18-002891PL Department Of Health, Bureau Of Emergency Medical Oversight vs. William J. Litsch, Pmd Status: Closed Recommended Order on Wednesday, September 12, 2018.

Summary: Respondent failed to pay his student loans and, by statute, his license must be, at a minimum, suspended until payment terms are agreed upon.

STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

DEPARTMENT OF HEALTH, BUREAU OF

EMERGENCY MEDICAL OVERSIGHT ,

Petitioner,

vs. Case No. 18 - 2891 PL

WILLIAM J. LITSCH , PMD ,

Respondent.

_______________________________/

RECOMMENDED ORDER

This case was heard on July 31 , 2018 , by video

teleconference at sites in Tallahassee and Daytona Beach ,

Florida, before E. Gary Early, an Administrative Law Judge

assigned by the Division of Administrative Hearings (DOAH) .

APPEARANCES

For Petition er: Rose L. Garrison , Esquire

John A. Wilson , Esquire

Eric L. Fryson, Esquire

Department of Health

Prosecution Services Unit

4052 Bald Cypress Way, Bin C - 65

Tallahassee, Florida 32399

For Respondent: William Litsch , pro se

763 Tumblebrook Drive

Port Orange , Florida 32 127

STATEMENT OF THE ISSUE S

The issue s to be determined are whether Respondent violated

section 456.072(1)(k) , Florida Statutes, by failing to repay a

student loan issued or guaranteed by the state or the Federal

g overnment i n accordance with the terms of the loan as alleged

in the Administrative Complaint ; and, if so, the appropriate

penalty.

PRELIMINARY STATEMENT

On December 13, 2017 , Petitioner, Department of Health

(Department or Petitioner), issued an Administrative Compl aint

against Respondent, William J. Litsch (Respondent), who is

certified as a paramedic by the Department, certificate number

PMD16223 . The complaint charged that Respondent Ðfailed to

perform a statutory or legal obligation when he defaulted on a

studen t loan provided by the state or federal government on or

about June 16, 2017 Ñ in violation of section 456.072(1)(k) .

On or about January 3, 2018 , Respondent timely filed an

Election of Rights , dated December 22, 2017, disputing that he

received a studen t loan from the state or Federal government.

The matter was initially referred to DOAH on February 5,

2018 , assigned to Judge R. Bruce McKibben as DOAH Case

No. 18 - 0607PL, and was set for hearing to commence on April 12,

2018, by video teleconference in Tallahassee and Daytona Beach,

Florida. Based on a series of motions, O rders, and responses

thereto , and on RespondentÓs expressed desire to surrender his

certification, Judge McKibben determined that Ð [n]o further

findings of fact are required in order f or Petitioner to take

action concerning the certification , and relinquished

jurisdiction to the Department for disposition.

On May 23, 2018, the Department determined that disputed

issues of material fact remained , and remanded the matter back to

DOAH. T he Order of Referral was received at DOAH on June 6,

2018. The matter was initially assigned to Judge J. Lawrence

Johns t on , senior Judge for DOAHÓs Middle District. Upon

determining that the case, with Respondent residing in Volusia

County, was within th e territorial bounds of DOAHÓs Northern

District, it was again a ssigned to Judge Mc Kibben as DOAH

Case No. 18 - 2891PL.

On J une 15, 2018 , the matter was set for hearing, to

commence on July 31, 2018. On that same date, Respondent,

through counsel, move d to recuse Judge McKibben. Counsel for

Respondent then moved to withdraw from representation of

Respondent. Judge McKibben granted the motion to withdraw on

June 19, 2018.

On June 22, 2018, Judge McKibben, despite correctly

determining that the Motion to Disqualify Administrative Law

Judge was legally insufficient , nonetheless granted the motion,

whereupon this case was transferred to the undersigned.

A series of motions and notices were filed by each of the

parties leading up to the date of the final hearing , and e ach was

disposed of by written O rder . Their disposition may be

determined by reference to the docket. Among the O rders entered

was an Order on RespondentÓs Failure to Appear at Deposition

which, as a sanction for failing to appear at a depo sition

ordered by the undersigned and properly noticed by Petitioner,

and pursuant to Florida Rule of Civil Procedure 1.380(b)(2), as

adopted in Florida Administrative Code Rule 28 - 106.206 ,

prohibited Respondent from introducing testimonial or documentary

evidence at the final hearing .

The hearing was convened on July 31, 2018, as scheduled. At

hearing, the Department called Lou Ann Standley, the Senior

Educational Program Policy Development Director for the Florida

Department of Education as its witness; and offered Department

Exhibits 1 through 7 , which were received in evidence. The

exhibits consist largely of financial and educational records

maintained by the Florida Department of Education and several

institutions now considered to be in the Florida College System .

The records were, with the exception of those from Valencia

College, accompanied by certifications attesting to their status

as business or public records. The certificates were found to

meet the standards for self - authentication pursuan t to section

90.902, Florida Statutes. The Department offered no witness

testimony.

The one - volume final hearing Transcript was filed on

August 22 , 2018. The Department timely filed a Proposed

Recommended Order that was considered in preparation of th is

Recommended Order. Respondent did not file a post - hearing

submittal.

The Department purchased RespondentÓs student loan

obligations from the lender upon default on November 10, 2016, at

which time the actions alleged in the Administrative Complaint

became fixed. This proceeding is governed by the law in effect

at the time of the commission of the acts alleged to warrant

discipline. See McCloskey v. DepÓt of Fin. Servs. , 115 So. 3d

441 (Fla. 5th DCA 2013). Thus, references to statutes and rules

are to the versions in effect on that date, unless otherwise

noted.

FINDING S OF FACT

1. The Department of Health, B ureau of Emergency Medical

Oversight , is the state agency charged with the investigation and

prosecution of complaints against license d parame dics pursuant to

chapters 456 and 401 , Florida Statutes .

2. At all times material to this proceeding, Respondent was

a paramedic in the state of Florida, holding certificate number

PMD 16223 . RespondentÓs license is currently active and does not

expire until December 1, 2018.

3. RespondentÓs current address of record is

763 Tumblebrook Drive, Port Orange, Florida 32127.

4. The Florida Department of Education (DOE) is the state

agency responsible for guaranteeing student loans in cooperation

with the United States Department of Education under the Federal

Family Education Loan Program.

5. As the guarantor of a student loan, DOE is bound to

purchase the debt of a borrower who fails to satisfy their loan

obligations.

6. On July 7, 1993, Respondent ex ecuted an

Ð Application/Promi s sory Note for a Florida Stafford Loan Ñ with a

requested loan amount of $3,500.00. The stated purpose of the

loan was Ðfor [RespondentÓs] attendance at Daytona Beach

Community College [DBCC] for the term(s) that begins on 8/93 and

ends on 4/94. Ñ The lender was Chase Manhattan Bank, Lender Code

807807. The loan proceeds were, as is normal for student loans,

paid directly to DBCC on RespondentÓs behalf for his tuition,

fees, and educational expenses.

7. On January 7, 1994, Res pondent executed an Ð Application

and Promissory Note for Federal Stafford Loan s Ñ for a s ubsidized

Federal Stafford Loan, with a requested loan amount of $ 1,750.00 ,

with a loan period of January 1994 to May 19 94. Pursuant to the

Borrower Certification and School Certification, the loan

proceeds were for RespondentÓs attendance at DBCC. The lender

was Ð Chase ,Ñ Lender Code 807807. The loan proceeds were, as is

normal for student loans, paid directly to DBCC on RespondentÓs

behalf for his tuition, fees, and educational expenses .

8. On June 1, 1994, Respondent executed an ÐApplication and

Promissory Note for Federal Stafford LoansÑ for a subsidized

Federal Stafford Loan, with a requested loan amount of $ 3,500 .00,

with a loan period of August 1994 to May 19 9 5 . Pursuant to the

Borrower Certification and School Certification, the loan

proceeds were for RespondentÓs attendance at DBCC. Respondent

requested a deferment of repayment for applicable in - school and

grace periods. The lender was Chase Manhattan Bank, Lender Code

807807. The loan proceeds were, as is normal for student loans,

paid directly to DBCC on RespondentÓs behalf for his tuition,

fees, and educational expenses .

9. On May 30, 1995, Respondent executed an ÐApplication and

Promissory Note for Fe deral Stafford LoansÑ for a subsidized

Federal Stafford Loan, with a requested loan amount of $3, 500.00,

with a loan period of August 19 9 5 to Ðend of deferment.Ñ T he

loan proceeds were for RespondentÓs attendance at DBCC.

Respondent requested a deferment of repayment for applicable in -

school and grace periods. The lender was Chase Manhattan Bank,

Lender Code 807807. The loan proceeds were, as is normal for

student loans, paid directly to DBCC on RespondentÓs behalf for

his tuition, fees, and educational expenses .

10. On August 19, 1996, Respondent executed an ÐApplication

and Promissory Note for Federal Stafford LoansÑ for a subsidized

Federal Stafford Loan, with a requested loan amount of $3, 500.00,

with a loan period of August 19 9 6 to May 19 97. The loan proceeds

were for RespondentÓs attendance at Valencia Community College on

RespondentÓs behalf for his tuition, fees, and educational

expenses . Respondent requested a deferment of repayment for

applicable in - school and grace periods. The lender was Chase

Manhattan Bank, Lender Code 807807. The loan proceeds were, as

is normal for student loans, paid directly to Valencia Community

College .

11. On August 22 , 199 7 , Respondent executed an ÐApplication

and Promissory Note for Federal Stafford LoansÑ f or a subsidized

Federal Stafford Loan, with a requested loan amount of $3, 500.00,

with a loan period of August 19 9 7 to May 19 9 8 . The loan proceeds

were for RespondentÓs attendance at DBCC . Respondent requested a

deferment of repayment for applicable in - s chool and grace

periods. The lender was Chase Manhattan Bank, Lender Code

807807. The loan proceeds were, as is normal for student loans,

paid directly to DBCC on RespondentÓs behalf for his tuition,

fees, and educational expenses .

12. Between August 2 2, 1997 , and June 14, 2005, the

evidence demonstrates that Respondent made no payments on any of

the above - referenced loans.

1 3 . On June 14, 2005, Respondent filed an on - line Federal

Consolidation Loan Application and Promi s sory Note by which

Respondent c onsolidat ed his outstanding student loans. By the

time the loans were being consolidated, they were held by the

Sallie Mae Trust. RespondentÓs total loan amount after

consolidation was $17,500.00. Pursuant to the Loan Consolidation

Disclosure Statement and Repayment Schedule, the first of

180 monthly payments of $128. 75 1/ on the consolidated student

loans was scheduled for August 21, 2005.

14. DOE was the guarantor of all of RespondentÓs student

loans, including the consolidated student loan.

15. The Federal Family Education Loan Program Claim Form

demonstrates that Respondent received a deferment of payment for

59 months, followed by forbearance from payment of 63 months - - a

total of 10 years and two months. As a result, RespondentÓs

payment due da te was extended to October 21, 2015.

16. In the more than 25 years since Respondent made

application for his first student loan, he has yet to repay a ny

of the loan proceeds paid to DBCC and Valencia Community College

on his behalf for tuition, fees, and educational expenses .

17. A n educational loan default occurs when a borrower

fails to make required payments on a loan for 270 days. On

November 3, 2016, having received no payments from Respondent on

his loan since payments became due on October 21, 201 5, the

lender submitted a default claim to DOE.

18 . On November 10, 2016, DOE determined Respondent

defaulted on his student loan obligations and purchased

RespondentÓs debt from the lender . At the time of the default,

RespondentÓs full $17,500.00 prin cipal balance remained, as well

as $3,794.90 of capitalized interest and $995.71 of unpaid

interest.

19. Respondent has made no payments against his student

loan obligations since DOE purchased his student loan obligations

on November 10, 2016.

CONCL USIONS OF LAW

A. Jurisdiction

20 . The Division of Administrative Hearings has

jurisdiction over the parties and the subject matter of this

proceeding. §§ 456.073(5), 120.569, and 120.57(1), Fla. Stat.

(201 8 ).

21 . The Department has authority to inve stigate and file

administrative complaints charging violations of the laws

governing paramedics . § 456.073, Fla. Stat. (2018 ).

B. Standards

22 . Section 4 56.072(1) (k) provides , as grounds for which

the Department m ay impose disciplinary sanctions, that:

The following acts shall constitute grounds

for which the disciplinary actions specified

in subsection (2) may be taken:

* * *

( k ) Failing to perform any statutory or

legal obligation placed upon a licensee.

For purposes of this section, failing to

rep ay a student loan issued or guaranteed by

the state or the Federal Government in

accordance with the terms of the loan or

failing to comply with service scholarship

obligations shall be considered a failure to

perform a statutory or legal obligation, and

t he minimum disciplinary action imposed

shall be a suspension of the license until

new payment terms are agreed upon or the

scholarship obligation is resumed, followed

by probation for the duration of the student

loan or remaining scholarship obligation

per iod, and a fine equal to 10 percent of

the defaulted loan amount. Fines collected

shall be deposited into the Medical Quality

Assurance Trust Fund.

C. Burden and Standard of Proof

23 . The Department bears the burden of proving the

specific allegations that support the charges alleged in the

Administrative Complaint by clear and convincing evidence.

DepÓt of Banking & Fin., Div. of Sec. & Inv. Prot. v. Osborne

Stern & Co. , 670 So. 2d 932 (Fla. 1996); Ferris v. Turlington ,

510 So. 2d 292 (Fla. 1987); Fo x v. Dep't of Health , 994 So. 2d

416 (Fla. 1st DCA 2008); Pou v. DepÓt of Ins. & Treasurer ,

707 So. 2d 941 (Fla. 3d DCA 1998).

24 . Clear and convincing evidence Ðrequires more proof

than a Òpreponderance of the evidenceÓ but less than Òbeyond and

to the exclusion of a reasonable doubt.ÓÑ In re Graziano ,

696 So. 2d 744, 753 (Fla. 1997). The clear and convincing

evidence level of proof:

[E]ntails both a qualitative and

quantitative standard. The evidence must be

credible; the memories of the witnesses m ust

be clear and without confusion; and the sum

total of the evidence must be of sufficient

weight to convince the trier of fact without

hesitancy.

Clear and convincing evidence

requires that the evidence must be

found to be credible; the facts to

which t he witnesses testify must be

distinctly remembered; the testimony

must be precise and explicit and the

witnesses must be lacking in

confusion as to the facts in issue.

The evidence must be of such weight

that it produces in the mind of the

trier of fact a firm belief or

conviction, without hesitancy, as to

the truth of the allegations sought

to be established.

In re Davey , 645 So. 2d 398, 404 (Fla. 1994) (quoting, with

approval, Slomowitz v. Walker , 429 So. 2d 797, 800 (Fla. 4th DCA

1983)); see also In re Henson , 913 So. 2d 579, 590 (Fla. 2005).

"Although this standard of proof may be met where the evidence

is in conflict, it seems to preclude evidence that is

ambiguous." Westinghouse Elec . Corp. v. Shuler Bros. , 590 So.

2d 986, 989 (Fla. 1st DCA 1991).

25 . A proceeding to suspend, revoke, or impose other

discipline upon a license is penal in nature. State ex rel.

Vining v. Fla. Real Estate Comm'n , 281 So. 2d 487, 491

(Fla. 1973). Penal statutes must be construed in terms of their

literal meaning , and words used by the Legislature may not be

expanded to broaden the application of such statutes. Thus, the

provisions of law upon which this disciplinary action has been

brought must be strictly construed, with any ambiguity construed

against Petitioner. Elmariah v. DepÓt of Bus. & ProfÓl Reg. ,

574 So. 2d 164, 165 (Fla. 1st DCA 1990); see also Griffis v.

Fish & Wildlife Conserv. Comm'n , 57 So. 3d 929, 931 (Fla. 1st

DCA 2011); Beckett v. DepÓt of Fin. Servs. , 982 So. 2d 94, 100

(Fla. 1 st DCA 2008); Whitaker v. DepÓt of Ins. , 680 So. 2d 528,

531 (Fla. 1st DCA 1996); Dyer v. DepÓt of Ins. & Treasurer ,

585 So. 2d 1009, 1013 (Fla. 1st DCA 1991).

26 . The allegations of fact set forth in the

A dministrative Complaint ar e the grounds upon which this

proceeding is predicated. Trevisani v. DepÓt of Health , 908 So.

2d 1108, 1109 (Fla. 1st DCA 2005); see also Cottrill v. DepÓt of

Ins. , 685 So. 2d 1371, 1372 (Fla. 1st DCA 1996). Thus, the

scope of this proceeding is properly restricted to those matters

as framed by Petitioner. M.H. v. DepÓt of Child. & Fam. Servs. ,

977 So. 2d 755, 763 (Fla. 2d DCA 2008).

D . Evidence

27 . As is to be expected, the evidence in this case

consists almost exclusively of documentary evidence of the

loans . Other than Respondent, who exercised his right to refuse

to testify, it is inconceivable that there would be an

individual with a specific recollection of loans taken out or

consolidated between 1993 and 2005 for the huge Stafford

guaranteed lo an program.

28 . Section 120.5 69 (1) (g) , Florida Statutes, provides that

Ð evidence of a type commonly relied upon by reasonably prudent

persons in the conduct of their affairs shall be admissible,

whether or not such evidence would be admissible in a trial in

the courts of Florida. Ñ The evidence in this case, consisting

primarily of properly authenticated business records of the DOE

used in the administration of the Stafford loan program , and

records o f DBCC and Valencia Community College regarding

Respond entÓs attendance and loan history with each of those

institutions, is evidence that reasonably prudent persons would

rely upon in determining the existence and amount of

RespondentÓs Stafford student loans.

29 . In addition to the provisions of section

12 0.569(1)(g), the loan applications constitute Ðbusiness

recordsÑ pursuant to section 90.803(6), in that they are:

[R] ecord [s] . . . of acts, events,

conditions, opinion, or diagnosis, made at

or near the time by, or from information

transmitted by, a perso n with knowledge, if

kept in the course of a regularly conducted

business activity and if it was the regular

practice of that business activity to make

such memorandum, report, record, or data

compilation, all as shown by the testimony

of the custodian or other qualified witness,

or as shown by a certification or

declaration that complies with paragraph (c)

and s. 90.902(11), unless the sources of

information or other circumstances show lack

of trustworthiness.

The loan documents were authenticated by the testimony of

Ms. Standley and by c ertificates that met the standards for

self - authentication pursuant to section 90.902 . Thus, the

application s and promissory note s may be used as substantive

evidence of the loan s .

30 . The authenticated loan records al so contain statements

made by Respondent that constitute admissions pursuant to

section 90.803(18). As such, RespondentÓs assertions cont ained

in the loan documents may be used as substantive evidence of the

existence of the loans.

31 . Finally, the offi cial transcripts and records

documenting RespondentÓs attendance at DBCC and Valencia

Community College constitute Ð[r] ecords, reports, statements

reduced to writing, or data compilations, in any form, of public

offices or agencies, setting forth . . . mat ters observed

pursuant to duty imposed by law as to matters which there was a

duty to report , Ñ and as such constitute public records pursuant

to section 90.803(8). The records were authenticated by

certificates that met the standards for self - authenticati on

pursuant to section 90.902. Thus, the official transcripts and

records may be used as substantive evidence of RespondentÓs

attendance and loan history with those educational institutions .

E . Allowable Inference

32 . Respondent , as was his right, rep eatedly declined to

respond to PetitionerÓs discovery based on his Fifth Amendment

privilege against self - incrimination. As a result, Respondent

did not testify at the final hearing.

33 . RespondentÓs assertion of his Fifth Amendment

p rivilege against s elf - incrimination permits the fact finder to

draw adverse inferences from his silence. Ð[T] he Fifth

Amendment does not forbid adverse inferences against parties to

civil actions when they refuse to testify in response to

probative evidence offered against them.Ñ Omulepu v. DepÓt of

Health , 2018 Fla. App. LEXIS 8894 , at *4 (Fla. 1st DCA June 22,

2018) ( quoting Baxter v. Palmigiano , 425 U.S. 308, 318 (1976) ) .

34 . Given the competent and substantial documentary

evidence establishing the existence and legiti macy of

RespondentÓs student loan s , the only rational conclusion to be

drawn from RespondentÓs assertion of his Fifth Amendment

p rivilege is that he is aware of his obligation to pay his

student loans and has no t done so .

F . Analysis

35 . The Administ rative Complaint alleges that Respondent

failed to repay a student loan issued or guaranteed by the state

or the Federal g overnment in accordance with the terms of the

loan .

36 . The evidence in this case clearly and convincingly

establishes that Respon dent took out a series of Stafford loans

from 1993 through 1998 to pay his educational expenses at D BCC

and Valencia Community College .

37 . The evidence in this case clearly and convincingly

establishes that Respondent consolidated his loans on June 14,

2005 , with a principal amount of $17,500.00 .

38 . The evidence in this case clearly and convincingly

establishes that Respondent has never made a payment on any of

the loans.

39 . The evidence in this case clearly and convincingly

establishes that Respo ndent Ós student loans were initially

guaranteed by the state of Florida, on beh alf of the Federal

Stafford Loans program . On November 10, 2016 , upon notification

of default by the lender, DOE pa id the lender, and assum ed

ownership of the debt obligations.

40 . Based on the full record of this proceeding, the

Department proved by clear and convincing evidence that

Respondent failed to repay student loans guaranteed by DOE . 2/

4 1 . Section 456.072(4) provides that the Board shall

assess costs related to th e investigation and prosecution, in

addition to other discipline imposed for violating a practice

act.

RECOMMENDATION

Based on the foregoing Findings of Fact and Conclusions of

Law, it is RECOMMENDED that the Department of Health , Bureau of

Emergency Manag ement Oversight, enter a final order: finding

that Respondent failed to repay a student loan issued or

guaranteed by the state or the Federal g overnment in accordance

with the terms of the loan ; imposing a suspension of

RespondentÓs paramedic certificatio n until new loan payment

terms are agreed upon, followed by probation for the duration of

the student loan ; imposing a fine equal to 10 percent of the

defaulted loan amount calculated as of the date of the Final

Order, to be d eposited into the Medical Qual ity Assurance Trust

Fund ; and requiring Respondent to pay the costs related to the

investigation and prosecution.

DONE AND ENTERED this 12th day of September , 2018 , in

Tallahassee, Leon County, Florida.

S

E. GARY EARLY

Administrative Law Judge

Divisi on 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 12th day of Septem ber , 2018 .

ENDNOTES

1/ The 180th and final payment was to be $12 9.36.

2/ Respondent maintained throughout this proceeding that section

456.072(1)(k) is an unconstitutional statute, designed to extort

money not owed by him. Since Respondent refused, on Fifth

Amendment grounds, to explain his assertion, the basis for his

claim that he does not owe any money r emains unknown. It should

be acknowledged that the following exchange between Respondent

and Ms. Standley occurred at the end of her testimony:

Q. Okay. So neither -- just to review ,

neither the State or federal government has

sued to enforce a claim against me, that

youÓre aware of, but you have contacted the

Department of Health and attempted to have

my license revoked on an unconstitutional

law put forth by the State of Florida in an

attempt to coerce money from me, correct?

A. Yes.

As can be gathered from a review of the transcript,

Ms. StandleyÓs testimony was frequently interrupted, and likely

frustr ating. The question itself, though not objected to, was

compound and confusing. More to the point, Ms. StandleyÓs

statement as to the constitutionality of the law or its purpose

is given no weight. As was explained to Respondent on more than

one occasion, the constitutionality of section 456.072(1)(k) is

beyond the scope of this proceeding, but is a matter that can be

taken up on in the event of an appeal under Section 120.68,

Florida Statutes . See Fla. Hosp. v. Ag. for Health Care Admin. ,

823 So. 2d 844, 849 (Fla. 1st DCA 2002); Carrollw ood State Bank

v. Lewis , 362 So. 2d 110, 113 - 12 (Fla. 1st DCA 1978).

COPIES FURNISHED:

William Litsch

763 Tumblebrook Drive

Port Orange, Florida 32127

(eServed)

Rose L. Garrison, Esquire

Department of Health

Prosecution Services Unit

Bin C - 65

4052 Ba ld Cypress Way

Tallahassee, Florida 32399

(eServed)

John A. Wilson, Esquire

Florida Department of Health

Prosecution Services Unit

Bin C - 65

4052 Bald Cypress Way

Tallahassee, Florida 32399

(eServed)

Eric L. Fryson, Esquire

Department of Health

Prosecut ion Services Unit

Bin C - 65

4052 Bald Cypress Way

Tallahassee, Florida 32399

(eServed)

Anthony Spivey, Executive Director

Bureau of Emergency Medical Oversight

Department of Health

4052 Bald Cypress Way, Bin C - 85

Tallahassee, Florida 32399 - 1703

Sha nnon Revels, Agency Clerk

Department of Health

4052 Bald Cypress Way, Bin A02

Tallahassee, Florida 32399 - 1703

(eServed)

Celeste M. Philip, M.D., M.P.H.

State Surgeon General

Department of Health

4052 Bald Cypress Way, Bin A00

Tallahassee, Florida 32399 - 170 1

(eServed)

Louise Wilhite - St Laurent, Interim Gen eral Counsel

Department of Health

4052 Bald Cypress Way, Bin C65

Tallahassee, Florida 32399 - 1703

(eServed)

NOTICE OF RIGHT TO SUBMIT EXCEPTIONS

All parties have the right to submit written exception s within

15 days from the date of this Recommended Order. Any exceptions

to this Recommended Order should be filed with the agency that

will issue the Final Order in this case.