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 # 112873239 E-Filed 09/03/2020 03:58:35 PM
IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
RAUL MEJIA and VIRGINIA LOPEZ, CASE NO. 18-12371 CA 34
Plaintiffs,
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.
_________________________________________________/
DEFENDANT MIAMI-DADE COUNTY PROPERTY APPRAISER’S
NOTICE OF TAKING DEPOSITION
(If an interpreter is required please notify undersigned immediately)
PLEASE TAKE NOTICE that pursuant to Fla. R. Civ. P. 1.310(b)(6), the undersigned
attorney will take the deposition of Plaintiff RAUL MEJIA. Such deposition will take place on
October 22nd, 2020 starting at 1:00 p.m. via Zoom video conference.
Said deposition will be upon oral examination before Veritext Legal Solutions, Notary
Public or an officer authorized by law to take depositions in the State of Florida. The oral
examination(s) will continue from day to day until completed. The deposition(s) is for the
purpose of discovery, for use at trial,or for such other purposes, as are permitted under the
applicable and governing rules.
CASE NO. 18-12371 CA 34
Respectfully submitted,
ABIGAIL PRICE-WILLIAMS
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 3rd
day of September, 2020 via e-mail generated by the Florida Courts E-Filing Portal to: Andre A.
Gibson, Esq., AAGibson@Gibsontaxlaw.com, Efile@Gibsontaxlaw.com; and Timothy Dennis
at Timothy.Dennis@myfloridalegal.com, Jon.Annette@myfloridalegal.com,
Rebecca.Padgett@myfloridalegal.com.
By: /s/ Michael J. Mastrucci
Assistant County Attorney
cc: Veritext Legal Solutions
In accordance with the Americans with Disabilities Act of 1990, persons needing a special accommodation to participate
in this proceeding should contact the court administrator at the Miami-Dade County Courthouse, 73 West Flagler Street,
Miami, Florida 33130, no later than seven days prior to the proceeding. Telephone (305) 349-7175 (voice) or (305) 349-
7174 (TDD) for information. If hearing impaired, call TDD (800) 955-8771 via Florida Relay Services.
Page 2
Document Filed Date
September 03, 2020
Case Filing Date
April 17, 2018
Category
Declaratory Judgment
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Filing # 112873239 E-Filed 09/03/2020 03:58:35 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION RAUL MEJIA and VIRGINIA LOPEZ, CASE NO. 18-12371 CA 34 Plaintiffs, 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. _________________________________________________/ DEFENDANT MIAMI-DADE COUNTY PROPERTY APPRAISER’S NOTICE OF TAKING DEPOSITION (If an interpreter is required please notify undersigned immediately) PLEASE TAKE NOTICE that pursuant to Fla. R. Civ. P. 1.310(b)(6), the undersigned attorney will take the deposition of Plaintiff RAUL MEJIA. Such deposition will take place on October 22nd, 2020 starting at 1:00 p.m. via Zoom video conference. Said deposition will be upon oral examination before Veritext Legal Solutions, Notary Public or an officer authorized by law to take depositions in the State of Florida. The oral examination(s) will continue from day to day until completed. The deposition(s) is for the purpose of discovery, for use at trial,or for such other purposes, as are permitted under the applicable and governing rules. CASE NO. 18-12371 CA 34 Respectfully submitted, ABIGAIL PRICE-WILLIAMS 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 3rd day of September, 2020 via e-mail generated by the Florida Courts E-Filing Portal to: Andre A. Gibson, Esq., AAGibson@Gibsontaxlaw.com, Efile@Gibsontaxlaw.com; and Timothy Dennis at Timothy.Dennis@myfloridalegal.com, Jon.Annette@myfloridalegal.com, Rebecca.Padgett@myfloridalegal.com. By: /s/ Michael J. Mastrucci Assistant County Attorney cc: Veritext Legal Solutions In accordance with the Americans with Disabilities Act of 1990, persons needing a special accommodation to participate in this proceeding should contact the court administrator at the Miami-Dade County Courthouse, 73 West Flagler Street, Miami, Florida 33130, no later than seven days prior to the proceeding. Telephone (305) 349-7175 (voice) or (305) 349- 7174 (TDD) for information. If hearing impaired, call TDD (800) 955-8771 via Florida Relay Services. Page 2