On April 17, 2018 a
Party Discovery
was filed
involving a dispute between
Lopez, Virginia,
Mejia, Raul,
and
Biegalski,
De La Mora,
Lopez,
for Declaratory Judgment
in the District Court of Miami-Dade County.
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Filing # 144147776 E-Filed 02/17/2022 04:02:54 PM
IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. 18-12371 CA 34
RAUL MEJIA and VIRGINIA LOPEZ,
Plaintiff,
vs.
PEDRO GARCIA, as Property Appraiser of
Miami-Dade County Florida; LEON M.
BIEGALSKI, as the Executive Director of the
Florida Department of Revenue; MARCUS
SAIZ DE LA MORA, as Tax Collector of
Miami Dade County Florida,
Defendants.
_______________________________________/
PROPERTY APPRAISER’S RESPONSE TO PLAINTIFFS’ AMENDED
SECOND REQUEST FOR PRODUCTION
Defendant PEDRO J. GARCIA, as Property Appraiser of Miami-Dade County, Florida, by
and through undersigned counsel, pursuant to Fla. R. Civ. P. 1.350, and files his response to
Plaintiffs’ Amended Second Request for Production, as follows:
1. Provide a copy of all document listed in your response to Interrogatory 1 of the Plaintiffs
Third set of Interrogatories.
Response: Property Appraiser will produce any document(s) responsive to this request
to the extent that production does not violate confidentiality statutes, work product, and/or
attorney client privilege.
2. Provide a copy of the relevant sections all procedural manual(s) then in existence as at
August 29, 2013 which is applicable to and/or includes procedures for revocation of a homestead
exemption regardless of how the information or notification of the facts giving rise to the
revocation is obtained or received by the VA.
Case No. 18-12371-CA 34
Response: Property Appraiser will produce any document(s) responsive to this request
to the extent that production does not violate confidentiality statutes, work product, and/or
attorney client privilege.
Respectfully submitted,
GERALDINE BONZON-KEENAN
Miami-Dade County Attorney
Stephen P. Clark Center
111 N.W. 1st Street, Suite 2810
Miami, FL 33128-1993
By: /s/Michael J. Mastrucci
Michael J. Mastrucci
Assistant County Attorney
Florida Bar No. 86130
Telephone: (305) 375-5151
Facsimilie: (305) 375-5611
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 17th
day of February, 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.
By: /s/ Michael J. Mastrucci
Assistant County Attorney
2
Document Filed Date
February 17, 2022
Case Filing Date
April 17, 2018
Category
Declaratory Judgment
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Filing # 144147776 E-Filed 02/17/2022 04:02:54 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. 18-12371 CA 34 RAUL MEJIA and VIRGINIA LOPEZ, Plaintiff, vs. PEDRO GARCIA, as Property Appraiser of Miami-Dade County Florida; LEON M. BIEGALSKI, as the Executive Director of the Florida Department of Revenue; MARCUS SAIZ DE LA MORA, as Tax Collector of Miami Dade County Florida, Defendants. _______________________________________/ PROPERTY APPRAISER’S RESPONSE TO PLAINTIFFS’ AMENDED SECOND REQUEST FOR PRODUCTION Defendant PEDRO J. GARCIA, as Property Appraiser of Miami-Dade County, Florida, by and through undersigned counsel, pursuant to Fla. R. Civ. P. 1.350, and files his response to Plaintiffs’ Amended Second Request for Production, as follows: 1. Provide a copy of all document listed in your response to Interrogatory 1 of the Plaintiffs Third set of Interrogatories. Response: Property Appraiser will produce any document(s) responsive to this request to the extent that production does not violate confidentiality statutes, work product, and/or attorney client privilege. 2. Provide a copy of the relevant sections all procedural manual(s) then in existence as at August 29, 2013 which is applicable to and/or includes procedures for revocation of a homestead exemption regardless of how the information or notification of the facts giving rise to the revocation is obtained or received by the VA. Case No. 18-12371-CA 34 Response: Property Appraiser will produce any document(s) responsive to this request to the extent that production does not violate confidentiality statutes, work product, and/or attorney client privilege. Respectfully submitted, GERALDINE BONZON-KEENAN Miami-Dade County Attorney Stephen P. Clark Center 111 N.W. 1st Street, Suite 2810 Miami, FL 33128-1993 By: /s/Michael J. Mastrucci Michael J. Mastrucci Assistant County Attorney Florida Bar No. 86130 Telephone: (305) 375-5151 Facsimilie: (305) 375-5611 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 17th day of February, 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. By: /s/ Michael J. Mastrucci Assistant County Attorney 2