Motion for Protective Order in RAUL MEJIA ET AL VS PEDRO LOPEZ (PROPERTY APPRAISER) ET AL| Trellis.Law

On April 17, 2018 a Order 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 # 114996222 E-Filed 10/14/2020 09:50:42 PM

IN THE CIRCUIT COURT OF THE ELEVENTH
JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

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’ MOTION FOR PROTECTIVE ORDER

COME NOW Plaintiffs, Raul Mejia, (MEJIA) and Virginia Lopez, (“LOPEZ”)

(Collectively, MEJIA and LOPEZ are referred to as “Plaintiffs”) pursuant to Fla. R. Civ. P.

1.280(c), and 1.280(b)(1), and moves this Court for a Protective Order, and state,

Defendants PROPERTY APPRAISER’S discovery request are
irrelevant and impertinent and only seeks annoy, oppress, or unduly
burden or to subject Plaintiffs to unnecessary expense

CRUX OF PLAINTIFF’S CLAIM

1. Plaintiffs’ claim relates to the improper and unlawful taking of their

homestead, and consequently Senior, exemptions for tax years 2014 through 2016.

2. Prior to filing this action, the PROPERTY APPRAISER has retroactively

revoked Plaintiffs homestead exemptions for tax years 2011 through 2016 and also

retroactively revoked Plaintiffs’ Senior exemption for tax year 2013 through 2016. The basis

for the PROPERTY APPRAISER’S retroactive revocation of the exemptions was “RENTAL

OF HOMESTEAD.”

3. As a result of pre-suit contests and PROPERTY APPRAISER’s review, the

PROPERTY APPRAISER reversed its revocation for tax years 2011 and 2012.
4. Upon filing suit, Plaintiffs maintained that there was a basis for revoking their

Exemptions for Tax year 2013 based upon rental of homestead, however, there is no such

basis based on “Rental of Homestead” for the revocation of their exemptions for tax years

2014 through 2016, as set forth in the PROPERTY APPRAISERS’ notice of intent to lien.

5. Moreover, the Plaintiffs maintain as follows:

On August 29, 2013 Raul Mejia, visited the Property Appraiser’s office to re-
apply for our homestead exemption and portability because Raul Mejia
informed them that me and my wife were out of the country for about a year,
and that the property was rented during our absence. The person with whom
Raul Mejia, met looked at property information in the computer and informed
me that the property still had homestead exemption and that Raul Mejia, did
not need to do anything. After further discussion, she inquired about and Raul
Mejia, told her my age. She informed me that Raul Mejia, was eligible for a
senior exemption if Raul Mejia, had the documents proving my income. Since
Raul Mejia went prepared with the necessary documents to apply for the
homestead exemption, Raul Mejia, had my social security statements with me
and provided them to her. She completed an application form which Raul
Mejia then signed.

If the person who attended to me had followed my request, based on what the
property appraiser is now telling me, she should have revoked our exemption
for 2013, and taken our application for 2014, and we would never have lost our
exemptions for 2014-2016. Also, in order to apply for a senior exemption, we
were required to have a homestead exemption, so if the person who attended
to me had done what she was supposed to have done – based on the property
appraiser’s claims that Raul Mejia was required to relinquish the homestead
for 2013 and reapply for the exemption for 2014 – Raul Mejia would have
submitted the homestead application and the senior exemption at the same
time. Raul Mejia, came prepared to apply for a homestead exemption and was
prevented from doing so.

Had the clerk done what the property appraiser is stating would have been
done in this situation, she would have accepted my application for a homestead
application, and since Raul Mejia was within the period of time to apply and
obtain the tax attributed of our home through portability, this application
would have been submitted at the same time.

6. As outlined below, a protective order is proper in this case for certain requests

or parts of certain requests which seeks documents or interrogatories outside of the scope of

Plaintiffs’ claims.

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I. ARGUMENTS AND MEMORANDUM OF LAW

Plaintiffs have objected individually to each of the discovery requests where an

objection is applicable and stated the basis therefor. Plaintiffs hereby incorporate each

objection by reference.

A. The discovery requests have either been satisfied or are impertinent,
irrelevant and/or premature if Plaintiff’s claims are dismissed

Rule 1.280, Florida Rules of Civil Procedure, in pertinent parts, provides,

(b) Scope of Discovery. --Unless otherwise limited by order of the court in
accordance with these rules, the scope of discovery is as follows:
(1) In General. --Parties may obtain discovery regarding any matter, not
privileged, that is relevant to the subject matter of the pending action, whether
it relates to the claim or defense of the party seeking discovery or the claim or
defense of any other party[].
(c) Protective Orders. --Upon motion by a party or by the person from whom
discovery is sought, and for good cause shown, the court in which the action is
pending may make any order to protect a party or person from annoyance,
embarrassment, oppression, or undue burden or expense that justice requires.

In the instant case, PROPERTY APPRAISER’S entire request for production seek

documents covering tax years 2011 through 2016, however, no part of Plaintiffs’ claim

includes tax years 2011 through 2013. See Exhibit A attached hereto. Additionally,

PROPERTY APPRAISER’S Interrogatories Numbers 9 through 24 includes requests for

information related to tax years 2011, 2012, and 2013 inclusively or individually. See

Exhibit B attached hereto. As such these requests are wholly irrelevant to PLAINTIFFS’

claims and/or PROPERTY APPRAISER’S defenses.

The PROPERTY APPRAISER also seek a series of documents which does not relate

to their defense that there was a “Rental of Homestead. Notably, document requests numbers

1, 2, 3, 4, 5, 7, 8, and 14, which includes requests for Bank statements, tax returns, bills, card

and membership statements, mortgage statements and applications, and licenses, has no

relevance to the rental of a homestead and nor does it establish that the homestead was being

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rented. If any of these documents is relevant to establish Plaintiffs’ income as a factor in

determining entitlement to a Senior exemption, this is likewise irrelevant to Property

Appraiser’s defenses. PROPERTY APPRAISER’S Notices of Intent to Lien all state “Reason

for the Lien: Rental of Homestead.” Notably, it did not state income exceeded threshold or

words to that effect. Thus, the PROPERTY APPRAISER revoked the Senior Exemption

solely on the basis that the Homestead was revoked and since a Homestead is a prerequisite

to a Senior Exemption, said the Senior Exemption was revoked for the same reason. The

PROPERTY APPRAISER cannot now change the reason so as to form a defense when it was

not given on the NOTICE OF INTENT TO LIEN. As such any request for documents to

establish income is outside of the scope of discovery established by Rule 1.280(b). Similarly,

requests for copies of Plaintiffs mortgage applications and mortgage statements, has

absolutely no relevance to Property Appraiser’s defenses for revoking the exemptions.

Clearly, these documents will not show whether the property was being rented. See Am.

Funding v. Hill, 402 So. 2d 1369, 1370 (Fla. 1st DCA 1981) (“Objections to a request for

production can be made either because the items requested are not within the permissible

scope of discovery or on any ground that would support an application for protective order

under Fla. R. Civ. P. 1.280(c).”); Capco Props., L.L.C. v. Monterey Gardens of Pinecrest Condo.,

982 So. 2d 1211, 1213-14, n.2 (Fla. 3d DCA 2008) (“Discovery in civil cases must be relevant

to the subject matter of the case and must be admissible or reasonably calculated to lead to

admissible evidence.”) Fla. R. Civ. P. 1.280(b)(1) (providing that discovery must be relevant

to the subject matter of the pending action); Krypton Broad. of Jacksonville, Inc. v. MGM-

Pathe Commc'ns Co., 629 So. 2d 852, 854 (Fla. 1st DCA 1993) (“It is axiomatic that

information sought in discovery must relate to the issues involved in the litigation, as framed

in all pleadings.”).

B. The discovery requests include documents that Plaintiffs have already

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provided to PROPERTY APPRAISER or are within PROPERTY
APPRAISERS custody and control

PROPERTY APPRAISER also seeks a series of documents which they know does not

exist (Request No. 1, 2), were already provided to the PROPERTY APPRAISER (Request No.

3, 5, 12); are public records and accessible by PROPERTY APPRAISER, (Request No. 6, 15).

Notably, Plaintiffs made two applications for Senior Exemption on August 29, 2013 and

August 31, 2017. Accompanying each of these applications are a series of documents which

includes their Social Security statements, IRS Form 4506-T permitting the property

appraiser to obtain Plaintiffs’ tax returns (which does not exist), certain bills and

identifications including voter registrations, thus the Property Appraiser either has these

documents already or know that the documents do not exist. Additionally, the Property

Appraiser seeks copies of deeds and transfers of property, however, these documents are

public records and are readily accessible to the Property Appraiser in the public records of

Miami-Dade County. As such, all of the foregoing requests seek to annoy, oppression, and/or

unduly burden Plaintiffs to produce documents that the Property Appraiser has, knows do

not exist, or are readily accessible to Property Appraiser.

Incident to deposing PROPERTY APPRAISER’S agents and employees, Plaintiffs

provided PROPERTY APPRAISER with a binder containing 618 pages of documents which

were bate stamped number 1 through 618. These documents contained all of the

correspondence between the Plaintiffs and PROPERTY APPRAISER. Nonetheless,

PROPERTY appraiser propounded discovery seeking the same documents, which Plaintiffs

obtained through discovery from the Property Appraiser. See Request for Production No.

16. Invariably, the property appraiser has these documents in its possession, either because

they have them in the ordinary course of business and produced them to the Plaintiffs on

their request for production, or because Plaintiffs provided them to the Property Appraiser.

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Such a request seek only to annoy, oppression, and/or unduly burden Plaintiffs.

WHEREFORE Plaintiffs requests that this Court enter an order of protection on the

basis that:

1. The discovery requests seeking documents or information related to tax years 2011

through 2013 are outside of the scope of discovery;

2. Discovery seeking to establish income of the Plaintiffs are outside of the scope of

discovery because Property Appraiser’s basis for revocation of the exemptions is

rental of homestead;

3. Discovery seeking documents that are in public records intended only to annoy

Plaintiffs;

4. Discovery seeking documents that Property Appraiser knows does not exist seek

only to annoy Plaintiffs;

5. Discovery seeking documents that are already in Property Appraiser’s control are

intended to annoy and unduly burden Plaintiffs;

6. Any other relief that this Court deem just and proper.

ANDRÉ GIBSON, CHARTERED

/s/ André A. Gibson
André A. Gibson
Florida Bar Number: 0635529
Attorney for Plaintiffs Raul Mejia and Virginia Lopez
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

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;

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Jon.Annette@myfloridalegal.com, Rebecca.Padgett@myfloridalegal.com; and Michael

Mastrucci, Assistant County Attorney, mastrucc@miamidade.gov; emily@miamidade.gov,

this 14th day of October, 2020.

/s/ André A. Gibson
André A. Gibson
Attorney for Plaintiffs

Page 7 of 7
EXHIBIT A

45 NE 167TH STREET, NORTH MIAMI BEACH, FL 33162
TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495
AAGibson@Gibsontaxlaw.com
Filing # 112790476 E-Filed 09/02/2020 02:41:30 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 01

RAUL MEJIA and VIRGINIA LOPEZ,

Plaintiffs,

vs.

PEDRO J. GARCIA, as Property Appraiser of
Miami-Dade County, Florida; LEON M.
BIEGALSKI, as Executive Director of Florida
Department of Revenue; and MARCUS SAIZ
DE LA MORA, as Tax Collector of Miami-
Dade County, Florida,

Defendants.
______________________________________/

DEFENDANT PROPERTY APPRAISER’S
FIRST REQUEST FOR PRODUCTION TO PLAINTIFFS

Pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, Defendant PEDRO J.

GARCIA, as Property Appraiser of Miami-Dade County, Florida (the “Property Appraiser”),

hereby requests Plaintiffs/Taxpayers RAUL MEJIA and VIRGINIA LOPEZ to produce at the

office of the Miami-Dade County Attorney, Stephen P. Clark Center, Suite 2810, 111 N.W. 1st

Street, Miami, Florida 33128-1993, the following described documents within thirty (30) days as

required under Florida Rule of Civil Procedure 1.350.
Case No. 18-12371 CA 01

DEFINITIONS AND INSTRUCTIONS

(a) The terms “you,” “your,” or “yourself” refer to Plaintiffs/Taxpayers RAUL MEJIA

and VIRGINIA LOPEZ.

(b) The term “Subject Property” as used herein shall mean the real property described

in the Complaint located at 201 178 Drive, Unit 531, Miami, FL 33160, and more specifically

identified by Folio No. 31-2211-039-1220.

January 1, 2011 through December 31, 2016, which constitutes the same time period covered

by the tax lien(s) at issue.

(d) The request is for documents in the possession of you, your agents, accountants,

attorneys, and employees.

(e) For any document produced, you may redact any information which is privileged

or confidential pursuant to law, but not the name, addresses, telephone number, or identifying

information of you or the other business, government, person or entities mentioned in the

document.

(f) If any item requested is not in Plaintiffs’ immediate possession, but is within

Plaintiffs’ control, such as income tax returns, you are hereby requested to take any and all steps

necessary to obtain possession of such items.

(g) If you object to a part of any request, you are required to produce any responsive

documents pertaining to the parts of said request not objected to.

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Case No. 18-12371 CA 01

DOCUMENT REQUESTS

1. Your complete federal income tax returns with corresponding schedule E’s (as

mentioned above, you may redact privileged or confidential information—the request is intended

to see the name and address used by you as well as any rental income reported).

2. All federal income tax returns signed by you for any trust or business entity for

which you have an interest or responsibility.

3. All bills addressed to you by name at the Subject Property, including but not limited

to electricity, water, waste, sewerage, cable television, mortgage, condominium fees, telephone,

cell phone, credit card, internet service, professional or license fees, property insurance, or flood

insurance.

4. Your bank statements from any bank, credit union, or other lending institution for

withdrawals, deposits, checking accounts, cancelled checks, or any other matters.

5. Your Form SSA-1099 Social Security Benefit Statements.

6. Deeds transferring property to or from you.

7. All cards which identify you by name and/or address, including but not limited to

driver’s license, voter’s registration card, vehicle registration cards, vehicle insurance cards, health

insurance cards, credit cards, debit cards, or business cards.

8. All documents reflecting any and all licenses held by you including, but not limited

to driver’s license, notary public license, contractor’s license, real estate agent or broker’s license,

hunting license, marriage license, or license or permit to carry a concealed weapon.

9. Applications for homestead exemption on the Subject Property.

10. Applications for senior exemption under section 196.075, Florida Statutes, on the

Subject Property.

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Case No. 18-12371 CA 01

11. Applications for Transfer of Homestead Assessment Difference (a/k/a

“Portability”) either to or from the Subject Property.

12. All rental or lease agreements involving the Subject Property entered into by

yourself or by any business entity in which you have an interest.

13. Any listings, quotes, or other written offers to lease or sell the Subject Property,

including any listings on a Multiple Listing Service (MLS).

14. Mortgage and/or home equity loan statements, and all other instruments, such as

loan applications, executed in connection with financing on the Subject Property.

15. All documents involving any transfer of the Subject Property and the notes,

agreements, and other documents reflecting the agreements upon which such transfers were based.

16. Any and all letters, correspondence, memoranda, notices, e-mails, and other

documents received from and/or sent to the Miami-Dade County Property Appraiser’s Office.

17. All life insurance policies and certificates on your life as well as all premium

notices, beneficiary designation forms and other records and documents received or compiled by

you in connection with any life insurance of which you are the owner and/or the insured person.

If you have changed the beneficiary of any of your life insurance, produce all forms reflecting

these changes.

18. All documents reflecting the location where your dependent children are registered

for school.

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Case No. 18-12371 CA 01

Respectfully submitted,

ABIGAIL PRICE-WILLIAMS
Miami-Dade County Attorney
Stephen P. Clark Center
111 N.W. 1st Street, Suite 2810
Miami, Florida 33128

By: s/ Michael J. Mastrucci
Michael J. Mastrucci
Assistant County Attorney
Florida Bar No. 86130
Telephone: (305) 375-5151
Facsimile: (305) 375-5634
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 2nd

day of September, 2020 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.

s/ Michael J. Mastrucci
Assistant County Attorney

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EXHIBIT B

45 NE 167TH STREET, NORTH MIAMI BEACH, FL 33162
TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495
AAGibson@Gibsontaxlaw.com
Filing # 112790476 E-Filed 09/02/2020 02:41:30 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 01

RAUL MEJIA and VIRGINIA LOPEZ,

Plaintiffs,

vs.

Defendants.
______________________________________/

DEFENDANT PROPERTY APPRAISER’S
FIRST SET OF INTERROGATORIES TO PLAINTIFFS

Defendant PEDRO J. GARCIA, as Property Appraiser of Miami-Dade County, Florida

(the “Property Appraiser”), by and through undersigned counsel, pursuant to Florida Rule of Civil

Procedure 1.340, propounds to Plaintiffs/Taxpayers RAUL MEJIA and VIRGINIA LOPEZ the

attached interrogatories consisting of twenty-six (26) questions, to be answered by said Plaintiffs

under oath within thirty (30) days in accordance with the requirements of the Florida Rule of Civil

Procedure 1.340.
Case No. 18-12371 CA 01

Respectfully submitted,

ABIGAIL PRICE-WILLIAMS
Miami-Dade County Attorney
Stephen P. Clark Center
111 N.W. 1st Street, Suite 2810
Miami, Florida 33128

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served this 2nd

day of September, 2020 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.

s/ Michael J. Mastrucci
Assistant County Attorney

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Case No. 18-12371 CA 01

DEFINITIONS AND INSTRUCTIONS

As used herein:

A. “Date” shall mean the exact day, month and year, if ascertainable, or, if not, the
best approximation (including relationship to other events).

B. “Description” or “describe” when referring to a document as hereinafter defined,
shall mean that the Taxpayers shall set forth the author or originator, addressee(s), date, title and
subject matter, and the present custodian of the original thereof, or if unknown, the present
custodian of any such copy thereof and the last known address of each such custodian. If a copy
of such document is attached to the interrogatories or made available to the Property Appraiser for
copying, pursuant to a request or notice to produce documents, a reference to such document by
an exhibit number or similar description shall be sufficient description.

C. “Document” shall mean any written, printed, typed or other graphic matter of any
kind or nature, and all mechanical and electronic sound recordings or transcripts thereof, including
photographs, in the possession, custody or control of the Taxpayers, its servants, officers,
employees, agents or its counsel (exclusive of work product of counsel) or known by the Taxpayer
to exist. It shall also mean all copies of documents by whatever means made.

D. “Identification” or “identify” when referring to an individual, a corporation or other
entity, shall mean that the Taxpayers shall set forth the name, present or last known address,
telephone number, and if a corporation or other entity, its principal place of business, or, if an
individual, his or her title or titles and by whom employed. Once an individual, corporation or
other entity has been thus identified in an answer to an interrogatory, it shall be sufficient thereafter
when identifying that individual, corporation or other entity to state merely his, her or its name.

E. “Person” shall mean an individual, corporation, proprietorship, partnership, trust,
association or any other entity.

F. “Pleadings” shall mean the complaint, answer, counterclaim, cross-claim, third
party complaint, and affirmative defenses, as defined in Fla. R. Civ. P. 1.100.

G. “Subject Property” shall mean the real property described in the Complaint located
at 201 178 Drive, Unit 531, Miami, FL 33160, and more specifically identified by Folio No. 31-
2211-039-1220.

H. “Taxpayers” shall mean Plaintiffs RAUL MEJIA and VIRGINIA LOPEZ, and
further includes any predecessors and/or successors in interest, attorneys, agents, representatives,
and all other persons acting or purporting to act on behalf of the above-named individuals.

I. “You” or “your” shall mean the Taxpayers, or any of its officers, servants, officials,
agents, representatives or employees, as the context so dictates. When “you” or “your” is used in
an interrogatory, please identify the person performing the task, doing the act, or preparing the
instrument by name and residence address.

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Case No. 18-12371 CA 01

INTERROGATORIES

1. Please state the name, title, address and telephone number of each person who assisted in
the preparation of the responses to these Interrogatories, including the person signing same.

2. Please describe the nature of the relationship between RAUL MEJIA and VIRGINIA
LOPEZ, including but not limited to, how long they have known one another and whether
they are related by blood or otherwise.

3. Please state with specificity the factual basis for your belief that the Subject Property is
entitled to a Homestead Exemption for tax years 2014 through 2016.

4. Please state with specificity the factual basis for your belief that the Subject Property is
entitled to a Senior Exemption under section 196.075, Florida Statutes, for tax years 2014
through 2016.

5. Please state with specificity the factual basis for your belief that the Subject Property is
entitled to a Transfer of Homestead Assessment Difference (a/k/a “Portability”) for tax
years 2014 through 2016.

6. Please list and describe with specificity any and all documents you believe support your
entitlement to a Homestead Exemption on the Subject Property for tax years 2014 through
2016.

7. Please list and describe with specificity any and all documents you believe support your
entitlement to a Senior Exemption under section 196.075, Florida Statutes, on the Subject
Property for tax years 2014 through 2016.

8. Please list and describe with specificity any and all documents you believe support your
entitlement to a Transfer of Homestead Assessment Difference (a/k/a “Portability”) on the
Subject Property for tax years 2014 through 2016.

9. Please list all addresses of any real property at which Taxpayers resided during tax years
2011 through 2016. For each such residence, please state the beginning and ending dates
of such residency, and any other persons, besides Taxpayers, including relatives and
children, who resided with them at each location during those years and the dates of same.

10. Please listthe names, business addresses, telephone numbers, and dates of employment
regarding all employers, including self-employment, for whom you have worked since
January 1, 2011.

11. Please list all of Taxpayers’ checking, money market, savings, credit union, and any other
such financial accounts, including any closed financial accounts, in which Taxpayers had
any legal or equitable interest during tax years 2011 through 2016, regardless of whether
the interest is or was held in their names individually, in their names with another person,

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Case No. 18-12371 CA 01

or in any other name, and state the address at which each such account was registered
during those years.

12. Please list all retirement accounts/plans, including but not limited to defined benefit plans,
401k, 403B, IRA accounts, pension plans, Florida Retirement System (FRS) plans, Federal
Government plans, money purchase plans, HR10 (Keogh) plans, profit sharing plans,
annuities, employee savings plans, etc., in which Taxpayers had any legal or equitable
interest during tax years 2011 through 2016. For each account/plan, please state the name
of the account/plan, the address at which it was registered, and any beneficiary(ies) and/or
alternate payee(s).

13. Please state the names, addresses, and telephone numbers of Taxpayers’ accountant(s),
bookkeeper(s), and any other persons who possessed Taxpayers’ financial records during
tax years 2011 through 2016, and state which records each such person possessed during
those years.

14. Please state the street address, if any, and if not, the legal description of all real property in
which Taxpayers possessed a legal or equitable ownership interest during tax years 2011
through 2016. For each property, please state the names and addresses of any other persons
or entities holding any legal or equitable interest during those years and their respective
percentage of interest.

15. Please list any motor vehicles registered in Taxpayers’ names during tax years 2011
through 2016 and the address at which each was registered for those years.

16. Please identify any and all persons who had a legal and/or equitable ownership interest in
the Subject Property during tax years 2011 through 2016 and describe the nature and
duration of said interest.

17. Did Taxpayers enter into any residential lease or rental agreement—whether written or
verbal—regarding the Subject Property at any point during tax years 2011 through 2016?
If so, please provide specific details about said agreement(s), including but not limited to
the date the agreement was entered into, the terms of the agreement, the parties to the
agreement, the name and address of any tenants under the agreement, rent payments and
charges under the agreement, deposits, advance rent and late charges under the agreement,
the name and address of any agents used pursuant to the agreement, and utilities or utility
services provided under the agreement.

18. Did Taxpayers list the Subject Property for lease, rent or sale on any listing service,
including MLS, at any point during tax years 2011 through 2016? If so, please provide
specific details about said listing(s), including but not limited to the date of said listing(s),
the asking price(s) for rent or sale, the listing service used (e.g. MLS), and the listing
identification number(s).

19. Please list the names and titles of anyone at the Office of the Property Appraiser with whom
you communicated, either verbally or in writing, regarding entitlement to a Homestead

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Case No. 18-12371 CA 01

Exemption on the Subject Property for tax years 2011 through 2016, and identify the dates
and subject matter of each of said communications.

20. Please list the names and titles of anyone at the Office of the Property Appraiser with whom
you communicated, either verbally or in writing, regarding entitlement to a Senior
Exemption on the Subject Property under section 196.075, Florida Statutes, for tax years
2011 through 2

Case Info

Case No.

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Document Filed Date

October 14, 2020

Case Filing Date

April 17, 2018

County

Parties

BIEGALSKI (EXECUTIVE DIRECTOR), LEON M Defendant
DE LA MORA (TAX COLLECTOR), MARCUS SAIZ Defendant
Dennis, Timothy E. Attorney for the Defendant
Gibson, Andre A Attorney for the Plaintiff
LOPEZ (PROPERTY APPRAISER), PEDRO Defendant
Lopez, Virginia Plaintiff
Mastrucci, Michael J (Asst. County Atty) Attorney for the Defendant
MEJIA, RAUL Plaintiff
Party Name Party Description
Jane Mastrucci Attorneys for Plaintiffs
Andrea Gibson Attorney

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Order: RAUL MEJIA ET AL VS PEDRO LOPEZ (PROPERTY APPRAISER) ET AL

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Case Info

Parties