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.


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Summary: Petitioners failed to establish that certain specifications in a solicitation were unreasonable, arbitrary, or capricious.

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.

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Date
Proceedings
PDF:
Date: 03/07/2017
Proceedings: Agency Final Order filed.
PDF:
Date: 02/28/2017
Proceedings: Agency Final Order
PDF:
Date: 02/28/2017
Proceedings: Agency Final Order
PDF:
Date: 02/28/2017
Proceedings: Agency Final Order
PDF:
Date: 01/25/2017
Proceedings: Recommended Order
PDF:
Date: 01/25/2017
Proceedings: Recommended Order. CASE CLOSED.
PDF:
Date: 01/25/2017
Proceedings: Recommended Order cover letter identifying the hearing record referred to the Agency.
PDF:
Date: 12/27/2016
Proceedings: Petitioner's Response to Motion to Strike filed.
PDF:
Date: 12/20/2016
Proceedings: Respondent's Motion to Strike filed.
PDF:
Date: 12/16/2016
Proceedings: Respondent's Proposed Final Order filed.
PDF:
Date: 12/16/2016
Proceedings: Respondent's Proposed Recommended Order filed.
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: 12/16/2016
Proceedings: Joint Stipulation (filed in Case No. 16-006699BID).
PDF:
Date: 11/30/2016
Proceedings: Notice of Taking Deposition of Corporate Represenative of Florida Housing Finance Corporation filed.
PDF:
Date: 11/23/2016
Proceedings: Order Closing File. (Closing DOAH Case No. 16-6168RX.)
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.
PDF:
Date: 11/22/2016
Proceedings: Order Granting Motion for Leave to Intervene.
Date: 11/22/2016
Proceedings: CASE STATUS: Pre-Hearing Conference Held.
PDF:
Date: 11/22/2016
Proceedings: Motion for Leave to Intervene filed.
PDF:
Date: 11/21/2016
Proceedings: Order Granting Motion to Intervene.
PDF:
Date: 11/21/2016
Proceedings: Notice of Appearance/Motion to Intervene (Michael Donaldson/Heritage Oaks, LLLP) filed.
PDF:
Date: 11/21/2016
Proceedings: Notice of Appearance (Michael Donalson) 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: Order of Assignment.
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: 11/16/2016
Proceedings: Motion to Consolidate filed.
PDF:
Date: 11/15/2016
Proceedings: Petition for Administrative Determination of Invalidity of RFA 2016-113 filed.
PDF:
Date: 11/15/2016
Proceedings: Petition for Administrative Determination of Invalidity of RFA 2016-113 filed.
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

Related Florida Statute(s) (6):