On April 17, 2018 a
Motion-Secondary
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 # 114308083 E-Filed 10/01/2020 10:12:50 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.
______________________________________________/
REPLY TO AFFIRMATIVE DEFENSES
Plaintiffs, Plaintiffs, Raul Mejia (hereinafter “MEJIA”) and Virginia Lopez
(Hereinafter LOPEZ”) (collectively, “Plaintiffs”) by and through their undersigned counsel
and files their Reply to the Defendant, LEON M. BIEGALSKI, as Executive Director of
Florida Department of Revenues, Florida Affirmative Defenses and state:
1. The Defendant, Department of Revenue, filed its answer and affirmative defenses to
the Plaintiffs’ Fourth Amended Complaint on September 14, 2020.
2. The Plaintiffs denies each and every Affirmative Defense raised by Defendant and
Demands strict proof thereof.
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
Page 1 of 2
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 1st day of October, 2020.
André A. Gibson
Attorney for Plaintiffs
Page 2 of 2
Document Filed Date
October 01, 2020
Case Filing Date
April 17, 2018
Category
Declaratory Judgment
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Filing # 114308083 E-Filed 10/01/2020 10:12:50 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. ______________________________________________/ REPLY TO AFFIRMATIVE DEFENSES Plaintiffs, Plaintiffs, Raul Mejia (hereinafter “MEJIA”) and Virginia Lopez (Hereinafter LOPEZ”) (collectively, “Plaintiffs”) by and through their undersigned counsel and files their Reply to the Defendant, LEON M. BIEGALSKI, as Executive Director of Florida Department of Revenues, Florida Affirmative Defenses and state: 1. The Defendant, Department of Revenue, filed its answer and affirmative defenses to the Plaintiffs’ Fourth Amended Complaint on September 14, 2020. 2. The Plaintiffs denies each and every Affirmative Defense raised by Defendant and Demands strict proof thereof. 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 Page 1 of 2 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 1st day of October, 2020. André A. Gibson Attorney for Plaintiffs Page 2 of 2