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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.
(c) Unless otherwise indicated, the request is for documents for the time period of
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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Preview
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. (c) Unless otherwise indicated, the request is for documents for the time period of 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. 2 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. 3 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. 4 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 5