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Filing # 145646455 E-Filed 03/14/2022 01:42:25 PM
IN THE CIRCUIT COURT OF THE ELEVENTH
JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CIVIL ACTION
RAUL MEJIA, and VIRGINIA LOPEZ
Plaintiffs,
CASE NO.: 2018-12371-CA
vs. DIVISION:
PEDRO GARCIA, as Property Appraiser of
Miami Dade County Florida; LEON M.
BIEGALSKI, as Executive Director of
Florida Department of Revenue; MARCUS
SAIZ DE LA MORA, as Tax Collector of
Miami Dade County, Florida
Defendants.
______________________________________________/
AMENDED SUBPOENA DUCES TECUM FOR DEPOSITION
(Non-Party Nuris Bello)
THE STATE OF FLORIDA:
TO: Ms. Nuris Bello
7952 NW 107 Court,
Doral, FL 33178
YOU ARE COMMANDED to appear before a person authorized by law to take
depositions at the office of André Gibson, Chartered, located at 45 NE 167th Street, North
Miami Beach, FL 33162 on April 27, 2022 at 2:00 PM, for the taking of your deposition
in this action and to have with you at that time and place the following documents:
SEE EXHIBIT “A”
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items.
If you fail to appear, you may be in contempt of court. You are subpoenaed by the
attorney(s) whose name(s) appear on this subpoena and unless excused from this subpoena
by the attorney(s) or the court, you shall respond to this subpoena as directed.
The deposition will be upon oral examination before a registered court reporter or before
any other notary public or officer authorized by law to take depositions. If you fail to
appear, you may be in contempt of court.
You are subpoenaed to appear by the following attorney and unless excused from this
subpoena by this attorney or the court, you shall respond to this subpoena as directed.
If you fail to appear as specified and furnish the records; or object to this subpoena, you
may be in contempt of court. You are subpoenaed to appear by the following attorney, and
unless excused from this subpoena by this attorney or the court, you shall respond to this
subpoena as directed.
COVID-19 PROTOCOL
Due to COVID-19, this deposition will be held remotely on the Zoom platform or
any other video conferencing method. You will receive an email from this office
with the information you need to connect to your event by video.
UPON RECEIPT OF THIS SUBPOENA, PLEASE CONTACT ANDRÉ A. GIBSON
AT 305-652-4900 FOR FURTHER INFORMATION ON ZOOM OR OTHER VIDEO
CONFERENCING MEETING ARRANGEMENTS.
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Definitions and Instructions
1. You may condition the preparation of the copies upon the payment in
advance of the reasonable cost of preparation.
2. Except as otherwise specified herein, all documents requested include
documents originated, received, used or distributed at any time.
3. In the event that any document called for in this Subpoena is withheld on the
basis of privilege, identify the document by date, author, type of document (i.e. letter,
memorandum, report, etc.) and all persons whom the document was distributed and
state the nature of the privilege asserted.
4. In the event that any document called for in this Subpoena does not now
exist, state whether the document did exist, the date upon which the document was
destroyed and the reason for such destruction.
5. In the event that any document called for in this Subpoena exists, but is
maintained outside of the defendant’s possession, custody, or control, state the
custodian and location of such document.
6. The term “you” or “your” means the Nuris Bello, individually and as former
employee of the Miami-Dade County Property Appraiser.
7. The term “document” or “documents’ shall include, without limiting the
generality of the foregoing, correspondence, agreements, memoranda, calendar and
diary entries, memoranda or conversations of meetings, studies, reports, offers,
inquiries, bulletins, summaries, newsletters, compilations, maps, charts, graphs,
photographs, film, microfilm, articles, announcements, books, books of account, ledgers,
vouchers, cancelled checks, invoices, bills, opinions, certificates, computer records and
entries, email sent or received, materials on hard drives, CD’s, floppy disks, and
including all other tangible things upon which any handwriting, typing, drawing,
representation, magnetic or electrical impulses or other form of communication is
recorded, including audio and video recordings and computer stored information.
8. To the extent that you consider any of the following requests to produce
objectionable, respond to so much of each production request, and each part thereof, as
is not objectionable in your view and separately state that part of each production
request as to which you raise objection and each ground for each objection.
9. If you object to the production of any document on a claim of attorney client
or work product privilege, identify the privilege claimed, together with the following
information with respect to each document: (a) date, (b) sender, (c) addressee, (d)
subject matter, (e) the basis on which the privilege is claimed, and (f) the names of all
persons to whom copies of any part of the document were furnished, together with an
identification of their employer and their job titles.
(a) The words “person” or “persons” mean all natural persons (individual
or individuals) and entities including without limitation corporations, companies,
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partnerships, limited partnerships, joint ventures, trusts, estates, associations,
public agencies, departments, bureaus and board.
(b) “Communication” shall mean every manner or means of disclosure,
transfer, or exchange, and every disclosure, transfer or exchange of information
whether orally, by electronic means, by face-to-face conversation, telephone, mail,
email, personal delivery, document or otherwise.
DATED this 14th day of March, 2022.
FOR THE COURT:
ANDRÉ GIBSON, CHARTERED
Andre A. Gibson
Attorney for Plaintiffs
Florida Bar Number: 0635529
45 NE 67th Street,
North Miami Beach, FL 33162
Telephone: (305) 652-4900
Fax: (305) 808-3495
E-Mail: AAGibson@Gibsontaxlaw.com
Secondary E-Mail: Efile@Gibsontaxlaw.com
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EXHIBIT “A”
DUCES TECUM
Please have with you at said time and place the following:
1. A copy of any and all documents related to Virginia Lopez and/or Raul Mejia and the
property located at 201178 DR 531, Sunny Isles Beach, 33160-2875 described by
Folio No.: 31-2211-039-1220
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