James Robert Kalway filed a petition to initiate rulemaking with the Department of Corrections ("DOC"), requesting that the DOC amend Rule 33-11.0065, Florida Administrative Code. See § 120.54(7), Fla. Stat. (Supp.1996) ("Any person regulated by an agency or having substantial interest in an agency rule may petition an agency to adopt, amend, or repeal a rule...."). The petition alleged that the unamended...
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