16-006698RU
American Residential Development, Llc, Madison Highlands, Llc, And Patrick Law vs.
Florida Housing Finance Corporation
Status: Closed
Recommended Order on Wednesday, January 25, 2017.
Recommended Order on Wednesday, January 25, 2017.
1STATE OF FLORIDA
4DIVISION OF ADMINISTRATIVE HEARINGS
8AMERICAN RESIDENTIAL DEVELOPMENT
11LLC; PATRICK LAW; MADISON
15HIGHLANDS, LLC; JONATH A N L.
21WOLF ; BERKSHIRE SQUARE, LTD;
25HAWTHORNE PARK, LTD; AND
29SOUTHWICK COMMONS, LTD,
32Petitioner s,
34vs. Case Nos. 16 - 66 98BID
4116 - 66 99BID
45FLORIDA HOUSING FINANCE
48CORPORATION ,
49Respondent ,
50and
51HERITAGE OAKS, LLLP; AND
55HTG ANDERSON TERRACE, LLC ,
59Intervenor s .
62_______________________________/
63RECOMMENDED ORDER
65This matter came before D. R. Alexander, Administrative Law
74Judge of the Division of Administrative Hearings (DOAH) , after
83the parties waived a final hearing and submitted a stipulate d
94record. The parties are represented as follows .
102APPEARANCES
103For Petitioner s : Craig D. Varn, Esquire
111Manson Bolves Donaldson Varn, P.A.
116Suite 201
118204 South Monroe Street
122Tallahassee, Florida 32301 - 1591
127For Respondent : Christopher Dale McGuire, Esquire
134Florida Housing Finance Corporation
138227 North Bronough Street , Suite 5000
144Tallahassee, Florida 32301 - 13 29
150For Intervenor: Michael P. Donaldson, Esquire
156(Heritage Park) Carlton Fields Jorden Burt, P.A.
163Post Office Box 190
167Tallahassee , Florida 32 3 02 - 0190
174For Intervenor: Maureen McCarth y Daughton, Esquire
181(HTG) Maureen McCarthy Daughton, LLC
186Suite 3 04
1891725 Capital Circle Northeast
193Tallahassee, Florida 32308 - 0595
198STATEMENT OF THE ISSUE
202The issue is wheth e r certain specifications in Request for
213Application s 2016 - 113 (RFA - 113) issued by Respondent, Florida
225Housing Finance Corporation ( Florida Housing), are contrary to
234Florida Housing's governing statutes, rules, or policies in
242violation of section 120. 5 7 (3) ( f) , Florida Statutes (2016) . 1/
256PRELIMINARY STATEMENT
258After Florida Housing published its notice soliciting
265applications pursuant to RFA - 113, o n November 1 5 , 201 6 , American
279Residential Development, LLC (ARD) , Madison Highlands, LLC
286(Madison) , and Patrick L aw (Law) filed with Florida Housing a
297Petition for Administrative Determination of Invalidity of
304RFA - 2016 - 113 (Petition) . On the same date, Jonathan L. Wolf
318(Wolf) , Berkshire Square, Ltd (Berkshire) , Hawthorne Park, Ltd
326(Hawthorne) , and Southwick Common s, Ltd (Southwick) , filed with
335Florida Housing a second Petition challenging the same
343specifications. The Petitions were referred by Florida Housing
351to DOAH with a request that a formal hearing be conducted. They
363were docketed as Case Nos. 16 - 6698 and 16 - 6699, assigned to
377Administrative Law Judge Peterson, consolidated, and then
384transferred to the undersigned. Intervenors Heritage Oaks, LLLP
392( H eritage) , and HTG Anderson Terrace, LLC (HTG) , who intend to
404file applications in response to the RFA - 113 solici tation, were
416authorized to inter vene in support of Florida Housing.
425Because rule challenge s related to RFA - 113 w ere also filed
438by the same Petitioners, a separate final order was entered in
449Case Nos. 16 - 6610RU and 16 - 6611RU. See § 120.57(1)(e) , Fla.
462Sta t., which now authorizes a person challenging agency action
472to file a collateral rule challenge under section 120.56
481regarding the agency's use of an invalid or unadopted rule in a
493section 120.57 proceeding.
496All parties agreed to waive a final hearing and submit a
507stipulated record. The record consists of J oint E xhibits 1
518through 3 : RFA - 113, as modified ; 26 U.S.C. S . § 42 of the
534Internal Revenue Code (IRC); and Florida Housing ' s 2016
544Qualified Allocation Plan (QAP) . Also, Florida Housing offered
553Exhibit 1 , which is the deposition of former Executive Director
563Steve Auger . Although Petitioners do not stipulate to any parts
574of the deposition , a ll exhibits are accepted in evidence .
585Finally, t he parties submitted a Joint S tipulation of certain
596facts .
598P ropos ed recommended orders (P R Os) were filed by
609Petitioners and Florida Housing , and they have been consid ered
619in the preparation of this Recommended Order. Intervenors have
628joined in Florida Housing 's P R O .
637F INDINGS OF FACT
641A. The Parties
6441. Florida Housin g is a public corporation created
653pursuant to section 420.504. One of its responsibilities is to
663award low - income housing tax credits, which developers use to
674finance the construction of affordable housing. Tax credits are
683made available to states annual ly by the United States Treasury
694Department and are then awarded pursuant to a competitive cycle
704that starts with Florida Housing's issuance of a n RFA. This
715proceeding concerns RFA - 113.
7202. Petitioner s ARD and Madison are developer s of
730affordable housin g units and submit applications for tax
739credits. Law and Wolf are principal s of a developer of
750affordable housing units. Berkshire , Hawthorne , and Southwick
757are limited partnerships that have submitt ed applications for
766tax credits . All Petitioners inten d to submit application s in
778response to RFA - 113 .
7843. Intervenors Heritage and HTG are developers of
792affordable housing who intend to file applications pursuant to
801RFA - 113.
804B. Background
8064. On October 28, 2016, Florida Housing published on its
816website pr oposed solicitation RFA - 113 , a 121 - page document
828inviting a pplic ations for the award of up to $14,669,052.00 in
842housing tax credits for the development of affordable ,
850multifamily housing located in Broward, Duval, Hillsborough,
857Orange, Palm Beach, and Pine llas Counties . After Petitioners
867gave notice of their intent to challenge RFA - 113 , Florida
878Housing attempted to resolve the dispute by modifying the
887solicitation on November 13, 2016 . The modification did not
897resolve the dispute.
9005 . On November 1 5 , 2016 , Petitioners timely filed with
911Florida Housing two Petitions, each challenging the same
919specifications in RFA - 113 , as modified .
927C. The RFA Process
9316 . The federal Low - Income Housing Credit Program is
942governed by 26 U.S.C.S. § 42 (section 42) . The prog ram
954allocates f ederal income tax credits to states annually on a per
966capita basis to help facilitate private development of
974affordable low - income housing.
9797 . As the housing credit agency for the State of Florida ,
991Florida Housing has the authority to ad minister various federal
1001and state affordable housing programs, including the Low - Income
1011H ousing C redit P rogram. See § 420.5099(1), Fla. Stat.
10228. Because the demand for housing credits exceeds the
1031amount available, Florida Housing administers the progr am
1039through a competitive process using RFAs. Based upon factors in
1049the RFAs, t he applications are scored and competitively ranked
1059by an evaluation committee to determine which applications will
1068be allocated tax credits.
10729 . Selection and preference crit eria for the low - income
1084housing tax credit programs are found in the 2016 QAP adopted by
1096Florida Administrative Code Rule 67 - 48.002(95). These criteria
1105are intended to provide general , but not specific, guidance for
1115the entire housing credit program, and not just RFA - 113. More
1127specific guidance is found in the individual RFAs, tailored to
1137each type of solicitation.
114110. Florida Housing issues around 15 to 20 RFAs annually.
1151Th e specifications being challenge d in this case are found in
1163RFA - 113. The Peti tions raise two broad areas of concern, which
1176are labeled in Petitioners' PRO as "Exclusion of Eligible
1185Developments from Funding" and "Illegal Delegation to Local
1193Governments . "
1195D . Exclusion of Eligible Developments
12011 1 . A new eligibility provision in RFA - 113 is the Racially
1215and Ethnically Concentrated Areas of Poverty (RECAP). RECAP
1223areas make up less than 3.5 percent of all census tracts in the
1236State and are defined in the RFA as an area where "at least
124940 percent of the population is living below the poverty line
1260and in which a concentration of individuals who identify as
1270other than non - Hispanic White exceeds 50 percent of the
1281population of the census tract." Jt. Ex. 1, p. 2. Florida
1292Housing has placed a link on its website identifying each RECA P
1304area in the State. Petitioners do not contend they were unaware
1315of RECA P areas before RFA - 113 was issued.
132512. The RECAP concept was developed after a series of
1335workshops, public dialogue, and discussions with stakeholders.
1342The purpose of the concept is to allow Florida Housing to
"1353appropriately balance" the location of affordable housing
1360projects. Without the RECAP limitation, described below,
1367Florida Housing is concerned that developers would choose to
1376build low - income housing only in the poorest a reas of a county
1390or areas with the highest concentration of minorities. The
1399RECAP limitation ensures that affordable housing will be
1407available throughout the county. Whether this concept will be a
1417permanent fixture in future RFAs depends on whether RECAP
1426achieves its intended purpose.
143013. RFA - 113 provides that f ive categories of development
1441are eligible for receiving tax credits: new construction,
1449rehabilitation, acquisition and rehabilitation, redevelopment,
1454and acquisition and redevelopment. See § 4A.5.c.(2).
146114. Section 4A.5.c.(1) provides the following limitation
1468on eligibility for tax credit funding for three categories of
1478development located within a RECAP area:
1484With one exception, proposed Developments
1489that select a Development Category of N ew
1497Construction, Rehabilitation, or Acquisition
1501and Rehabilitation at question 5.c.(2) of
1507Exhibit A are not eligible to receive
1514funding under this RFA if any part of the
1523proposed D evelopment is located in a RECAP
1531designated area. The one exception to the
1538above prohibition is for a proposed
1544Development where the Applicant selects and
1550qualifies for Local Government Areas of
1556Opportunity Funding points as outlined in
1562Section Four A.10.(b) of the RFA. Proposed
1569Developments that are located in a RECAP
1576designate d area where the Applicant selects
1583and qualifies for the Development Category
1589of Redevelopment or Acquisition and
1594Redevelopment at question 5.c.(2) of
1599Exhibit A are eligible for funding under
1606this RFA.
16081 5 . Therefore, new construction, rehabilitation, an d
1617acquisition and rehabilitation categories are no t eligible to
1626receive funding if any part of the proposed development is
1636located in a RECAP area. If, h owever, such a development is in
1649a RECAP area and qualifies for Local Government Areas of
1659Opportunity Funding points, the project is eligible for funding.
166816. A Local Government Area of Opportunity is defined in
1678Section Two of the RFA as follows:
1685D e velopments receiving a high level of Local
1694Government interest in the project as
1700demonstrated by an irrevo cable funding
1706contribution that equals or exceeds 2.5
1712times the Total Development Cost Per Unit
1719Base Limitation (exclusive of any add - ons or
1728multipliers), as provided in Item 7 of
1735Exhibit C to the RFA, for the Development
1743Type committed to for the proposed
1749Development.
175017. In plainer terms, in order for an applicant to receive
1761points for a local government contribution, it must demonstrate
1770that the county has contributed a cash loan or grant for the
1782proposed development. See § 4A.10.b. H aving done so, t he
1793applicant is then eligible for funding even if all or part of
1805the proposed development lies within a RECAP area.
181318. Petitioners contend the specifications which limit
1820funding for certain types of projects violate section 42 and are
1831illegal. But they cite no provision in section 42 which
1841requires Florida Housing to conform to every requirement in the
1851IRC in order to allocate housing credit s . And nothing in the
1864IRC prevents local housing agencies from setting eligibility
1872requirements for funding, or r equires that all projects located
1882in low - income areas are automatically eligible for funding.
189219. Petitioners also assert the limitations in the RFA run
1902afoul of chapter 420 . However, Florida Housing has the
1912authority to adopt allocation procedures tha t take into account
1922a number of considerations during the competitive solicitation
1930process. They include "the timeliness of the application, the
1939location of the proposed housing project, the relative need in
1949the area for low - income housing and the availab ility of such
1962housing, the economic feasibility of the project, and the
1971ability of the application to proceed to completion of the
1981project in the calendar year for which the credit is sought."
1992§ 420.5099(2), Fla. Stat. The challenged specifications addr ess
2001these considerations.
200320. In conjunction with their RECAP argument , Petitioners
2011contend the limitations prevent the same th ree categories of
2021development from receiving a 30 percent "boost" in the ir cost
2032basis, which allows them to receive a larger all ocation of tax
2044credits and make s the project more financially feasible . They
2055argue this violates section 42. For the reasons cited above,
2065this contention is rejected. Notably, an application without a
2074boost could be selected for funding , while an applic ation
2084receiving one is not automatically selected for funding.
2092E . Illegal Delegation to Local Governments
20992 1. Petitioners generally contend Florida Housing has
2107unlawfully delegated authority to local governments to select
2115eligible applications. More spe cifically, t hey assert Florida
2124Housing has failed to establish any standards to be used by
2135local government s when providing cash or loans ; the local
2145government essentially pick s the winner , as RFA section 2 limits
2156funding eligibility to only one locally - fu nded developer for
2167each jurisdiction ; and section 4A.6.a.(2) allows a locally -
2176funded developer to receiv e preferential treatment in the award
2186process by waiving two eligibility requirements .
219322. For many years , Florida Housing has considered local
2202gover nment input in the selection process by giving applicants
2212points for local government contributions and requiring forms
2220signed by the local government officials certifying compliance
2228with zoning , site plan, and infrastructure requirements. Thus,
2236r eliance on local government input is not a new concept in the
2249solicitation process .
22522 3 . Florida Housing relies on local governments to
2262evaluate such things as the location of the proposed housing
2272project, the relative need in the a rea for low - income housing,
2285the availability of such housing, the economic feasibility of
2294the project, and the ability of the applicant to proceed to
2305completion of the project. This is because without local input,
2315it would be difficult , if not impossible , for Florida Housing to
2326evaluat e these factors for every applicant for every RFA.
2336Florida Housing also takes into account a local government's
2345revitalization plan in making its funding selection , a
2353requirement in the QAP . See Jt. Ex. 3, p. 1, § I.B.
2366(in allocating credits, t he agency must consider the "project's
2376characteristics including housing as part of a community
2384revitalization plan").
23872 4 . Other than establishing the minimum amount and type of
2399funding by a local government , Florida Housing does not direct
2409local govern ments how to evaluate or select projects to receive
2420local approvals or funding. Attempting to provide specific
2428criteria for local governments would be impractical , as there
2437are hundreds of local jurisdictions in the State, and Florida
2447H ousing believes tha t local governments , and not someone in
2458Tallahassee, can best evaluate local con cerns for revitalizing
2467those communities. Notably, local governments do not have a
2476final say over which projects get funded and which do not , and
2488local funding does not guaran tee an applicant will be awarded
2499tax credits .
2502CONCLUSIONS OF LAW
25052 5 . This case involves a protest to specifications in
2516RFA - 113. Section 120.57(3) (f) provides:
2523Unless otherwise provided by statute, the
2529burden of proof shall rest with the party
2537protesti ng the proposed agency action. In a
2545competitive - procurement protest, other than
2551a rejection of all bids, proposals, or
2558replies, the administrative law judge shall
2564conduct a de novo proceeding to determine
2571whether the agency's proposed action is
2577contrary t o the agency's governing statutes,
2584the agency's rules or policies, or the
2591solicitation specifications. The standard
2595of proof shall be whether the proposed
2602agency action was clearly erroneous,
2607contrary to competition, arbitrary, or
2612capricious.
26132 6 . Petiti oners must demonstrate the factual basis for
2624their challenge by a preponderance of the evidence. Fla. Dep't
2634of Transp. v. J.W.C. Co. , 396 So. 2d 778, 788 (Fla. 1st DCA
26471981); § 120.57(1), Fla. Stat.
26522 7 . Petitioners are substantially affected by the
2661chall enged specifications and have standing to bring this
2670action. Intervenors also have standing to participate.
26772 8 . Petitioners are challenging the specifications in the
2687RFA as opposed to challenging an award of tax credits.
2697Therefore, " a challenge to the [ RFA ] must be directed to
2709specifications that are so vague that applicants cannot
2717formulate an accurate [ application ] , or are so unreasonable that
2728they are either impossible to comply with or too expensive to do
2740so and remain competitive. " Advocacy Ctr. f o r Pers. w ith
2752Disab., Inc. v. Dep't of Child. & Fam. Servs. , 721 So. 2d 753,
2765755 (Fla. 1st DCA 1998). See also Hadi v. Liberty Behavioral
2776Health Corp. , 927 So. 2d 34, 38 (Fla. 1st DCA 2006)(to prevail
2788in a challenge to specifications, a challenger must sho w the
2799agency's decision to include the specifications in the
2807solicitation was arbitrary or capricious).
28122 9 . Petitioners do not claim the challenged specifications
2822are so vague that they cannot formulate an accurate application .
2833Rather, t hey contend the specifications a re unreasonable and
2843arbitrary and capricious. On these issues, t he record shows the
2854RECAP s pecifications were adopted after a thoughtful and
2863deliberative process which included workshops, public dialogue ,
2870and discussions with stakeholders , including presumably
2876Petitioners . Their purpose is to ensure low - income affordable
2887housing is available throughout the local jurisdiction, and not
2896just in limited areas. Similarly, reliance on local government
2905input was shown to be necessary, as the lo cal governments
2916provide essential insight and information on how tax credits can
2926best be used to revitalize th eir communities. The
2935specifications are neither unreasonable nor arbitrary or
2942capricious .
294430 . T hroughout their PRO , Petitioners argue that Flo rida
2955Housing has violated section 42 by excluding certain
2963developments from funding and illegally delegating authority to
2971local governments. But federal law does not govern this
2980proceeding , and there is no evidence that the Department of
2990Housing and Urban Development or the Internal Revenue Service
2999has mandated that Florida Housing comply with section 42, word
3009for word, as a condition precedent to serving as the state's
3020housing credit agency. Absent a statutory requirement that
3028Florida Housing seek pre - ap proval from the federal government or
3040adopt procedures that are identical to federal procedures,
3048allegations concerning a deviation from federal standards cannot
3056be adjudicated in this forum. See, e.g. , Bridges of Am., Inc.
3067v. Dep't of Corr. , Case No. 16 - 5237BID (Fla. DOAH Nov. 23, 2016 ;
3081Fla. DOC Dec. 15, 2016).
30863 1 . Finally, nothing in chapter 420 prevents Florida
3096Housing from set ting eligibility requirements for funding ,
3104excluding certain categories of projects from eligibility , or
3112receiving local gove rnment input in the manner that it does .
312432. In summary, Petitioners have failed to prove t he
3134specifications are contrary to Florida Housing's governing
3141statutes, rules, or policies or that they are unreasonable,
3150arbitrary, or capricious . § 120.57(3)(f ), Fla. Stat.
3159RECOMMENDATION
3160Based on the foregoing Findings of Fact and Conclusions of
3170Law, it is
3173RECOMMENDED that Florida Housing Finance Corporation enter
3180a final order d i smissing the Petitions.
3188DONE AND ENTERED this 25th day of January, 2017, in
3198T alla hassee, Leon County, Florida.
3204S
3205D . R. ALEXANDER
3209Administrative Law Judge
3212Division of Administrative Hearings
3216The DeSoto Building
32191230 Apalachee Parkway
3222Tallahassee, Florida 32399 - 3060
3227(850) 488 - 9675
3231Fax Filing (850) 921 - 6847
3237www.doah.state.fl.us
3238Fi led with the Clerk of the
3245Division of Administrative Hearings
3249this 25th day of January, 2017.
3255ENDNOTE
32561/ As a basis for relief, t he Petitions allege RFA - 113 exceeds
3270the agency's grant of legislative authority ; enl arges, modifies,
3279or contravenes the spe cific provisions of law implemented ; and
3289contains "non - rule policies that are arbitrary and capricious."
3299Petitions, pp . 17 and 18 . None implicate section 120.57(3) (f) .
3312In t he parties' Joint Stipulation , however, the issue is broadly
3323redefined as "[w]het her the terms, conditions and specifications
3332of RFA 2016 - 113 are invalid pursuant to Section 120.57(3), F.S."
3344Jt. Stip., ¶ H.4.
3348COPIES FURNISHED:
3350Kate Flemming, Corporation Clerk
3354Florida Housing Finance Corporation
3358227 North Bronough Street, Suite 5000
3364Tallahassee, Florida 32301 - 1329
3369(eServed)
3370Craig D. Varn, Esquire
3374Manson Bolves Donaldson Varn, P.A.
3379204 South Monroe Street, Suite 201
3385Tallahassee, Florida 32301 - 1591
3390(eServed)
3391Michael P. Donaldson, Esquire
3395Carlton Fields Jorden Burt, P.A.
3400Post Of fice Box 190
3405Tallahassee, Florida 32302 - 0190
3410(eServed)
3411Ch r istopher Dale M cGuire, Esquire
3418Florida Housing Finance Corporation
3422227 North Bronough Street , Suite 5000
3428Tallahassee, Florida 323 01 - 13 29
3435(eServed)
3436Douglas P. M anson, Esquire
3441Manson Bolves Donald son Varn, P.A.
34471101 Swann Avenue
3450Tampa, Florida 33606 - 2637
3455(eServed)
3456Maureen M. Daughton, Esquire
3460Maureen McCarthy Daughton, LLC
34641725 Capital Circle Northeast, Suite 304
3470Tallahassee, Florida 32308 - 0595
3475(eServed)
3476Hugh R. Brown, General Counsel
3481Florida Housing Finance Corporation
3485227 North Bronough Street, Suite 5000
3491Tallahassee, Florida 32301 - 13 29
3497(eServed)
3498NOTICE OF RIGHT TO SUBMIT E XCEPTIONS
3505A ll parties have the right to submit written exceptions within
351610 days from the date of this Recommended O rder. Any exceptions
3528to this Recommended Order should be filed with the agency that
3539will issue the Final Order in this case.
- Date
- Proceedings
- PDF:
- Date: 01/25/2017
- Proceedings: Recommended Order cover letter identifying the hearing record referred to the Agency.
- PDF:
- Date: 12/16/2016
- Proceedings: Petitioners' Proposed Final Order (filed in Case No. 16-006699BID).
- PDF:
- Date: 12/16/2016
- Proceedings: Petitioners' Proposed Recommended Order (filed in Case No. 16-006699BID).
- PDF:
- Date: 12/16/2016
- Proceedings: Heritage Oaks, LLLP's Notice of Joinder in the Proposed Recommended Order and Final Order of Florida Housing filed.
- PDF:
- Date: 12/16/2016
- Proceedings: Intervenor, HTG Anderson Terrace, LLC's Notice of Joinder in Respondent's Proposed Recommended Order filed.
- PDF:
- Date: 11/30/2016
- Proceedings: Notice of Taking Deposition of Corporate Represenative of Florida Housing Finance Corporation filed.
- PDF:
- Date: 11/22/2016
- Proceedings: Notice of Voluntary Dismissal of Consolidated Petition for Administrative Determination of Invalidity of RFA 2016-110 and Rules 67-48.002(95) and 67-60.010, Florida Administrative Code filed.
- Date: 11/22/2016
- Proceedings: CASE STATUS: Pre-Hearing Conference Held.
- PDF:
- Date: 11/21/2016
- Proceedings: Notice of Appearance/Motion to Intervene (Michael Donaldson/Heritage Oaks, LLLP) filed.
- PDF:
- Date: 11/21/2016
- Proceedings: Order Granting Motion to Consolidate (DOAH Case Nos. 16-6168RX, 16-6610RU, 16-6611RU, 16-6698RU, and 16-6699RU). Hearing will start at 9:30.
- PDF:
- Date: 11/17/2016
- Proceedings: Rule Challenge transmittal letter to Ernest Reddick from Claudia Llado copying Ken Plante and the Agency General Counsel.
- PDF:
- Date: 11/15/2016
- Proceedings: Petition for Administrative Determination of Invalidity of RFA 2016-113 filed.
Case Information
- Judge:
- D. R. ALEXANDER
- Date Filed:
- 11/15/2016
- Date Assignment:
- 11/21/2016
- Last Docket Entry:
- 03/07/2017
- Location:
- Tallahassee, Florida
- District:
- Northern
- Agency:
- Other
- Suffix:
- RU
Counsels
-
Hugh R. Brown, General Counsel
Florida Housing Finance Corporation
Suite 5000
227 North Bronough Street
Tallahassee, FL 32301
(850) 488-4197 -
Craig D. Varn, Esquire
Manson Bolves Donaldson Varn, P.A.
Suite 201
204 South Monroe Street
Tallahassee, FL 32301
(850) 583-0007 -
Hugh R. Brown, General Counsel
Address of Record -
Craig D. Varn, Esquire
Address of Record -
Hugh R Brown, General Counsel
Address of Record -
Craig D Varn, Esquire
Address of Record