20-001770BID Htg Addison Ii, Llc vs. Florida Housing Finance Corporation
 Status: Closed
Recommended Order on Friday, June 19, 2020.


View Dockets  
Summary: Petitioners HTG Addison and Madison Oaks failed to prove that Florida Housing's determination of eligibility and intended award of tax credits were contrary to statutes, rules, the RFA, clearly erroneous, contrary to competition, arbitrary or capricious.

1M ADISON S QUARE , LLC, A ND A RC 2019,

11LLC ,

12Petitioners , Case No. 20 - 1779BID

18vs.

19F LORIDA H OUSING F INANCE

25C ORPORATION ,

27Respondent ,

28and

29D IPLOMAT S OUTH , LLC,

34Intervenor .

36/

37M ADISON O AKS E AST , L L C, A ND A RC

502019, LLC,

52Petitioners ,

53vs . Case No. 20 - 1780BID

60F

61LORIDA H OUSING F INANCE

66C ORPORATION ,

68Respondent,

69and

70R

71ETREAT A T C OCOA C OMMONS , LLC,

79A ND T RANQUILITY A T M ILTON , LLC,

88Intervenors .

90/

91R ECOMMEN DED O RDER

96These cases came before Administrative Law Judge Darren A. Schwartz of

107the Division of Administrative Hearings ( " DOAH " ) for final hearing on

119May 8, 2020, by Zoom Conference.

125A PPEARANCES

127For Petitioner HTG Addison II, LLC , and Intervenor HTG Edgew ood,

138Ltd. :

140Maureen McCarthy Daughton, Esquire

144Maureen McCarthy Daughton, LLC

1481400 Village Square Boulevard, Suite 3 - 231

156Tallahassee, Florida 32312

159For Petitioners Madison Square, LLC , and Arc 2019, LLC ; and Madison

170Oaks East, L LC, and Arc 2019, LLC:

178J. Timothy Schulte, Esquire

182Zimmerman, Kiser & Sutcliffe, P.A.

187315 East Robinson Street

191Post Office Box 3000 (32802)

196Orlando, Florida 32801

199For Petitioners Rochester Park, Ltd., and Rochester Park Deve loper, LLC:

210Craig D. Varn, Esquire

214Manson Bolves Donaldson Varn, P.A.

219106 East College Avenue , Suite 82 0

226Tallahassee, Florida 32301

229For Respondent Florida Housing Finance Corporation :

236Betty Zachem, Esquire

239Florida Hous ing Finance Corporation

244227 North Bronough Street, Suite 5000

250Tallahassee, Florida 32301

253For Intervenors Tranquility at Milton , LLC ; Diplomat South, LLC; and

263Westside Phase I, LLLP:

267Michael P. Donaldson, Esquire

271Carlton Fields

273215 South Monroe Street, Suite 500

279Tallahassee, Florida 32302 - 0190

284For Intervenor Retreat at Cocoa Commons, LLC:

291Donna Elizabeth Blanton, Esquire

295Radey Law Firm, P.A.

299301 South Bronough Street, Suite 200

305Tallahassee, Flo rida 32301

309S TATEMENT OF T HE I SSUE S

317Whether Respondent, Florida Housing Finance Cor poration’s ( " Florida

326Housing " ) intended action to award housing ta x credit funding to Intervenors

339Westside Phase, I, LLLP ( " Westside " ), HTG Edgewood, Ltd . ( " HTG

352Edgewood " ), Diplomat South, LLC ( " Diplomat " ), and Tranquility at Milton,

364LLC ( " Tranquility " ), under Request for Applications 2019 - 113 Housing Credit

377Financing for Affordable Housing Developments Located in Medium and

386Small Counties (the " RFA " ), is contrary to governi ng statutes, rules, the RFA

400specifications, and clearly erroneous, contrary to competition, arbitrary, or capricious.

410P RELIMINARY S TATEMENT

414These cases involve multiple protests to a Notice of Intent to Award issued

427by Florida Housing. On August 20, 2019, Florida Housing issued the RFA,

439soliciting applications to compete for an allocation of Federal Low - Income

451Housing Tax Credit Funding ( " housing tax credits " ) for the construction of

464affordable housing developments in medium and small counties. Modificatio ns to the RFA were issued on September 10, 2019. In response to

486the RFA, Florida Housing received 184 applications, includin g applications

496from Petitioners HTG Addison, II, LLC ( " HTG Addison " ); Rochester Park

508Ltd., and Rochester Park Developer, LLC ( " Roche ster " ); Madison Square,

520LLC , and ARC 2019, LLC ( " Madison Square " ); and Madison Oaks East, LLC ,

534and ARC 2019, LLC ( " Madison Oaks " ).

542On March 6, 2020, Florida Housing posted notice of its intended dec ision

555to award funding to 11 ap plicants, including Interv enors Westside, HTG

567Edgewood, Diplomat, and Tranquility. Petitioners timely filed Notices of Protest and Petitions for Formal Administrative Proceedings and Intervenors

585timely intervened. On April 9, 2020, Florida Housing referred the matters to

597DOAH to as sign an Administrative Law Judge to conduct the final hearing.

610On April 9, 2020, Florida Housing also filed a motion to consolidate these

623matters with other matters filed by Turn stone Eustis, LP (DOAH Case

635No. 20 - 1775BID); Tranquility Milton, LLC ("Tranqu ility Milton") (DOAH

648Case No. 20 - 1776BID); and Meadowlark Court, Ltd . (DOAH Case

660No. 20 - 1777BID). On April 17, 2020, the undersigned entered an Order

673granting the motion and set the final hearing for May 8, 2020. On April 20,

6882020, Rochester filed an unopp osed motion to amend its petition. On April 27,

7022020, Meadowlark Court, Ltd ., filed a voluntary dismissal of its petition in

715DOA H Case No. 20 - 1777BID. On April 30, 2020, the undersigned entered an

730Order granting Rochester’s motion. On May 4, 2020, Turnston e Eustis, LP ,

742filed a voluntary dismissal of its petition in DOAH Case No. 20 - 1775BID and

757Madison Oaks filed a notice of voluntary dismissal of its challenge to the

770Retreat at Cocoa Commons, LLC , in DOAH Case No. 20 - 1780BID. On May 4,

7852020, Rochester, Flor ida Housing, and HTG Edgewood also entered into a

797written stipulation in DOAH Case No. 20 - 1778BID for the entry of findings of

812fact and a recommended order deeming HTG Edgewood’s application for funding ineligible and Rochester’s application eligible for f unding. On May 5,

8342020, Tranquility filed an unopposed motion to amend its notice of

845appearance in DOAH Case No. 20 - 1780BID.

853On May 5, 2020, the undersigned entered an Order closing DOAH Case

865Nos. 20 - 1775BID and 20 - 1777BID, and relinquishing jurisdiction of these

878cases to Florida Housing. On May 5, 2020, Madison Square, Florida Housing,

890and Diplomat entered into a written stipulation in DOAH Case No. 20 -

9031779BID for the entry of findings of fact and a recommended order deeming Diplomat’s application for fu nding ineligible and Madison Square’s

925application eligible for funding. On May 6, 2020, Tranquility Milton filed a

937voluntary dismissal of its petition in DOAH Case No. 20 - 1776BID. On May 7,

9522020, the undersigned entered an Order closing DOAH Case No. 20 - 17 76BID

966and relinquishing jurisdiction of this case to Florida Housing.

975The final hearing commenced as schedule d and concluded on May 8,

9872020. At the hearing, the parties presente d evidence as to DOAH Case

1000Nos. 20 - 1780BID and 20 - 1770BID. Madison Oaks prese nted the testimony of

1015Marisa Button and Stacy Banach. Tranquility presented the testimony of

1025Todd Wind. HTG Addison presented the testimony of Marisa Butt on. Joint

1037Exhibits 1 through 10 and 12 through 14 were received into evidence.

1049Madison Oak’s Exhibits 2 through 4, 6, 7, 11 , and 13 were received into

1063evidence. Tranquility’s Exhibits 1 through 6 were received into evidence.

1073HTG Addison’s Exhibits 1 through 4 were received into evidence. Madison

1084Square’s Exhibit 2 was received into evidence.

1091The one - volu me final hearing Transcript was filed on May 21, 2020. All of

1107the parties except HTG Edgewood and Retreat at Cocoa Commons, LLC,

1118timely filed proposed recommended orders, which were considered in the

1128preparation of this Recommended Order. HTG Edgewood and Retreat at

1138Cocoa Commons, LLC, did not file proposed recommended order s . The

1150stipulated facts in the parties’ stipulations filed May 4 and 5, 2020; the Joint

1164Pre - hearing Stipulation filed May 6, 2020; and the Joint Stipulation filed

1177May 20, 2020, have been incorporated herein as indicated below. Unless

1188otherwise indicated, references to the Florida Statutes are to the 2019 version.

1200F INDINGS OF F ACT

12051. Florida Housing is a public corporat ion created pursuant to

1216section 420.504, Florida Statutes. Its purpo se is to promote public welfare by

1229administering the governmental function of financing affordable housing in Florida. Pursuant to section 420.5099, Florida Housing is designated as the

1249housing credit agency for Florida within the meaning of section 42(h)( 7)(A) of

1262the Internal Revenue Code , and has the responsibility and authority to

1273establish procedures for allocating and distributing low income housing tax

1283credits.

12842. The low income housing tax credit program (commonly referred to as

" 1296tax credits " or " ho using credits " ) was enacted to incentivize the private

1309market to invest in affordable rental housing. These housing tax credits are

1321awarded competitively to housing developers in Florida for rental housing

1331projects that qualify. These credits are then norm ally sold by developers for

1344cash to raise capital for their projects. The effect is that the credits reduce the

1359amount that the developer would otherwise have to borrow. Because the total

1371debt is lower, a housing tax credit property can (and must) offer lo wer, more

1386affordable rents. Developers also covenant to keep rents at affordable levels

1397for periods of 30 to 50 years as consideration for receipt of the housing

1411credits. The demand for housing tax credits provided by the federal

1422government exceeds the sup ply.

1427The Competitive Application Process

14313. Florida Housing is authorized to allocate housing tax credits and other

1443funding by means of a request for applications or other competitive

1454solic itation in section 420.507(48) and Flor ida Administrative Code

1464Cha pter 67 - 60, which govern the competitive solicitation process for several

1477different programs, including the program for housing tax credits. Chapter 67 - 60 provides that Florida Housing allocate its competitive funding through

1499the bid protest provisions of section 120.57(3) , Florida Statutes .

15091

15104 . In their applications, applicants request a specific dollar amount of

1522housing tax credits to be given to the applican t each year for a period of

1538ten years. Applicants normally sell the rights to that future stream of income

1551housing tax credits (through the sale of almost all of the ownership interest

1564in the applicant entity) to an investor to generate the amount of capital

1577ne eded to build the development. The amount which can be received depends

15901 A request for application is equivalent to a " request for proposal " as indicated in rule 67 -

160860.009(3).

1609upon the accomplish ment of several factors, such as a certain percentage of

1622the projected t otal d evelopment c ost; a maximum funding amount per

1635development based on the county in which the development will be located;

1647and whether the development is located within certain desi g nated areas of

1660some counties. T his, however, is not an exhaustive list of the factors

1673considered.

16745 . The RFA was issued on August 20 , 201 9 , and responses were initially

1689due October 2 9 , 201 9 . The RFA was modified on September 10 , 201 9 , and t he

1708application deadline was extended to November 5 , 201 9 . No challenges were

1721made to the terms of the RFA.

17286 . Through the RFA, Florida Housing expects to award up to an estimated

1742$ 14 ,8 05 , 028 of housing tax credits to proposed developments in medium

1756counties and up to a n estimated $1,413,414 of housing credits to proposed

1771developments in small counties. Florida Housing received 184 applications in

1781response to the RFA.

17857 . A review committee was appointed to review the applications and make

1798recommendations to Florida Hous ing's Boa rd of Directors (the " Board " ). The

1811review committee found 1 6 9 applications eligible and 15 applications

1822ineligible. Through the ranking and selection process outlined in the RFA,

183311 applications were preliminarily recommended for funding. The revi ew

1843committee developed charts listing its eligibility and funding

1851recommendations to be presented to the Board.

18588 . On March 6 , 20 20 , the Board met and considered the recommenda tions

1873of the review committee. Also, on March 6 , 20 20 , at approximately 9: 35 a. m.,

1889Petitioners and all other applicants received notice that the Board

1899determined whether applications were eligible or ineligible for consideration for funding, and that certain eligible applicants were selected for award of

1920housing credits, subject to s atisfactory completion of th e credit underwriting

1932process. Such notice was provided by the posting of two spreadsheets on the

1945Florida Housing website, www.floridahousing.org , one listing the Board

1953approved scoring results and one identifying the applicatio ns which Florida

1964Housing proposed to fund.

19689 . In the March 6 , 20 20 , posting, Florida Housing announced its intention

1982to award funding to 11 applicants, including Westside, HTG Edgewood,

1992Diplomat, and Tranquility . Petitioners timely filed notices of protest and

2003petitions for formal administrative proceedings, and Intervenors timely

2011intervened .

2013The RFA Ranking and Selection Process

20191 0 . The RFA contemplates a structure in which the applica nt is scored on

2035eligibility items and obtains points for other items. A summary of the

2047eligibility items is available in section 5.A.1 . , beginning on page 6 4 of the

2062RFA. Only applications that meet all the eligibility items will be eligible for

2075funding and considered for funding selection.

20811 1 . There were two total point ite ms scored in this RFA. Applicants could

2097receive five points for Submission of Principal s Disclosure Form , stamped by

2109the Corporation as " Pre - Approved , " and five points for Development

2120Experience Withdrawal Disincentive, for a total application score of up to

2131ten points.

213312. The RFA has three funding goals:

2140a. The Corporation has a goal to fund four Medium

2150County Developments that qualify for the Local

2157Government Areas of Opportunity Funding Goal

2163outlined in Section Four A.11.a. of the RFA .

2172b. The Corpora tion has a goal to fund two

2182Developments with a Demographic commitment of

2188Family that select and qualify for the Geographic Areas of Opportunity/SADDA Goal outlined in Section Four A.11.b. of the RFA .

2209c. The Corporation has a goal to fund one (1)

2219Devel opm ent that qualifies for the Local

2227Community Revitalization Initiative Goal outlined in Section Four A.11.c. of the RFA .

2240*Note: During the Funding Selection Process

2246outlined below, Developments selected for these

2252goals will only count toward one goal.

22591 3 . As part of the funding selection process, the RFA starts with the

2274application sorting order on page 68 . The highest scoring applications are

2286determined by first sorting together all eligible applications from the highest

2297score to lowest score, with any scores that are tied separated as follows:

2310( a ) First, by the Application's eligibility for the

2320Proximity Funding Preference (which is outlined in

2327Section Four A.5.e. of the RFA) with Applications that qualify for the preference listed above Applications that do not qualify for the preference;

2350( b ) Next, by the Application's eligibility for the Per

2361Unit Construction Funding Preference which is outlined in Section Four A.1 0 .e. of the RFA (with

2378Applications that qualify for the preference listed above Ap plications that do not qualify for the

2394preference);

2395( c ) Next, by the Application's eligibility for the

2405Development Category Funding Preference which is outlined in Section Four A.4 . b . (4) of the RFA

2423(with Applications that qualify for the preference liste d above Applications that do not qualify for the

2440preference);

2441( d ) Next, by the Application's Leveraging

2449Classification, applying the multipliers outlined in

2455item 3 of Exhibit C of the RFA (with Applications

2465having the Classification of A listed above

2472App lications having the Classification of B);

2479( e ) Next, by the Application's eligibility for the

2489Florida Job Creation Funding Preference which is

2496outlined in Item 4 of Exhibit C of the RFA (with

2507Applications that qualify for the preference listed above Appl ications that do not qualify for the

2523preference);

2524( f ) And finally, by lottery number, resulting in the

2535lowest lottery number receiving preference.

254014. The RFA includes a Funding Test where small county applications will

2552be selected for funding only if th ere is enough small county funding available

2566to fully fund the eligible housing credit request amount, and medium county

2578applications will be selected for funding only if there is enough medium

2590county funding available to fully fund the eligible housing cr edit request

2602amount.

260315. The RFA outlines a specific County’s Award Tally:

2612As each application is selected for tentative

2619funding, the county where the proposed Development is located will have one Application credited towards the County’s Award Tally. Th e

2640Corporation will prioritize eligible unfunded Applications that meet the Funding Test and are located within counties that have the lowest

2660County Award Tally above other eligible unfunded Applications with a higher County Award Tally

2674that also meet the F unding Test, even if the

2684Applications with a higher County Award Tally are

2692higher ranked.

26941 6 . According to the RFA , the funding selection process is as follows :

2709a. The first Application selected for funding will be

2718the highest ranking eligible Applic ations that qualifies for the Local Community Revitalization

2731Initiative Goal .

2734b. The next four Applications s elected for funding

2743will be the highest ranking eligible Medium County Applications that qualify for the Local Government

2758Areas of Opportunity Fu nding Goal, subject to the

2767Funding Test and the County Award Tally.

2774c. The next two Application s selected for funding

2783will be the highest ranking eligible Family

2790Applications that qualify for the Geographic Areas

2797of Opportunity/HUD - designated SADDA Goal,

2803subject to the Funding Test and the County Award

2812Tally .

2814d. The next Applications selected for funding will

2822be the highest ranking eligible unfunded Small

2829County Applications that (i) can meet the Small

2837County Funding Test and (ii) have a County Award

2846Ta lly that is less than or equal to any other eligible

2858unfunded Small County Applications. If Small

2864County funding remains and no unfunded eligible Small County Application can meet the Small County Funding Test, no further Small County Applications will be selected and the remaining

2892Small County funding will be added to the Medium

2901County funding amount.

2904e. The next Application(s) selected for funding will

2912be the highest ranking eligible unfunded Medium County Applications that (i) can meet the Medium Count y Funding Test and (ii) have a County Award

2937Tally that is less than or equal to any other eligible unfunded Medium County Applications.

2952f. If Medium County funding remains and no unfunded eligible Medium County Application can meet the Medium County Fund ing Test, no further

2975Applications will be selected and the remaining

2982funding will be distributed as approved by the

2990Board.

299117. According to the terms of the RFA:

2999Funding that becomes available after the Board takes action on the [Review] Committee’ s

3013recommendation(s), due to an Applicant withdrawing its Application, an Applicant declining its invitation to enter credit underwriting, or an

3032Applicant’s inability to satisfy a requirement

3038outlined in this RFA, will be distributed as approved by the Boar d.

305118. All 184 applications for the RFA were received, processed, deemed

3062eligible or ineligible, scored, and ranked, pursuant to the terms of the RFA,

3075Florida Administrative Code Chapters 67 - 48 and 67 - 60, and applicable

3088federal regulations.

3090HTG Edge wood’s Application (DOAH Case No. 20 - 1778BID)

310019. During scoring, Florida Housing determined that the HTG Edgewood

3110application was eligible and, pursuant to the terms of the RFA, selected HTG

3123Edgewood for funding.

312620. HTG Edgewood, Florida Housing, and Ro chester now agree that HTG

3138Edgewood’s application is ineligible for consideration for funding and t he

3149application of Rochester is eligible for funding. Accordingly, HTG Edgewood,

3159Florida Housing, and Roch ester agree that Florida Housing should deem the

3171HTG Edgewood application ineligibl e for funding and Rochester ’s application

3182eligible for funding.

3185Diplomat’s Application ( DOAH Case No. 20 - 1779BID )

319521. During scoring, Florida Housing deemed the Diplomat application

3204eligible and , pursuant to the terms of th e RFA, preliminarily selected

3216Diplomat for funding.

321922. Diplomat and Madison Square now agree that Diplomat is ineligible

3230for funding. Florida Housing does not contest Diplomat’s admission of ineligibility.

324123. Madison Square, Diplomat, and Florida Housi ng agree that Madison

3252Square is eligible for funding.

3257Tranquility’s Application (DOAH Case No. 20 - 1780BID)

326524. Florida Housing deemed the Tranquility application eligible for

3274funding, and pursuant to the terms of the RFA, Tranquility was selected for prel iminary funding.

3290Tranquility’s Principals Disclosure Form

329425. Madison Oaks contests Florida Housing’s preliminary selection of

3303Tranquility for an award of housing tax credits. In its challenge, Madison

3315Oaks argues that Tranquility failed to correctly com plete its Principals

3326Disclosure Form by not identifying the multiple roles of its disclosed

3337principal. Specifically, Madison Oaks argues that Tranquility failed to list

3347Tranquility Milton Manager, LLC, which is disclosed as a manager, as a non -

3361investor mem ber as well. Accordingly, Madison Oaks contends Tranquility is

3372not eligible or should lose five points.

337926. The purpose of the Principals Disclosure Form is to allow Florida

3391Housing to track an entity’s past and future dealings with Florida H ousing so

3405tha t Florida Housing is aware of the entity with which it is dealing. In regard

3421to principal disclosure, the RFA states, in relevant part:

3430c. Principals Disclosure f or the Applicant and for

3439each Developer (5 points)

3443(1) Eligibility Requirements

3446To meet the submission requirements, the

3452Applicant must upload the Principals of the

3459Applicant and Developer(s) Disclosure Form (Form

3465Rev. 0 5 - 2019 )( " Principals Disclosure Form " ) with

3476the Application and Development Cost Pro Forma, as outlined in Section Three above. Prior versions

3491of the Principal Disclosure Form will not be accepted.

3500The Principals Disclosure Form must identify ,

3506pursuant to subsections 67 - 48.002(94), 67 -

351448.0075(8) and 67 - 48.0075(9), the Principals of the

3523Applicant and Developer(s) as of the Applica tion

3531Deadline. The investor limited partner of an

3538Applicant limited partnership or the investor member of an Applicant limited liability company

3551investor must be identified. A Principals Disclosure

3558Form should not include, for any organizational

3565structure , any type of entity that is not specifically

3574included in the Rule definition of Principals.

3581(2) Point Item

3584Applicants will receive 5 points if the uploaded Principal Disclosure Form was stamped " Approved "

3598during the Advance Review Process. The Advance

3605Review Process for Disclosure of Applicant and

3612Developer Principals is available on the RFA

3619Website and also includes samples which may

3626assist the Applicant in completing the required

3633Principals Disclosure Form.

3636Note: It is the sole responsibility of the Applicant to review the Advance Review Process procedures and to submit any Principals Disclosure Form for review in a timely manner in order to meet the

3670Application Deadline.

367227. The RFA website provides guidance and instructions to assist

3682applicants in completing the principal disclosure. The instructions state: " List

3692the name of each Member of the Applicant Limited Liability Company and

3704label each as either non - investor Member or investor Member (i.e., equity

3717provider and/or placeholder), as applicable . "

37232 8. The RFA website guidance and instructions further provides

3733Frequently Asked Questions ( " FAQ’s " ) concerning principal disclosures.

374229. FAQ number 4 states:

3747Q: If the Applicant entity is a member managed

3756limited liability company, how should it be r eflected

3765on the form since there is no " member - manager "

3775choice at the First Principal Disclosure Level?

3782A: Each member - manager entity/ person should be

3791listed twice — once as a non - investor member and

3802once as a manger. If Housing Credits are being

3811reque sted, the investor - member(s) must also be

3820listed in order for the form to be approved for a Housing Credit Application.

383430. On its Principals Disclosure Form, Tranquility listed two entities at

3845the first principal disclosure level: Tranquility Milton Man ager, LLC,

3855identified as a manager of the applicant and Timshel Partners, LLC,

3866identified as an investor member of the applicant. However, Tranquility

3876failed to identify the dual role of Tranquility Milton Manager, LLC , as a non -

3891investor member in addition to its disclosed role as a manger.

390231. Nevertheless, Tranquility’s equity proposal letter submitted as part of

3912its application identified Tranquility Milton Manager, LLC , as a member of

3923the LLC because according to the equity proposal, Tranquility Milton

3933Manager, LLC , would retain a .01% ownership interest in the company.

3944Thus, the role of Tranquility Milton Manager, LLC , as a member is available

3957within Tranquility’s application.

396032. Tranquility participated in Florida Housing’s Advance Review Process,

3969and on October 17, 2019, Florida Housing approved the Principals Disclosure

3980Form submitted by Tranquility during the Advance Review Process for an

3991award of housing credits. During scoring, Tranquility received five points for

4002having its Principals Disclosu re Form stamped " Approved " by Florida

4012Housing.

401333. Tranquility’s Principals Disclosure Form met the eligibility

4021requirements of the RFA and Tranquility is entitled to the five points.

403334. In addition, Ms. Button persuasively and credibly testified that even if

4045Tranquility’s failure to list the dual role of its disclosed principal on the

4058Principals Disclosure Form is an error, it is so minor as to constitute a waivable, minor irregularity. As detailed above, Tranquility Milton Manager,

4081LLC , was specifical ly designated as a man a ger on the form and information

4096identifying Tranquility Milton Manager, LLC’s , additional role as a member

4106is included in the equity proposal letter submitted with the application.

4117Madison Oak’s Application ( DOAH Case No. 20 - 1779BI D )

412935. Madison Oaks’ application was deemed eligible for funding, but

4139pursuant to the terms of the RFA, Madison Oaks was not selected for

4152preliminary funding.

4154Madison Oaks Site Control Certification

415936. Florida Housing and Tranquility now argue that Madis on Oak s failed

4172to demonstrate site control. As an eligibility item, the RFA requires applicants to demonstrate site control by providing a properly completed and

4194executed Florida Housing Finance Corporation Site Control Certification

4202form ( " Site Control Fo rm " ). For the Site Control F orm to be considered

4218complete , the applicant must attach documentation demonstrating that it is a

4229party to an eligible contract or lease or is the owner of the subject property.

424437. Applicants can demonstrate site control by pr oviding documentation

4254that meets the requirements in the RFA for an eligible contract, deed or

4267certificate of title, or a lease.

427338. An eligible contract must meet all of the following conditions:

4284(a) It must have a term that does not expire before

4295April 30, 2020 or that contains extension options

4303exercisable by the purchaser and conditioned solely upon payment of additional monies which, if exercised, would extend the term to a date that is not earlier than April 30, 2020;

4333(b) It must specifically stat e that the buyer’s

4342remedy for default on the part of the seller includes or is specific performance;

4356(c) The Applicant must be the buyer unless there is an assignment of the eligible contract, signed by the assignor and the assignee, which assigns all of

4383the buyer’s rights, title and interests in the eligible contract to the Applicant; and

4397(d) The owner of the subject property must be the seller, or is a party to one or more intermediate contracts, agreements, assignments, options, or

4422conveyances b etween or among the owner, the

4430Applicant, or other parties, that have the effect of

4439assigning the owner’s right to sell the property to

4448the seller. Any intermediate contract must meet

4455the criteria for an eligible contract in (a) and (b)

4465above.

446639. In demo nstrating site control, the RFA states:

4475Note: The Corporation will not review the site

4483control documentation that is submitted with the

4490Site Control Certification form during the scoring

4497process unless there is a reason to believe that the

4507form has been i mproperly executed, nor will it in

4517any case evaluate the validity or enforceability of

4525any such documentation. During scoring, the

4531Corporation will rely on the properly executed Site

4539Control Certification form to determine whether an

4546Applicant has met the requirements of this RFA to demonstrate site control. The Corporation has no authority to, and will not, evaluate the validity or enforceability of any eligible site control

4577documentation that is attached to the Site Control

4585Certification form during the s coring process.

4592During credit underwriting, if is determined that the site control documents do not meet the above requirements, the Corporation may rescind the

4614award.

461540. Additionally, the RFA requires that the site control " documentation

4625include all r elevant intermediate contracts, agreements, assignments,

4633options, conveyances, intermediate leases, and subleases. "

463941. In the instant case, Madison Oaks attached a Purchase and Sale

4651Agreement ( " Madison Oaks Agreement " ) to its Site Control Form.

466242. The Madison Oaks Agreement lists West Oak Developers, LLC , as the

" 4674Seller " and Madison Oaks East, LLC , as the " Purchaser. "

468343. However, the City of Ocala owns the property in question.

469444. The Madison Oaks Agreement in s ection 12 states that : " Seller has a

4709v alid and binding agreement with the City of Ocala, Florida pursuant to

4722which Seller has the right to acquire fee simple title to the Property …. "

473645. Tranquility and Florida Housing contend that Madison Oaks failed to

4747demonstrate site control because Madis on Oaks failed to include the City of

4760Ocala Redevelopment Agreement for Pine Oaks ( " Redevelopment

4768Agreement " ) in its site control documentation.

477546. Madison Oaks maintains that the City of Ocala is a seller , pursuant to

4789the Joinder and Section 28 of the M adison Oaks Agreement, and therefore,

4802the Redevelopment Agreement did not need to be included. However, the

4813Madison Oaks Agreement clearly identifies West Oak as the " Seller " and the

4825City of Ocala as the " City. "

483147. At hearing, Ms. Button persuasively and credibly testified that the

4842Madison Oaks application is ineligible because it did not include the

4853Redevelopment Agreement, which is a relevant agreement for purposes of

4863demonstrating site control. The Redevelopment Agreement was a relevant intermediate co ntract , which was required to be included in Madison Oak’s

4884application. Madison Oak’s failure to include the Redevelopment Agreement renders its application ineligible.

489748. Madison Oaks contends that including the Redevelopment Agreement

4906in its applicat ion was unnecessary because of a joinder provision within the

4919Madison Oaks Agreement. The Madison Oaks Agreement contains a Joinder

4929and Consent of the City of Ocala approved by the City Council ( " the Joinder " ),

4945whereby the City of Ocala joined and consente d to the Madison Oaks

4958Agreement " solely for the purposes set forth in, and subject to, Section 28

4971herein. "

497249. The Madison Oaks Agreement in Section 28 states that : " Seller hereby

4985acknowledges and agrees that in the event of Seller’s default hereunder, th at

4998is not timely cured, or Seller ' s refusal to close hereunder, Purchaser shall be

5013entitled to close on the property subject to this Agreement … directly with

5026the City on the terms and conditions set forth in this Section 28. "

503950. However, Section 28 only applies in the event of a default by West

5053Oaks that is not timely cured or West Oak’s refusal to close. There is no

5068information within the Madison Oaks application to determine whether a

5078default or termination of the Redevelopment Agreement occurred as of the

5089application deadline.

5091Westside’s A pplication ( DOAH Case No. 20 - 177 0 BID )

510451. Florida Housing deemed Westside’s application eligible and , pursuant

5113to the terms of the RFA, Westside was preliminary selected for funding to

5126meet the goal to fund one devel opment that qualifies for the Local

5139Community Revitalization Initiative Goal.

5143Westside’s Election to Compete for the L ocal Community Revitalization

5153Initiative Goal

515552. In order to qualify for the Local Community Revitalization Initiative

5166Goal, the RFA s tates:

5171Applicants for proposed Developments that are

5177part of a local revitalization plan may elect to compete for this goal. To qualify for this goal, the Applicant must submit the properly completed

5202Florida Housing Finance Corporation Local

5207Government/Co mmunity Redevelopment Agency Verification That Development Is Part Of A Local Community Revitalization Plan form (Form Rev. 08 - 2019) as Attachment 18. The form is available

5235on the RFA Website.

5239Included with the form must be either (1) a link to the lo cal community revitalization plan or (2) a

5259copy of the local community revitalization plan. The

5267plan must have be en adopted on or before

5276January 1, 2019.

527953. Florida Housing , pursuant to the terms of the RFA , also has a goal to

5294fund four medium county de velopments that qualify for the Local

5305Government Areas of Opportunity Funding Goal.

531154. Westside included an executed Florida Housing Finance Corporation

5320Local Government/Community Redevelopment Agency Verification that

5326Development is Part of a Local Comm unity Revitalization Plan form (the

" 5338Local Community Revitalization Plan Form " ) and a link to the local

5350government revitalization plan at Attachment 18 of its application.

535955. At question 11.c. in the application, applicants are asked to select

" 5371Yes " or " No " from a drop - down menu in response to the question: " Is the

5387proposed Development eligible for the Local Community Revitalization

5395Initiative Goal? "

539756. Westside selected " No " from the Yes/No drop - down menu in answering

5410question 11.c. regarding the Local Community Revitalization Initiative Goal.

541957. At question 11.a. in the application, applicants are asked to select

" 5431Yes " or " No " from a drop - down menu in response to the question: " Is the

5447proposed Development eligible for the Local Government Areas of

5456Opp ortunity Funding Goal? "

546058. Westside selected " Yes " from the Yes/No drop - down menu in

5472answering questions 11.a. regarding the Local Government Areas of Opportunity Funding Goal.

548459. During scoring, Westside was deemed to have qualified for the Local

5496Gover nment Areas of Opportunity Funding Goal and the Local Community

5507Revitalization Initiative Goal. During the funding selection process, Westside

5516was selected for funding to meet the Local Government Community

5526Revitalization Initiative Goal.

552960. HTG Addison selected " Yes " from the Yes/No drop - down menu in

5542answering question 11.c. regarding the Local Community Revitalization Initiative Goal.

555261. HTG Addison included an executed Local Community Revitalization

5561Plan Form at Attachment 18 of its application.

556962. HTG Addison selected " No " from the Yes/No drop - down menu in

5582answering question 11.a . regarding the Local Government Areas of

5592Opportunity Funding Goal.

559563. HTG Addison is the next highest ranked eligible applicant qualified

5606for the Local Community Revital ization Initiative Goal after Westside. If

5617Westside is deemed not to have qualified for the revitalization goal, then

5629HTG Addison, as the next highest ranked eligible applicant, would qualify for

5641that goal.

564364. HTG Addison alleges that Westside should not be selected to meet the

5656Local Community Revitalization Initiative Goal because Westside selected " No " from the drop - down menu in response Question 11.c.

567565. Ms. Button persuasively and credibly testified that Florida Housing

5685does not rely on the drop - down responses to questions 11a., b., or c. in

5701determining whether an applicant " elects to be eligible for a certain goal "

5713because answering " Yes " or " No " to these requirements is not a requirement

5725of the RFA.

572866. Rather, Ms. Button persuasively and credibly testified that in

5738determining whether an applicant qualifies for a funding goal, Florida

5748Housing relies on the documentation submitted with the application that is

5759required for the funding goal.

576467. In the instant case, Westside included the executed Flor ida Housing

5776Finance Corporation Local Government Revitalization Plan form and a link

5786to the local community revitalization plan at Attachment 18 of its application.

57982

579968. In addition, Ms. Button persuasively and credibly testified that even if

5811Westside err ed in selecting " Yes " in response to question 11.c., it is so minor

5826as to constitute a waivable, minor irregularity because Florida Housing has

5837the required information within the application (the executed form and a link

5849to the local community revitalizat ion plan at Attachment 18).

58592 Notably, another applicant responding to the RFA, Tranquility at Ferry Pass, selected " Yes "

5873in response to question 11.c. , but failed to i nclude at Attachment 18 either a copy of or a link

5893to the local community revitalization plan. During scoring, Florida Housing determined that

5905Tranquility at Ferry Pass did not qualify for the revitalization goal. Florida Housing’s

5918scoring of the Westside application is consistent with its scoring of the Tranquility at Ferry

5933Pass application because in both cases, Florida Housing scored the application based on the requirements of the RFA for the revitalization goal and the documentation submitted in

5960respon se to those requirements. Florida Housing did not rely on the applicant’s response to

5975question 11.c. regarding the applicant’s expressions of its own eligibility.

5985C ONCLUSIONS OF L AW

599069 . DOAH has personal and subject matter jurisdiction in this proceeding

6002pursuant to sections 120.569, 120.57(1), and 120.57(3), Florida Statutes.

601170 . Pursuant to section 120.57(3)(f), the burden of proof rest s with

6024P etitioners as the part ies opposing the proposed agency action. State

6036Contracting & Eng'g Corp. v. Dep't of Transp. , 709 So. 2d 607, 609 (Fla. 1st

6051DCA 1998). Petitioners must sustain their burden of proof by a

6062preponderance of the evidence. See Dep' t of Transp. v. J.W.C. Co., Inc. , 396

6076So. 2d 778, 787 (Fla. 1st DCA 1981).

608471 . Section 120.57(3)(f) provides, in part, as follows:

6093Unless otherwise provided by statute, the burden of

6101proof shall rest with the party protesting the

6109proposed agency action. I n a competitive -

6117procurement protest, other than a rejection of all

6125bids, proposals, or replies, the administrative law

6132judge shall conduct a de novo proceeding to

6140determine whether the agency's proposed action is

6147contrary to the agency's governing statutes , the

6154agency's rules or policies, or the solicitation

6161specifications. The standard of proof for such

6168proceedings shall be whether the proposed agency

6175action was clearly erroneous, contrary to

6181competition, arbitrary, or capricious.

618572. The phrase " de novo proceeding, " as used in section 120.57(3)(f),

6196describes a form of intra - agency review. " The judge may receive evidence, as

6210with any formal hearing under section 120.57(1), but the object of the

6222proceeding is to evaluate the action taken by the agency. " Sta te Contracting ,

6235709 So. 2d at 609.

624073 . A bid protest proceeding is not simply a record review of the

6254information that was before the agency. Rather, a new evidentiary record

6265based upon the facts established at DOAH is developed. J.D. v. Fla. Dep't of

6279Child . & Fams. , 114 So. 3d 1127, 1132 - 33 (Fla. 1st DCA 2013).

629474 . After determining the relevant facts based on the evidence presented

6306at hearing, Florida Housing's intended action will be upheld unless it is

6318contrary to the governing statutes, the corporation 's rules, or the bid

6330specifications. The agency's intended action must also remain undisturbed

6339unless it is clearly erroneous, contrary to competition, arbitrary, or capricious.

63507 5 . The Florida Supreme Court explained the " clearly erroneous " standard

6362as follows:

6364[ A ] finding of fact is clearly erroneous when,

6374although there is evidence to support such finding,

6382the reviewing court upon reviewing the entire evidence is left with the definite and firm conviction that a mistake has been committed. This

6405standa rd plainly does not entitle a reviewing court

6414to reverse the finding of the trier of fact simply because it is convinced that it would have decided the case differently. Such a mistake will be found to

6443have occurred where findings are not supported by subs tantial evidence, are contrary to the clear weight of the evidence, or are based on an

6468erroneous view of the law. Similarly, it has been

6477held that a finding is clearly erroneous where it

6486bears no rational relationship to the supporting

6493evidentiary data, wh ere it is based on a mistake as

6504to the effect of the evidence, or where, although there is evidence which if credible would be substantial, the force and effect of the testimony

6529considered as a whole convinces the court that the

6538finding is so against the g reat preponderance of the

6548credible testimony that it does not reflect or represent the truth and right of the case.

6564Dorsey v. State , 868 So. 2d 1192, 1209 n.16 (Fla. 2003).

657576 . The " contrary to competition " standard preclude s actions , which, at a

6588minimu m: (a) create the appearance of and opportunity for favoritism;

6599(b) erode public confidence that contracts are awarded equitably and

6609economically; (c) cause the procurement process to be genuinely unfair or

6620unreasonably exclusive; or (d) are unethical, dis honest, illegal, or fraudulent.

6631Ambar Riverview, Ltd. v. Fl a . Hous. Fin. Corp . , Case No. 19 - 1261BID (Fla.

6648DOAH May 21, 2019 ; F HFC June 21, 2019).

665777 . An action is " arbitrary if it is not supported by logic or the necessary

6673facts, " and " capricious if it is adopted without thought or reason or is

6686irrational. " Hadi v. Lib. Behav. Health Corp. , 927 So. 2d 34, 38 - 9 (Fla. 1st

6702DCA 2006). If agency action is justifiable under any analysis that a

6714reasonable person would use to reach a decision of similar importance, the

6726decision is neither arbitrary nor capricious. J.D. , 114 So. 3d at 1130. Thus,

6739under the arbitrary or capricious standard, " an agency is to be subjected only

6752to the most rudimentary command of rationality. The reviewing court is not

6764authorized to exami ne whether the agency's empirical conclusions have

6774support in substantial evidence. " Adam Smith Enters., Inc. v. Dep't of Envtl.

6786Reg. , 553 So. 2d 1 260, 1273 (Fla. 1st DCA 1989). Nevertheless,

6798the reviewing court must consider whether the

6805agency: (1) has co nsi dered all relevant factors;

6814(2) has given actual, good faith consideration to

6822those factors; and (3) has used reason rather than

6831whim to progress from consideration of each of these factors to its final decision.

6845Id.

684678 . Moreover, it has long been reco gnized that " [a]lthough a bid containing

6860a material variance is unacceptable, not every deviation from the invitation

6871to bid is material. It is only material if it gives the bidder a substantial

6886advantage over the other bidders and thereby restricts or sti fles competition. "

6898Tropabest Foods, Inc. v. State , Dep't of Gen. Servs. , 493 So. 2d 50, 52 (Fla. 1st

6914DCA 1986).

691679 . Pursuant to rule 67 - 60.008, Florida Housing has reserved the right to

6931waive minor irregularities in an application. Under this rule, minor

6941i rregularities are those errors " that do not result in the omission of any

6955material information; do not create any uncertainty that the terms and

6966requirements of the competitive solicitation have been met; do not provide a

6978competitive advantage or benefit n ot enjoyed by other Applicants; and do not

6991adversely impact the interests of the Corporation or the public. "

700180 . In Ambar Riverview , Ltd. , Ambar argued that Las Brisas should be

7014ineligible or lose five points because Las Brisas failed to identify the mult iple

7028roles of a disclosed principal. However, the multiple roles of the disclosed

7040principal could be found within the four corners of the application. The

7052undersigned concluded there was no requirement to include the multiple

7062roles of the disclosed princip al in the Principal Disclosures Form and, in any

7076event, Las Brisas’ s failure to identify the multiple roles of its disclosed

7089principals on the form was, at most, a waivable, minor irregularity.

710081 . However, in HTG Village View, LLC v. Florida Housing Finan ce

7113Corporation , Case No. 18 - 2156BID (Fla. DOAH J uly 27, 2018; FHFC

7126Sept . 17, 2018), Adm inistrative Law Judge Yolo nda Y. Green properly found

7140Marquis Partners ineligible by failing to disclose Leon Wolfe as a manager of

7153Cornerstone Marquis, LLC , on its Prin cipals Disclosure Form. In Blue

7164Broadway, LLC v. Florida Housing Finance Corporation , Case No. 17 -

71753273BID ( Fla. DOAH Aug. 29, 2017; FHFC Sept. 22, 2017), Administrative

7187Law Judge Linzie F. Bogan properly found an intervenor ineligible by failing

7199to disclos e two officers (Jason Pritchard and Nathan Barth) on its Principals

7212Disclosure Form.

721482 . Applying the foregoing legal principles to the instant case, Florida

7226Housing's proposed action in awarding the housing tax credits to Tranquility ,

7237and not Madison Oak s , is not contrary to the governing statutes, rules, the

7251RFA specifications, clearly erroneous, contrary to competition, arbitrary, or capricious.

72618 3 . As detailed above, Tranquility identified Tranquility Milton Manager,

7272LLC , on the Principals Disclosure form as a manager. The information

7283regarding Tranquility Milton Manager, LLC’s , additional role as a member

7293was also available within the equity proposal included within Tranquility’s

7303application. This is not a situation, as in the cases of HTG Village Vie w , LLC ,

7319and Blue Broadway, LLC , where an applicant failed to identify a principal.

733184 . At most, the failure of Tranquility to identify Tranquility Milton

7343Manager, LLC’s , additional role as a member on the Principals Disclosure

7354Form is a waivable, minor ir regularity. Madison Oaks failed to demonstrate

7366that Florida Housing’s proposed action finding the Tranquility application

7375eligible and awarding it five points is contrary to governing statutes, rules,

7387the RFA specifications, or clearly erroneous, contrary to competition,

7396arbitrary, or capricious. In sum, Tranquility is eligible for funding and should

7408not lose any points.

74128 5. On the issue of site control, Madison Oaks substantially deviated from

7425the requirements of the RFA and is ineligible by failing to sub mit the

7439Redevelopment Agreement with its site control documentation. The

7447Redevelopment Agreement is a relevant, intermediate agreement required to

7456be included within the site control documentation. Flagship Manor, LLC v.

7467Fl a . Hous. Fin. Corp . , 199 So. 3d 1 090 (Fla. 1st DCA 2016)(upholding Florida

7484Housing’s conclusion that applicant was ineligible for failing to provide

7494exhibit to site control contract and that failing to provide docum ent was not

7508minor irregularity).

75108 6 . Madison Oaks’ reliance on VLX Prope rties, Inc. v. Southern States

7524Utilities, Inc. , 792 So. 2d 504 (Fla. 5th DCA 2001), is misplaced. That case

7538involved a claim for inverse condemnation and has no application to the

7550instant case. Moreover, as detailed above, the Joinder in the instant case o nly

7564applies in the event of a default by West Oaks that is not timely cured or

7580West Oak’s refusal to close. There is no information within the Madison Oaks application to determine whether a default or termina tion of the

7604Redevelopment Agreement occurred as of the application deadline.

76128 7 . Tranquility sufficiently demonstrated that Florida Housing’s proposed

7622action finding the Madison Oaks application eligible is contrary to the

7633governing statutes, rules, the RFA specifications, clearly erroneous, contrary

7642to competition, arbitrary, or capricious. In sum, Madison Oaks is not eligible

7654for funding.

76568 8 . Finally, as to Westside’s application and the Local Community

7668Revitalization Initiative Goal, the failure to check " Yes " from the drop - down

7681menu in response to Question 11.c. did not relate to a requirement of the

7695RFA. As detailed above, Ms. Button persuasively and credibly testified that

7706in determining whether an applicant qualifies for a funding goal, Florida

7717Housing relies on the documentation submitted with the application that is

7728required for the funding goal. In the instant case, Westside included the

7740executed Florida Housing Finance Corporation Local Government

7747Revitalization Plan form and a link to the local community revitalization plan

7759at Attachment 18 of its application.

776589 . In addition, Ms. Button persuasively and credibly testified that even if

7778Westside erred in selecting " Yes " in response to question 11.c., it is so minor

7792as to constitute a waivable, minor irregularity because Florida Housing has

7803th e required information within the application (the executed form and a link

7816to the local community revitalization plan at Attachment 18).

782590 . HTG Addison’s reliance on Berkeley Landing, Ltd. , and Berkely

7836Landing Developer, LLC v. Florida Housing Finance Co rporation , Cas e

7847No. 20 - 0 140BID (Fla. DOAH Apr. 6, 2020; F HFC Apr. 17, 2020), is misplaced.

7864That case involved materially contradictory information regarding an eligibility requirement of the RFA. The Berkeley Landing application named an individual as its authorized principal representative, but that individual

7892did not meet the requirements of the RFA to be an authorized principal representative. As detailed above, the answer to Question 11.c. in the instant

7917case did not relate to a requirement of the RFA a nd Westside submitted the

7932proper documentation required by the RFA to demonstrate it qualifies for the

7944funding goal.

794691 . In sum, HTG Addison failed to demonstrate that Florida Housing’s

7958propos ed action finding the Westside application eligible is con trary to

7970governing statutes, rules, the RFA specifications, or clearly erroneous,

7979contrary to competition, arbitrary, or capricious. In sum, Westside is eligible

7990for funding.

7992R ECOMMENDATION

7994Based on the foregoing Findings of Fact and Conclusions of Law, i t is

8008R ECOMMENDED that Florida Housing Finance Corporation enter a final order:

8019(1) dismissing the protests of HTG Addison and Madison Oaks; (2) finding the

8032HTG Edgewood, Diplomat , and Madison Oaks applications ineligible for

8041funding; an d (3) finding the Ro chester , Madison Square, Tranquility, and

8053Westside applications eligible for funding.

8058D ONE A ND E NTERED this 19th day of June, 2020 , in Tallahassee, Leon

8073County, Florida.

8075D ARREN A. S CHWARTZ

8080Administrative Law Judge

8083Division of Administ rative Hearings

8088The DeSoto Building

80911230 Apalachee Parkway

8094Tallahassee, Florida 32399 - 3060

8099(850) 488 - 9675

8103Fax Filing (850) 921 - 6847

8109www.doah.state.fl.us

8110Filed with the Clerk of the

8116Division of Administrative Hearings

8120this 19 th day of June , 2020 .

8128C OPIES F U RNISHED :

8134Hugh R. Brown, General Counsel

8139Florida Housing Finance Corporation

8143227 North Bronough Street , Suite 5000

8149Tallahassee, Florida 32301 - 1329

8154(eServed)

8155Maureen McCarthy Daughton, Esquire

8159Maureen McCarthy Daughton, LLC

81631400 Village Square Boulevard , Suite 3 - 231

8171Tallahassee, Florida 32312

8174(eServed)

8175Amy Wells Brennan, Esquire

8179Manson Bolves Donaldson Varn, P.A.

8184109 North Brush Street , Suite 300

8190Tampa, Florida 33602

8193(eServed)

8194Michael P. Donaldson, Esquire

8198Carlton Fields

8200215 South Monroe Street , Suite 500

8206Tallahassee, Florida 32302

8209(eServed)

8210Sarah Pape, Esquire

8213Zimmerman, Kiser & Sutcliffe, P.A.

8218315 East Robinson Street, Suite 600

8224Post Office Box 3000 (32802)

8229Orlando, Florida 32801

8232(eServed)

8233J. Timothy Schulte, Esquire

8237Zimmerman, Kiser & Sutcliffe, P.A.

8242315 East Robinson Street

8246Post Office Box 3000 (32802)

8251Orlando, Florida 32801

8254(eServed)

8255Craig D. Varn, Esquire

8259Manson Bolves Donaldson Varn, P.A.

8264106 East College Avenue , Suite 820

8270Tallahassee, Florida 32301

8273(eServed)

8274Donna Elizabeth Blanton, Esqui re

8279Radey Law Firm, P.A.

8283301 South Bronough Street , Suite 200

8289Tallahassee, Florida 32301

8292(eServed)

8293M. Christopher Bryant, Esquire

8297Oertel, Fernandez, Bryant & Atkinson, P.A.

8303Post Office Box 1110

8307Tallahassee, Florida 32302 - 1110

8312(eServed)

8313Betty Zachem, Esq uire

8317Florida Housing Finance Corporation

8321227 North Bronough Street , Suite 5000

8327Tallahassee, Florida 32301

8330(eServed)

8331Corporation Clerk

8333F lorida H ousing F inance C orporation

8341227 North Bronough Street , Suite 5000

8347Tallahassee, Florida 32301 - 1329

8352(eServed)

8353N OTICE OF R IGHT T O S UBMIT E XCEPTIONS

8364All parties have the right to submit written exceptions within 1 0 days from

8378the 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.

Select the PDF icon to view the document.
PDF
Date
Proceedings
PDF:
Date: 07/20/2020
Proceedings: Agency Final Order filed.
PDF:
Date: 07/17/2020
Proceedings: Agency Final Order
PDF:
Date: 06/19/2020
Proceedings: Recommended Order
PDF:
Date: 06/19/2020
Proceedings: Recommended Order (hearing held May 8, 2020). CASE CLOSED.
PDF:
Date: 06/19/2020
Proceedings: Recommended Order cover letter identifying the hearing record referred to the Agency.
PDF:
Date: 06/17/2020
Proceedings: Order Granting Petitioners, Madison Oaks East, LLC, and ARC 2019, LLC's Motion to Correct the Trial Transcript.
PDF:
Date: 06/17/2020
Proceedings: Petitioners, Madison Oaks East, LLC and ARC 2019, LLC's Motion to Correct the Trial Transcript filed.
PDF:
Date: 06/01/2020
Proceedings: Florida Housing Finance Corporation's Proposed Recommended Order filed.
PDF:
Date: 06/01/2020
Proceedings: Proposed Recommended Order filed.
PDF:
Date: 06/01/2020
Proceedings: Intervenors Tranquility Milton LLC, Diplomat South, LLC and Westside Phase I, LLLP's Notice of Filing Proposed Recommended Order filed.
PDF:
Date: 06/01/2020
Proceedings: HTG Addison II, LLC's Proposed Recommended Order (filed in Case No. 20-001778BID).
PDF:
Date: 06/01/2020
Proceedings: Petitioners, Madison Oaks East, LLC, and ARC 2019, LLC's Notice of Filing Clean Copy of Exhibit 2 filed.
PDF:
Date: 06/01/2020
Proceedings: Petitioners, Madison Oaks East, LLC, and ARC 2019, LLC's Recommended Proposed Order filed.
PDF:
Date: 06/01/2020
Proceedings: Petitioners, Madison Square, LLC, and ARC 2019, LLC's, Proposed Recommended Order filed.
PDF:
Date: 05/27/2020
Proceedings: Petitioners Rochester Park, Ltd. and Rochester Park Developer, LLC's Proposed Recommended Order filed.
PDF:
Date: 05/21/2020
Proceedings: Notice of Filing Transcript.
Date: 05/21/2020
Proceedings: Transcript of Proceedings (not available for viewing) filed.
PDF:
Date: 05/12/2020
Proceedings: Joint Stipulation filed.
Date: 05/08/2020
Proceedings: CASE STATUS: Hearing Held.
Date: 05/08/2020
Proceedings: Petitioner's Proposed Exhibits filed (exhibits not available for viewing).
PDF:
Date: 05/07/2020
Proceedings: Notice of Filing Correct Joint Exhibit 4 filed (exhibit not available for viewing).
PDF:
Date: 05/07/2020
Proceedings: Order Severing Case, Closing File, and Relinquishing Jurisdiction. (DOAH Case No. 20-1776BID is Closed.)
PDF:
Date: 05/07/2020
Proceedings: Petitioners, Madison Oaks East, LLC, and ARC 2019, LLC's Notice of Filing Exhibit (Exh. 8 Todd Wind Depo) filed.
Date: 05/07/2020
Proceedings: Petitioner's Proposed Exhibits filed (exhibits not available for viewing).
PDF:
Date: 05/06/2020
Proceedings: Joint Pre-hearing Stipulation filed.
PDF:
Date: 05/06/2020
Proceedings: Petitioners, Madison Oaks East, LLC and ARC 2019, LLC's Notice of Filing Exhibit filed. DUPLICATE
PDF:
Date: 05/06/2020
Proceedings: Tranquility Milton, LLC, Notice of Voluntary Dismissal filed.
Date: 05/06/2020
Proceedings: Petitioner's Proposed Exhibits filed (exhibits not available for viewing).
Date: 05/06/2020
Proceedings: Petitioner's Proposed Supplemental Exhibits filed (exhibits not available for viewing).
PDF:
Date: 05/06/2020
Proceedings: Notice of Filing Correct Joint Exhibit 4 filed.
PDF:
Date: 05/06/2020
Proceedings: Petitioners, Madison Oaks East, LLC, and ARC 2019, LLC's Notice of Filing Exhibit filed.
PDF:
Date: 05/05/2020
Proceedings: Petitioners, Madison Oaks East, LLC and ARC 2019, LLC's Notice of Supplemental Filing of Exhibits filed.
PDF:
Date: 05/05/2020
Proceedings: Petitioners' Rochester Park, Ltd. and Rochester Park Developer, LLC's Amended Notice of Filing Exhibits filed.
PDF:
Date: 05/05/2020
Proceedings: Order Severing Case, Closing File, and Relinquishing Jurisdiction. (Case No. 20-1777, CASE CLOSED.)
PDF:
Date: 05/05/2020
Proceedings: Order Severing Case, Closing File, and Relinquishing Jurisdiction. (Case No. 20-1775 CASE CLOSED.)
PDF:
Date: 05/05/2020
Proceedings: Petitioners' Rochester Park, Ltd. and Rochester Park Developer, LLC's Notice of Filing Exhibits filed.
PDF:
Date: 05/05/2020
Proceedings: Tranquility & Westside Exhibits filed (exhibits not available for viewing).
PDF:
Date: 05/05/2020
Proceedings: Stipulation for Entry of Findings of Fact and Recommended Order in Favor of Madison Square and ARC 2019 filed.
PDF:
Date: 05/05/2020
Proceedings: Unopposed Motion to Amend Tranquility Milton, LLC's Notice of Appearance filed.
Date: 05/05/2020
Proceedings: Petitioner's Proposed Exhibits filed (exhibits not available for viewing).
Date: 05/05/2020
Proceedings: Petitioner's Proposed Exhibits filed (exhibits not available for viewing).
PDF:
Date: 05/05/2020
Proceedings: Notice of Filing of Proposed Exhibits filed.
PDF:
Date: 05/04/2020
Proceedings: Notice of Filing of Proposed Exhibits filed.
PDF:
Date: 05/04/2020
Proceedings: Joint Exhibits filed (exhibits not available for viewing).
PDF:
Date: 05/04/2020
Proceedings: Intervenor Retreat at Cocoa Commons, LLC's Notice of Filing Proposed Final Hearing Exhibit filed (exhibit not available for viewing).
PDF:
Date: 05/04/2020
Proceedings: Petitioners, Madison Square, LLC and ARC 2019, LLC's Notice of Filing Exhibits filed.
PDF:
Date: 05/04/2020
Proceedings: Petitioner's Madison Oaks East, LLC and ARC 2019, LLC's Notice of Filing Exhibits filed.
PDF:
Date: 05/04/2020
Proceedings: Intervenor Retreat at Cocoa Commons, LLC's Notice of Filing Proposed Final Hearing Exhibit filed.
PDF:
Date: 05/04/2020
Proceedings: Notice of Filing Joint Exhibits filed.
Date: 05/04/2020
Proceedings: Petitioner's Proposed Exhibits filed (exhibits not available for viewing).
PDF:
Date: 05/04/2020
Proceedings: Amended Notice Hearing by Zoom Conference (hearing set for May 8 and 11, 2020; 9:00 a.m.; amended as to Zoom meeting information).
PDF:
Date: 05/04/2020
Proceedings: Notice of Filing Proposed Exhibits filed.
PDF:
Date: 05/04/2020
Proceedings: Stipulation for Entry of Findings of Fact and Recommended Order in Favor of Petitioners Rochester Park, Ltd. and Rochester Park Developer, LLC filed.
PDF:
Date: 05/04/2020
Proceedings: Petitioners' Notice of Partial Voluntary Dismissal filed.
PDF:
Date: 05/04/2020
Proceedings: Weldon Crossings, LLC's, Notice of Withdrawal of Notice of Appearance filed.
PDF:
Date: 05/04/2020
Proceedings: Turnstone Eustis LP's Notice of Voluntary Dismissal (filed in Case No. 20-001776BID).
PDF:
Date: 05/01/2020
Proceedings: Madison Oaks East, LLC and ARC 2019, LLC's Notice of Service of First Interrogatories to Florida Housing Finance Corporation filed.
PDF:
Date: 04/30/2020
Proceedings: Petitioners Rochester Park, Ltd. and Rochester Park Developer, LLC's Cross-Notice of Taking Deposition of Marisa Button filed.
PDF:
Date: 04/30/2020
Proceedings: Madison Oaks East, LLC, and ARC 2019, LLC's, Amended Notice of Taking Deposition Duces Tecum of Corporate Representative of Tranquility Milton, LLC filed.
PDF:
Date: 04/30/2020
Proceedings: Madison Square, LLC, and ARC 2019, LLC's, Cross-Notice of Taking Deposition of Corporate Representative of Florida Housing Finance Corporation filed.
PDF:
Date: 04/30/2020
Proceedings: Tranquility Milton, LLC's Cross-Notice of Taking Deposition of Stacy Banach filed.
PDF:
Date: 04/30/2020
Proceedings: Westside Phase I, LLLP's Cross-Notice of Taking Deposition of Marisa Button filed.
PDF:
Date: 04/30/2020
Proceedings: Turnstone Eustis, LP's Cross-Notice of Taking Deposition of Marisa Button filed.
PDF:
Date: 04/30/2020
Proceedings: Tranquility Milton, LLC's Cross-Notice of Taking Deposition of Marisa Button filed.
PDF:
Date: 04/30/2020
Proceedings: Order Granting Unopposed Motion to Amend Retreat at Cocoa Commons, LLC's, Notice of Appearance of a Specifically Named Party.
PDF:
Date: 04/30/2020
Proceedings: Order Granting Turnstone Eustis LP's Motion for Leave to Amend Formal Written Protest and Petition for Administrative Proceeding.
PDF:
Date: 04/30/2020
Proceedings: Order Granting Petitioners' Rochester Park, Ltd. and Rochester Park Developers, LLC Motion for Leave to Amend.
PDF:
Date: 04/30/2020
Proceedings: Intervenor Retreat at Cocoa Commons, LLC's Notice of Taking Deposition of Stacy Banach filed.
PDF:
Date: 04/30/2020
Proceedings: Second Request for Production of Documents to Madison Oaks East, LLC from Intervenor Retreat at Cocoa Commons, LLC filed.
PDF:
Date: 04/30/2020
Proceedings: Turnstone Eustis, LP's Notice of Serving Verified Responses to Weldon Crossings, LLC's First Set of Interrogatories filed.
PDF:
Date: 04/29/2020
Proceedings: Turnstone Eustis LP's Responses to Weldon Crossings, LLC's First Request for Admissions filed.
PDF:
Date: 04/29/2020
Proceedings: Turnstone Eustis, LP's Notice of Serving Unverified Responses to Weldon Crossings, LLC's First Set of Interrogatories filed.
PDF:
Date: 04/29/2020
Proceedings: Madison Oaks East, LLC, and ARC 2019, LLC's, Notice of Taking Deposition of Corporate Representative of Tranquility Milton, LLC filed.
PDF:
Date: 04/29/2020
Proceedings: Intervenor, HTG Edgewood, Ltd's Notice of Service of Responses to Interrogatories Propounded by Petitioner Rochester Park, Ltd and Rochester Park Developer, LLC filed.
PDF:
Date: 04/29/2020
Proceedings: Tranquility Milton, LLC's Notice of Serving Verified Responses to Madison Oaks East, LLC and ARC 2019, LLC's First Set of Interrogatories filed.
PDF:
Date: 04/29/2020
Proceedings: Petitioners Rochester Park, Ltd. and Rochester Park Developer, LLC's Notice of Cancellation of Deposition Duces Tecum of Mark McQueen filed.
PDF:
Date: 04/29/2020
Proceedings: Tranquility Milton, LLC's Responses to Madison Oaks East, LLC and ARC 2019, LLC's First Request for Production of Documents filed.
PDF:
Date: 04/29/2020
Proceedings: Intervenor, HTG Edgewood, Ltd.'s Cross Notice of Taking Depositions of Mike Lane and Mark McQueen filed.
PDF:
Date: 04/29/2020
Proceedings: Tranquility Milton, LLC's Responses to Madison Oaks East, LLC and ARC 2019, LLC's First Request for Admissions filed.
PDF:
Date: 04/29/2020
Proceedings: Tranquility Milton, LLC's Notice of Serving Unverified Responses to Madison Oaks East, LLC and ARC 2019, LLC's First Set of Interrogatories filed.
PDF:
Date: 04/28/2020
Proceedings: Madison Oaks East, LLC's Response to Retreat at Cocoa Commons, LLC's Request for Production filed.
PDF:
Date: 04/28/2020
Proceedings: Madison Oaks East, LLC, and ARC 2019, LLC's Response to Tranquility Milton, LLC's First Request for Production filed.
PDF:
Date: 04/28/2020
Proceedings: Madison Oaks East, LLC's Notice of Service of Answers to Retreat at Cocoa Commons, LLC's First Interrogatories filed.
PDF:
Date: 04/28/2020
Proceedings: Madison Oaks East, LLC, and ARC 2019, LLC's Notice of Service of Answers to Tranquility Milton, LLC's First Interrogatories filed.
PDF:
Date: 04/28/2020
Proceedings: Madison Oaks East, LLC and ARC 2019, LLC's Response to Tranquility Milton, LLC's First Request for Admissions filed.
PDF:
Date: 04/28/2020
Proceedings: Intervenor Retreat at Cocoa Commons, LLC's Cross-Notice of Taking deposition of Marisa Button filed.
PDF:
Date: 04/28/2020
Proceedings: Madison Oaks East, LLC, and ARC 2019, LLC's, Notice of Taking Deposition of Corporate Representative of Florida Housing Finance Corporation filed.
PDF:
Date: 04/27/2020
Proceedings: Notice of Service of Florida Housing Finance Corporation's Answers to Petitioner HTG Addison II, LLC's First Set of Interrogatories filed.
PDF:
Date: 04/27/2020
Proceedings: Notice of Cancellation of Depositions filed.
PDF:
Date: 04/27/2020
Proceedings: Retreat at Cocoa Commons, LLC's Notice of Service of Sworn Answers to Madison Oaks East, LLC and ARC 2019, LLC's First Set of Interrogatories filed.
PDF:
Date: 04/27/2020
Proceedings: Retreat at Cocoa Commons, LLC's Response to Madison Oaks East, LLC's and ARC 2019, LLC's First Request for Production filed.
PDF:
Date: 04/27/2020
Proceedings: Florida Housing Finance Corporation's Response to Petitioner Madison Oaks East, LLC and ARC 2019, LLC's Request for Production filed.
PDF:
Date: 04/27/2020
Proceedings: Florida Housing Finance Corporation's Response to Petitioner HTG Edgewood, Ltd's Request for Admissions filed.
PDF:
Date: 04/27/2020
Proceedings: Florida Housing Finance Corporation's Response to Petitioner HTG Addison II, LLC's Request for Admissions filed.
PDF:
Date: 04/27/2020
Proceedings: Florida Housing Finance Corporation's Response to Petitioner Madison Square, LLC and ARC 2019, LLC's Request for Production filed.
PDF:
Date: 04/27/2020
Proceedings: Meadowlark Court, Ltd.'s Notice of Voluntary Dismissal filed.
PDF:
Date: 04/27/2020
Proceedings: HTG Edgewood, Ltd.'s Responses to Petitioners Rochester Park, LTd. and Rochester Park Developer, LLC's First Request for Admissions filed.
PDF:
Date: 04/24/2020
Proceedings: Petitioners Rochester Park, Ltd. and Rochester Park Developer, LLC's Notice of Taking Depositions Duces Tecum filed.
PDF:
Date: 04/24/2020
Proceedings: Weldon Crossing LLC's First Requests for Admission to Petitioner Turnstone Eustis, LP filed.
PDF:
Date: 04/24/2020
Proceedings: Intervenor Weldon Crossings, LLC's Notice of Service of First Set of Interrogatories to Petitioner Turnstone Eustis, LP filed.
PDF:
Date: 04/23/2020
Proceedings: Madison Square, LLC, and ARC 2019, Notice of Taking Deposition Duces Tecum of Records Custodian of Habitat Diplomat, LLC filed.
PDF:
Date: 04/23/2020
Proceedings: Madison Square, LLC, and ARC 2019, LLC's Notice of Taking Deposition Duces Tecum of Corporate Representative of Habitat Diplomat, LLC filed.
PDF:
Date: 04/23/2020
Proceedings: Motion to Amend HTG Oak Villas, LLCs Notice of Appearance of a Named Party filed.
PDF:
Date: 04/23/2020
Proceedings: Motion for Leave to Amend Formal Written Protest and Petition for Administrative Proceeding filed.
PDF:
Date: 04/23/2020
Proceedings: Notice of Service of First Set of Interrogatories to Madison Oaks East, LLC from Intervenor Retreat at Cocoa Commons, LLC filed.
PDF:
Date: 04/23/2020
Proceedings: First Request for Production of Documents to Madison Oaks East, LLC from Intervenor Retreat at Cocoa Commons, LLC filed.
PDF:
Date: 04/22/2020
Proceedings: Madison Square, LLC and ARC 2019, LLC"s Request for Production to Florida Housing Finance Corporation filed.
PDF:
Date: 04/22/2020
Proceedings: Madison Square, LLC and ARC 2019, LLC's Request for Production to Diplomat South, LLC, filed.
PDF:
Date: 04/22/2020
Proceedings: Madison Square, LLC, and ARC 2019, LLC's Notice of Service of First Interrogatories to Diplomat South, LLC, filed.
PDF:
Date: 04/22/2020
Proceedings: Madison Oaks East, LLC and ARC 2019, LLC"s Request for Production to Tranquility Milton, LLC, filed.
PDF:
Date: 04/22/2020
Proceedings: Madison Oaks East, LLC and ARC 2019, LLC's Request for Production to Retreat at Cocoa Commons, LLC, filed.
PDF:
Date: 04/22/2020
Proceedings: Madison Oaks East, LLC and ARC 2019, LLC's Request for Production to Florida Housing Finance Corporation filed.
PDF:
Date: 04/22/2020
Proceedings: Madison Oaks, East, LLC, and ARC 2019, LLC's Request for Admissions to Tranquility Milton, LLC, filed.
PDF:
Date: 04/22/2020
Proceedings: Madison Oaks, East, LLC, and ARC 2019, Notice of Service of First Interrogatories to Tranquility Milton, LLC, filed.
PDF:
Date: 04/22/2020
Proceedings: Weldon Crossings, LLC's Responses to Petitioner Turnstone Eustis, LP's First Request for Production of Documents filed.
PDF:
Date: 04/22/2020
Proceedings: Intervenor Weldon Crossings, LLC's Responses to PetitionerTurnstone Eustis, LP's First Request for Admissions filed.
PDF:
Date: 04/22/2020
Proceedings: Madison Oaks, East, LLC, and ARC 2019, LLC"s Notice of Service of First Interrogatories to Retreat at Cocoa Commons, LLC filed.
PDF:
Date: 04/22/2020
Proceedings: Intervenor Weldon Crossings, LLC's Notice of Service of Answers to Turnstone Eustis, LP's First Set of Interrogatories filed.
PDF:
Date: 04/22/2020
Proceedings: Petitioners Rochester Park, Ltd. and Rochester Park Developer, LLC's Notice of Unverified Responses to HTG Edgewood, Ltd.'s First Set of Interrogatories filed.
PDF:
Date: 04/22/2020
Proceedings: Tranquility Milton, LLC's First Request for Production to Madison Oaks East, LLC and ARC 2019, LLC filed.
PDF:
Date: 04/22/2020
Proceedings: Tranquility Milton, LLC's First Request for Admissions to Madison Oaks East, LLC and ARC 2019, LLC filed.
PDF:
Date: 04/22/2020
Proceedings: Tranquility Milton, LLC's Notice of Serving First Set of Interrogatories to Madison Oaks East, LLC and ARC 2019, LLC filed.
PDF:
Date: 04/22/2020
Proceedings: Petitioners Rochester Park, Ltd. and Rochester Park Developer, LLC's First Request for Admissions to HTG Edgewood, Ltd filed.
PDF:
Date: 04/22/2020
Proceedings: Petitioners Rochester Park, Ltd. and Rochester Park Developer, LLC's Notice of Service of First Set of Interrogatories to HTG Edgewood, Ltd filed.
PDF:
Date: 04/22/2020
Proceedings: Intervenor HTG Oak Villas, LLC's First Request for Production of Documents to Meadowlark Court, Ltd filed.
PDF:
Date: 04/22/2020
Proceedings: Intervenor, HTG Oak Villas, LLC's Notice of Service of First Set of Interrogatories to Petitoner Meadowlark Court, Ltd filed.
PDF:
Date: 04/22/2020
Proceedings: Unopposed Motion to Amend Retreat at Cocoa Commons LLC's Notice of Appearance of a Specifically Named Party (filed in Case No. 20-001780BID).
PDF:
Date: 04/21/2020
Proceedings: Intervenor, HTG Edgewood Ltd.'s, First Request for Admissions to Florida Housing Finance Corporation filed.
PDF:
Date: 04/20/2020
Proceedings: HTG Addison II, LLC's Notice of Service of Interrogatories to Respondent Florida Housing Finance Corporation filed.
PDF:
Date: 04/20/2020
Proceedings: Petitioner HTG Addison, II, LLC's First Request for Admissions to Florida Housing Finance Corporation filed.
PDF:
Date: 04/20/2020
Proceedings: Petitioners Rochester Park, Ltd., and Rochester Park Developer, LLC's Motion for Leave to Amend filed.
PDF:
Date: 04/17/2020
Proceedings: Order of Consolidation (DOAH Case Nos. 20-1770, 20-1775, 20-1776, 20-1777, 20-1778, 20-1779, 20-1780)
PDF:
Date: 04/17/2020
Proceedings: Turnstone Eustis LP's First Request for Production to Weldon Crossing, LLC filed.
PDF:
Date: 04/17/2020
Proceedings: Turnstone Eustis LP's First Request for Admissions to Weldon Crossing, LLC filed.
PDF:
Date: 04/17/2020
Proceedings: Turnstone Eustis LP's Notice of Serving First Set of Interrogatories to Weldon Crossing, LLC, filed.
PDF:
Date: 04/17/2020
Proceedings: Intervenor HTG Edgewood, Ltd's Notice of Service of First Set of Interrogatories to Petitioner Rochester Park Developer, LLC filed.
PDF:
Date: 04/17/2020
Proceedings: Order of Pre-hearing Instructions.
PDF:
Date: 04/17/2020
Proceedings: Notice of Hearing by Zoom Conference (hearing set for May 8 and 11, 2020; 9:00 a.m.).
Date: 04/15/2020
Proceedings: CASE STATUS: Status Conference Held.
PDF:
Date: 04/15/2020
Proceedings: Notice of Appearance (Michael P. Donaldson).
PDF:
Date: 04/15/2020
Proceedings: Notice of Transfer.
PDF:
Date: 04/09/2020
Proceedings: Unopposed Motion to Consolidate Cases.
PDF:
Date: 04/09/2020
Proceedings: Notice of Appearance (Betty Zachem).
PDF:
Date: 04/09/2020
Proceedings: Notice of Appearance/Motion to Intervene (Tranquility Milton, LLC; Michael Donaldson).
PDF:
Date: 04/09/2020
Proceedings: Noticed to All Bidders on RFA 2019-113 filed.
PDF:
Date: 04/09/2020
Proceedings: Formal Written Protest and Petition for Administrative Hearing filed.
PDF:
Date: 04/09/2020
Proceedings: Agency referral filed.

Case Information

Judge:
DARREN A. SCHWARTZ
Date Filed:
04/09/2020
Date Assignment:
04/15/2020
Last Docket Entry:
07/20/2020
Location:
Tallahassee, Florida
District:
Northern
Agency:
ADOPTED IN TOTO
Suffix:
BID
 

Counsels

Related DOAH Cases(s) (4):

Related Florida Statute(s) (6):