposed Recommended Order (for Judge Signature) filed.
Date: 09/13/1999
Proceedings: CASE STATUS: Hearing Held.
Date: 09/13/1999
Proceedings: (M. Daughton) Notice of Filing; The Deposition of: R. J. Collins ; Deposition of: Eddie Hobby filed.
Date: 09/10/1999
Proceedings: Respondent Florida Housing Finance Corporation`s Notice of Taking Deposition filed.
Date: 09/08/1999
Proceedings: Respondent Florida Housing Finance Corporation`s Amended Notice of Taking Telephonic Deposition filed.
Date: 09/07/1999
Proceedings: Respondent Florida Housing Finance Corporation`s Notice of Taking Telephonic Deposition filed.
Date: 06/22/1999
Proceedings: Notice of Hearing sent out. (hearing set for 9:00am; Tallahassee; 9/13/99)
Date: 06/18/1999
Proceedings: Joint Response to Initial Order filed.
Date: 06/11/1999
Proceedings: (M. Daughton) Notice of Appearance of Counsel for Defendant Florida Housing Finance Corporation (filed via facsimile).
Date: 06/08/1999
Proceedings: Initial Order issued.
Date: 06/03/1999
Proceedings: Agency Referral Letter; Petition for Administrative Proceedings; Supportive Documents filed.

Case Information

Date Filed:
Date Assignment:
Last Docket Entry:
Tallahassee, Florida

Related DOAH Cases(s) (1):

Related Florida Statute(s) (2):

Related Florida Rule(s) (4):