On April 17, 2018 a
Party Notice
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 # 144748522 E-Filed 02/28/2022 03:55:59 PM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
RAUL MEJIA, and VIRGINIA LOPEZ,
Plaintiffs,
v. Case No. 2018-CA-012371
PEDRO GARCIA, as Property Appraiser
of Miami-Dade County; LEON M.
BIEGALSKI, as Executive Director of
the Florida Department of Revenue; MARCUS
SAIZ DE LA MORA, as Tax Collector of
Miami-Dade County,
Defendants.
______________________________________/
DEFENDANT, EXECUTIVE DIRECTOR’S NOTICE OF SERVING
ANSWERS TO PLAINTIFFS’ FIRST SET OF INTERROGATORIES
Defendant, Jim Zingale, as Executive Director of the Florida Department
of Revenue 1, pursuant to Rule 1.340, Florida Rules of Civil Procedure, and by
and through undersigned counsel, hereby gives notice serving Answers to
“Plaintiffs’ First Interrogatories to Florida Department of Revenue,” served by
the Plaintiffs on January 27, 2022.
RESPECTFULLY SUBMITTED this 28th day of February, 2022.
ASHLEY MOODY
ATTORNEY GENERAL
S/Timothy E. Dennis
TIMOTHY E. DENNIS
Chief Assistant Attorney General
1
Jim Zingale was named Executive Director of the Florida Department of
Revenue on January 29, 2019. Pursuant to Florida Rule of Civil Procedure
1.260(d)(1), Dr. Zingale is automatically substituted as a party to this action.
1
Florida Bar No. 575410
Office of the Attorney General
Revenue Litigation Bureau
PL-01, The Capitol
Tallahassee, FL 32399-1050
(850) 414-3300
Primary Email:
Timothy.Dennis@myfloridalegal.com
Secondary Emails:
Jon.Annette@myfloridalegal.com
Rebecca.Padgett@myfloridalegal.com
Counsel for Defendant
Jim Zingale, Executive Director
Florida Department of Revenue
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by e-mail to Andre′ A. Gibson, Esquire, 45 NE 67th Street, North
Miami Beach FL 33162, AAGibson@Gibsontaxlaw.com, Efile@Gibsontaxlaw.com
(Counsel for the Plaintiffs); and Michael J. Mastrucci, Esquire, Assistant
County Attorney, Stephen P. Clark Center, Suite 2810, 111 Northwest First
Street, Miami, Florida 33128, mastrucc@miamidade.gov,
wilma.morillo@miamidade.gov (Counsel for the Property Appraiser and Tax
Collector), on this 28th day of February, 2022.
S/Timothy E. Dennis
TIMOTHY E. DENNIS
Chief Assistant Attorney General
2
Document Filed Date
February 28, 2022
Case Filing Date
April 17, 2018
Category
Declaratory Judgment
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Filing # 144748522 E-Filed 02/28/2022 03:55:59 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA RAUL MEJIA, and VIRGINIA LOPEZ, Plaintiffs, v. Case No. 2018-CA-012371 PEDRO GARCIA, as Property Appraiser of Miami-Dade County; LEON M. BIEGALSKI, as Executive Director of the Florida Department of Revenue; MARCUS SAIZ DE LA MORA, as Tax Collector of Miami-Dade County, Defendants. ______________________________________/ DEFENDANT, EXECUTIVE DIRECTOR’S NOTICE OF SERVING ANSWERS TO PLAINTIFFS’ FIRST SET OF INTERROGATORIES Defendant, Jim Zingale, as Executive Director of the Florida Department of Revenue 1, pursuant to Rule 1.340, Florida Rules of Civil Procedure, and by and through undersigned counsel, hereby gives notice serving Answers to “Plaintiffs’ First Interrogatories to Florida Department of Revenue,” served by the Plaintiffs on January 27, 2022. RESPECTFULLY SUBMITTED this 28th day of February, 2022. ASHLEY MOODY ATTORNEY GENERAL S/Timothy E. Dennis TIMOTHY E. DENNIS Chief Assistant Attorney General 1 Jim Zingale was named Executive Director of the Florida Department of Revenue on January 29, 2019. Pursuant to Florida Rule of Civil Procedure 1.260(d)(1), Dr. Zingale is automatically substituted as a party to this action. 1 Florida Bar No. 575410 Office of the Attorney General Revenue Litigation Bureau PL-01, The Capitol Tallahassee, FL 32399-1050 (850) 414-3300 Primary Email: Timothy.Dennis@myfloridalegal.com Secondary Emails: Jon.Annette@myfloridalegal.com Rebecca.Padgett@myfloridalegal.com Counsel for Defendant Jim Zingale, Executive Director Florida Department of Revenue CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by e-mail to Andre′ A. Gibson, Esquire, 45 NE 67th Street, North Miami Beach FL 33162, AAGibson@Gibsontaxlaw.com, Efile@Gibsontaxlaw.com (Counsel for the Plaintiffs); and Michael J. Mastrucci, Esquire, Assistant County Attorney, Stephen P. Clark Center, Suite 2810, 111 Northwest First Street, Miami, Florida 33128, mastrucc@miamidade.gov, wilma.morillo@miamidade.gov (Counsel for the Property Appraiser and Tax Collector), on this 28th day of February, 2022. S/Timothy E. Dennis TIMOTHY E. DENNIS Chief Assistant Attorney General 2