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.
Preview
Filing # 124486477 E-Filed 04/07/2021 01:18:28 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.
______________________________________________/
PLAINTIFFS’ CROSS-NOTICE OF TAKING DEPOSITION
PLEASE TAKE NOTICE that pursuant to Fla. R. Civ. P. 1.280 and 1.310(b), the Plaintiffs in
the above styled case, through the undersigned attorney, will take the depositions of the
following persons at the date, time, and place stated below. 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. The oral examinations of the following persons will
continue from day to day until completed. The depositions are being taken for the purpose of
discovery, for use at trial, and for all other purposes permitted under the Florida Rules of Civil
Procedure, including the to preserve the testimony of the witness in the event of unavailability.
Witness: Raul Mejia
DATE AND TIME: April 8, 2021; at the conclusion of the Defendants’ deposition of the
witness
PLACE: 45 NE 167th Street, North Miami Beach, FL 33162 – Via Zoom
conference:
https://proceedings.veritext.com/?token=e63eb2e44fb4695a0a383cc74e87d95
a
Page 1 of 2
Respectfully submitted,
ANDRÉ GIBSON, CHARTERED
Andre A. Gibson
Attorney for Plaintiffs, Virginia and Raul Mejia
Florida Bar Number: 0635529
45 NE 67th Street,
North Miami Beach, FL 33162
Telephone: (305) 652-4900
E-Mail: AAGibson@Gibsontaxlaw.com
Secondary E-Mail: Efile@Gibsontaxlaw.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been furnished via electronic
mail to Timothy Dennis at Timothy.Dennis@myfloridalegal.com,
Jon.Annette@myfloridalegal.com, Rebecca.Padgett@myfloridalegal.com; and Michael
Mastrucci, Assistant County Attorney, mastrucc@miamidade.gov; emily@miamidade.gov,
this 7th day of April, 2021.
André A. Gibson
Attorney for Plaintiffs
Page 2 of 2
Document Filed Date
April 07, 2021
Case Filing Date
April 17, 2018
Category
Declaratory Judgment
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Filing # 124486477 E-Filed 04/07/2021 01:18:28 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. ______________________________________________/ PLAINTIFFS’ CROSS-NOTICE OF TAKING DEPOSITION PLEASE TAKE NOTICE that pursuant to Fla. R. Civ. P. 1.280 and 1.310(b), the Plaintiffs in the above styled case, through the undersigned attorney, will take the depositions of the following persons at the date, time, and place stated below. 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. The oral examinations of the following persons will continue from day to day until completed. The depositions are being taken for the purpose of discovery, for use at trial, and for all other purposes permitted under the Florida Rules of Civil Procedure, including the to preserve the testimony of the witness in the event of unavailability. Witness: Raul Mejia DATE AND TIME: April 8, 2021; at the conclusion of the Defendants’ deposition of the witness PLACE: 45 NE 167th Street, North Miami Beach, FL 33162 – Via Zoom conference: https://proceedings.veritext.com/?token=e63eb2e44fb4695a0a383cc74e87d95 a Page 1 of 2 Respectfully submitted, ANDRÉ GIBSON, CHARTERED Andre A. Gibson Attorney for Plaintiffs, Virginia and Raul Mejia Florida Bar Number: 0635529 45 NE 67th Street, North Miami Beach, FL 33162 Telephone: (305) 652-4900 E-Mail: AAGibson@Gibsontaxlaw.com Secondary E-Mail: Efile@Gibsontaxlaw.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been furnished via electronic mail to Timothy Dennis at Timothy.Dennis@myfloridalegal.com, Jon.Annette@myfloridalegal.com, Rebecca.Padgett@myfloridalegal.com; and Michael Mastrucci, Assistant County Attorney, mastrucc@miamidade.gov; emily@miamidade.gov, this 7th day of April, 2021. André A. Gibson Attorney for Plaintiffs Page 2 of 2