96-000286 Frank T. Brogan, As Commissioner Of Education vs. Eston Mansfield Status: Closed Recommended Order on Thursday, August 1, 1996.

Summary: Photographing nonstudent minor naked and in lingerie not shown to constitute act of gross immorality or to seriously reduce effectiveness as teacher.

STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

FRANK T. BROGAN, as Commissioner )

of Education, )

)

Petitioner, )

)

vs. ) CASE NO. 96-0286

)

ESTON MANSFIELD, )

)

Respondent. )

__________________________________)

RECOMMENDED ORDER

Pursuant to notice, the Division of Administrative Hearings, by its

designated Hearing Officer, William J. Kendrick, held a formal hearing in the

above-styled case on May 21, 1996, in Miami, Florida.

APPEARANCES

For Petitioner: Bruce Taylor, Esquire

501 First Avenue North, Suite 600

St. Petersburg, Florida 33701

For Respondent: Sheldon Zipkin, Esquire

Twenty Twenty Professional Center

2020 Northeast 163rd Street, Suite 300

North Miami Beach, Florida 33162

STATEMENT OF THE ISSUE

At issue in this proceeding is whether respondent committed the offenses

alleged in the administrative complaint, as amended, and, if so, what

disciplinary action should be taken.

PRELIMINARY STATEMENT

By administrative complaint dated October 3, 1995, as amended at hearing,

1/ petitioner charged that respondent, the holder of a Florida teaching

certificate, had, on or about February 25, 1993, provided A. E., a 15-year-old

female, with an alcoholic beverage and took several photographs of her in

lingerie, as well as 20 to 30 nude photographs. It was further alleged that

while taking the nude photographs, respondent rubbed A. E.'s breasts with his

hands and fingers, as well as his mouth, so that her nipples would be "hard for

the pictures." As a consequence, petitioner contended that respondent violated

the provisions of Subsections 231.28(1)(c), (f) and (i), Florida Statutes, and

Rules 6B-1.006(3)(a), (e), and (f), Florida Administrative Code.

Respondent filed an election of rights which disputed the allegations of

the administrative complaint, and requested a formal hearing. Consistent with

such election, petitioner referred the matter to the Division of Administrative

Hearings for the assignment of a Hearing Officer to conduct a formal hearing

pursuant to Section 120.57(1), Florida Statutes.

At hearing, petitioner called A. E. and Wendy Colvin, as witnesses, and its

exhibit 1 was received into evidence. Respondent testified on his own behalf,

but offered no exhibits.

The transcript of the hearing was filed June 7, 1996, and the parties were

accorded ten days from that date to file proposed recommended orders.

Petitioner elected to file such a proposal, and the proposed findings of fact

contained therein are addressed in the appendix to this recommended order.

FINDINGS OF FACT

Preliminary matters

1. At all times material hereto, respondent, Eston Mansfield, held Florida

teaching certificate number 691581, covering the area of middle grades

mathematics, grades 5 through 9. Such certificate expired June 30, 1995.

2. At the time of the incidents at issue, respondent was, from time to

time, employed as a substitute teacher by the School Board of Dade County,

Florida, and the School Board of Broward County, Florida. Moreover, during such

times, respondent was also self-employed, as a professional photographer.

The incident in question

3. In or about February 1993, A. E., a fifteen year old female, was

referred to respondent, who she understood to be a professional photographer.

2/ At the time, A. E. was entertaining an interest in modeling, and had need

for a modeling portfolio.

4. A. E. and respondent spoke by telephone, and respondent agreed to do

the photographs for the portfolio, and quoted a price between $1,500 and $2,000.

When A. E. told respondent she could not afford the cost, respondent countered

by telling her that he was looking for a model to practice some nude photography

and that if she would agree to pose for the photographs he would do the

photographs for the portfolio at no charge. A. E. agreed to the trade.

5. At the time A. E. spoke with respondent, she was not a student, having

"legally withdrawn" from school, was sharing an apartment with her older sister,

age 18, and their respective boyfriends. A. E.'s boyfriend at the time was

older than A. E., and A. E., although underage, was not a stranger to alcohol.

6. Although A. E. and respondent had no personal contact prior to their

telephone conversation, respondent had visited with her sister in the past, in

an effort to interest her in a wedding portfolio, and was aware of A. E. and her

living arrangements. Respondent was further aware that A. E. was the younger of

the two sisters and knew, before the photography session hereinafter discussed,

that A. E. was 15 years of age.

7. In February or March, 1993, A. E., together with her friend, Wendy

Colvin, went to respondent's home for the anticipated photography session. As

described at hearing, respondent's home included an area that was suitably

equipped for professional photography and the session, based on the persuasive

proof, appears to have been conducted in a professional manner. 3/

8. Before the session began, respondent offered and A. E. accepted an

alcoholic drink to help her "relax". Thereafter, A. E. posed in several sets of

lingerie that she had brought for the session, and then posed for a number of

nude photographs.

9. Apart from the observation that some of the lingerie A. E. wore was her

sister's wedding lingerie, the record is devoid of any descriptive observations

from which one could draw any reliable, as opposed to speculative, conclusion as

to its character. Likewise, the record is largely devoid of any descriptive

observations of the lingerie or nude photographs, such that one cannot draw any

reliable, as opposed to speculative, conclusion regarding their character or

content.

10. Notably, the photographs were not exhibited or offered at hearing, and

only the vaguest of descriptions elicited from the witnesses. In A. E.'s

opinion, some of the photographs "were tasteful, some were not." In

respondent's opinion, some of the photographs that might be described as

"tasteless" did not meet "a professional standard," which he attributed to A.

E.'s amateur status and unfamiliarity with proper positioning or posing. 4/

11. Given the paucity of proof concerning the character or content of the

photographs, it cannot be concluded that the photographs, in whole or in part,

offended contemporary community standards by predominantly appealing to

prurient, shameful or morbid interest, that the photographs were without any

serious artistic value, or that the photographs were otherwise obscene, as that

term is commonly understood. Moreover, there was no proof offered, by student,

teacher, or otherwise, that respondent's practice of nude photography, albeit

with a 15-year-old girl, otherwise offended community values or reduced his

effectiveness as a teacher.

CONCLUSIONS OF LAW

12. The Division of Administrative Hearings has jurisdiction over the

parties to and the subject matter of these proceedings. Sections 120.57(1) and

231.262(5), Florida Statutes.

13. Where, as here, it is proposed that the Education Practices Commission

take action to revoke, suspend, or otherwise discipline the certificate of a

teacher, petitioner bears the burden of proving the charges contained in the

administrative complaint by clear and convincing evidence. Ferris v.

Turlington, 510 So.2d 292 (Fla. 1987). "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."

Slomowitz v. Walker, 492 So.2d 797, 800 (Fla. 4th DCA 1983).

14. Moreover, in determining whether respondent violated the provisions of

Section 231.28, as alleged in the administrative complaint, one "must bear in

mind that it is, in effect, a penal statute . . . This being true, the statute

must be strictly construed and no conduct is to be regarded as included within

it that is not reasonably proscribed by it. Furthermore, if there are any

ambiguities included such must be construed in favor of the licensee." Lester

v. Department of Professional and Occupational Regulation, 348 So.2d 923, 925

(Fla. 1st DCA 1977). Finally, the disciplinary action taken can be based only

upon the facts specifically alleged in the administrative complaint. See,

MacMillan v. Nassau County School Board, 629 So.2d 226 (Fla. 1st DCA 1993),

Kinney v. Department of State, 501 So.2d 129 (Fla. 1st DCA 1987), and Hunter v.

Department of Professional Regulation, 458 So.2d 842 (Fla. 2d DCA 1984).

15. Pertinent to this case, the administrative complaint charges that by

providing A. E., age 15, with an alcoholic beverage, and taking photographs of

her in lingerie, as well as nude photographs, respondent violated the provisions

of subsections 231.28(1)(c), (f), and (i), Florida Statutes, and Rules 6B-

1.006(3)(a), (e), and (f), Florida Administrative Code.5

16. Those provisions of subsection 231.28(1), relied upon by petitioner,

authorize the Education Practices Commission to revoke, suspend or otherwise

discipline a teaching certificate provided that it can be shown the teacher:

(c) Has been guilty of gross immorality or

an act involving moral turpitude;

* * *

(f) Upon investigation, has been found guilty

of personal conduct which seriously reduces that

person's effectiveness as an employee of the

school board;

* * *

(i) Has violated the Principles of Professional

Conduct for the Education Profession described by

State Board of Education rules....

To sustain the alleged violation of subsection 231.28(1)(i), petitioner relies

upon the provisions of Rule 6B-1.006, which provides:

(1) The following disciplinary rule shall

constitute the Principles of Professional Conduct

for the Education Profession in Florida.

(2) Violation of any of these principles shall

subject the individual to revocation or suspension

of the individual educator's certificate, or the

other penalties as provided by law.

(3) Obligation to the student requires that

the individual:

(a) Shall make reasonable effort to protect

the student from conditions harmful to learning

and/or to the student's mental and/or physical

health and/or safety.

* * *

(e) Shall not intentionally expose a student

to unnecessary embarrassment or disparagement.

(f) Shall not intentionally violate or deny a

student's legal rights. . . .

17. Addressing first the charge that respondent's conduct violated the

provisions of Rule 6B-1.006(3)(a), (e) and (f), and therefore subsection

231.28(1)(i), Florida Statutes, it is observed that the proof clearly

demonstrates that, at the time of the incident in question, A. E. was not a

student, and the record is devoid of any suggestion or proof that when she was a

student A. E. ever knew of or was associated with respondent in any fashion.

Moreover, the record is devoid of proof from which it could be reasonably

concluded that respondent's conduct exposed A. E. to mental or physical harm,

intentionally exposed A. E. to unnecessary embarrassment or disparagement, or

intentionally violated or denied A. E.'s legal rights. Consequently, the proof

fails to support the conclusion that respondent's conduct violated subsection

231.28(1)(i), Florida Statutes.

18. Having rejected subsection 231.28(1)(i) as a basis for discipline,

this case resolves itself to whether respondent's conduct, under the

circumstances, constitutes "gross immorality or an act involving moral

turpitude", as proscribed by subsection 231.28(1)(c), or "conduct which

seriously reduces. . . [his] . . . effectiveness as an employee of the school

board," as proscribed by subsection 231.28(l)(f).

19. Rule 6B-4.009(2), Florida Administrative Code, defines immorality as

follows:

Immorality is defined as conduct that is

inconsistent with the standards of public

conscience and good morals. It is conduct

sufficiently notorious to bring the individual

concerned or the education profession into

public disgrace or disrespect and impair the

individual's service in the community.

Moreover, the term "gross" in conjunction with "immorality" has heretofore been

found to mean "immorality which involves an act of misconduct that is serious,

rather than minor in nature, and which constitutes a flagrant disregard of

proper moral standards." Education Practice Commission v. Knox, 3 FALR 1373-A

(DOE 1981). Accord, State ex rel. Tullidge v. Hollingsworth, 146 So. 660, 661

(1933), wherein the court concluded:

Moral turpitude [or synonymously, "gross immorality"

as that term is also used in the subject statute]

involves the idea of inherent baseness or depravity

in the private social relations or duties owed by

man to man or by man to society . . . It has also

been defined as anything done contrary to justice,

honesty, principle, or good morals, though it often

involves the question of intent as when uninten-

tionally committed through error of judgment when

wrong was not contemplated.

20. The moral standard to be upheld must be viewed in context with the

profession at issue. See Adams v. Professional Practices Council, 406 So.2d

1170 (Fla. 1st DCA 1981). Teachers "charged by Sections 231.09 and 231.28(1)

with providing leadership and maintaining effectiveness as teachers . . . are

traditionally held to a high moral standard in the community." Adams, supra, at

page 1172. Accord, Tomerlin v. Dade County School Board, 318 So.2d 159 (Fla.

1st DCA 1975), wherein the court observed at page 160:

A school teacher holds a position of great trust.

We entrust the custody of our children to the teacher.

We look to the teacher to educate and to prepare our

children for their adult lives. To fulfill this

trust, the teacher must be of good moral character;

to require less would jeopardize the future lives

of our children.

21. While teachers are certainly held to a high moral standard in the

community, the quantum of proof adduced in this case fails to substantiate

wrongdoing on respondent's part warranting disciplinary action. In so

concluding, it is observed that the isolated instance of according A. E. one

alcoholic beverage, considering the circumstances, and the act of photographing

A. E., albeit fifteen years of age, in lingerie and nude, was not shown to be a

crime or a violation of any rule or statute. 6/ Moreover, while some segments

of American population might consider respondent's conduct offensive, there was

no proof at hearing that it offended community standards, that it had an adverse

effect on students, or that his effectiveness as a teacher had been impaired.

Consequently, the proof fails to demonstrate, clearly and convincingly, that

respondent's conduct constituted "gross immorality or an act involving moral

turpitude," as proscribed by subsection 231.28(1)(c) or "conduct which seriously

reduces . . . [his] . . . effectiveness as an employee of the school board," as

proscribed by subsection 231.28(1)(f). See, Tenbroeck v. Castor, 640 So.2d 164,

167 (Fla. 1st DCA 1994) ("Speculation, surmise and suspicion cannot form the

basis of disciplinary action against a teacher's professional license."), and

Sherburne v. School Board of Suwannee County, 445 So.2d 1057 (Fla. 1st DCA

1984).

RECOMMENDATION

Based on the foregoing findings of fact and conclusions of law, it is,

hereby, RECOMMENDED:

That a final order be rendered dismissing the charges filed against

respondent.

DONE AND ENTERED this 1st day of August, 1996, in Tallahassee, Leon County,

Florida.

____________________________________

WILLIAM J. KENDRICK, Hearing Officer

Division of Administrative Hearings

The DeSoto Building

1230 Apalachee Parkway

Tallahassee, Florida 32399-1550

[phone] SUNCOM 278-9675

Filed with the Clerk of the

Division of Administrative Hearings

this 1st day of August, 1996.

ENDNOTES

1/ The administrative complaint alleged that "on or about February 25, 1995,

Respondent photographed A. E., a 15-year-old female, at his home." At hearing,

the date was amended to read "February 25, 1993."

2/ A. E. expressed her desire for a modeling portfolio to her friend Wendy

Colvin. At the time, Wendy was 18 years of age, and worked for a company that

catered weddings, bar mitzvahs, and other social events. Respondent frequently

photographed those events, was known to Wendy, and she referred A. E. to

respondent, who she deemed a professional photographer, to do the portfolio

work.

3/ At hearing, A. E. testified on direct examination that before the nude

session began, and while Wendy was in the bathroom, the respondent "told me he

would have to get my nipples hard for the picture" and that he then "used his

fingers and rubbed them." While not mentioned on direct, A. E. elaborated on

cross, and further testified that respondent "licked [her] nipples." Respondent

denied any such activity. Having considered the circumstances, including

respondent's awareness of A. E.'s age, the proximity of Wendy, the fact that A.

E. never mentioned such actions to Wendy, the evolving nature of A. E.'s

testimony, and the professional manner in which the session was apparently

conducted, it is concluded that the proof is not persuasive respondent touched

or licked A. E.'s nipples.

In concluding that the session was apparently professionally conducted,

Wendy's testimony that "[t]he only time I really questioned [respondent's

professionalism] was when he was taking photographs of me" has not been

overlooked. (Such testimony referred to a time respondent was taking

photographs of her in a bathing suit, which occurred while A. E. was in the

bathroom changing for the nude session.) No elaboration of Wendy's comment was

sought at hearing, and the record is quite devoid of any explanation of what she

considered unprofessional. Consequently, such testimony is of little value in

resolving the issues in this case. Notably, however, her observations of the

lingerie and nude session with A. E. speaks positively for respondent's

professionalism.

4/ The only testimony that might arguably shed a different light or suggest a

different conclusion would be A. E.'s testimony at page 15 of the transcript,

where she testified as follows to the question posed:

Q. Do you remember him saying anything to you that was

vulgar while he was taking the pictures?

A. He did made a comment about one of the pictures he

had taken. He said it would have been all, excuse

my language, "pussy in stockings."

However, to attach any significance to that statement, in assessing the

character or content of the photographs, would require unwarranted speculation,

surmise and speculation. Indeed, such comment is as susceptible to an

observation of lack of professional quality, attributable to improper posing, as

it is to any other characterization of the photographs.

5/ As noted in the preliminary statement, the administrative complaint also

charged that respondent rubbed A. E.'s breasts with his hands and fingers, as

well as his mouth, so that her nipples would be "hard for the pictures." As

heretofore found, such allegation has not been sustained by clear and convincing

evidence. Therefore, it is unnecessary to address those allegations further.

6/ Petitioner cited no criminal law violated, and independent research has

disclosed none. In reaching such conclusion, the laws of the State of Florida

governing abuse of children, Chapter 827, Florida Statutes; obscene literature,

profanity, Chapter 847, Florida Statutes; the beverage law, Chapter 562, Florida

Statutes, and in particularly subsection 562.11(1)(a), which was designed to

regulate licensed vendors of alcoholic beverages upon the licensed premises and

not individuals (See, Bonds v. Fleming 539 So.2d 583 (Fla. 5th DCA 1989), and

Bryant v. Pistulka, 366 So.2d 479 (Fla. 1st DCA 1979); and lewdness, Chapter

800, Florida Statutes, have not been overlooked. Respondent's conduct was not,

however, shown to violate any of these statutory prohibitions.

APPENDIX TO RECOMMENDED ORDER, CASE NO. 96-0286

Petitioner's proposed findings of fact are addressed as follows:

1. Addressed in paragraph 1.

2. Addressed in paragraph 2.

3. Addressed in endnote 2.

4. Addressed in paragraph 2.

5. Addressed in endnote 2.

6. Subordinate and unnecessary detail.

7 and 8. Addressed in paragraph 3.

9. Addressed in endnote 2, otherwise contrary to the proof.

10. Unnecessary detail.

11 through 16. Addressed in paragraphs 3 through 6, otherwise subordinate

or unnecessary detail.

17 through 20. Addressed in paragraphs 7 and 8, and endnote 3, otherwise

contrary to the facts as found.

21. Rejected as not relevant in view of the conclusions drawn, as

reflected in endnote 3.

22. Not relevant or unnecessary detail.

23. Not relevant.

24. Addressed in endnote 3, otherwise unnecessary detail.

25. Addressed in endnote 4.

COPIES FURNISHED:

Bruce Taylor, Esquire

501 First Avenue North, Suite 600

St. Petersburg, Florida 33701

Sheldon Zipkin, Esquire

Twenty Twenty Professional Center

2020 Northeast 163rd Street, Suite 300

North Miami Beach, Florida 33162

Karen Barr Wilde, Executive Director

Florida Education Center

224-B Florida Education Center

325 West Gaines Street

Tallahassee, Florida 32399-0400

Kathleen M. Richards, Administrator

Professional Practices Services

352 Fla. Education Center

325 West Gaines Street

Tallahassee, Florida 32399-0400

NOTICE OF RIGHT TO SUBMIT EXCEPTIONS

All parties have the right to submit written exceptions to this Recommended

Order. All agencies allow each party at least 10 days in which to submit

written exceptions. Some agencies allow a larger period within which to submit

written exceptions. You should contact the agency that will issue the final

order in this case concerning agency rules on the deadline for filing exceptions

to this Recommended Order. Any exceptions to this Recommended Order should be

filed with the agency that will issue the final order in this case.

=================================================================

AGENCY FINAL ORDER

=================================================================

STATE OF FLORIDA

EDUCATION PRACTICES COMMISSION

FRANK BROGAN, as

Commissioner of Education,

Petitioner, EPC CASE NO. 95-307-RT

DOAH CASE NO. 96-0286

vs. EPC INDEX NO. 96-160-FOF

ESTON MANSFIELD,

Respondent.

______________________________/

Respondent, ESTON MANSFIELD, held Florida educator's certificate no. 691581

which expired June 30,1995. Petitioner has filed an Administrative Complaint

seeking suspension, revocation, permanent revocation or other disciplinary

action against the certificate.

Respondent requested a formal hearing and such was held before a hearing

officer of the Division of Administrative Hearings. A Recommended Order issued

by the Division Hearing Officer on August 1, 1996, was forwarded to the

Commission pursuant to Section 120.57(1), F.S. (copy attached to and made a part

or this order.)

A panel of the Education Practices Commission (EPC) met on September 27,

1996, in Tampa, Florida, to take final agency action. Petitioner was

represented by David Holder, Attorney at Law. Respondent was neither present

nor represented. The panel reviewed the entire record in this case.

Neither Petitioner nor Respondent filed exceptions to the Recommended

Order.

FINDINGS OF FACT

The Commission adopts as its Findings of Fact paragraphs 1-11 of the

hearing officer's Findings of Fact.

CONCLUSIONS OF LAW

Except as hereafter stated, the Commission adopts paragraphs 12-21 in the

hearing officer's Conclusions of Law as its Conclusions of Law.

The Commission rejects the conclusion of law in that portion of paragraph

21 of the Recommended Order which reads:

[T]he isolated instance of according A.E. one

alcoholic beverage, considering the circum-

stances, and the act of photographing A. E.,

albeit fifteen years of age, in lingerie and

in the nude, was not shown to be a crime or a

violation of any rule or statute. ...

Consequently, the proof fails to demonstrate,

clearly and convincingly, that respondent's

conduct constituted "gross immorality or

an act involving moral turpitude," as

proscribed by subsection 231.28(1)(c)

[Florida Statutes]...

On the contrary, the Commission concludes, that the facts, established and

found, to-wit: that the respondent, an adult male, gave an alcoholic beverage

to a minor female person and photographed her in lingerie and in the nude,

constitute, as a matter of law, gross immorality or acts involving moral

turpitude, as proscribed by subsection 231.28(1)(c), Florida Statutes.

The Commission has jurisdiction of the parties and subject matter of this

cause pursuant to Section 120.57 and Chapter 231, F.S, and because of the

foregoing findings and modified conclusions, hereby deviates from the Hearing

Officer's recommended disposition.

WHEREFORE, it is ORDERED AND ADJUDGED as follows:

1. Respondent shall not receive a Florida educator's certificate for a

period of four years from the effective date of this order.

2. As conditions for recertification, respondent shall:

(a) Provide written verification from a Florida licensed psychologist,

psychiatrist or mental health counselor that applicant poses no threat to

children and is capable of assuming the responsibilities of an educator.

(b) Provide a certified college or in-service program transcript to verify

successful a grade of "pass" or a letter grade no lower than a "B" completion of

a course in the area of professional ethics.

Upon employment in a position requiring a Florida educator's certificate,

Respondent shall be placed on three employment years of probation with the

conditions that during that period, he shall:

1. Notify EPC immediately upon his employment as an educator in any public

or private Florida school.

2. Have his immediate supervisor submit performance reports to the EPC at

least every three months.

3. Within ten days of issuance, submit to the EPC copies of all formal

observation/evaluation forms.

4. During the first three months of each probation year, pay to the EPC

the sum of $150.00 to defray the costs of monitoring probation during that year.

All costs incurred in fulfilling the terms of probation shall be borne by

the Respondent.

This Order becomes effective upon filing.

This Order may be appealed by filing notices of appeal and a filing fee, as

set out in Section 120-68(2), F.S., and Florida Rule of Appellate Procedure

9.110(b) and (c), within thirty days of the date of filing.

DONE AND ORDERED, this 27th day of September, 1996.

COPIES FURNISHED:

Kathleen Richards, Program _______________________________

Director Toni Brummond, Toni Brummond

Professional Practices Services Presiding Officer

Florida Admin. Law Reports I HEREBY CERTIFY that a copy of

the foregoing Order in the matter

Frank R. Petruzielo, Supt. of Brogan vs. Eston Mansfield, was

Broward County Schools Zipkin, mailed to Sheldon Zipkin, Attorney

K.C. Wright Bldg. 10th Flr. at Law, 2020 NE 163rd St., Suite

600 S.E. 3rd Ave. 300, North Miami Beach, Fl. 33162

Ft. Lauderdale, Florida 33301 this 12th day of October, 1996,

by U.S. Mail.

Mark S. Seigle

Associate Supt.

Personnel, Governmental _________________________________

and Community Relations KAREN B. WILDE, Clerk

Broward County Schools

David Holder, Attorney at Law

14 South 9th St.

DuFuniak Springs, Florida 32433

William J. Kendrick, Hearing Officer

Division of Administrative

Hearings

1230 Apalachee Parkway

Tallahassee, Florida 32399-1550

Ann Cole, Clerk

Division of Administrative

Hearings

1230 Apalachee Parkway

Tallahassee, Florida 32399-1550

Larry T. Richardson, Dir.

Recovery Network Program

P.O. Box 37206

Jacksonville, Florida 32236-7206

[phone]

Bruce Taylor, Esquire

5011st Ave. North, Suite 600

St. Petersburg, Florida 33162

Eston Mansfield, Reg. and Cert.