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Complaint for injunction and declaratory relief - …

IN THE CIRCUIT COURT IN AND FOR THE SECOND JUDICIAL CIRCUIT, LEON COUNTY, FLORIDA WILLIAM LAYTON LYONS, FRANCESCA CORREA, by and through her guardian Lorraine Rodriguez, JOHN BODACK, and THE ADVOCACY CENTER FOR PERSONS WITH DISABILITIES, INC., Plaintiffs, CASE NO: vs THEAGENCY FOR PERSONS WITH DISABILITIES, a State of Florida agency, Defendant _____/ Complaint FOR injunction AND declaratory JUDGMENT Plaintiffs, by and through undersigned counsel, hereby petition this Court for declaratory and injunctive relief and state as follows: INTRODUCTION 1. This action is filed by three persons with developmental disabilities (DD) who receive home and community based services under a Medicaid Waiver for persons with DD (waiver recipients), and the Advocacy Center for Persons with Disabilities, Inc.

IN THE CIRCUIT COURT IN AND FOR THE SECOND JUDICIAL CIRCUIT, LEON COUNTY, FLORIDA WILLIAM LAYTON LYONS, FRANCESCA CORREA, by and through her guardian Lorraine Rodriguez,

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