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BROW ARD COUNTY, a political

subdivision of the State of Florida,


Plaintiff,
v.
FREEDOM MARINE FINANCE,
LLC, a dissolved Florida limited
liability company and TODD
LITTLEJOI-IN d/b/a FREEDOM
MARINE FINANCE, LLC,
Defendants.

IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROW ARD COUNTY, FLORIDA
CASE NO. CACE 13-014847
Division 08
DEFENDANTS' MOTION TO DISMISS
Defendants, Freedom Marine Finance LLC (FMF) and Todd Littlejohn (Littlejohn), by
and through their undersigned attomey, move to dismiss this action based upon the following:
I. Plaintiff has named as party defendants both FMF and Littlejohn.
2. Plaintiff's pretense for naming Littlejolm as a defendant is alleged in paragraphs 5
and 6 of Plaintiffs Complaint:
"5. DEFENDANT, TODD LITTLEJOI-IN, d/b/a FREEDOM
MARINE FINANCE, LLC, a dissolved Florida limited liability company, was the
managing member of Freedom Marine Finance, LLC, a dissolved Florida limited
liability company and has at all relevant times operated a marine facility business
at 790 NW !
51
Avenue, Deerfield Beach, FL 33067."

"6. DEFENDANTS, FREEDOM AND TODD LITTLEJOHN d/b/a
FREEDOM MARINE FINANCE, LLC, a dissolved Florida limited liability
company, are a "person" within the meaning of Section27-4(29) Broward County
Code of Ordinances ("BCC") and a "responsible party" within the meaning of
Section 27-4(32), BCC."
3. In paragraph 4 of its Complaint, Plaintiff alleges that Defendant, Freedom, is a
Florida Limited Liability Company ... which was dissolved on September 28, 2012 for failure to
submit an annual report.
4. Section 608.4227(1 ), Florida Statutes, limits the liability of members, managers
and managing members of limited liability companies:
Except as provided in this chapter, the members, managers, and
managing members of a limited liability company are not liable,
solely by reason of being a member or serving as a manager or
managing member, under a judgment, decree, or order of a court,
or in any other manner, for a debt, obligation, or liability of the
limited liability company.
5. Section 608.4421 (I 0) through (13 ), Florida Statutes, limits the liability of any
member of a dissolved limited liability company as follows:
2 l p (1 g l'
(1 0) A dissolved limited liability company which has not
followed the procedures described in subsections (2) and (3) shall
pay or make reasonable provision to pay all claims and obligations,
including all contingent, conditional, or unmatured claims known .
to the limited liability company and all claims which are known to
the dissolved limited liability company but for which the identity
of the claimant is unknown. Such claims shall be paid in full, and
any such provision for payment made shall be made in full if there
are sufficient funds. If there are insufficient funds, such claims and
obligations shall be paid or provided for according to their priority
and, among claims of equal priority, ratably to the extent of funds
legally available therefor. Any remaining funds shall be distributed
pursuant to s. 608.444.
(II) A member of a dissolved limited liability company, the
assets of which were distributed pursuant to subsection (9) or
subsection (I 0) is not liable for any claim against the limit.ed
liability company in an amount in excess of such member's pro
rata share of the claim or the amount distributed to the member,
whichever is less.
( 12) A member of a dissolved limited liability company, the
assets of which were distributed pursuant to subsection (9) is not
liable for any claim against the limited liability company on which
a proceeding is not begun prior to the expiration of 3 years
following the effective date of dissolution.
(13) The aggregate liability of any member of a dissolved limited
liability company for claims against the dissolved limited liability
company may not exceed the amount distributed to the member in
dissolution.
6. In a field where both the State and local government can legislate concurrently, a
county cannot enact an ordinance that directly conflicts with a state statute. Phantom o.f
Brevard, Inc. v. Brevard County, 3 So.3d 309, 314 (Fla. 2008); Tallahassee Memorial Regional
Medical Center., Inc. v. Tallahassee Medical Center., Inc., 681 So.2d 826,831 (Fla. 1st DCA,
1996).
7. Local "ordinances are inferior to laws of the state and must not conflict with any
controlling provision of a statute." Thomas v. State, 614 So.2d 468, 470 (Fla. 1993);
Hillsborough County v. Fla. Restaurant Association, 603 So.2d 587,591 (Fla. 2d DCA, 1992)
("If [a county] has enacted such an inconsistent ordinance, the ordinance must be declared null
and void."); see also Rin:der v. Carson, 262 So.2d 661, 668 (Fla.l972).
8. Here, Section 27-4(32), Broward County Code of Ordinances, is in direct and
irreconsileable conflict with the Section 608.4421(10) through (13), Florida Statutes.
9. As such, the county ordinance is unconstitutional both on its face and as applied
to the facts of this case.
I 0. Further, the remedy Plaintiff seeks, mandatory injunction, is an inappropriate and
unavailable remedy on the facts as plead.
I I. The gist of Plaintiffs Petition for Mandatory Injunction is that Defendants owe
money to the County because of a failure to pay certain fees or special assessments.
12. Because Defendants have failed to pay, the county has been irreparably harmed.
13. It is well settled that where an injunction petitioner is entitled to a money
judgment, he has an adequate remedy at law and has not suffered irreparable harm. Hiles v. Auto
Balm Federation, Inc., 498 So.2d 997, 998 (Fla. 4
111
DCA, 1986). relief may not be
used to enforce money damages, or to prevent any party from disposing of assets until an action
at law for an alleged debt can be concluded.")
WHEREFORE, Detendants move to dismiss Plaintiffs Complaint together with such
other relief as the Court shall deem appropriate.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy was sent to DAPHNE E. JONES, Assistant County
Attorney, .Toni Annstrong Coffey, Broward County Attorney, Govenm1ental Center, Suite 423,
4ll'agc
115 South Andrews Avenue, Fort Lauderdale, Florida 33301 via email to dajones@broward.org
and to trice(llbroward.org this 1 day of August, 2013.
5I Page
THE GILLESPIE LAW FIRM
2211 NE 36'
11
Street, Suite 203
Lighthouse Point, FL 33064
Telephone 954-785-0001
954-785-0011
ohn R. Gillespie, P
Fla. Bar No. 218707
BROWARD COUNTY, apolitical
subdivision of the State of Florida,
Plaintiff,
v.
FREEDOM MARINE FINANCE,
LLC, a dissolved Florida limited
liability company and TODD
LITTLEJOHN d/b/a FREEDOM
MARINE FINANCE, LLC,
Defendants.
____________________ ./
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. CACE 13-014847
Division 08
DEFENDANTS' NOTICE OF COMPLIANCE WITH RULE 2.516
AND DESIGNATION OF E-MAIL ADDRESSES
Defendants, Freedom Marine Finance LLC and Todd Littlejohn, by and through the
undersigned counsel, files this Notice of Compliance with Rule 2.516 and Designation of E-mail
addresses (effective September I, 2012), and notifies all parties that the following e-mail
addresses are the designated e-mail addresses for service of all pleadings and documents required
to be served on parties in the above-styled matter as follows:
Primary e-mail: jgillespie@gillespiefinn.com (Attorney handling file)
Secondary e-mail: pwilson@gillespiefinn.com (Paralegal handling file)
liP age
I HEREBY CERTIFY that a copy was sent to DAPHNE E. JONES, Assistant County
Attorney, Joni Armstrong Coffey, Broward County Attorney, Governmental Center, Suite 423,
115 South Andrews Avenue, Fort Lauderdale, Florida 3330 l via email to dajones@broward.org
and to !lice@broward.org this l day of August, 2013.
2jPagc
THE GILLESPIE LAW FIRM
John R. Gillespie, P .A.
2211 NE 36'
11
Street, Suite 203
Lighthouse Point, FL 33064
Telephone: 954-785-0001
Facsimile: 954-785-0011
jgillespie@gillespiefinn.com
pwilson@gillespiefinn.com
Is/ Jolm R. Gillespie
John R. Gillespie
Fla. Bar No. 218707
, .
..:RIFlED RETURN OF SERVL -
State of Florida County of BROWARD Circuit Court
Case Number: CACE13-014847 08
111111111111111111111 II II 111111111111
Plaintiff:
BROWARD COUNTY
vs.
Defendant:
FREEDOM MARINE FINANCE, LLC., ET AL
For:
Joni Armstrong Coffey
Broward County
JVS2013004093
Received by COMPASS INVESTIGATIONS on the 25th day of June, 2013 at 11 :52 am to be served on TODD LITTLEJOHN
D/B/A FREEDOM MARINE FINANCE, LLC., 7169 NW 71 TERRACE, PARKLAND, FL 33067.
I, Krystal King, do hereby affirm that on the 26th day of June, 2013 at 8:15pm, 1:
INDIVIDUALLY/PERSONALLY served by delivering a true copy of the SUMMONS; COMPLAINT FOR INJUNCTIVE
RELIEF; EXHIBITS with the date and hour of service endorsed thereon by me, to: TODD LITTLEJOHN D/B/A FREEDOM
MARINE FINANCE, LLC. , at the address of: 7169 NW 71 TERRACE, PARKLAND, FL 33067, and informed said person of
the contents therein, in compliance with state statutes.
Description of Person Served: Age: 50, Sex: M, Race/Skin Color: WHITE, Height: 5.10, Weight: 225, Hair: BROWN,
Glasses: N
I certify that I am over the age of 18, have no interest in the above action, and am a Special Process Server, in good
standing, in the judicial circuit in which the process was served. Under penalties of perjury, I declare that I have read the
foregoing document and that the facts stated in it are true.
Krystal King
SPS #1234
COMPASS INVESTIGATIONS
10 South New River Drive, East
Suite 205
Fort Lauderdale, FL 33301
(954) 527-5722
Our Job Serial Number: JVS-2013004093
Copyright C 1992-2011 Database Services, Inc. - Process Servers Toolbox V6.5m
' .
~ R I F l E D RETURN OF SERV. t:.
State of Florida County of BROWARD Circuit Court
Case Number: CACE13-014847 08
1111111111111111111111111111111111111
Plaintiff:
BROWARD COUNTY
vs.
Defendant:
FREEDOM MARINE FINANCE, LLC., ET AL
For:
Joni Armstrong Coffey
Broward County
JVS2013004092
Received by COMPASS INVESTIGATIONS on the 25th day of June, 2013 at 11:52 am to be served on FREEDOM MARINE
FINANCE, LLC., C/0 TODD LITTLEJOHN, MANAGER, 7169 NW 72ND TERRACE, PARKLAND, FL 33067.
I, Krystal King, do hereby affirm that on the 26th day of June, 2013 at 8:15pm, 1:
CORPORATE -RIA RESIDENTIAL: served by delivering a true copy of the SUMMONS; COMPLAINT FOR INJUNCTIVE
RELIEF; EXHIBITS with the date and hour of service endorsed thereon by me, to: TODD LITTLEJOHN as
MANAGER/MEMBER, at the address of 7169 NW 71 ST TERRACE, PARKLAND, FL 33067 the within named person's
usual place of abode. The corporation was served in this manner because the address provided for the registered agent,
officer, director, or principal place of business is a residence. Papers have been served in accordance with state statutes.
Additional Information pertaining to this Service:
SERVICE WAS NOT ATTEMPTED AT THE ADDRESS PROVIDED OF 7169 NW 72ND TERRACE, PARKLAND, FL
33067AS THE ADDRESS DOES NOT EXIST. PUBLIC RECORDS SHOWS THAT THE CORRECT ADDRESS IS 7169 NW
71ST TERRACE, PARKLAND, FL 33067. SERVICE WILL BE ATTEMPTED AT THIS ADDRESS.
Description of Person Served: Age: 50, Sex: M, Race/Skin Color: WHITE, Height: 5.10, Weight: 225, Hair: BROWN,
Glasses: N
I certify that I am over the age of 18, have no interest in the above action, and am a Special Process Server, in good
standing, in the judicial circuit in which the process was served. Under penalties of perjury, I declare that I have read the
foregoing document and that the facts stated in it are true.
Krystal King
SPS #1234
COMPASS INVESTIGATIONS
10 South New River Drive, East
Suite 205
Fort Lauderdale, FL 33301
(954) 527-5722
Our Job Serial Number: JVS-2013004092
Copyright @ 1992-201 1 Database Services, Inc. - Process Serve(s Toolbox V6.5m
*
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Case Number: CACE-13-014' 7 Division: 08
Elcctro.,..ally Filed 06/18/2013 01:53:41 PM ET
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
BROWARD COUNTY, a political subdivision
Of the State of Florida
Plaintiff,
vs. CASE NO.:
FREEDOM MARINE FINANCE, LLC.,
a dissolved Florida limited liability company and
TODD LITTLEJOHN d/b/a FREEDOM
MARINE FINANCE, LLC., a dissolved
Florida limited liability company
Defendant.
- - - - - - - - - - - - - - - - - - - - - - ~ '
SUMMONS
TO: Freedom Marine Finance, LLC., a dissolved Florida limited liability company
c/o Todd Littlejohn, Manager
7169 NW 72 Terrace
Parkland FL 33067
IMPORTANT
A lawsuit has been filed against you. You have 20 calendar days after this
summons is served on you to file a written response to the attached complaint with the
clerk of this court. A phone call will not protect you. Your written response, including the
case number given above and the names of the parties, must be filed if you want the court
to hear your side of the case. If you do not file your response on time, you may lose the
case, and your wages, money, and property may thereafter be taken without further
warning from the court. There are other legal requirements. You may want to call an
attorney right away. If you do not know an attorney, you may call an attorney referral
service or a legal aid office (listed in the phone book).
If you choose to file a written response yourself, at the same time you file your
written response to the court you must also mail or take a copy of your written response to
the "Plaintiff/Plaintiff's Attorney" named below.
IMPORT ANTE
Usted ha side demandado legalmente. Tiene 20 dias, contados a partir del recibo
de esta notificacion, para contestar Ia demanda adjunta, por escrito, y presentarla ante
este tribunal. Una llamada telefonica no Ia protegera. Si usted desea que el tribunal
considers su defensa, debe presentar su respuesta par escrito, incluyendo el numero del
case y los nombres de las partes interesadas. Si usted no contesta Ia demanda a tiempo,
pudiese perder el case y pod ria ser despojado de sus ingresos y propiedades, o privado
de sus derechos, sin previa aviso del tribunal. Existen otros requisites legales. Si Ia
desea, puede usted consultar a un abogado inmediatamente. Si no conoce a un
abogado, puede !lamar a una de las oficinas de asistencia legal que aparecen en Ia guia
telefonica.
Si desea responder a Ia demanda par su cuenta, al mismo tiempo en que presenta
su respuesta ante el tribunal, debera usted enviar por correo o entregar una copia de su
respuesta a Ia persona denominada abajo como "Plaintiff/Plaintiffs Attorney"
(Demandante o Abogado del Demandante).
IMPORTANT
Des poursuites judiciares ont ete entreprises contre vous. Vous avez 20 jours
consecutifs a partir de Ia date de I' assignation de cette citation pour deposer une reponse
ecrite a Ia plainte ci-jointe aupres de ce tribunal. Un simple coup de telephone est
insuffisant pour vous proteger. Vous etes oblige de deposer votre reponse ecrite, avec
mention du numero de dossier ci-dessus et du nom des parties nommees ici, si vous
souhaitez que le tribunal entende votre cause. Si vous ne deposez pas votre reponse
ecrite dans le relai requis, vous risquez de perdre Ia cause ainsi que votre salaire, votre
argent, et vos biens peuvent etre saisis par Ia suite, sans aucun preavis ulterieur du
tribunal. II y a d'autres obligations juridiques et vous pouvez requerir les services
immediats d'un avoca!. Si vous ne connaissez pas d'avocat, vous pourriez telephoner a
un service de reference d'avocats ou a un bureau d'assistance juridique (figurant a
l'annuaire de telephones).
Si vous choisissez de deposer vous-meme une reponse ecrite, il vous faudra
egalement, en meme temps que cette formalite, faire parvenir ou expedier une copie de
votre reponse ecrite au "Plaintiff/Plaintiffs Attorney" (Piaignant ou a son avocat) nomme
ci-dessous.
JONI ARMSTRONG COFFEY
County Attorney for Broward County
Daphne E. Jones, Assistant County Attorney
Governmental Center, Suite 423
115 South Andrews Avenue
Fort Lauderdale, Florida 33301
Telephone: (305) 357-7600
Telecopier: (305) 357-6968
-2-
THE STATE OF FLORIDA
TO EACH SHERIFF OF THE STATE:
You are commanded to serve this summons and a copy of the complaint in this
lawsuit on the above-named defendant.
JUN 24 2013
DATED ON _______ , 2013.
(SEAL)
FORMAN
IN ACCORDANCE WITH THE AMERICANS WITH DISABILITIES ACT OF 1990 (ADA),
ALL PERSONS WHO ARE DISABLED AND WHO NEED SPECIAL
ACCOMMODATIONS TO PARTICIPATE IN THIS PROCEEDING BECAUSE OF THAT
DISABILITY SHOULD CONTACT THE 17TH CIRCUIT COURT ADA COORDINATOR
NOT LATER THAN FIVE BUSINESS DAYS PRIOR TO THE PROCEEDING. THE 17TH
CIRCUIT COURT ADA COORDINATOR MAY BE REACHED AT 201 SOUTHEAST
SIXTH STREET, ROOM 880, FORT LAUDERDALE, FL, 33301; THE TELEPHONE
NUMBER IS (305) 831-7017; OR 1-800-955-8770 VIA FLORIDA RELAY SERVICE.
-3-



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Case Number: CACE-13-014P . ., Division: 08
Electro1. .ily Filed 06/18/2013 01:53:41 PM ET
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
BROWARD COUNTY, a political subdivision
Of the State of Florida
Plaintiff,
vs. CASE NO.:
FREEDOM MARINE FINANCE, LLC.,
a dissolved Florida limited liability company and
TODD LITTLEJOHN d/b/a FREEDOM
MARINE FINANCE, LLC., a dissolved
Florida limited liability company
Defendant.
- - - - - - - - - - - - - - - - - - - - - - - - ~ /
SUMMONS
TO: Todd Littlejohn d/b/a Freedom Marine Finance, LLC.,
a dissolved Florida limited liability company
7169 NW 71 Terrace
Parkland, FL 33067
IMPORTANT
A lawsuit has been filed against you. You have 20 calendar days after this
summons is served on you to file a written response to the attached complaint with the
clerk of this court. A phone call will not protect you. Your written response, including the
case number given above and the names of the parties, must be filed if you want the court
to hear your side of the case. If you do not file your response on time, you may lose the
case, and your wages, money, and property may thereafter be taken without further
warning from the court. There are other legal requirements. You may want to call an
attorney right away. If you do not know an attorney, you may call an attorney referral
service or a legal aid office (listed in the phone book).
If you choose to file a written response yourself, at the same time you file your
written response to the court you must also mail or take a copy of your written response to
the "Plaintiff/Plaintiff's Attorney" named below.
IMPORT ANTE
Usted ha sido demandado legal mente. Tiene 20 dias, contados a partir del recibo
de esta notificacion, para contestar Ia demanda adjunta, por escrito, y presentarla ante
este tribunal. Una Hamada telefonica no lo protegera. Si usted desea que el tribunal
considers su defensa, debe presentar su respuesta por escrito, incluyendo el numero del
caso y los nombres de las partes interesadas. Si usted no contesta Ia demanda a tiempo,
pudiese perder el caso y podria ser despojado de sus ingresos y propiedades, o privado
de sus derechos, sin previa aviso del tribunal. Existen otros requisitos legales. Si lo
desea, puede usted consultar a un abogado inmediatamente. Si no conoce a un
abogado, puede Hamar a una de las oficinas de asistencia legal que aparecen en Ia guia
telefonica.
Si desea responder a Ia demanda por su cuenta, al mismo tiempo en que presenta
su respuesta ante el tribunal, debera usted enviar por correo o entregar una copia de su
respuesta a Ia persona denominada abajo como "Plaintiff/Plaintiffs Attorney"
(Demandante o Abogado del Demandante).
IMPORTANT
Des poursuites judiciares ont ete entreprises contre vous. Vous avez 20 jours
consecutifs a partir de Ia date de !'assignation de cette citation pour deposer une reponse
ecrite a Ia plainte ci-jointe aupres de ce tribunal. Un simple coup de telephone est
insuffisant pour vous proteger. Vous etes oblige de deposer votre reponse ecrite, avec
mention du numero de dossier ci-dessus et du nom des parties nommees ici, si vous
souhaitez que le tribunal entende votre cause. Si vous ne deposez pas votre reponse
ecrite dans le relai requis, vous risquez de perdre Ia cause ainsi que votre salaire, votre
argent, et vas biens peuvent etre saisis par Ia suite, sans aucun preavis ulterieur du
tribunal. II y a d'autres obligations juridiques et vous pouvez requerir les services
immediats d'un avoca!. Si vous ne connaissez pas d'avocat, vous pourriez telephoner a
un service de reference d'avocats ou a un bureau d'assistance juridique (figurant a
l'annuaire de telephones).
Si vous choisissez de deposer vous-meme une reponse ecrite, il vous faudra
egalement, en meme temps que cette formalite, faire parvenir ou expedier une copie de
votre reponse ecrite au "Plaintiff/Plaintiff's Attorney" (Piaignant ou a son avoca!) nomme
ci-dessous.
JONI ARMSTRONG COFFEY
County Attorney for Broward County
Daphne E. Jones, Assistant County Attorney
Governmental Center, Suite 423
115 South Andrews Avenue
Fort Lauderdale, Florida 33301
Telephone: (305) 357-7600
Telecopier: (305) 357-6968
-2-
THE STATE OF FLORIDA
TO EACH SHERIFF OF THE STATE:
You are commanded to serve this summons and a copy of the complaint in this
lawsuit on the above-named defendant.
DATED ON
JUN 24 2013
2013.
(SEAL)
IN ACCORDANCE WITH THE AMERICANS WITH DISABILITIES ACT OF 1990 (ADA),
ALL PERSONS WHO ARE DISABLED AND WHO NEED SPECIAL
ACCOMMODATIONS TO PARTICIPATE IN THIS PROCEEDING BECAUSE OF THAT
DISABILITY SHOULD CONTACT THE 17TH CIRCUIT COURT ADA COORDINATOR
NOT LATER THAN FIVE BUSINESS DAYS PRIOR TO THE PROCEEDING. THE 17TH
CIRCUIT COURT ADA COORDINATOR MAY BE REACHED AT 201 SOUTHEAST
SIXTH STREET, ROOM 880, FORT LAUDERDALE, FL, 33301; THE TELEPHONE
NUMBER IS (305) 831-7017; OR 1-800-955-8770 VIA FLORIDA RELAY SERVICE.
-3-
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
BROWARD COUNTY, a political subdivision
Of the State of Florida
Plaintiff,
vs.
FREEDOM MARINE FINANCE, LLC.,
a dissolved Florida limited liability company and
TODD LITTLEJOHN d/b/a FREEDOM
MARINE FINANCE, LLC.
Defendant.
__________________________ ./
CASE NO.: CAt,E 13- 0ILj 8'41
01V oe
COMPLAINT FOR INJUNCTIVE RELIEF
COMES NOW Plaintiff, BROWARD COUNTY ("COUNTY") and files this
complaint against Defendants, FREEDOM MARINE FINANCE, LLC., a dissolved
Florida limited liability company ("FREEDOM") and TODD LITTLEJOHN d/b/a
FREEDOM MARINE FINANCE, LLC., a dissolved Florida limited liability company, for
issuance of a mandatory injunction to enforce compliance with the Final Orders
(attached hereto as Exhibit "A" and "B"), and stating as grounds therefore the following:
1. This Court has jurisdiction pursuant to Article V, Section 5(b), Florida
Constitution, Section 26.012(2)(a), Florida Statutes ("F.S.").
2. As all actions giving rise to this cause of action occurred in Broward County,
Florida, this Court is the proper venue.
3. PLAINTIFF, BROWARD COUNTY, is a subdivision of the State of Florida.
4. DEFENDANT, FREEDOM, is a Florida limited liability company with a principle
address of 790 NW 1
51
Avenue, Deerfield Beach, FL 33441, and which was
dissolved on September 28, 2012 for failure to submit an annual report.
5. DEFENDANT, TODD LITTLEJOHN, d/b/a FREEDOM MARINE FINANCE, LLC.,
a dissolved Florida limited liability company, was the managing member of
Freedom Marine Finance, LLC., a dissolved Florida limited liability company and
has at all relevant times operated a marine facility business at 790 NW 1st
Avenue, Deerfield Beach, FL 33067.
6. DEFENDANTS, FREEDOM and TODD LITTLEJOHN d/b/a FREEDOM MARINE
FINANCE, LLC., a dissolved Florida limited liability company, are a "person"
within the meaning of Section 27-4(29) Broward County Code of Ordinances
("BCC") and a "responsible party" within the meaning of Section 27-4(32), BCC.
FACTS
7. On January 4, 2010, the Hearing Examiner of the Broward County Environmental
Protection Department ("Hearing Examiner") issued a Final Order (Exhibit "A")
requiring FREEDOM to submit a completed Broward County Marine Facility
Operating License and to pay the required fees for the License Application.
FREEDOM was also found liable to pay a civil penalty of $500.00.
-2-
8. On June 29, 2012, the Hearing Examiner in the tribunal found that FREEDOM
failed to obtain a Broward County Marine Facility Operating License (MFOL) as
required Section 27-342, Broward County Code (BCC) and failed to pay manatee
protection plan fees as required by Section 27-334(c)(2), BCC in violation of 27-
27(a)(2), BCC and failed to obtain a MFOL as required by Final Order issued on
January 4, 2010, by the Hearing Examiner for the Broward County EPGMD
regarding Citation No. CIT09-0051 in violation of 27-23(b), BCC.
9. The Hearing Examiner ordered that the DEFENDANT FREEDOM pay a civil
penalty of $17,400.00, MFOL past due fees of $25,139.28 and administrative
costs of $600.00 for a total sum due and owing of $43,139.28. In addition, the
Hearing Examiner ordered corrective action that included within fifteen (15) days
of rendition of the Final Order, that the DEFENDANT FREEDOM shall obtain a
MFOL for the facility located at 790 NW 1st Avenue, Deerfield Beach, Florida and
shall remit to Broward County EPGMD $25,139.28 in MFOL fees due from
October 1, 2008 to present.
10. DEFENDANT, FREEDOM, has not obtained a MFOL for the facility located at
790 NW 1st Avenue, Deerfield Beach, Florida with the required fees, nor paid the
outstanding penalties and costs. Sections 27-342, 27-334(c)(2) and 27-27(a)(2).
FAILURE TO COMPLY WITH COUNTY FINAL ORDER
11. Paragraphs 1-10 are hereby realleged and incorporated herein.
-3-
12. DEFENDANT, FREEDOM, failed to comply with the Final Orders issued by the
Hearing Examiner on January 4, 2010 and June 29, 2012, (Exhibit "A" and "B") in
violation of County Code 27-23.
13. DEFENDANT, FREEDOM, was ordered to pay a civil penalty of $500.00 and
complete the License within the 30 days of the Order. No payments have been
made as of the date of filing this complaint. In addition, the DEFENDANT,
FREEDOM, has failed to obtain a license application form.
14. DEFENDANT, FREEDOM, was ordered to pay a civil penalty of $17,400.00,
MFOL past due fees of $25,139.28 and administrative costs of $600.00 for a total
sum due and owing of $43,139.28 within 30 days of the rendition of the Final
Order. DEFENDANT, FREEDOM, failed to pay the amount ordered to COUNTY
by July 20, 2012, and no payment has been received as of the date of filing this
Complaint.
15. DEFENDANT, FREEDOM, was ordered to obtain a MFOL for the facility located
at 790 NW 1st Avenue, Deerfield Beach, Florida, within fifteen (15) days of the
rendition of the Final Order or by July 20, 2012. DEFENDANT, FREEDOM,
failed to obtain a MFOL for the facility located at 790 NW 1st Avenue, Deerfield
Beach, Florida by July 20, 2012, and no application has been received as of the
date of filing this Complaint.
16. DEFENDANT, TODD LITTLEJOHN d/b/a FREEDOM MARINE FINANCE, LLC.,
a dissolved Florida limited liability company, as the managing member is
personally liable for monetary damages when he failed to act regarding
-4-
management or policy decisions which resulted in DEFENDANT, FREEDOM,
becoming administratively dissolved. (See F.S. 608.4228).
17. DEFENDANT, TODD LITTLEJOHN d/b/a FREEDOM MARINE FINANCE, LLC.,
a dissolved Florida limited liability company, failed to exercise a duty of loyalty
and a duty of care. Specifically, DEFENDANT, TODD LITTLEJOHN d/b/a
FREEDOM MARINE FINANCE, LLC., a dissolved Florida limited liability
company, breached the duty of loyalty when it failed to wind up the limited liability
company business as or on behalf of a party, having an interest adverse to the
limited liability company.
18. In addition, DEFENDANT, TODD LITTLEJOHN d/b/a FREEDOM MARINE
FINANCE, LLC., a dissolved Florida limited liability company, breached its duty
of care when it knowingly violated the law by failing to comply with the Final
Orders as seen in Exhibits "A" and "B" issued by the Hearing Examiner on
January 4, 2010 and June 29, 2012 in violation of the County Code 27-23. (See
F.S. 608.4225).
19. As a result, DEFENDANTS, have made no payments or complied with the Final
Orders.
AUTHORITY FOR A MANDATORY INJUNCTION
20. This Court has authority to enforce Broward County Final Orders (Exhibit "A" and
"B") by injunction pursuant to Section 26.012(3), F.S. In order to be entitled to
injunctive relief under Florida case law, a Plaintiff must establish irreparable
-5-
harm, a clear legal right, an inadequate remedy at law, and that consideration of
the public interest weighs in the Plaintiff's favor. Hiles v. AutoBahn Federation,
Inc .. 498 So. 2d 997 (Fla. 4th DCA 1986); Contemporarv Interiors, Inc. v. Four
Marks. Inc., 384 So. 2d 734 (Fla. 4th DCA 1986). The COUNTY is entitled to
mandatory, permanent injunctive relief based upon DEFENDANTS refusal to
comply with the BCC and Final Order, and the traditional elements of injunctive
relief weigh in favor of issuance of an injunction.
21. DEFENDANTS caused irreparable harm by not obtaining a Broward County
MFOL as required by Section 27-342, BCC and failing to pay manatee protection
fees as required by Section 27-334(c)(2), BCC in violation of 27-27(a)(2), BCC
and failed to obtain as required by Final Order issued on January 4, 2010,
(Exhibit "A") by the Hearing Examiner for the Broward County EPGMD regarding
Citation No. CIT09-0051 in violation of 27-23(b), BCC. By failing to obtain a
Broward County MFOL, the DEFENDANTS are causing irreparable harm to the
COUNTY's regulatory program and its authority to ensure that DEFENDANTS
are not causing pollution or environmental harm by its use marine facilities with
five or more slips.
22. COUNTY has a clear legal right to obtain the requested injunctive relief to
remedy DEFENDANTS violation pursuant to the provisions of the BCC and the
Final Order. The BCC requires that a MFOL be obtained by any owner or
operator who operates a marine facility with five or more slips. See Sections 27-
27(a)(2), 27-23(b),BCC. COUNTY has a clear legal right to require
permits/licenses and to enforce that requirement. See Sections 27-14, 27-23,
-6-
27-26, 27-37, 27-54, 27-342(b), BCC. DEFENDANTS violation is subject to
COUNTY'S clear legal right to seek compliance by duly rendered Final Orders
(Exhibit "A" and "B"). Section 27-22(h), 27-23(a)(7), BCC. When Final Orders
are not complied with, COUNTY has the clear legal right to seek judicial
injunctive relief to enforce compliance with Chapter 27 of the Code and the Final
Order. See Sections 27-53, 27-54, 27-342(b), BCC, and Section 26.012(2)(a),
F.S.
23. COUNTY does not have an adequate remedy at law. There is no adequate
remedy when an individual refuses to obtain a required permit or pay the
required fees. COUNTY'S only remaining remedy is to request that this Court
issue a mandatory injunction to force DEFENDANTS compliance with the BCC.
24. The public interests at stake weigh especially heavily in favor of this Court
issuing an injunction. First, there is a fundamental public interest in COUNTY'S
ability to enforce the BCC and duly rendered Final Orders. Sections 27-2, 27-3,
BCC. Second, the public interest weighs in favor of prohibiting continuing non-
compliance with duly enact County Codes. Third, the public interest weighs in
favor of maintaining a level playing field amongst regulated businesses and
individuals and against allowing willful non-compliance with permit and licensing
requirements. All of the above reasons warrant this Court to exercise its
discretionary powers and grant the necessary injunctive relief requested.
WHEREFORE, PLAINTIFF, COUNTY, requests that this Court:
-7-
(a) Issue a mandatory injunction compelling DEFENDANTS, FREEDOM
MARINE FINANCE, LLC., a dissolved Florida limited liability company, and
TODD LITTLEJOHN d/b/a FREEDOM MARINE FINANCE, LLC., a dissolved
Florida limited liability company, to comply with the terms of the Final Orders
of January 4, 2010 and June 29, 2012 (Exhibit "A" and "8"), obtain the license
and remit payment $18,000.00 in penalties and costs and $25,139.28 in
license fees.
(b) Grant costs as well as court costs and pre and post judgment interest of
4.75% per annum, which order to be in the form of a Final Judgment a
certified copy may be recorded as a lien on all real or personal property of the
DEFEDNANTS and
(c) Grant such further relief as the Court may deem proper, including but not
limited to, additional penalties for having filed this action.
PAGE INTENTIONALLY LEFT BLANK
-8-
DESIGNATION OF PRIMARY E-MAIL ADDRESS
In accordance with Fla. R. Jud. Admin. 2.516(b)(1)(A), the undersigned attorney
for the Plaintiff hereby designates
Primary E-Mail: dajones@broward.org.
Secondary Email: trice@broward.org
Dated : _ __,J"'u'-"n e,__l'--'8""''""'2,_,0'-'1 ""3 __ _
JONI ARMSTRONG COFFEY
Broward County Attorney
Governmental Center, Suite 423
115 South Andrews Avenue
Fort Lauderdale, Florida 33301
Telephone: (954) 357-7600
Telecopier: (954) 357-7641
By /s/ Daphne E. Jones
Daphne E. Jones
Assistant County Attorney
Florida Bar No. 844111
-9-
Primary Email: dajones@broward.org
Secondary Email: trice@broward.org
\
CFN # 109166390
JR BK 46893 Pages 1909-1913
RECORDED 02/23/10 09:55:04
BROWARD COUNTY COMMISSION
DEPUTY CLERK 1043
#1, 5 Pages
BEFORE THE HEARING EXAMINER FOR THE BROWARD COUNTY
ENVIRONMENTAL PROTECTION DEPARTMENT
IN AND FOR BROWARD COUNTY, FLORIDA
Broward County,
Petitioner,
vs.
Freedom Marine Finance, LLC,
Citation No: CIT09-0051
Respondent.
-----------------------'
FINAL ORDER
Upon Motion for Final Order after Non-compliance with Citation made by Petitioner, it is
ORDERED and ADJUDGED as follows:
Respondent, Freedom Marine Finance, LLC, shall remit to the Broward County
Environmental Protection and Growth Management Department the sum of $500.00
and evidence of compliance with CIT09-0051 attached Exhibit "A" within thirty (30)
days of this Final Order.
)0
' 20.00:
CERTIFICATE OF SERVICE
I HEREBY CERTIFY a copy of this Final Order have been furnished by U.S. Mail,
to Respondent, Freedom Marine Finance, LLC, this day
I -A .. 20W. -
__ /()
RECEIVED
JAN -7 2010
PPRAQD-ENF ADMIN
Environmental Protection and Growth
Management Department
EXHIBIT
J ---4A4----
Environmental Protection and Growth Management Department
DEVELOPMENT AND ENVIRONMENTAL REGULATION DIVISION
EXHIBIT A
One N. University Drive, Suite 201, Plantation, Florida 33324 954-519-1483 FAX 954-519-1412
CITATION
CITATION NUMBER: CIT09-0051
The undeiSigned certifies that he/she has just grounds to believe that on or about October 01, 2008, 0800
hours, at the location below, the following Respondent violated the sections of the Broward County Code
(BCC) identified in each count:
Location:
790 NW 1ST AVE
Deerfield Beach, FL 33441
COUNT 1: Respondent: Freedom Marine Finance, LLC
Violated Section 27-54, BCC, which states:
"Prior to the commencement of construction, modification, alteration, replacement or
operation of any facirtty or the commencement of any activity that may cause or be a source
of pollution, or that may impact, eliminate, reduce or control pollution of the air, ground,
groundwaters, surface waters or other natural or biological resources, the owner and/or
operator shall obtain a EPGMD license and pay required fees as established by resolution
of the Board .... "
By: Operating without a Broward County Marine Facility Operating License as required by
Section 27-342, BCC.
Corrective Action:
Respondent shall submit a complete Marine Facility Operating License application
and pay the appropriate fee.
Correct within 15 days of service of this notice.
Penalty Amount: $500.00
The Respondent must either pay the civil penalty(ies), associated with each count and complete the
corrective action(s) as stated in this Citation, or dispute Whichever counl(s) you believe are necessary by
requesting a Hearing before the Environmental protection and Growth Management Department
(Department) Hearing Examiner.
Rya Goldman, Natural Resource Enforcement Officer
Phone: (954) 519-1266 FAX: (954) 519-1412 Email: rgoldman@broward.org
Broward County Board of County Commlsslcners
to{ 1'1{1PePr 1(: oo t1M
Date and 11me of Issuance
Josephus Eggelloetion, Jr ... Sue Gunzburger K r i s ~ n 0. Jacobs Ken K ~ l Ilene Lieberman Stacy Ritter John E. Rocigtrom, Jr. Diana Wasserman-Rubin . Lois Wexler
www.broward.org
Page 1 of3
CITATION NUMBER: CIT09-0051
Failure to request an Administrative Hearing within ten (1 0) days after service of the Citation $hall
constitute a waiver of your right to an Administrative Hearing before the Hearing Examiner, and that such
waiver shall constitute an admission of the violation(s). A written request must be delivered and be in the
possession of the Department Enforcement Administration (115 South Andrews Avenue, Room A-240,
Fort Lauderdale, FL 33301), before the end of the t e n ~ y period. At the Hearing, the Hearing Examiner
may assess civil penaHies not to exceed five hundred dollars ($500.00) per violation, reasonable costs of
the Administrative Hearing, and corrective action should the violator be found guiHy of the violation.
If the violator does not elect to appeal the Citation to the Hearing Examiner, fails to pay the civil
penaHy(ies) within the time allowed, or fails to appear to contest the Citation, the violator shall be deemed
to have waived its right to contest the Citation and that, in such case, judgment shaD be rendered ex parte,
without notice to the violator, by the Hearing Examiner Into a Final Order for an amount up to five hundred
dollars ($500.00) per violation. The certified copy of an Order imposing a civil penalty may be recorded in
the public records and thereafter shall constitute a rren against the real and personal property of the
violator. After three (3) months from the filing of any such lien which remains unpaid, the County may
foreclose or otherwise execute on the lien.
Failure to pay a civil penaHy is an additional violation of section 27-38 (f) (2) of the Broward County Code of
Ordinances. Payment of the civil penaHy must be received by the Department within thirty (30) calendar
days of the receipt of this Citation. Additional Citations or Notices of Violation may be Issued for each day
the applicable violation is found to exist.
Any person who willfully refuses to sign and accept a Citation issued by a Natural Resource Enforcement
Officer shall be in violation of the Code and shall be guilty of a misdemeanor of the second degree,
punishable as provided in s.775.082 or s.775.083, Florida Statutes.
Please complete; detach and return the enclosed Citation Response Summary Page to the
Department at the address identified in the Summary Page Instructions.
Registered Agent/Mailed To:
Tanya L. Bower, ESQ.
(for Freedom Marine Finance, LLC)
110 SE 6th St., 15th Floor
Fort Lauderdale, FL 33301
RRR: 7004 2890 0000 5987 8999
CC: Enforcement Administration
Page2of3
Environmental Protection and Growth Management Department
ENVIRONMENTAL MONITORING AND ENFORCEMENT DIVISION- ENFORCEMENT ADMINISTRATION
One N. University Olive, Sune 307, PlnlaUon, FL 33324-2038 954-519-1210 FAX 954-519-1493
Citation Response Summary Page
CITATION NUMBER: CITOB-0051
Respondent: Freedom Marine Finance, LLC
Instructions: Please complete this Citation Response Summary Page addressing each count. Attach additional
pages if needed. Make check payable to: The Broward County Board of County Commissioners. Detach and
either deliver or mail the Response Summary Page and payment, if applicable, to the Environmental Protection
and Growth Management Department, Collections Department, One N. University Dr., Suite 102, Plantation, FL
33324. DO NOT SEND CASH. Please include the Citation number on your check or money order to ensure
proper credit. A request for an Administrative Hearing must be made within 10 days of service of the Citation. If
you have any questions, please call (954) 519-1210.
Count 1: Penalty Amount: $500.00
Please check one: 0 Payment enclosed 0 Hearing requested
Grounds for requesting a hearing:---------------------
Total Penalty Amount Due: $500.00
Amount Enclosed:-----
Signature ________ -'------
Print Name _____________ ___
Daytime Phone Number------'-----
Trtle _______ _
Date ___ _
Page3of3

. COUNTY
FLORIDA
Environmental Protection and Growth Management Department
POLLUTION PREVENTION, REMEDIATION AND AIR QUALITY DIVISION- ENFORCEMENT ADMINISTRATION
One N. University Drive, Suite 307, Plantation, Florida 33324
954-519-1210 FAX 954-519-1493
BROWARD COUNTY ENVIRONMENTAL
PROTECTION AND GROWTH MANAGEMENT
DEPARTMENT
Petitioner,
vs.
FREEDOM MARINE FINANCE, LLC,
Respondent.
---------------------------------'
STATE OF FLORIDA
BROWARD COUNTY
CIT09-0051
I HEREBY CERTIFY that the above and foregoing is a true and correct copy of the Final
Order issued by the Hearing Examiner for the Environmental Protection and Growth
Management Department, on January 4, 2010, in Broward County vs Freedom Marine Finance,
LLC.
' ... ' ...
WITNESS my hand and the official seal in the City of Plantation, Florida, this 16h day of
February 2010. Environmental Protection and Growth Management Department:
By
Broward County Board of County Commissioners
Sue Gunzburger Kristin D. Jacobs Albert c. Jones Ken Keechl Ilene Lieberman Stacy Ritter Johrl E. Rodstrom, Jr. Diana Wasserman-Rubin Lois Wexler
\
\
\
BEFORE THE HEARING EXAMINER FOR THE BROWARD COUNTY
ENviRONMENTAl PROTECTION AND GROWTH MANAGEMENT DEPARTMENT
IN AND FOR BROWARD COUNTY, FLORIDA
BROWARD COUNTY ENVIRONMENTAL
PROTECTION AND GROWTH
MANAGEMENT DEPARTMENT,
NOV12-0016
Petitioner,
vs.
CFN # 11 0930368
OR BK 48980 Pages 1464- 1469
RECORDED 08/08/12 11:33:05 AM
BROWARD COUNTY COMMISSION
DEPUTY CLERK 1926
FREEDOM MARINE FINANCE, LLC,
Respondent.
#1, 6 Pages
- - - - - - - - - - - - - - - - - - - - - - - - - - ~ '
FINAL ORDER
THIS MATTER came before the undersigned Hearing Examiner for the
Broward County Environmental Protection and Growth Management Department
{EPGMD) at a regularly scheduled hearing held on June 28, 2012 in Plantation,
Florida. The issue to be determined is whether Respondent, Freedom Marine
Finance, LLC, violated the following provisions of Chapter 27 of the Broward County
Code in the two-count Notice of Violation at issue herein as follows:
Count 1: Whether Respondent failed to obtain a Broward County
Marine Facility Operating license {MFOL) as required by Section 27-
342, Broward County Code (BCC) and failing- to pay manatee
protection plan fees as required by Section 27-334(c)(2), BCC, in
violation of Section 27 -27(a)(2) of the BCC.
Count 2: Whether Respondent failed to obtain a MFOL as required
by the Final Order issued by January 4, 201 0, by the Hearing
I
EXHIBIT
B
it-.)
\UJ
Examiner for the Broward County EPGMD regarding Citation No.
CIT09-0051 in violation of Section 27-23(b), BCC.
EPGMD is seeking a civil penalty in the amount of $17,400.00, MFOL past
due fees of $25,139.28, and administrative costs of $600.00 for a total of
$43,139.28. EPGMD also requests certain specified corrective action detailed at the
end of this Final Order.
Daphne E. Jones, Esquire of the Broward County Attorney's Office
represented the EPGMD and presented the testimony of Meredith Brannon, Natural
Resource Specialist Ill and Ryan Goldman, Natural Resource Specialist II. No one
appeared on behalf of Respondent.
FINDINGS OF FACT
1. Respondent is the owner of property located at 790 NW 1
51
Avenue, Deerfield
Beach, Florida 33441.
2. EPGMD's Ryan Goldman testified that, on August 26, 2008, notice was sent
by Certified Mail Return Receipt Requested to Respondent advising that, as
part of the Broward County Manatee Protection Plan (MPP) accepted by the
Florida Fish and Wildlife Conservation Commission and the United States
Fish and Wildlife Service in December 2007, the Broward County
Commissioners adopted Ordinance No. 2007-34, which requires, inter alia.,
that all marine facilities with five or more slips apply for and obtain a MFOL.
Respondent was given a deadline of October 1, 2008 to, submit the
application for a MROL and return it with the appropriate fee. The evidence
reflects that Respondent received the notice on September 5, 2008.
2
3. Mr. G o l d ~ a n testified that, on July 7, 2009, a Notification, of Potential
Enforcement Action (NPEA} was sent by Certified Mail Return Receipt
Requested to Respondent advising that the required MFOL application and
fee had not been received. Respondent was given fifteen (15} days of receipt
of the letter to submit the required application and fee. The evidence reflects
that Respondent received the NPEA on July 13, 2009.
4. Mr. Goldman testified that, on August 5, 2009, Citation Warning Notice
WRN09-0413 was sent by Certified Mail Return Receipt Requested to
Respondent for failing to submit a complete MFOL application and pay the
associated fee. The evidence reflects that Respondent received WRN09-
0413 on August 10,2009.
5. Mr. Goldman testified that, on October 19, 2009, Citation CIT09-0051 was
sent by Certified Mail Return Receipt Requested to Respondent for failing to
submit a complete MFOL application and pay the associated fee. The
evidence reflects that Final Order CIT09-0051 was entered against
Respondent on January 4, 2010.
6. Mr. Goldman t$$tified that, on June 16, 2010, he performed a site inspection
' .. ' ..
of the subject property and confirmed a slip count of 296 slips. Mr. Goldman
testified that he mailed an MFOL Renewal Notice to Respondent on August
15, 201 0 for fiscal year 2011 and again on August 15, 2011 for fiscal year
2012.
7. Mr. Goldman testified that, on January 19, 2012, he performed a site
inspection of the subject property and confirmed slip count of 296 slips.
3
8. Mr. Goldman testified that, on May 14, 2012, Notice of Violation and Notice
of Hearing to Assess a Civil Penalty (Notice) relative to Case No. NOV12-
0016 was sent by certified mail, return receipt requested to Respondent.
EPGMD's Meredith Brannon testified that, according to the United States
Postal Service Track and Confirm website, the Notice was delivered to
Respondent on May 18, 2012. The evidence presented reflected that
Respondent was properly noticed of the hearing and a default was entered
against Respondent.
CONCLUSIONS OF LAW
The evidence is uncontroverted that Respondent, Freedom Marine Finance,
LLC, failed to obtain a Broward County MFOL as required by Section 27-342,
BCC and failing to pay manatee protection plan fees as required by Section 27-
33(c)(2), BCC in violation of 27-27(a)(2), BCC and failed to obtain a MFOL as
required by Final Order issued on January 4, 2010, by the Hearing Examiner for
the Broward County EPGMD regarding Citation No. CITOS-0051 in violation of
27-23(b), BCC.
WHEREFORE, it is hereby ORDERED AND ADJUDGED that:
Respondent, Freedom Marine Finance, LLC, did violate Chapter 2T of the
Broward County Code as set forth in Counts 1 and 2. Accordingly, Respondent
shall pay a civil penalty of $17,400.00, MFOL past due fees of $25,139.28 and
administrative costs of $600.00 for a total sum due and owing of $43,139.28.
In addition, the following corrective action shall be imposed in this case:
Within fifteen (15) days of rendition of this Final Order, Respondent shall obtain a
4
MFOL for the facility located at 790 NW 1st Avenue, Deerfield Beach, Florida and
shall remit to the Broward County EPGMD $25,139.28 in MFOL fees due from
October 1, 2008 to present.
DONE AND ORDERED on this 29th day of June, 2012.
Copies Furnished to:
Daphne E. Jones, Esq., Assistant County Attorney
Freedom Marine Finance, LLC, Respondent
John Stagnari, EPGMD Enforcement Administrator
5
RECEIVED
JUL - 5 2012
PPRAQO-ENF ADMIN