AMENDED PETITION FOR ALTERNATE WRIT IN MANDAMUS

IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT,
IN AND FOR LEON COUNTY, FLORIDA
ANABELLE DIAS & ASSOCIATES, P.A.
BRANDON HEPBURN
OMAR BLEECHINGTON
ZACK PETERSON Case Number 2008-CA 2446
TEDRICK CHILDS
WILLIE COLSON, and
ANABELLE DIAS Circuit Civil Division
Petitioners,
v.
LARRY CAMPBELL, as SHERIFF
OF LEON COUNTY, FLORIDA,
Respondent,
________________________________/
AMENDED PETITION FOR ALTERNATE WRIT IN MANDAMUS
COMES NOW THE Petitioners, ANABELLE DIAS AND ASSOCIATES, P.A., BRANDON HEPBURN, OMAR BLEECHINGTON, ZACK PETTERSON, TEDRICK CHILDS, WILLIE COLSON and ANABELLE DIAS, hereinafter Petitioners and requests this honorable Court to issue its Alternate Writ in Mandamus against the Respondent, LARRY CAMPBELL, as SHERIFF OF LEON COUNTY, FLORIDA, a Constitutional Officer of the State of Florida, hereinafter the Sheriff, pursuant to Florida Rule of Civil Procedure 1.630 and states:
This is an action for a alternative writ of mandamus.
This Court has jurisdiction over this action pursuant to the Florida Public Records Act, Fla. Stat. 119 and under Section 5 of Article V of the Florida Constitution.
Petitioners are residents of the State of Florida.
Larry Campbell is the Sheriff of Leon County, Florida, and is subject to the Public Records Law as an “Agency” of the State of Florida as that term is defined in section 119.011(2), Florida Statutes and as a “Criminal justice agency” as that term is defined in section 119.011(4), Florida Statutes.
On August 03, 2007, Petitioner, Dias, requested documents and records from the Sheriff by a written request emailed for the Records Manager for the Leon County Sheriff's Office, Henry Eggers to his assistant email address Cassandra Austin. This request was specific to “Any emails within the State Attorney's office of the Second Judicial Circuit from or to Rick Eggers and/or Rick Courtmanche regarding public records request made by defense attorneys, myself and/or my office from January 1, 2006 to present.” The second item requested was “Any emails to Terry Brown and/or Cassandra Austin regarding how to handle public records request made by defense attorneys, myself and/or my office from January 1, 2006.” The records requested are “public record”, as that term is defined by Section 119.011(1), Florida Statutes. A copy of Dias' Public Records Request is attached hereto as Exhibit “A1” and incorporated herein for all purposes.
Dias also requested documents and records from the Sheriff by a written request emailed to the Records Manager for the Leon County Sheriff's Office, Henry Eggers, on August 07, 2007, the requested “Public Records” was for emails referencing “Dias Requests” or “Dias” in the subject line from or to anyone within the State Attorney's Office to and/or from anyone within the LCSO. The records requested are “public record”, as that term is defined by Section 119.011(1), Florida Statutes. A copy of Dias Public Records Request is attached hereto as Exhibit “A2” and incorporated herein for all purposes.
On August 10, 2007, August 14, 2007, and August 22, 2007, Dias requested an update on the above mentioned records requests. Ms. Cassandra Austin replied on August 10, 2008 stating that “we will have this information by the end of next week.” On August 22, 2007, a status update was requested from Records Manager for the Leon County Sheriff's Office, Henry Eggers. To this date neither of the above two records requests has been produced by the Sheriff. A copy of these communications is attached hereto as Exhibit “A3” and incorporated herein for all purposes.
Dias requested documents and records from the Sheriff by a written request emailed to the Records Manager for the Leon County Sheriff's Office, Henry Eggers, on February 20, 2008, the requested “Public Records” was for “any emails to and/or from anyone (other than to or from our office) at the Leon County Sheriff's Office and/or the Leon County Jail in regards to the following individuals: Omar Bleechington SPN 137840 from 9/18/2006 19:30:25 PM to present; Willie Colson SPN 158335 from 11/04/2007 01:25:17 AM to present; and/or Zack Petterson SPN 33366; from 07/04/2006 22:58:51PM to present. Any emails referring to cell K.29 and/or Robert Wilson SPN 192293 from 07/14/2007 12:10:53 to present.” The records requested are “public record”, as that term is defined by Section 119.011(1), Florida Statutes. A copy of Dias Public Records Request is attached hereto as Exhibit “B1” and incorporated herein for all purposes.
Records manager for the Leon County Sheriff's Office, Henry Eggers, responded to the email request on February 20, 2008 by stating that he could not provide a time when the request would be ready for pick-up because “LCSO does not have any system in place which would provide the information you have asked for. Without names of specific LCSO staff you think may have sent e-mail(s) I can only send out an e-mail to our distribution e-mail lists (which I will do today) and ask for anyone who has sent e-mail(s) concerning your request to provide a copy to me.”Public Records Request is attached hereto as Exhibit “B2” and incorporated herein for all purposes.
On February 20, 2008, Dias also made a records request for copies of policies regarding what attorneys can and can not give their clients after a client had envelopes confiscated by jail staff as contraband. ”Public Records Request is attached hereto as Exhibit “B3” and incorporated herein for all purposes.
Dias requested documents and records from the Sheriff by a written request emailed to the Records Manager for the Leon County Sheriff's Office, Henry Eggers, on March 06, 2008, any documents to and from Lt. Leod Davis in reference to attorney, visits, and legal mail from Jan. 01, 2008 to present. The records requested are “public record”, as that term is defined by Section 119.011(1), Florida Statutes. A copy of Dias Public Records Request is attached hereto as Exhibit “B4” and incorporated herein for all purposes. In the same email Dias requested an update of her previous requests especially for emails to and from the LCSO and SAO in regards to discovery requests. Public Records Request is attached hereto as Exhibit “B4” and incorporated herein for all purposes.
Records manager for the Leon County Sheriff's Office, Henry Eggers, responded to the email request on March 10, 2008, by stating the request for Lt. Davis e-mails “should be ready this week for pick-up.” Dias have yet to receive such emails to this date.
Dias requested documents and records from the Sheriff by a written request emailed to the Records Manager for the Leon County Sheriff's Office, Henry Eggers, on March 10, 2008. The requested “Public Records” was for “copies of any and all emails within any employees of the LCSO 05/15/2006 19:44:55 to present in reference to Inmate Brandon Hepburn as well as attorney visits from Anabelle Diaz (also spelled Dias). Public Records Request is attached hereto as Exhibit “C1” and incorporated herein for all purposes. On April 2, 2008, Dias sent an email to LCSO records asking for the status of this request. Public Records Request is attached hereto as Exhibit “C2” and incorporated herein for all purposes
On March 11, 2008, Dias requested documents and records from the Sheriff by a written request emailed to the Records Manager for the Leon County Sheriff's Office, Henry Eggers,
in reference to records regarding to a tazing incident between Lt Leod Davis and Petitioner Bleechington. Public Records Request is attached hereto as Exhibit “D” and incorporated herein for all purposes.
On April 02, 2008, Dias requested to be informed on the status of the request that was sent on March 6, 2008 and March 10, 2008. To this date no response has been received and the status of the records request remains unfulfilled.
On April 7, 2008, Dias requested on behalf of Petitioner Hepburn, copies of the CAD notes and Radio Transmissions for LCSO case number 06-080073 from the Sheriff by a written request emailed to the Records Manager for the Leon County Sheriff's Office, Henry Eggers. Public Records Request is attached hereto as Exhibit “E1” and incorporated herein for all purposes.
On April 7, 2008, Dias requested on behalf of Petitioner Colson, copies of certain records in LCSO case number 07-251052 via a written request emailed to the Records Manager for the Leon County Sheriff's Office, Henry Eggers. Public Records Request is attached hereto as Exhibit “E2” and incorporated herein for all purposes.
On April 8, 2008, Dias requested on behalf of Petitioner Colson, copies of certain documents in reference to a Rosemita Pierre via a written request emailed to the Records Manager for the Leon County Sheriff's Office, Henry Eggers. Public Records Request is attached hereto as Exhibit “E3” and incorporated herein for all purposes.
On April 14, 2008, Dias requested again on behalf of Petitioner Hepburn, copies of the CAD notes for LCSO case number 06-080073. Public Records Request is attached hereto as Exhibit “E4” and incorporated herein for all purposes.
On April 17, 2008, Dias requested on behalf of Petitioner Colson, copies of all the records in reference to LCSO case number 07-251052 from the Sheriff by a written request emailed to the Records Manager for the Leon County Sheriff's Office, Henry Eggers. Public Records Request is attached hereto as Exhibit “E4” and incorporated herein for all purposes.
On April 21, 2008, Dias requested on behalf of all Petitioners an update on her still unanswered August 2007 records requests. Public Records Request is attached hereto as Exhibit “E5” and incorporated herein for all purposes.
On this date April 27, 2008, Dias requested to be informed of the status of emails of the requested documents and records on February 20, 2008, & March 10, 2008. This request included possible search methods to be utilized by the Records Manager in order to properly obtain the requested documents.
On April 28, 2008, Dias requested on behalf of Petitioner Hepburn, a copy of all text or emails from LCSO cars regarding his case from the Sheriff by a written request emailed to the Records Manager for the Leon County Sheriff's Office, Henry Eggers. Public Records Request is attached hereto as Exhibit “E6” and incorporated herein for all purposes.
On May 3, 2008, Dias requested documents and records from the Sheriff by a written request emailed to Rebecca Gay, Supervisor of Communications for the Leon County Sheriff's Office. This request was a duplicate request because there had been no response from the Records Manager, Henry Eggers. Ms. Gay responded by stating “I am unable to process this request. All records requests must be made through our records custodian Mr. Rick Eggers.” A copy of these communications is attached hereto as Exhibit “F1” and incorporated herein for all purposes. Ultimately, a motion for subpoena duces tecum had to be filed and a hearing was held on July 17, 2008 where Judge Kathleen Dekker granted the motion for the previously requested documents and records.
Dias requested documents and records on behalf of Mr Colson from the Sheriff by a written request emailed to the Records Manager for the Leon County Sheriff's Office, Henry Eggers, on May 7, 2008, the requested “Public Records” was in reference to 07-251052. The request was for all LCSO records in reference to 07-251052; copies of any policy applicable to retention of Radio Transmissions; radio transmissions for November 2, 2007 from 15:00PM to 23:00PM; when the Radio transmissions for 07-251052 were recycled, destroyed or became no longer available for copy; as well as any reason why the LCSO believes that Mr Colson and his attorney of records would not be entitled to a copy of the CAD notes and Radio Transmissions upon written requests despite having filed a proper Demand for Discovery. Public Records Request is attached hereto as Exhibit “F3” and incorporated herein for all purposes.
On May 15, 2008, Dias requested to be informed on the status of the emails of the requested documents and records on February 20, 2008, March 10, 2008 and April 27, 2008. To this date no response has been received and the status of the records request remains unfulfilled.
On May 15, 2008, Dias requested an update for records request for Lt Davis emails which should have been ready sometime in March 2008. Public Records Request is attached hereto as Exhibit “F4” and incorporated herein for all purposes.
On May 15, 2008, Dias made another records request on behalf of Willie Colson in LCSO case number 07-251052 (Public Records Request is attached hereto as Exhibit “F5” and incorporated herein for all purposes); Brandon Hepburn in LCSO 06-080073; 06-105405; 06-083572; and agency ORI#370000 (Public Records Request is attached hereto as Exhibit “F6” and incorporated herein for all purposes). Dias also requested an update on an outstanding records request sent on February 20, 2008. Public Records Request is attached hereto as Exhibit “F7” and incorporated herein for all purposes.
On May 27, 2008, Dias sent a formal letter to Records Manager, Henry Eggers, detailing the various outstanding requests. Also included in the letter were duplicate requests for previously submitted records requests that had gone unanswered as well as a new request for “ALL Leon County Sheriff's Policies and/or Procedures and/or Rules....” A copy of this letter was attached with the previous petition.
On May 27, 2008, Dias sent unanswered records request on behalf of Brandon Hepburn to LCSO Attorney Alan Griner. Public Records Request is attached hereto as Exhibit “F8” and incorporated herein for all purposes.
On June 4, 2008, Dias sent an email to Cassandra Austin requesting that LCSO respond to all unanswered records requests and comply with the subpeona duce tecum served on behalf of petioner Hepburn. Public Records Request is attached hereto as Exhibit “G” and incorporated herein for all purposes.
On June 10, 2008, Dias sent an email to Henry Eggers in reponse to request asking that the records Cassandra Austin requesting that LCSO respond to all unanswered records requests and comply with the subpeona duce tecum served on behalf of petioner Hepburn. Public Records Request is attached hereto as Exhibit “G” and incorporated herein for all purposes.
Dias requested documents and records from Sheriff by a written request emailed to the Records Manager for the Leon County Sheriff's Office, Henry Eggers, on June 4-6, 2008, with a follow up email on the status of this request on June 06, 2008. A copy of these communications is attached hereto as Exhibit “H1; H2; H3; H4; H5” and incorporated herein for all purposes.
On this date June 19-20, 2008, Dias request to inspect records from Sheriff by written requests emailed to the Records Manager for the Leon County Sheriff's Office, Henry Eggers, with an email requesting a follow up on June 20, 2008 and June 24, 2008.A copy of these communications is attached hereto as Exhibit “I1; I2; I3; I4; I5; I6; I7; I8” and incorporated herein for all purposes. Dias also requested to inspect LCSo Records Custodian log showing all public records request made by her firm from January 1, 2007, to present. As of today, Dias has still not received the documentation requested.
Records manager for the Leon County Sheriff's Office, Henry Eggers, responded to the email request on June 20, 2008 and June 24, 2008 by stating “Due to the nature of your various requests it 's expected that extensive staff time will be required to gather the records and then review the records for exempt information as required by Law. Also, at this time due to the unknown quantity of records which meet your requests we are unable to provide an estimate of the time and/or costs associated with completing your requests."
On June 20, 2008, Dias requested on behalf of Mr Bleechington, copies of Internal Affair investigation Case#08-59234 by written requests Captain Coughlin of the Leon County Sheriff's Office. A copy of these communications is attached hereto as Exhibit “J” and incorporated herein for all purposes.
On June 20, 2008, Dias also requested on behalf of Mr Hepburn, that we be allowed to inspect certain records previously asked by Dias as well as a copy of all of his jail calls. A copy of Hepburn Jail calls to his attorney office is the only items that was provided to date. A copy of these communications is attached hereto as Exhibit “K” and incorporated herein for all purposes.
On June 24, 2008, Dias email Henry Eggers requesting that Mr Bleechington and Mr Hepburn be allowed to inspect the previous records they had requested as well as other records including an internal affair report, if one exists, or any other documents which was added to Officer Baker's file in the last 12 months. A copy of these communications is attached hereto as Exhibit “L” and incorporated herein for all purposes.
On June 25, 2008, Dias received an email stating that the Jail calls for Mr Hepburn were ready to be picked up. The undersigned was out of the country and was unable to review the CD until July 25, 2008. The CD contains only phone calls from Mr Hepburn to his attorney's office. A copy of these communications is attached hereto as Exhibit “M” and incorporated herein for all purposes.
On July 8, 2008, Dias emailed Cassandra Austin and Henry Eggers requesting yet again that she be provided a copy of documents kept by the LCSO in reference to our firm's attorney client visits as well as an update as to when to expect previously records request. A copy of these communications is attached hereto as Exhibit “N1 & N2” and incorporated herein for all purposes.
On July 9, 2008, Dias emailed Henry Eggers to authorize payment for the records previously requested. A copy of these communications is attached hereto as Exhibit “N3 & N4” and incorporated herein for all purposes.
On July 24, 2008, Dias emailed Henry Eggers at the Leon County Sheriff's Office and requested that they inform our office whether or not they intended to comply with our many outstanding records request dating as far back as August 3, 2007. Mr Eggers replied via email
in part, as follow: “ Therefore, since your 2nd e-mail today provided authorization, we will start the process of pulling and reviewing this information and you will be notified once we have completed. Also, as was explained in the last e-mail concerning this request, it requires extensive staff time to pull the information and review it for exempt information; it is not a request that "could be quickly and easily located” Please provide a copy of any request which you believe LCSO has not responded to so that “ A copy of these communications is attached hereto as Exhibit “O1 & O2” and incorporated herein for all purposes.
ARGUMENT:
Since 1909, Florida law has guaranteed its citizens access to public records. In 1993, the right was even written into the Florida Constitution, giving powerful protection for the public to inspect any document generated by the government unless it carries a specific statutory exemption. Section 119.07(3)(a), Florida Statutes, provides that any person shall have the right of access to public records for the purpose of making photographs of the record while such record is in the possession, custody, and control of the custodian of public records. Furthermore Section 119.07, Florida Statutes, requires the designated custodian of records to produce the requested records without undo delay. This provision of Florida Statutes has been construed by the Supreme Court of Florida to mean: The only delay permitted by the Act is the limited reasonable time allowed the custodian to retrieve the record and delete those portions of the record the custodian asserts are exempt. Tribune Company v. Cannella, 458 So.2d 1075, 1078 (Fla. 1984) appeal diss., Deperte v. Tribune Company, 105 S.Ct. 2315, 85 L. Ed.2d 835 (1985). Furthermore, Section 119.07(c) states that a custodian of public records and his or her designee must acknowledge requests to inspect or copy records promptly and respond to such requests in good faith. A good faith response includes making reasonable efforts to determine from other officers or employees within the agency whether such a record exists and, if so, the location at which the record can be accessed. In addition, Section 119.07(d) states that a person who has custody of a public record who asserts that an exemption applies to a part of such record shall redact that portion of the record to which an exemption has been asserted and validly applies, and such person shall produce the remainder of such record for inspection and copying. Florida Statutes Section 119.07(e) provides that If the person who has custody of a public record contends that all or part of the record is exempt from inspection and copying, he or she shall state the basis of the exemption that he or she contends is applicable to the record, including the statutory citation to an exemption created or afforded by statute while Section 119.07(f) provides that if requested by the person seeking to inspect or copy the record, the custodian of public records shall state in writing and with particularity the reasons for the conclusion that the record is exempt or confidential.
It is clear that Sheriff Larry Campbell and his appointed Records Manager have unlawfully with held Public Records Request information from Petioner as evidenced by the records. For example, on August 10, 2007 Cassandra Austin an employee under Rick Eggers stated that a request would be ready by the end of the week after a request was made on August 3, 2007. However, on February 20, 2008 Henry Eggers responded to the same Public Records Request in question stating that he could not provide a time when request would be ready for pick up because the Sheriff's Office does not have any system in place which would provide the information requested without specific “LCSO” staff names she believe sent e-mails and that he could only send out an email to their distribution list asking who may have sent one. This seems to operate to restrict or circumvent a person's right to access by requesting specific names. It is clear that no agency can impose such conditions.
For a period of months the Sheriff's Office trough its Record Manager, Henry Eggers, delayed petioners rights to inspect the records requested without providing any legal cause. Petitioners records request(s) were simple in nature to what was requested to be inspected in that they stated with particularity what each records pertained to.
Sheriff Campbell and/or his records manager have unlawfully if not purposely, prevented Petitioners' from accessing Public Records. This can not been a mistake nor oversight and their efforts or actions are in clear violation of the spirit of Chapter 119.
An agency's unreasonable and excessive delays in producing public records can constitute an unlawful refusal to provide access to public records. Town of Manalapan v. Rechler, 674 So.2d 789, 790 (Fla. 4th DCA). In Town of Manalapan, the appellate court affirmed the lower court's finding that the town engaged in a “pattern of delays” by taking months to fully comply with the petitioner's public records requests. See also State v. Webb, 786 So.2d 602 (Fla. 1st DCA 2001).
Section 119.07, Florida Statutes, further requires that the Sheriff allow inspection and copying of Public Records at any reasonable time, under any reasonable conditions. The Sheriff, may not, therefore, impose any restrictions or conditions on Petitioner' inspection of the requested Public Records which would hamper or frustrate, directly or indirectly Petitioners' right of inspection. E.g., Wait v Fla. Pw'r & Light Com., 372 So. 2D 420 (Fla 1979); Davis v Sarasota County Public Hospital Board, 480 So 2d 203 (Fla 2d DCA 1985), rev. den., 488 So 2d 829 (Fla 1986); Fuller v State, 17 So 2d 607 (Fla. 1944); Op. Att'y Gen. Fla. 75-50 (1973); Op. Att'y Gen. 93-48 (1993); Op. Att'y Gen. 80-57 (1980)
The Records Manager for the Leon County Sheriff's Office failure to respond to Petitioners' public records request violates both the spirit and letter of the Public Records Law codified in Chapter 119, Laws of Florida, and the General State Policy on Public Records recited in Section 119.01, Florida Statutes.
The Leon County Sheriff's inaction, and effective denial of Petitioners'' Public Records Request by inaction, is a continuing violation of the letter, spirit, and intent of Chapter 119 and indicate a complete indifference to the requirements of Chapter 119 as well unwillingness to cooperate with the Petitioners individually. Petitioners' are, therefore, entitled to compel the Sheriff's compliance with Chapter 119, Laws of Florida, by means of the Extraordinary Writ of Mandamus pursuant to Florida Rule of Civil Procedure 1.630 and Florida Case Law.
As stated by the Fifth District Court Appeal: A writ of mandamus is a command from a court directed to another such as an inferior court, public officer or governmental entity, requiring the party whom it is directed to perform an act that the party has legal duty to perform because of its official position. State ex rel. Buckwalter v City of Lakeland, 112 Fla. 200, 150, So. 508 (1933). The act commanded by the writ must be ministerial and cannot be one that the party sought to be coerced has any discretion in performing. See, English v McCrary, 348 So 2d 293 (Fla 1977). Mandamus is proper to enforce a right which is clearly and certainly established in the law, but not to litigate the existence of such right. See Florida League of Cities v Smith, 607 So 2d 297 (Fla 1992). Soto v Board of County Com'rs of Hernando County, 716 So 2d 863, 864 (Fla. 5th DCA 1998). The obligation of the Sheriff to produce the Public Records requested by Dias is clearly a “ministerial” obligation under Florida Law. “A duty or act is defined as ministerial when there is no room for the exercise of discretion, and the performance being required is directed by law. “Town of Manalapan v Rechler, 674 So 2d 789, 790 (Fla. 4th DCA 1996)
Mandamus is appropriate to enforce compliance with the Public Records Act. Staton v McMillan, 597 So 2d 940 (Fla 1st DCA 1992), review dismissed sub nom., Staton v Austin, 605 So 2d 1266 (Fla 1992). See also Weeks v Golden, 764 So 2d 633 (Fla 1st DCA 2000); Smith v State, 696 So 2d 814 (Fla 2d DCA 1997); Donner v Edelstein,415 So 2d 830 (Fla 3d DCA 1982); Mills v Doyle, 407 So 2d 348 (Fla 4th DCA 1981). Because Dias Petition presents prima facie claim for relief, this Court should issue its Alternative Writ of Mandamus requiring the Sheriff to comply with Dias' Public Records request immediately or show why he has failed to comply with the Public Records request and why the Writ should not be issued. Staton v McMillan, supra. Accord, Gay v. State, 697 So 2d 170 (Fla 1st DCA 1997).
Petitioners are entitled to have this matter advanced before all other actions on the docket, pursuant to Section 119.11, Florida Statues, and, therefore, demands that this Court issue its Alternative Writ of Mandamus forwith. For the Court's convenience, a copy of Dias' proposed Alternative Writ of Mandamus is attached to this Petition as Exhibit “C” and electronic copy of this Petition and the proposed Alternative Writ of Mandamus will be forwarded to the this Court.
WHEREFORE, the Petitioners, having all demonstrated a prima facie entitlement to the
Writ, requests this Court advance this matter before all other actions on the docket is required by Section 119.11, Florida Statues, and issue forthwith its Alternative Writ of Mandamus commanding the Sheriff to do the following:
A. Produce all of the “Public Records” requested by Petitioners; OR IN THE ALTERNATIVE
B. Require the Sheriff to file its Answer and Defenses to this Petition within a time certain;
and
C. Expeditiously hear those issues which are contested, advancing this matter before all others on the docket, and upon proper proof by Dias of the Sheriff default in it obligation under Chapter 119, Laws of Florida, let this Court's Writ then issue compelling the production of the public records by the Sheriff, on a date and time certain, and
INCLUSIVE OF SUCH ALTERNATIVES
D. Require the Sheriff to produce the public records at NO COST to the petitioners;
E. Award Petitioners the costs of this action and a reasonable attorney's fee pursuant to section 119.12, Florida Statutes.
F. And grant such other further relief as this Court deems necessary or appropriate
Respectfully Submitted,
________________________ Anabelle Dias,
Florida Bar No. 162604
1226 E. 7th Ave.
Tallahassee, Florida 32303
Ph: 850-422-3427
Fax: 850-893-9901