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Filing # 72862936 E-Filed 05/31/2018 08:19:49 AM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
RAUL MEJIA, and VIRGINIA LOPEZ,
Plaintiffs,
v. Case No. 2018-012371-CA
PEDRO GARCIA, as Property Appraiser
of Miami-Dade County; LEON M.
BIEGALSKI, as Executive Director of
the Florida Department of Revenue; MARCUS
SAIZ DE LA MORA, as Tax Collector of
Miami-Dade County,
Defendants.
/
DEFENDANT LEON M. BIEGALSKI’S ANSWER TO AMENDED COMPLAINT
Defendant Leon M. Biegalski, as Executive Director of the Florida Department of
Revenue (“the Department”), by and through undersigned counsel, responds to the allegations
contained in the Amended Complaint served by Raul Mejia and Virginia Lopez (“Plaintiffs”), on
or about May 17, 2018, and states as follows.
Nature of the Case
1 Admitted.
Parties
2 The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 2.
3 Admitted
4. Admitted.
5 Admitted.Jurisdiction
6. The Department admits this is an action contesting the removal of ad valorem tax
exemptions. The Department admits that if all jurisdictional prerequisites have been met,
jurisdiction is proper in the circuit court, but is without knowledge sufficient to admit or deny
whether all such requirements have been met. Chapter 194, Florida Statutes, Article V, sections
5 and 20 of the Constitution of the State of Florida, and section 86.011, Florida Statutes, speak
for themselves.
Venue
7 The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 7.
General Allegations
8. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 8.
9. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 9
10. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 10.
11 The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 11.
12. The Department admits that Exhibit “A” is attached to the Amended Complaint
and speaks for itself. The Department is without knowledge sufficient to admit or deny the
remaining allegations contained in paragraph 12.13. The Department admits that Exhibit “C” is attached to the Amended Complaint
and speaks for itself. The Department is without knowledge sufficient to admit or deny the
remaining allegations contained in paragraph 13
14 The Department admits that Exhibits “B” and “D” are attached to the Amended
Complaint and speak for themselves. The Department is without knowledge sufficient to admit
or deny the remaining allegations contained in paragraph 14.
15. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 15, inclusive of subparagraphs a-b
16. The Department admits that Exhibit “E” is attached to the Amended Complaint
and speaks for itself. The Department is without knowledge sufficient to admit or deny the
remaining allegations contained in paragraph 16
17. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 17.
18 The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 18.
19. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 19.
20. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 20.
21 The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 21.
22. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 22.23. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 23
24. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 24.
25. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 25
26. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 26.
27. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 27.
28. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 28
29. Section 86.011, Florida Statutes, speaks for itself. The Department is without
knowledge sufficient to admit or deny the remaining allegations contained in paragraph 29
30. Section 86.051, Florida Statutes, speaks for itself. The Department is without
knowledge sufficient to admit or deny the remaining allegations contained in paragraph 30
31. Section 86.111, Florida Statutes, speaks for itself. The Department is without
knowledge sufficient to admit or deny the remaining allegations contained in paragraph 31
32. Section 86.101, Florida Statutes, speaks for itself. The Department is without
knowledge sufficient to admit or deny the remaining allegations contained in paragraph 32
33. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 3334. The Department admits that Exhibits “E,” “F,” and “G” are attached to the
Amended Complaint and speak for themselves. The Department is without knowledge sufficient
to admit or deny the remaining allegations contained in Paragraph 34, inclusive of subparagraphs
a-c.
35. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 35.
COUNT I - Removal of Tax Lien
(As to Tax Years 2014 through 2016)
36. | The Department restates its answers to Paragraphs 1-35 as if fully set forth herein.
37. The Department admits that Exhibits “A” through “D,” “H,” and “I” are attached
to the Amended Complaint and speak for themselves. The Department is without knowledge
sufficient to admit or deny the remaining allegations contained in Paragraph 37.
38 The Department admits that the “Lien Notices” and Exhibits “A” and “B” speak
for themselves. The Department is without knowledge sufficient to admit or deny the remaining
allegations contained in Paragraph 38.
39. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 39.
40. Section 196.161, Florida Statutes, speaks for itself. The Department is without
knowledge sufficient to admit or deny the remaining allegations contained in paragraph 40
41. Sections 196.061 and 196.193(3) and (4), Florida Statutes, and Florida Attorney
General Opinion 2008-13 speak for themselves. The Department is without knowledge
sufficient to admit or deny the remaining allegations contained in paragraph 41.
42. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 42.43. The Department admits that Article VIL, section 6 of the Constitution of the State
of Florida, and section 196.031, Florida Statutes, speak for themselves. The Department is
without knowledge sufficient to admit or deny the remaining allegations contained in paragraph
43
44. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 44.
COUNT II - Removal of Tax Lien Interest and Penalties
(As to Tax Years 2014-2016)
45. The Department restates its answers to Paragraphs 1-35 as if fully set forth herein.
46. The Department admits that Exhibits “A” through “D,” “H,” and “I” are attached
to the Amended Complaint and speak for themselves. The Department is without knowledge
sufficient to admit or deny the remaining allegations contained in Paragraph 46.
47 Section 196.161, Florida Statutes, speaks for itself. The Department is without
knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 47
48 Sections 196.061 and 196.193(3) and (4), Florida Statutes, and Florida Attorney
General Opinion 2008-13 speak for themselves. The Department is without knowledge
sufficient to admit or deny the remaining allegations contained in Paragraph 48.
49. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 49.
50. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 50.
51. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 5152. Sections 196.161(1)(b) and 196.011, Florida Statutes, speak for themselves. The
Department is without knowledge sufficient to admit or deny the remaining allegations contained
in Paragraph 52.
53 Sections 196.161(1)(b) and 196.161, Florida Statutes, speak for themselves. The
Department is without knowledge sufficient to admit or deny the remaining allegations contained
in Paragraph 53.
54, Section 196.161, Florida Statutes, speaks for itself. The Department is without
knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 54.
55, Section 196.161, Florida Statutes, speaks for itself. The Department is without
knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 55.
56. Section 196.161(1)(b), Florida Statutes, speaks for itself. The Department is
without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph
56.
57. The decision of Mitchell v. Higgs, 61 So. 3d 1152 (Fla. 3rd DCA 2011) speaks for
itself. The Department is without knowledge sufficient to admit or deny the remaining
allegations contained in Paragraph 57.
58. Section 196.131(3), Florida Statutes, speaks for itself. The Department is without
knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 58.
59. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 59.
60. Section 196.161(1)(b), Florida Statutes, speaks for itself. The Department is
without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph
60.61. Sections 196.161(1)(b) and 196.161(3), Florida Statutes, speak for themselves.
The Department is without knowledge sufficient to admit or deny the remaining allegations
contained in Paragraph 61
62. The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 62
63 The Department is without knowledge sufficient to admit or deny the allegations
contained in Paragraph 63
64. Section 196.161(1)(b), Florida Statutes, speaks for itself. The Department is
without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph
64
COUNT III - Removal of 2016 Recapture Tax, Interest and Penalties and
Overassessment for Tax Year 2017
65 The Department restates its answers to Paragraphs 1-35 as if fully set forth herein.
66. Section 196.161, Florida Statutes, speaks for itself. The Department is without
knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 66.
67. Section 193.1554(3), Florida Statutes, speaks for itself. The Department is
without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph
67.
68 Section 193.1554(3), Florida Statutes, speaks for itself. The Department is
without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph
68
69. Section 193.1554(3), Florida Statutes, speaks for itself. The Department is
without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph
69.First Defense
(No Case or Controversy Alleged Against the Department)
The Plaintiffs have failed to state a claim against the Department upon which this Court
could grant relief. The Department is named as a nominal party, as required by the notice-
joinder provision of Section 194.181(5), Florida Statutes, but the Plaintiffs do not allege any
wrongdoing by, nor request any relief from, the Department. A complaint must allege ultimate
facts, that when established by competent evidence, support an order granting the relief a
plaintiff seeks. See, e.g., KC Leisure, Inc. v. Haber, 972 So. 2d 1069, 1075 (Fla. 4th DCA 2008)
This Court cannot grant relief against the Department where no request for relief has been made
by the Plaintiffs.
WHEREFORE, Defendant Leon M. Biegalski, as Executive Director of the Florida
Department of Revenue, requests entry of judgment in his favor, an award of costs, and such
other relief as deemed appropriate.
RESPECTFULLY SUBMITTED this 31st day of May, 2018
PAMELA JO BONDI
ATTORNEY GENERAL
S/Timothy E. Dennis
TIMOTHY E. DENNIS
Chief Assistant Attorney General
Florida Bar No. 575410
Office of the Attorney General
Revenue Litigation Bureau
PL-01, The Capitol
Tallahassee, FL 32399-1050
(850) 414-3300
Primary Email:
Timothy.Dennis@myfloridalegal.com
Secondary Emails:
Jon.Annette@myfloridalegal.com
Rebecca.Padgett@myfloridalegal.comCounsel for Defendant
Leon M. Biegalski, Executive Director
Florida Department of Revenue
CERTIFICATE OF SERVICE
THEREBY CERTIFY that on a true and correct copy of the foregoing has been furnished
by e-mail to Andre’ A Gibson, Esquire, 45 NE 67th Street, North Miami Beach, FL 33162,
AAGibson@Gibsontaxlaw.com, Efile@Gibsontaxlaw.com (Counsel for the Plaintiffs); Michael
J. Mastrucci, Esquire, Assistant County Attorney, Stephen P. Clark Center, Suite 2810, 111
Northwest First Street, Miami, Florida 33128, mastrucc@miamidade.gov,
wilma.morillo@miamidade.gov (Counsel for Property Appraiser and Tax Collector), on this 31st
day of May, 2018.
S/Timothy E. Dennis
TIMOTHY E. DENNIS
Chief Assistant Attorney General
10
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Filing # 72862936 E-Filed 05/31/2018 08:19:49 AM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA RAUL MEJIA, and VIRGINIA LOPEZ, Plaintiffs, v. Case No. 2018-012371-CA PEDRO GARCIA, as Property Appraiser of Miami-Dade County; LEON M. BIEGALSKI, as Executive Director of the Florida Department of Revenue; MARCUS SAIZ DE LA MORA, as Tax Collector of Miami-Dade County, Defendants. / DEFENDANT LEON M. BIEGALSKI’S ANSWER TO AMENDED COMPLAINT Defendant Leon M. Biegalski, as Executive Director of the Florida Department of Revenue (“the Department”), by and through undersigned counsel, responds to the allegations contained in the Amended Complaint served by Raul Mejia and Virginia Lopez (“Plaintiffs”), on or about May 17, 2018, and states as follows. Nature of the Case 1 Admitted. Parties 2 The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 2. 3 Admitted 4. Admitted. 5 Admitted.Jurisdiction 6. The Department admits this is an action contesting the removal of ad valorem tax exemptions. The Department admits that if all jurisdictional prerequisites have been met, jurisdiction is proper in the circuit court, but is without knowledge sufficient to admit or deny whether all such requirements have been met. Chapter 194, Florida Statutes, Article V, sections 5 and 20 of the Constitution of the State of Florida, and section 86.011, Florida Statutes, speak for themselves. Venue 7 The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 7. General Allegations 8. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 8. 9. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 9 10. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 10. 11 The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 11. 12. The Department admits that Exhibit “A” is attached to the Amended Complaint and speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in paragraph 12.13. The Department admits that Exhibit “C” is attached to the Amended Complaint and speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in paragraph 13 14 The Department admits that Exhibits “B” and “D” are attached to the Amended Complaint and speak for themselves. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in paragraph 14. 15. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 15, inclusive of subparagraphs a-b 16. The Department admits that Exhibit “E” is attached to the Amended Complaint and speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in paragraph 16 17. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 17. 18 The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 18. 19. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 19. 20. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 20. 21 The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 21. 22. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 22.23. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 23 24. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 24. 25. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 25 26. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 26. 27. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 27. 28. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 28 29. Section 86.011, Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in paragraph 29 30. Section 86.051, Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in paragraph 30 31. Section 86.111, Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in paragraph 31 32. Section 86.101, Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in paragraph 32 33. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 3334. The Department admits that Exhibits “E,” “F,” and “G” are attached to the Amended Complaint and speak for themselves. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 34, inclusive of subparagraphs a-c. 35. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 35. COUNT I - Removal of Tax Lien (As to Tax Years 2014 through 2016) 36. | The Department restates its answers to Paragraphs 1-35 as if fully set forth herein. 37. The Department admits that Exhibits “A” through “D,” “H,” and “I” are attached to the Amended Complaint and speak for themselves. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 37. 38 The Department admits that the “Lien Notices” and Exhibits “A” and “B” speak for themselves. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 38. 39. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 39. 40. Section 196.161, Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in paragraph 40 41. Sections 196.061 and 196.193(3) and (4), Florida Statutes, and Florida Attorney General Opinion 2008-13 speak for themselves. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in paragraph 41. 42. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 42.43. The Department admits that Article VIL, section 6 of the Constitution of the State of Florida, and section 196.031, Florida Statutes, speak for themselves. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in paragraph 43 44. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 44. COUNT II - Removal of Tax Lien Interest and Penalties (As to Tax Years 2014-2016) 45. The Department restates its answers to Paragraphs 1-35 as if fully set forth herein. 46. The Department admits that Exhibits “A” through “D,” “H,” and “I” are attached to the Amended Complaint and speak for themselves. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 46. 47 Section 196.161, Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 47 48 Sections 196.061 and 196.193(3) and (4), Florida Statutes, and Florida Attorney General Opinion 2008-13 speak for themselves. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 48. 49. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 49. 50. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 50. 51. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 5152. Sections 196.161(1)(b) and 196.011, Florida Statutes, speak for themselves. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 52. 53 Sections 196.161(1)(b) and 196.161, Florida Statutes, speak for themselves. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 53. 54, Section 196.161, Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 54. 55, Section 196.161, Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 55. 56. Section 196.161(1)(b), Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 56. 57. The decision of Mitchell v. Higgs, 61 So. 3d 1152 (Fla. 3rd DCA 2011) speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 57. 58. Section 196.131(3), Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 58. 59. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 59. 60. Section 196.161(1)(b), Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 60.61. Sections 196.161(1)(b) and 196.161(3), Florida Statutes, speak for themselves. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 61 62. The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 62 63 The Department is without knowledge sufficient to admit or deny the allegations contained in Paragraph 63 64. Section 196.161(1)(b), Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 64 COUNT III - Removal of 2016 Recapture Tax, Interest and Penalties and Overassessment for Tax Year 2017 65 The Department restates its answers to Paragraphs 1-35 as if fully set forth herein. 66. Section 196.161, Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 66. 67. Section 193.1554(3), Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 67. 68 Section 193.1554(3), Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 68 69. Section 193.1554(3), Florida Statutes, speaks for itself. The Department is without knowledge sufficient to admit or deny the remaining allegations contained in Paragraph 69.First Defense (No Case or Controversy Alleged Against the Department) The Plaintiffs have failed to state a claim against the Department upon which this Court could grant relief. The Department is named as a nominal party, as required by the notice- joinder provision of Section 194.181(5), Florida Statutes, but the Plaintiffs do not allege any wrongdoing by, nor request any relief from, the Department. A complaint must allege ultimate facts, that when established by competent evidence, support an order granting the relief a plaintiff seeks. See, e.g., KC Leisure, Inc. v. Haber, 972 So. 2d 1069, 1075 (Fla. 4th DCA 2008) This Court cannot grant relief against the Department where no request for relief has been made by the Plaintiffs. WHEREFORE, Defendant Leon M. Biegalski, as Executive Director of the Florida Department of Revenue, requests entry of judgment in his favor, an award of costs, and such other relief as deemed appropriate. RESPECTFULLY SUBMITTED this 31st day of May, 2018 PAMELA JO BONDI ATTORNEY GENERAL S/Timothy E. Dennis TIMOTHY E. DENNIS Chief Assistant Attorney General Florida Bar No. 575410 Office of the Attorney General Revenue Litigation Bureau PL-01, The Capitol Tallahassee, FL 32399-1050 (850) 414-3300 Primary Email: Timothy.Dennis@myfloridalegal.com Secondary Emails: Jon.Annette@myfloridalegal.com Rebecca.Padgett@myfloridalegal.comCounsel for Defendant Leon M. Biegalski, Executive Director Florida Department of Revenue CERTIFICATE OF SERVICE THEREBY CERTIFY that on a true and correct copy of the foregoing has been furnished by e-mail to Andre’ A Gibson, Esquire, 45 NE 67th Street, North Miami Beach, FL 33162, AAGibson@Gibsontaxlaw.com, Efile@Gibsontaxlaw.com (Counsel for the Plaintiffs); Michael J. Mastrucci, Esquire, Assistant County Attorney, Stephen P. Clark Center, Suite 2810, 111 Northwest First Street, Miami, Florida 33128, mastrucc@miamidade.gov, wilma.morillo@miamidade.gov (Counsel for Property Appraiser and Tax Collector), on this 31st day of May, 2018. S/Timothy E. Dennis TIMOTHY E. DENNIS Chief Assistant Attorney General 10