13-002154 In Re: Petition To Expand The Village Community Development District No. 10 vs. * Status: Closed Recommended Order on Monday, August 26, 2013.

Summary: Evidence established that petition to amend (expand) boundaries of an existing CDD should be approved, as all statutory criteria satisfied.

STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

IN RE: PETITION TO EXPAND THE

VILLAGE COMMUNITY DEVELOPMENT Case No. 13 - 2154

DISTRICT NO. 10

/

REPORT TO THE FLORID A

LAND AND WATER ADJUD ICATORY COMMISSION

Pursua nt to notice, a local public hearing was held in this

matter in The Villages, Florida, on August 14, 2013, before

D. R. Alexander, an Administrative Law Judge of the Division of

Administrative Hearings (DOAH).

APPEARANCES

For Petitioner: Martha Harrell Ch umbler, Esquire

Carlton Fields, P.A.

Post Office Drawer 190

Tallahassee, Florida 32302 - 0190

STATEMENT OF THE ISSUE

The issue presented in this proceeding is whether the

Amended Petition t o Amend the Boundaries of Village Community

Development District No. 10 (Amended Petition) satisfies the

requirements set forth in chapter 190, Florida Statutes , and

Florida Administrative Code Chapter 42 - 1. The purpose of the

local public hearing was to gather information in anticipation

of quasi - legislative rulemaking by the Florida Land and Water

Adjudicatory Commission (Commission).

PRELIMINARY STATEMENT

On May 29, 2013, the Village Community Development District

No. 10 (District) filed its Petition to Amend the Boundaries of

the District (Initial Petition) with the Commission, requesting

that the Commission adopt a rule expanding the District's

boundaries by 89.5 acres. On June 13, 2013, the Secretary of

the Commission certified that the Initial Pet ition contained all

required elements and referred it to DOAH to conduct a local

public hearing, as required by section 190.005(1)(d).

On July 18, 2013, the District filed a motion for leave to

amend the Initial Petition in order to increase the requested

boundary expansion to 99.3 acres. That motion was granted on

July 22, 2013, and the Amended Petition deemed filed.

Notice of the public hearing was published in accordance

with section 190.005(1)(d ) . The District pre - filed proposed

E xh ibits 1 through 29, which included the written testimony of

seven witnesses: Janet Tutt, Gary Moyer, Darrin Taylor,

Dr. Henry Fishkind, Robert Farner, Stephanie Vaughn, and

Bill Kearns. The District also filed a Request for Official

Recognition of Sumter County Ordina nces 2004 - 38, 2010 - 09, 2012 -

10, and 2012 - 13; Sumter County Resolution 2013 - 27; City of

Wildwood Ordinance 2013 - 28; City of Wildwood Resolution R 2013 -

10; the Commission's certification that the Initial Petition

contained all elements required by section 190 .046(1) (f) ; and

the Notice of Receipt of Amended Petition published by the

Commission in the Florida Administrative Register . 1/

At the local public hearing, the District's pre - filed

e x hibits, which included the pre - filed testimon y , were accepted

into the r ecord, as were two additional e xh ibits, Exhibits 30

and 31. Late - filed Exhibit 32, which corrected a typographical

error in the pre - filed testimony of Janet Tutt, was admitted by

Order dated August 20, 2013. The District supplemented its

previous request for official recognition to include Sumter

County Resolution 2013 - 37 . All requests for official

recognition were granted.

The District presented the live testimony of Janet Tutt,

the executive director of the District; Gary Moyer, a

representative of t he owners of the 99.3 acres and expert in

community development district (CDD) governance; and Dr. Henry

Fishkind, an economist and senior partner of Fishkind and

Associates.

No members of the public offered testimony at hearing or

submitted written commen ts into the record. See Fla. Admin.

Code R. 42 - 1.012(3).

A T ranscript of the hearing has been prepared. T he

District filed a Proposed Report , which has been considered in

the preparation of this Report .

SUMMARY OF THE RECORD

History of the District

1. The District is located in Sumter County and was first

established in 2004 through Sumter County Ordinance 2004 - 38, as

a CDD consisting of 998.8 acres, all of which are located in

unincorporated areas. In the intervening years, the District's

boundaries have been expanded twice: in 2010 with the addition

of 399.01 acres and again in 2012 with the addition of another

91.69 acres, for a total current aggregate of 1,489.5 acres.

These two expansions did not result in a cumulative increase of

land within t he District's boundaries of more than either 50

percent or 500 acres. To date, all of the District's expansions

have been restricted to properties lying within unincorporated

Sumter County.

2. On May 16, 2013, the District's Board of Supervisors

(Distric t Board) authorized the filing of a petition to again

expand the District's boundaries. On August 1, 2013, the

District Board confirmed its authorization of the filing of the

Amended Petition. On May 17, 2013, copies of the Initial

Petition were submitte d to the City of Wildwood and Sumter

County, together with a filing fee to each government entity in

the amount of $15,000.00.

3. By resolution adopted on June 10, 2013, the City of

Wildwood expressed its support for the expansion of the

District's bound aries. By resolution adopted on May 28, 2013,

Sumter County expressed its support for the expansion of the

District's boundaries as reflected in the Initial Petition and,

on August 13, 2013, stated its support for the expansion as

revised in the Amended P etition. 2/

4. The current petition for expansion of the District's

boundaries would increase the land within the District by an

additional 99.5 acres, to an aggregate of 1,589 acres -- an

increase which exceeds the original size of the District by more

th an both 50 percent and a cumulative net amount of 500 acres .

Of the 99.3 acres that would be added to the District, 9.8 acres

lie within unincorporated Sumter County and 89.5 acres within

the City of Wildwood.

5. The 9.8 acres in unincorporated Sumter County are

located approximately one quarter mile east of Morse Boulevard.

The 89.5 acres that are within the City of Wildwood consist of

two parcels, both located south of County Road 44A. Forty - three

and nine/tenths (43.9) acres lie west of Powell Road and

approximately 45 acres lie east of Buena Vista Boulevard.

6. The areas to be added to the District are owned by The

Villages of Lake - Sumter, Inc., and Village of Southwest Plazas,

LLC, both of which consent to the proposed expansion of the

District. The property owners intend to use the land for

residential development, ultimately to include 374 units.

E xh ibits

7. Exhibit 1 is the Amended Petition, with exhibits, as

filed with the Commission and DOAH .

8. Exhibit 2 is a composite exhibit consisting of a copy

of minutes reflecting the District Board's initial authorization

for the Initial Petition to be filed and the District Board's

Resolution 13 - 17, reflecting verification of the District

Board's authorization for the Amended Petition to be filed.

9. Exhibits 3 through 6 are various maps of the District.

E xh ibit 3 identifies the general location of the District.

Exhibit 4 depicts the District's current boundaries. Exhibit 5

adds those areas that are proposed to be added and Exhibit 6

reflects the District's boundaries as they will exist if the

requested rule is adopted.

10. Exhibit 7 is a map identifying the location of

existing stormwater interceptors and outfalls that will serve

the expansion areas.

11. Exhibit 8 is the current resume of Robe rt Farner.

12. Exhibits 9 through 11 are legal descriptions, in metes

and bounds, of the District, with E xh ibit 9 describing the

District's current boundaries, E xh ibit 10 describing the areas

to be added, and Exhibit 11 describing the boundaries as they

w ill exist if the requested rule is approved.

13. Exhibit 12 is a table identifying the estimated cost

of the infrastructure planned for the expansion areas and the

estimated schedule for its construction.

14. Exhibit 13 is the resume of Darrin Taylor.

15. Exhibit 14 is an excerpt of the Future Land Use Map

(FLUM) of the City of Wildwood, including those areas to be

added to the District.

16. Exhibit 15 is an excerpt of the F LUM of Sumter County,

including those areas that currently lie within the Di strict and

those areas to be added.

17. Exhibit 16 is a copy of combined Amended Development

Plans for The Villages of Sumter D evelopment of Regional Impact

(Villages DRI) and Villages of Wildwood DRI .

18. Exhibit 17 is the resume of Gary Moyer.

19. Exhibit 18 is a copy of the executed consent of the

property owners to the expansion of the District.

20. Exhibit 19 is the resume of Dr. Henry Fishkind.

21. Exhibit 20 is the revised Statement of Estimated

Regulatory Costs (Revised SERC).

22. Exhibit 2 1 is a copy of the notice of local public

hearing that was published in T he Villages Daily Sun , a local

newspaper of general circulation .

23. Exhibit 22 is a letter from the Department of Economic

Opportunity (DEO) stating that DEO has no comment on the I nitial

Petition.

24. Exhibits 23 through 29 are the pre - filed testimon y of

Janet Tutt, Stephanie Vaughn, Robert Farner, Darrin Taylor,

Gary Moyer, Williams Kearns, and Dr. Henry Fishkind,

respectively. The pre - filed testimon y of Stephanie Vaughn,

Robert Farner, Darrin Taylor, and Williams Kearns are

accompanied by verified affidavits executed by each of these

witnesses.

25. Exhibit 30 is a letter from DEO, stating that the

agency has no comment on the Amended Petition.

26. Exhibit 31 is the a proof of p ublication provided by

T he Villages Daily Sun , verifying the publication of the notice

of local public hearing on July 17, 24, and 31 , and August 7,

2013 .

27. Exhibit 32 is the affidavit of Janet Tutt, identifying

a typographical error in her pre - filed te stimony,

28. The sole purpose of this proceeding is to establish

the record to be relied upon by the Commission when deciding

whether to adopt a rule expanding the District's boundaries.

Because paragraph 190.005(1)(e) applies in this matter and

contains the statutory criteria to be considered, a summary of

the evidence relating to each is set forth below.

SUMMARY OF EVIDENCE AND TESTIMONY

Factors Set Forth in Section 190.005(1)(e), Florida Statutes

A. Whether all statements contained in the Amended

Petit ion are found to be true and correct.

29. Janet Tutt, manager of the District for the past six

years, testified that she had reviewed the contents of the

Amended Petition and the exhibits and that, to the best of her

knowledge, all are true and correct.

30. Based on this testimony, and in the absence of any

contrary evidence, the evidence establishes that the Amended

Petition and the exhibits attached to it are all true and

correct.

B. Whether the proposed expansion of the District is

inconsistent with any applicable element or portion of the state

comprehensive plan or the effective local government

comprehensive plans.

31. Darrin Taylor is a land use planner who has worked in

the public sector for the former Department of Community

Affairs, for a lo cal government, and in the private sector.

Much of his experience has involved review and analysis of

comprehensive plans and growth management laws.

32. The land use category assigned by the City of Wildwood

FLUM to that portion of the expansion that l ies within the

municipal boundaries is The Villages of Wildwood. The category

permits a mixture of land uses, including residential, retail,

and similar uses.

33. Specific policies were developed for The Villages of

Wildwood that supersede all other pol icies in the City of

Wildwood Comprehensive Plan. No other provisions in the City of

Wildwood Comprehensive Plan apply within that land use category.

Mr. Taylor reviewed The Villages of Wildwood policies and

determined that the CDD expansion is consisten t with the City of

Wildwood Comprehensive Plan.

34. Mr. Taylor also concluded that the proposed expansion

is consistent with the Sumter County Comprehensive Plan. The

most relevant portion of th at p lan with respect to the proposed

expansion is the Futur e Land Use Element (FLUE). The expansion

area in unincorporated Sumter County is designated Mixed Use on

the County's FLUM. The County FLUE provides that a variety of

uses are allowed within the Mixed Use category, including

residential and retail.

35. In addition, since the property in question lies

within The Villages DRI, the County's C omprehensive P lan

requires it to have a separate community plan. Mr. Taylor

reviewed The Villages DRI community plan and determined that the

proposed District expansi on is consistent with that plan. He

also reviewed the other elements in the County's C omprehensive

P lan and determined that the proposed expansion is not

inconsistent with those provisions.

36. Mr. Taylor further stated that the proposed expansion

of the District is not inconsistent with the s tate c omprehensive

p lan. The development within the District, including those

areas proposed to be added, is an integral part of the overall

Villages development. The Villages development furthers many of

the state 's goals in protecting and providing for the elderly,

in planning and developing land in an efficient manner, and in

the protection of our natural resources. The Villages

development also provides transportation alternatives such as

the extensive use of g olf carts and many amenities which keep

the residents healthy. Each of these furthers a general goal

set forth in the s tate c omprehensive p lan.

37. After reviewing both the Initial and the Amended

Petitions, DEO stated that it had no comments relating t o the

proposed District expansion.

38. The testimony and exhibits indicate that the expanded

District will not be inconsistent with any applicable element or

portion of either the local comprehensive plans or the state

comprehensive plan.

C. Whether th e area of land within the expanded District

is of sufficient size, is sufficiently compact, and is

sufficiently contiguous to be developable as one functional

interrelated community.

39. Gary Moyer, a n expert in the governance of CDDs ,

testified that, wi th the proposed expansion, the District will

still be of sufficient size, compactness, and contiguity to be

developed as an interrelated community. That opinion was echoed

by Robert Farner, a professional engineer whose firm has been

involved in creating and financing over 15 CDDs. Both Mr. Moyer

and Mr. Farner explained that the District is part of a

nationally known active adult community -- The Villages -- that

includes over 21,000 acres. The District, as expanded, will

continue to function as part of this already interrelated

community.

40. In addition, Mr. Moyer stated that the property to be

included in the District is similar in character to the other

residential properties in the District.

41. The testimony establishes that the expanded Distr ict

will be of sufficient size, compactness, and contiguity to be

developed as a single functionally interrelated community.

D. Whether expansion of the District is the best

alternative available for delivering community development

services and facilitie s to the area that will be served by the

District.

42. Mr. Moyer further testified that expansion of the

District is the best alternative available for providing CDD

services and facilities to the area. The CDD structure

facilitates a focus on the manag ement of infrastructure that

allows better coordination between the construction of

infrastructure and development. In addition, for this

particular expansion, there are economies of scale to be

realized as a result of the larger base over which to alloca te

costs, especially for certain fixed costs such as management,

insurance, and other administrative costs.

43. Dr. Henry Fishkind, a n expert in economics with

significant experience involving CDDs, testified that the

District provides property owners w ith a governance structure

that is focused on providing services and facilities specific to

the property within its boundaries. Dr. Fishkind also testified

that the District structure affords the ability to issue long -

term bonds to fund infrastructure imp rovements at a cost that is

equal to -- and perhaps lower than -- other available funding

sources.

44. Both Mr. Moyer and Dr. Fishkind indicated that other

alternatives that could have been considered include provision

of services and facilities by the c ounty and municipal

governments, either directly or through a dependent special

district, or by developer - financed infrastructure, with

responsibility for maintenance and operation eventually

transferred to a property owners' association.

45. Under eithe r the direct local government or dependent

special district option, the County would incur the significant

costs of administering the program. The requested expansion

will allow the District, rather than the County, to shoulder

this expense. The expansio n will also free the County from the

possible entanglements associated with debt incurred to finance

construction infrastructure improvements.

46. Expansion of the District is also preferable to

reliance on developers to construct facilities, with long - t erm

operation and maintenance ultimately transferred to a property

owners' association. Unlike fees charged by a property owners'

association, the District's assessments are collected along with

other property taxes, giving greater assurance of obtaining

needed funds. In addition, the District is subject to specific

regulations, including both those specific to CDDs and those

that apply to all government agencies in Florida. A property

owners' association is not.

47. The testimony and exhibits demonstra te that expansion

of the District is the best alternative available for providing

community development services to the area.

E. Whether the community development services and

facilities of the District will be incompatible with the

capacity and uses of e xisting local and regional community

development services and facilities.

48. Both Mr. Moyer and Mr. Farner testified that the

services and facilities that will be provided by the District to

the expansion areas will not be incompatible with the capacity

and uses of existing local and regional community development

services and facilities. There are currently no regional or

local facilities and services serving the expansion areas and

the expansion will not adversely impact the District's capacity

to pro vide services and facilities within its existing

boundaries. Furthermore, the expansion will not result in

overly burdening either existing or planned facilities.

49. The testimony submitted establishes that the community

development services and facili ties of the District will not be

incompatible with the capacity and uses of existing local and

regional community development services and facilities.

F. Whether the area that will be served by the expanded

District is amenable to separate special - distric t government.

50. Ms. Tutt testified that she expects the expansion to

have no adverse impact on the successful operation of the

District.

51. Mr. Moyer testified that the areas to be added to the

District are amenable to a special - district type of gov ernance

and that the expansion will have no adverse impact on the

District's ability to successfully operate under the separate

special - district form of governance. In Mr. Moyer's opinion,

CDD s provide an efficient and focused mechanism for managing and

s upervising the construction of capital improvements in the

expanded areas, as well as managing and operating those

improvements once installed.

52. The testimony submitted establishes that the area to

be added to the District is amenable to a separate sp ecial -

district type of governance.

G. Other Statutory and Regulatory Requirements Elements of

the Petition and Public Notice.

53. The Commission has certified that the Initial Petition

met all of the applicable requirements of section 190.005(1)(a).

54 . Notice of the local public hearing was published in

The Villages Daily Sun for four consecutive weeks prior to the

hearing, on July 17, 24, and 31, and August 7, 2013. In

addition, the Commission published notice of its receipt of the

Initial Petition and Amended Petition in the July 25, 2013,

Florida Administrative Register .

Statement of Estimated Regulatory Costs (SERC)

55. The initial SERC, which accompanied both the Initial

Petition and the Amended Petition, was prepared under the

supervision of D r. Henry Fishkind, a n expert in economic

analysis with significant experience relating to CDDs. Prior to

the hearing, a Revised SERC was prepared, reflecting the small

increase in the size of the expansion sought by the District --

from 89.5 acres to 99.3 -- and the correction of a typographical

error in the original SERC.

56. The Revised SERC includes an analysis of all of the

elements required by section 120.541, including: (a) a good

faith estimate of the costs and any anticipated effect of

revenues o f state and local government; (b ) a good faith

estimate of the transactional costs that individuals and

entities subject to the expanded District boundary are likely to

incur; and (c ) an analysis of any impacts on small businesses

and small cities. 3/ Beca use the current proceeding involves the

expansion of an existing District, the Revised SERC's scope is

limited to the costs and impacts of that expansion.

57. Dr. Fishkind opined that the economic benefits of the

requested expansion to all affected parti es will exceed any

costs incurred. Following formation of the District, the County

and City incur no additional direct costs. To the extent the

Property Appraiser or Tax Collector is utilized to collect

District assessments, the District is required to c over those

costs. Moreover, neither the County nor the City will become

liable for debts incurred by the District and bonds issued by

the District will not affect the bonding capacity of either the

City or the State.

58. Dr. Fishkind also concluded that property values in

the expansion areas will increase by more than the cost of

assessment levied by the District to fund infrastructure

improvements .

59. The testimony and exhibits establish that the Revised

SERC satisfies the requirements of section 120.5 41.

Other Requirements

60. The District provided both the City and the County

with copies of the Initial Petition and, because an additiona l

9.8 acres in the unincorporated area were later added to the

expansion request, the District also provided the Cou nty with a

copy of the Amended Petition. The District also submitted

filing fees of $15,000 .00 each to both local governments. Both

the City and the County adopted resolutions consenting to the

expansion.

61. All of the properties to be added to the Di strict are

owned by either Village of Southwest Plazas, LLC , or Villages of

Lake - Sumter, Inc. Village of Southwest Plazas, LLC, has two

members -- the Villages Operating Company and Acorn Investments.

The Villages of Lake - Sumter, Inc. , and Village of Sou thwest

Plazas, LLC -- through its two members -- both consent to the

requested expansion.

62. Notice of the local public hearing was published in a

newspaper once a week for each of the four weeks immediately

preceding the hearing. The notice included t he time and place

of the hearing, a description and map of the area affected by

the expansion, and a summary of the District's expansion

request. The notice was also posted on the newspaper's website

and on the Florida Press Association's website.

APPLIC ABLE LAW

63. This proceeding is governed by sections 190.00 5 and

190.046 and rule chapter 42 - 1.

64. A petition to expand a CDD that was initially

established by local ordinance must be processed as provided in

section 190.005 if the expansion will increa se the size of the

district by either 50 percent over its initial size, or by a

cumulative net amount of 500 acres. See § 190.046(1)(f), Fla.

Stat. While prior expansions of the District have not exceeded

this limitation, the expansion requested through the Amended

Petition does.

65. A petition for expansion that exceeds the limitation

described above shall "include only the elements set forth in

section 190.005(1)(a)1. and 5. - 8. and the consent required by

paragraph (g)." § 190.046(1)( f ), Fla. Stat.

6 6 . The evidence establishes that the District has

satisfied the requirement of section 190.046(1)(g), which

requires that written consent be obtained from the owners of the

property to be added. The filing of the Initial Petition and

Amended Petition by o r on behalf of the District Board

constitutes the consent of the property owners within the

current District boundaries. See § 190.046(1)(g), Fla. Stat.

The evidence establishes that the District Board authorized the

filing of both the Initial Petition a nd the Amended Petition.

6 7 . The evidence also establishes that the District fully

satisfied the notice requirements imposed by section 190.005(1)

by providing the City with copies of the Initial Petition and

the County with copies of both the Initial Pet ition and Amended

Petition, as well as by publishing notice of the local public

hearing in the manner required by the statute. The District

also submitted the required filing fees to the City and County.

6 8 . The Amended Petition includes the elements req uired by

subparagraphs 1 . and 5 . - 8 . of section 190.005(1)(a).

6 9 . The evidence is that each of the statutory criteria

imposed by section 190.005(1)(e) is satisfied.

70 . The evidence is that the statements contained in the

Amended Petition are true and co rrect. See § 190.005 (1)(e)1 . ,

Fla. Stat.

7 1 . The evidence is that the amendment of the District's

boundaries will not be inconsistent with either the applicable

local comprehensive plans or the state comprehensive plan. See

§ 190.005(1)(e)2 . , Fla. Stat .

7 2 . The evidence is that the District, with the expanded

boundaries, will be of sufficient size, sufficiently compact,

and sufficiently contiguous to be developable as one functional

interrelated community. See § 190.005(1)(e)3 . , Fla. Stat.

7 3 . The ev idence is that the District, as expanded, is the

best alternative available for delivering community development

services and facilities to the areas being added. See

§ 190.005(1)(e)4 . , Fla. Stat.

7 4 . The evidence is that the services and facili ties that

will be provided by the District to the expansion areas are not

incompatible with the capacity or uses of any local or regional

community development services and facilities. See

§ 190.005(1)(e)5 . , Fla. Stat.

7 5 . The evidence is that the Distri ct, as expanded, is

amenable to separate special - district government. See

§ 190.005(1)(e)6 . , Fla. Stat.

CONCLUSION

Section 190.005(1)(e) provides that the " Commission shall

consider the entire record of the local hearing, the transcript

of the hearing, re solutions adopted by local general - purpose

governments . . .," and the factors set forth in section

190.005(1)(e)1 . through 6 . when determining whether to grant or

deny a petition to amend the boundaries of a CDD . Based on the

record evidence, the A mended Petition satisfies all of the

statutory requirements and, therefore, there is no reason not to

grant the District's request for amendment of its boundaries.

DONE AND ENTERED this 26th day of August , 2013 , in

Tallahassee, Leon County, Florida.

S

D. R. ALEXANDER

Administrative Law Judge

Division of Administrative Hearings

The DeSoto Building

1230 Apalachee Parkway

Tallahassee, Florida 32399 - 3060

(850) 488 - 9675

Fax Filing (850) 921 - 6847

www.doah.state.fl.us

Filed with the Clerk of the

Division of Administrative Hearings

this 26th day of August , 2013 .

ENDNOTES

1/ The Florida Administrative Weekly was replaced by the Florida

Administrative Register effective October 1, 2012. See

§ 120.55(1)( b ), Fla. Stat.

2/ The 9.8 a cres added to the expansion area through the Amended

Petition are all located in the unincorporated areas of Sumter

County. Thus, the acreage lying within the City of Wildwood

remained unchanged from that described in the Initial Petition.

3/ Because Su mter County has a population that exceeds 25,000,

it is not categorized as a small county. However, the Revised

SERC reflects the conclusion that the District expansion will

have no adverse affect on either Sumter County or the City of

Wildwood.

COPIES FURNISHED :

Jerry McDaniel, Secretary

Florida Land and Water

Adjudicatory Commission

The Capitol, Room 1802

Tallahassee, Florida 32399 - 0001

Peter Antonacci, General Counsel

Office of the Governor

The Capitol, Suite 209

Tallahassee, Florida 32399 - 1001

Robert N. Sechen, General Counsel

Department of Economic Opportunity

The Caldwell Building, MSC 110

107 East Madison Street

Tallahassee, Florida 32399 - 4128

Barbara R. Leighty, Clerk

Transportation and Economic

Development Policy Unit

The Capitol, Room 1801

Tallahassee, Florida 32399 - 0001

Martha Harrell Chumbler, Esquire

Carlton Fields, P.A.

Post Office Drawer 190

Tallahassee, Florida 32302 - 0190