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Filing # 146778184 E-Filed 03/31/2022 10:15:26 AM
IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. 18-12371 CA 01
RAUL MEJIA and VIRGINIA LOPEZ,
Plaintiffs,
vs.
PEDRO J. GARCIA, as Property Appraiser of
Miami-Dade County, Florida; LEON M.
BIEGALSKI, as Executive Director of Florida
Department of Revenue; and MARCUS SAIZ
DE LA MORA, as Tax Collector of Miami-
Dade County, Florida,
Defendants.
______________________________________/
DEFENDANT PROPERTY APPRAISER’S
SECOND REQUEST FOR PRODUCTION TO PLAINTIFFS
Pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, Defendant PEDRO J.
GARCIA, as Property Appraiser of Miami-Dade County, Florida (the “Property Appraiser”),
hereby requests Plaintiffs/Taxpayers RAUL MEJIA and VIRGINIA LOPEZ to produce at the
office of the Miami-Dade County Attorney, Stephen P. Clark Center, Suite 2810, 111 N.W. 1st
Street, Miami, Florida 33128-1993, the following described documents within thirty (30) days as
required under Florida Rule of Civil Procedure 1.350.
Case No. 18-12371 CA 01
DEFINITIONS AND INSTRUCTIONS
(a) The terms “you,” “your,” or “yourself” refer to Plaintiffs/Taxpayers RAUL MEJIA
and VIRGINIA LOPEZ.
(b) The term “Subject Property” as used herein shall mean the real property described
in the Complaint located at 201 178 Drive, Unit 531, Miami, FL 33160, and more specifically
identified by Folio No. 31-2211-039-1220.
(c) Unless otherwise indicated, the request is for documents for the time period of
January 1, 2011 through December 31, 2016, which constitutes the same time period covered
by the tax lien(s) at issue.
(d) The request is for documents in the possession of you, your agents, accountants,
attorneys, and employees.
(e) For any document produced, you may redact any information which is privileged
or confidential pursuant to law, but not the name, addresses, telephone number, or identifying
information of you or the other business, government, person or entities mentioned in the
document.
(f) If any item requested is not in Plaintiffs’ immediate possession, but is within
Plaintiffs’ control, such as income tax returns, you are hereby requested to take any and all steps
necessary to obtain possession of such items.
(g) If you object to a part of any request, you are required to produce any responsive
documents pertaining to the parts of said request not objected to.
2
Case No. 18-12371 CA 01
DOCUMENT REQUESTS
1. Copies of any and all documents you brought to your meeting with the Property
Appraiser's office on or about August 29, 2013.
2. Copies of any and all documents you took with you from your meeting with the
Property Appraiser's office on or about August 29, 2013.
Respectfully submitted,
GERALDINE BONZON-KEENAN
Miami-Dade County Attorney
Stephen P. Clark Center
111 N.W. 1st Street, Suite 2810
Miami, Florida 33128
By: s/ Michael J. Mastrucci
Michael J. Mastrucci
Assistant County Attorney
Florida Bar No. 86130
Telephone: (305) 375-5151
Facsimile: (305) 375-5634
Email: mastrucc@miamidade.gov
Wilma.Morillo@miamidade.gov
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served this 2nd
day of March 31st, 2022 via E-Mail generated by the Florida Courts E-Filing Portal to: Andre A.
Gibson, Esq., 45 NE 67th Street, North Miami Beach, FL 33162, AAGibson@Gibsontaxlaw.com,
Efile@Gibsontaxlaw.com.
s/ Michael J. Mastrucci
Assistant County Attorney
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Filing # 146778184 E-Filed 03/31/2022 10:15:26 AM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. 18-12371 CA 01 RAUL MEJIA and VIRGINIA LOPEZ, Plaintiffs, vs. PEDRO J. GARCIA, as Property Appraiser of Miami-Dade County, Florida; LEON M. BIEGALSKI, as Executive Director of Florida Department of Revenue; and MARCUS SAIZ DE LA MORA, as Tax Collector of Miami- Dade County, Florida, Defendants. ______________________________________/ DEFENDANT PROPERTY APPRAISER’S SECOND REQUEST FOR PRODUCTION TO PLAINTIFFS Pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, Defendant PEDRO J. GARCIA, as Property Appraiser of Miami-Dade County, Florida (the “Property Appraiser”), hereby requests Plaintiffs/Taxpayers RAUL MEJIA and VIRGINIA LOPEZ to produce at the office of the Miami-Dade County Attorney, Stephen P. Clark Center, Suite 2810, 111 N.W. 1st Street, Miami, Florida 33128-1993, the following described documents within thirty (30) days as required under Florida Rule of Civil Procedure 1.350. Case No. 18-12371 CA 01 DEFINITIONS AND INSTRUCTIONS (a) The terms “you,” “your,” or “yourself” refer to Plaintiffs/Taxpayers RAUL MEJIA and VIRGINIA LOPEZ. (b) The term “Subject Property” as used herein shall mean the real property described in the Complaint located at 201 178 Drive, Unit 531, Miami, FL 33160, and more specifically identified by Folio No. 31-2211-039-1220. (c) Unless otherwise indicated, the request is for documents for the time period of January 1, 2011 through December 31, 2016, which constitutes the same time period covered by the tax lien(s) at issue. (d) The request is for documents in the possession of you, your agents, accountants, attorneys, and employees. (e) For any document produced, you may redact any information which is privileged or confidential pursuant to law, but not the name, addresses, telephone number, or identifying information of you or the other business, government, person or entities mentioned in the document. (f) If any item requested is not in Plaintiffs’ immediate possession, but is within Plaintiffs’ control, such as income tax returns, you are hereby requested to take any and all steps necessary to obtain possession of such items. (g) If you object to a part of any request, you are required to produce any responsive documents pertaining to the parts of said request not objected to. 2 Case No. 18-12371 CA 01 DOCUMENT REQUESTS 1. Copies of any and all documents you brought to your meeting with the Property Appraiser's office on or about August 29, 2013. 2. Copies of any and all documents you took with you from your meeting with the Property Appraiser's office on or about August 29, 2013. Respectfully submitted, GERALDINE BONZON-KEENAN Miami-Dade County Attorney Stephen P. Clark Center 111 N.W. 1st Street, Suite 2810 Miami, Florida 33128 By: s/ Michael J. Mastrucci Michael J. Mastrucci Assistant County Attorney Florida Bar No. 86130 Telephone: (305) 375-5151 Facsimile: (305) 375-5634 Email: mastrucc@miamidade.gov Wilma.Morillo@miamidade.gov CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served this 2nd day of March 31st, 2022 via E-Mail generated by the Florida Courts E-Filing Portal to: Andre A. Gibson, Esq., 45 NE 67th Street, North Miami Beach, FL 33162, AAGibson@Gibsontaxlaw.com, Efile@Gibsontaxlaw.com. s/ Michael J. Mastrucci Assistant County Attorney 3