Response Re Motion To Stay

Case 1:18-cv-24190-RS Document 632 Entered on FLSD Docket 02/22/2024 Page 1 of 19
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
Case No.: 1:18-cv-24190
WILLIAM O. FULLER, and

MARTIN PINILLA, II,
Plaintiffs,
v.
JOE CAROLLO,
Defendant.
___________________________________/
PLAINTIFFS’ OPPOSITION TO DEFENDANT’S

MOTION FOR STAY OR INJUNCTIVE RELIEF;
CROSS-MOTION FOR EXPEDITED DISCOVERY;
AND REQUEST FOR EVIDENTIARY HEARING
Defendant Joe Carollo hopes to thwart this Court’s Final Judgment by lodging a homestead
exemption claim that stems from a pattern of corruption, deception, and abuse of his government
authority similar to that which triggered his underlying liability for damages in the first instance.
Just yesterday, in rejecting Carollo’s contention that jury’s award was “so grossly excessive that
they shock the conscience,” this Court emphasized that the “only shock to the conscience here is
that [Carollo] used his position and power to weaponize the City government against Plaintiffs
because Plaintiffs chose to exercise their First Amendment rights by supporting [Carollo’s]
election opponent.” DE 631 at 7; accord id. at 8 (“[T]he factors for consideration weigh heavily
in favor of finding a high degree of reprehensibility” based on Carollo’s “continuous and
unrelenting” actions that were “intentional and malicious,” “specifically targeted Plaintiffs’
financial vulnerabilities,” and “continued long after Plaintiffs filed suit”). The egregious, bad-faith
misbehavior that underlies Carollo’s claim for a homestead exemption represents more of the same
reprehensible conduct.
The property that Carollo now claims as his homestead was pointedly abandoned as his
residence several years ago because it was located outside of the district that he hoped to represent
as a commissioner. Thus, Carollo could only prevail in the litigation that challenged his eligibility
for office by publicizing his abandonment of that property and establishing a different residence
within his district in Little Havana. Under the shadow of this Court’s Final Judgment, however,
Carollo retracted his promise to refrain from voting on the redistricting maps given his stark
conflict of interest, and instead cast the deciding vote—along with former (and since-arrested)
Commissioner Alex de la Portilla—to enact an illegal racial gerrymander that moved Carollo’s
property into Carollo’s district while excluding Commissioner’s de la Portilla’s chief election
opponent’s residence from Commissioner de la Portilla’s district. Though the consultant who drew
the redistricting maps attempted to obscure Carollo’s role by asserting a claim of attorney-client
privilege, he nevertheless testified under oath that the boundary lines were revised because “it was
very clear to him . . . where [Carollo’s] house was” and he “thought yes, that would make [Carollo]
happy” to re-draw the boundary lines to create more favorable conditions for “whether [Carollo]
can homestead the house or not.” Exhibit A at 86 (GRACE, Inc., et al., v. City of Miami,
No. 22-CV-24066-KMM (S.D. Fla.) (Jan. 30, 2024 Trial Tr.).
That brief narrative merely describes the genesis of Carollo’s homestead exemption claim,
which he has attempted to perpetuate by engaging in even more corrupt, deceptive, and misleading
conduct described below. To be sure, the Florida Constitution exempts legitimate homestead
property from being subject to forced sales in order to promote a laudable public interest in
preventing families from facing unwarranted financial insecurity. But that that public purpose
would not be served—and in fact would be undermined—if Carollo’s homestead exemption claim
allowed him to escape the consequences of a career spent wielding his government authority as a
weapon of retaliation and leaving a trail of destroyed businesses and insecure families in his wake.
Based on the unique confluence of factors presented in this case involving an elected official who
abused his political power to create the very conditions that he claims to give rise to his homestead
exemption, Carollo is not entitled to frustrate Plaintiffs’ ability to enforce this Court’s Final
Judgment any longer. To the extent that this Court does not deny Carollo’s motion in its entirety,
Plaintiffs respectfully request narrowly-tailored expedited discovery to rebut the unsubstantiated
factual assertions in Carollo’s motion, as well as an evidentiary hearing.
FACTS
By September 22, 2016 at the latest, Defendant Joe Carollo affirmatively abandoned any
homestead status that may have existed with respect to the property located at 3230 Morris Lane,
Coconut Grove, Florida (the “Morris Lane Property”). He cannot now reclaim that homestead
status at the eleventh hour to impede this Court’s Final Judgment.
2
A. Carollo Abandons the Morris Lane Property as His Homestead

The reason why Carollo long ago abandoned any claim to homestead that he previously
had for the Morris Lane Property is because it was always located in District 2 (which encompassed
Coconut Grove), but Carollo planned to run for office as a City Commissioner for District 3 (which
encompassed Little Havana). And, according to the City of Miami Charter, “candidates for the city
commission shall have resided within the district at least one (1) year before qualifying and be
electors in the district, and shall maintain residence in that district for the duration of their term of
office.” City of Miami Charter at § A.4(c).
Thus, as Carollo explained in several binding judicial admissions, by September 2016 he
had “executed a Residential Lease for his tenancy at the Brickell Station Lofts apartments” at
110 SW 10th Street, Miami, Florida (the “Brickell Property”) and established his residency
there. Exhibit B (Leon v. Carollo, et al., No. 2017-026678-CA-01, Answer at 4); accord id. at 7
(citing “publicly filed documents . . . filed with the City of Miami” that “are property judicially
noticed by the court”). In fact, Carollo further admits that he “changed his voter registration and
drivers license address to his new residence, did not vote in any election thereafter from any
different address, and maintained no other residence.” Id. at 15-16, ¶ 42. In short, as Carollo put
it, he abandoned his residency at the Morris Lane Property in District 2, and “established his
residency in Commission District 3 on September 22, 2016”:
He did so by his intent to establish residency in District 3 as corroborated by his
objective conduct of obtaining a valid lease effective September 22, 2016, paying
for that lease with a Cashier's Check on September 22, 2016, and moving into the
apartment unit with his wife on September 22, 2016.
Id. (emphasis added).
Notably, Carollo proved that he was no longer claiming homestead on the Morris Lane
Property by attaching, among other things, a document from the Miami-Dade Property Appraiser’s
website showing that the Morris Lane Property was not processed for any homestead tax
exemption commencing January 1, 2017. Id. at 71 (Attachment C). And, as of last week, the Morris
Lane Property still is not designated as homestead property on the Property Appraiser’s website.
accord Miami-Dade Property Appraiser, How Assessed Value Is Calculated (REF 193.155, F.S.),
MIAMI DADE GOV, http://tinyurl.com/3wxw34cj (last accessed Feb. 19, 2024) (explaining that
property subject to a “Non-Homestead Cap” is an automatic benefit for “[p]roperties without a
homestead exemption”); infra at 13-14 (explaining that the property information that was once
3
publicly available on the Miami-Dade Property Appraiser’s website has since been blocked from
public view since the recent commencement of these supplementary proceedings).
Based on these admission and evidence, Carollo prevailed in a challenge to his eligibility
based on his residence and was permitted to serve as Commissioner for District 3 because he
successfully established that he had abandoned his Morris Lane Property which was located in
District 2. As the trial court noted, “it is undisputed that certainly as of the time [Carollo] was
sworn in,” in December 2017, “he has resided in the district.” Exhibit D at 613.
B. Carollo Establishes the Little Havana Property as His Homestead
Shortly after taking office in December 2017, Carollo and his wife, Marjorie, moved from
the Brickell Property that he had been renting into a house located at 1521 SW 10th Street
(the “Little Havana Property”). The Little Havana Property remained the Carollos’ primary and
permanent residence throughout the trial and judgment in this case.
Indeed, as Carollo explained under oath during the trial in this matter, it was important to
him to “know what is happening [in the] neighborhood” he represented by “being part of it.”
DE 557 at 13 (May 3, 2023 Trial Tr.). Thus, Carollo testified that he moved into the Little Havana
Property during his term in office:
I was living in the district. In fact, from Calle Ocho, the main business district, my
wife had found a pretty little small house that she decided that's where she wanted
to move to and we rented it and that was only a block and a half from 8th Street.
Exhibit E at 12.
Leading up to the trial in this matter, Carollo not only identified the Little Havana Property
as his residence in sworn testimony, but he could not even recall the address of the Morris Lane
Property. Specifically, on February 6, 2023, just two months before the start of trial, Carollo was
deposed in a related case, was asked to provide his address, and responded: “1521 S.W. 10th Street,
Miami, Florida 33135” (i.e., the Little Havana Property). Exhibit F at 7-8. Then, on March 21,
2023, Carollo reaffirmed that he had abandoned the Morris Lane Property and could not
“remember the address”:
Q. Do you own a home?
A. I own a property, sir.
Q. What is the address?
A. I'm trying to remember the address. It's on Morris Lane. I'm sorry. I can't
remember the numbers right now.
4
Q. What year did you purchase it?

A. To the best of my recollection, it was 2002, in the beginning. I don't know if it
was January or February 2002.
Q. And how long did you reside there?
A. I resided there until 2016.
Exhibit G at 42:9 – 44:4.
Various important documents accord with Carollo’s abandonment of the Morris Lane
Property and the establishment of the Little Havana Property as his homestead. For instance,
Carollo’s January 15, 2023 Online Request to be a Supporter and Declaration of Financial Support
identify the Little Havana Property as his mailing address. Exhibit H at JC-DIAOE-000291.
Likewise, through at least June 30, 2023, Carollo’s Retirement Plan statements list his address at
the Little Havana Property:
Moreover, through July 2023, Carollo’s First Horizon Mortgage Interest statements reflect that his
address is the Little Havana Property:
5
According to documents produced by Carollo’s landlord this week, Carollo’s lease at the
Little Havana Property was first extended for six months from April 27, 2022 until November 26,
2022, and then he remained there on a month-to-month basis thereafter. See Mar. 24, 2022
Renewal Rental Agreement, at 1. Indeed, as of at least April 2, 2023, Carollo was still intending
to reside in the Little Havana Property because he paid his rent through that month. See Invitation
Homes, Inc. Resp. to Pls.’ RFPs, Ex. A at ¶ 1. By all appearances, Carollo intended to reside in
the Little Havana property indefinitely because he was confident that his plan to avert nearly all
pretrial discovery would culminate in a favorable outcome at trial. But that outlook changed when
trial commenced in April 2023 and Carollo was faced with the sheer volume of devastating
testimony offered against him by senior City Officials who all explained under oath how Carollo
had weaponized City government to shut down Plaintiffs’ businesses, including: City Manager
Emilio Gonzalez (4/11/23), Police Chief Art Acevedo (4/18/23), Police Chief Jorge Colina
(4/18/23), Carollo’s Chief of Staff and Doral Police Chief Richard Blom (4/18/23), City
Commissioner Ken Russell (4/19/23), Carollo’s aide Steven Miro (4/20/23), Director of Code
Compliance Orlando Diez (4/24/23), and Carollo’s secretary and niece Tanjha Quintana (4/28/23).
In fact, after attending trial every day throughout April 2023, Carollo, failed to appear on
the day that Plaintiffs notified him that they intended to call him as an adverse witness, requiring
this Court to order Carollo to appear in Court for his examination the following full day of trial.
DE 553; DE 554 at 62:20-63:19. It was only around this same time, in April 2023, that Carollo
provided his landlord written notice that he would be “terminating [his] tenancy, vacating the
premises, and surrendering same to you as the landlord or, or agent for same on or before
April 29, 2023.” Exhibit C. And, as explained in more detail below, it was also at this time that
Carollo unsuccessfully attempted to record a quitclaim deed transferring an interest in the Morris
Lane Property to his wife as it became clear that Plaintiffs would inevitably prevail at trial.
C. Carollo Attempts to Manufacture a Futile Homestead Exemption Claim for the
Morris Lane Property through Egregious, Bad-Faith, and Fraudulent Misconduct
While Carollo lacked any intention to make the Morris Lane Property his permanent
residence, he did hope to protect it from any final judgment that the Court might enter in this case.
Accordingly, Carollo engaged in unprecedented tactical gamesmanship in an effort to accomplish
that corrupt objective which ultimately frustrates any putative homestead claim that he might
otherwise assert over the Morris Lane Property.
6
First, Carollo attempted to plant the seeds of his homestead exemption claim over the
Morris Lane Property by engaging in a shocking abuse of authority with respect to the City of
Miami’s redistricting process. Because Carollo could not simultaneously continue to serve as a
City Commissioner for District 3 while residing in the Morris Lane Property located in District 2,
he made it known that the City of Miami District boundary lines would have to change to serve
his personal pecuniary interests. The corrupt motive underlying the adjustment of District 3’s
electoral map to encompass the Morris Lane Property is not a matter of speculation, but rather the
subject of a frank admission by the individual who expressly drew the boundary lines to “make
[Carollo] happy” by helping to thwart this Court’s Final Judgment in this case, as reflected in the
map below. Ex. A at 86. 1
Miguel DeGrandy, the consultant who drew the revised maps, explained how the Morris
Lane Property ended up in District 3. Mr. DeGrandy testified that “it was very clear” to him “where
[Carollo’s] house was,” and there would be a dispute as to “whether [Carollo] can homestead the
house or not” in connection with this “very public lawsuit.” Ex. A at 86. According to Mr.
1
As this Court found, Carollo’s actions were “continuous,” “unrelenting,” “intentional,” and
“malicious,” DE 631 at 8, and individuals engaged in such knowing misconduct often clearly
communicate their plans to confederates even if they attempt to cloak them in coded or implicit
terms, as Carollo did. See, e.g., DE 552 at 133-34 (Apr. 24, 2023 Trial Tr.) (testimony reflecting
that “it was well known” to “[e]veryone in the city” that Carollo “had it out for” Plaintiffs, and it
was “common knowledge” that Carollo was “targeting” Plaintiffs’ tenants, even in the absence of
explicit directives to retaliate against them).
7
DeGrandy he “did not draw” the Morris Lane Property within District 3 “in [his] first plan”
because the boundary line “did not go that far south.” Id. But, at some point, Mr. DeGrandy
testified, he became “very aware that [Carollo] owned a house in that area right there,” and
“thought yes, that would make [Carollo] happy,” to stretch the District 3 boundary over the Morris
Lane Property and provide Carollo an opportunity to advance a homestead claim in the face of this
Court’s Final Judgment. Id.
Under these circumstances, Mr. DeGrandy cannot rely on the attorney-client privilege to
conceal his communications with Carollo about their plan to redraw the electoral maps to
manufacture the grounds for Carollo to lodge a homestead exemption claim over the Morris Lane
Property. Accordingly, to the extent that this Court does not deny Carollo’s motion based on the
extensive misconduct described herein relating to his claim of homestead, Plaintiffs request that
this Court issue an order requiring Carollo and DeGrandy to substantiate any claim of
attorney-client privilege or compelling them to testify regarding their conversations and produce
relevant documents concerning this issue.
Second, the redistricting plan that Carollo supported also constituted an unconstitutional
racial gerrymander that would have the effect of tightening Carollo’s grip on political power in
District 3 and allow him to prolong his putative homestead exemption claim. In fact, within four
days of Carollo’s lease for the Little Havana Property expiring on April 29, 2023, this Court on
May 3, 2023, issued a Report & Recommendation enjoining the implementation of the new district
maps. This Court’s conclusion that those maps constituted an impermissible gerrymander was
supported by Carollo’s public comments that were quoted extensively in the R&R, including the
following:
What I care is that in the future, there is sufficient Hispanic votes [in Districts 1, 3,
and 4] to elect a Hispanic. And a Hispanic that is not going to be a lap dog for
anybody.
GRACE, Inc. v. City of Miami, No. 22-CV-24066-KMM, 2023 WL 3594310, at *29-30 (S.D. Fla.
May 23, 2023).
The trial in the GRACE action concluded in January 2024 and Judge Moore is virtually
certain to issue a final ruling invalidating the racially gerrymandered district map and enter a new
map in which Carollo’s Coconut Grove house is no longer in District 3. In light of that likely
outcome, Carollo cannot substantiate his assertion that he intends to make the Morris Lane
8
Property (in Coconut Grove) his permanent residence, as he cannot maintain a residence there
while continuing to represent District 3 (in Little Havana). And regardless of whether Carollo
would resign as a Commissioner for District 3 to preserve his homestead exemption claim, he
cannot be permitted to retain any windfall that he sought to obtain by moving the Morris Lane
Property into District 3 using an impermissible map.
Third, to perpetuate his homestead claim over the Morris Lane Property, Carollo made
misrepresentations about the redistricting process to mislead his constituents in general and this
Court in particular. With respect to the public, Carollo represented that he would refrain from
voting on the proposed redistricting maps given the significant conflict of interest arising from the
substantial asset protection benefits that he stood to gain through the redistricting process. See
GRACE, Inc. v. City of Miami, No. 22-CV-24066-KMM, 2023 WL 3594310, at *35 & n.13
(S.D. Fla. May 23, 2023) (“Carollo . . . report[ed] that he would abstain from the vote to prevent
anyone later blaming him in any future court case over the redistricting.” Yet, Carollo not only
ultimately reversed course on his representation that he would not participate in the vote, but in
fact he cast the deciding vote in favor of its passage, moving the District 3 boundary line to include
the Morris Lane Property by a 3-2 margin. Id. (“Carollo did participate in the vote when it was
ultimately conducted”). Remarkably, Carollo’s vote was supported by former (and since-arrested)
Commissioner Alex de la Portilla, who had similarly redrawn his district to exclude his main
competitor, Miguel Gabela.
And Carollo made equally misleading representations to this Court. In response to the
transparently corrupt motivations animating the redistricting efforts, Plaintiffs sought an order
enjoining Carollo from “manipulating the redistricting of the City of Miami to protect his home
from being subject to a judgment in this case,” which would expose him to millions of dollars in
damages stemming from his First Amendment retaliation campaign. DE 221. But Carollo refused
to acknowledge his corrupt—or, at best, mixed—motives in supporting redistricting, and instead
insisted to this Court that Plaintiffs’ requested injunction was not actually geared towards his
“retaliatory actions,” but rather sought to “enjoin [him] from exercising his legislative
responsibilities.” DE 223. Of course, Carollo did not ever explain why it would interfere with his
so-called “legislative responsibilities” to recognize a glaring conflict of interest that should have
resulted in his recusal.
9
Nor could he, given that part of Carollo’s “legislative responsibilities” includes complying
with Florida law that required him to abstain under such circumstances. See George v. City of
Cocoa, Fla., 78 F.3d 494, 496 (11th Cir. 1996) (quoting, inter alia, Op. Fla. Comm. Ethics 90-20
(1990)) (“A ‘special private gain’” requiring a municipal official to “abstain from voting” “refers
to a financial interest of the public official that is directly enhanced by the vote in question”). See
also Fla. Stat § 112.313 (“No public officer . . . shall corruptly use or attempt to use his or her
official position . . . or perform his or her official duties, to secure a special privilege, benefit, or
exemption for himself or herself”); Fla. Stat. § 112.3143 (“No . . . municipal, or other local public
officer shall vote in an official capacity upon any measure which would inure to his or her special
private gain or loss”).
And Carollo’s assertion to this Court is even more indefensible in hindsight, since
Mr. DeGrandy later testified that the boundary lines for District 3 did not encompass the Morris
Lane Property until it became apparent that Carollo “owned a house in that area” and it “would
make [Carollo] happy” if it were included within District 3. Ex. A at 86. Without misleading this
Court about the legitimate justification for Plaintiffs’ requested injunction, Carollo might never
have been capable of enacting the self-serving boundary lines that form the basis of his current
homestead exemption claim.
Fourth, in addition to failing to establish a legitimate homestead claim over the Morris
Lane Property in the first instance, Carollo has also deprived Plaintiffs and the Court of discovery
that would be likely to affirmatively defeat it in these supplemental proceedings. Despite insisting
that he temporarily occupied the Morris Lane Property for a limited period of time in advance of
the entry of judgment in this case, Carollo refuses to produce discovery materials that are germane
to determining whether the Morris Lane Property—as opposed to any other residential property—
currently serves as his residence.
For instance, Plaintiffs issued discovery requests for the residential property that Carollo
leased in Little Havana; the additional residential properties in the city for which Carollo
apparently pays the utility bills; and the residential property that Carollo presumably inherited
from his mother. Despite Plaintiffs’ repeatedly requesting information about these properties since
August 2023, and filing a motion to compel on January 12, 2024 (DE 603), Carollo has continued
to slow-drip and stonewall his responses. As of this month, February 2024, Carollo’s counsel
responded in a non-committal manner when requested to identify “when the remainder of the
10
documents will be produced or a certificate of completion issue[d],” merely indicating in vague

terms that they would “review” and “advise,” which they have not done to date. Meanwhile,
information relating to at least some residential properties that are seemingly associated with
Carollo that were once publicly available on the Miami-Dade Property Appraiser’s website have
since been blocked from public view. 2
Fifth, Carollo infected his claim of homestead with yet another badge of fraud by
unsuccessfully attempting to transfer an interest in the Morris Lane Property to his wife during the
trial in this case. But this transfer was itself fraudulent under the statutory definition of that term,
as it was made “to an insider,” and occurred long after Carollo “had been sued” and “shortly
before . . . a substantial debt was incurred” (i.e., during trial on the eve of the entry of judgment),
with the “actual intent to hinder, delay, or defraud” the Court’s ability to effectuate its impending
Final Judgment in Plaintiffs’ favor. Fla. Stat. § 726.105. And although the Carollos then attempted
to leverage that transfer to frustrate this Court’s Final Judgment, they stumbled in their race to the
courthouse. Specifically, the Carollos did not record a “Corrective Quit Claim Deed” until
February 5, 2024, approximately eight months after the Final Judgment in this matter was entered
on June 1, 2023 by this Court and recorded by Plaintiffs on June 14, 2023. See In re McCall, 58
B.R. 54, 55-56 (Bankr. M.D. Fla. 1986) (“It was the [judgment debtor’s] obligation to record that
warranty deed in order to protect his title against subsequent . . . creditors”).
And, in the end, Carollo’s attempted fraudulent transfer is doubly ineffective in frustrating
this Court’s Final Judgment because it was not properly recorded until after the judgment was
recorded. Specifically, Carollo did not record a “Corrective Quit Claim Deed” until
February 5, 2024, approximately eight months after the Final Judgment in this matter was entered
on June 1, 2023 by this Court and recorded by Plaintiffs on June 14, 2023. Thus, in addition to
constituting a fraudulent conveyance, Carollo did not timely record the deed before the judgment
was recorded. See In re McCall, 58 B.R. 54, 55-56 (Bankr. M.D. Fla. 1986) (“It was the [judgment
debtor’s] obligation to record that warranty deed in order to protect his title against subsequent . . .
2
Relatedly, by designating his motion as an “emergency,” Carollo has frustrated Plaintiffs’ ability
to complete their discovery concerning the egregious, bad-faith abuse of his government authority
that resulted in the expansion of the District 3 boundaries to encompass the Morris Lane Property
while retracting the District 2 boundaries to exclude the residence of former (and since-arrested)
Commissioner de la Portilla’s election opponent. Accordingly, Plaintiffs also respectfully request
expedited discovery regarding these issues.
11
creditors”). While the Carollos may contend that these latest fraudulent acts and procedural
fumbles would not be sufficient to overcome the homestead exemption on their own, they remain
part and parcel with the egregious, bad-faith, and fraudulent conditions that Carollo created to
manifest the homestead claim in the first instance. Accordingly, the deception inherent in the
Carollos’ overall scheme to frustrate the Court’s Final Judgment is indelibly linked to their
homestead exemption claim and further militates against granting the relief sought in their motion.
ANALYSIS
The touchstone of any homestead inquiry is whether a judgment debtor like Carollo “in
good faith” intends to “make[ ] the property his . . . permanent residence” under a totality-of-the-
circumstances analysis which cannot be unmoored from the “public policy” underpinning the
exemption, which is designed to “‘promote the stability and welfare of the state by securing to the
householder a home . . . .” Baldwin v. Henriquez, 279 So. 3d 328, 333 n.4 & 336 (Fla. 2d DCA
2019). Here, Carollo cannot demonstrate that the Morris Lane Property he abandoned years ago is
his current homestead. In fact, it would undermine the public policy that animates the homestead
exemption to allow Carollo to abuse the public trust and engage in corrupt, deceptive maneuvers
to manufacture a claim of homestead in order to interfere with the enforcement of this Court’s
Final Judgment holding him accountable for wrongfully targeting the stability and welfare of
innocent families to chill the political expression of his constituents. Because none of Carollo’s
technicality-laden arguments to the contrary have any merit, a stay or an injunction is not
warranted.
A. This Court Has Jurisdiction to Adjudicate Carollo’s Homestead Exemption Claim
Carollo is incorrect to suggest that this Court is somehow precluded from adjudicating—
and ultimately denying—his homestead claim. Carollo’s apparent misunderstanding stems from
his misguided reliance on a solitary and clearly distinguishable state court case which held that, as
between Florida’s state courts and for purposes of enforcing a judgment entered by a Florida
state court, it is the Florida “circuit court [that] has exclusive jurisdiction to determine the validity
of a claimed homestead exemption.” DE 628 at 3-5 (quoting Sepulveda v. Westport Recovery
Corp., 145 So. 3d 162, 167 (Fla. 3d DCA 2014)). But, putting aside that lone state-centric case,
the relevant Florida statute has nothing to say about granting Florida state courts “exclusive
jurisdiction” over federal courts’ ability to enforce federal judgments, despite Carollo’s misleading
12
argument otherwise. See Fla. Stat. § 222.10 (“The circuit courts have equity jurisdiction . . . to
determine whether any property . . . claimed to be exempt . . . is so exempt”) (emphasis added).
To the contrary, the Federal Rules merely require federal courts to implement a “procedure
on execut[ing]” its judgments that “accord[s] with the procedure of the state where the court is
located,” without requiring—or permitting—the entirety of the proceedings to be transferred to
state courts. Fed. R. Civ. P. 69(a). There is no provision of state or federal law that requires a
federal court to deviate from standard federal-supremacy principles, refrain from adjudicating a
disputed homestead exemption claim, and wait for a state court to determine whether such a
homestead exemption claim can impede the execution of a federal judgment. Carollo does not cite
any case adopting the rule that he proposes, and in fact federal courts routinely adjudicate such
claims by applying the procedures set forth in Fla. Stat. § 222.01, et seq., within the confines of
the federal courthouse. See In re Martinez, 595 B.R. 912, 921 (Bankr. S.D. Fla. 2019) (citing
several cases in which federal courts “reviewed the [Florida homestead] standard defined above—
actual residence plus continuous intent to reside—and found that, under the facts presented, the
scale tipped in favor of abandonment”).
B. Carollo’s Homestead Exemption Claim Is Meritless
In this case there is scant evidence that Carollo has ever lived in the Morris Lane Property
after abandoning it as his homestead by September 2016, consistent with his repeated judicial
admissions that he had abandoned the property to meet the residency requirements to serve as a
Commissioner for District 3. Rather, Carollo’s only fixed intention has been to reside in a location
that permits him to serve as Commissioner for District 3, which he will not be able to do from the
Morris Lane Property when the Court invalidates the illegal racial gerrymander supported by
Carollo’s corrupt participation. Finally, in this one-of-a-kind case involving a government official
who ran roughshod over a glaring conflict of interest and abused his authority to engineer the
foundation for his putative homestead exemption claim, there are several other indications of bad
faith, fraud, and egregiousness that preclude the relief Carollo seeks in his motion to prevent the
prompt and effective enforcement of this Court’s Final Judgment.
1. Carollo Abandoned the Morris Lane Property and Lacks Any Good-Faith Intention to
Make it His Permanent Residence
It is well-established that homestead status is established by the actual intention to live
permanently in a place coupled with actual use and occupancy. Hillsborough Inv. Co. v. Wilcox,
152 Fla. 889, 895, 13 So. 2d 448, 452 (1943) (“The character of property as a homestead depends
13
upon an actual intention to reside thereon as a permanent place of residence, coupled with the fact
of residence”); accord In re Brown, 165 B.R. 512 (Bankr. M.D. Fla. 1994); In re Frederick, 183
B.R. 968, 971 (Bankr. M.D. Fla. 1995) (debtor not entitled to homestead exemption when he
abandoned property by leasing it for six years, treated it as rental property for tax purposes, and
failed to claim Florida homestead exemption); In re Goode, 146 B.R. 860, 862 (Bankr. M.D. Fla.
1992) (debtors abandoned homestead by entering into lease, attempting sale to lessee, and failing
to reside in premises for over two years, even though debtors' furniture and personal property
remained in residence).
To determine whether a homestead property was abandoned, the Court must consider “all
of the pertinent facts and circumstances of each individual case.” Marsh v. Hartley, 109 So.2d 34,
38 (Fla. 2d DCA 1959). And although a “[d]ebtor’s expression of his intention is probative, . . . a
claim for exemption may fail” if he “acts inconsistently with a self-professed intention to establish
homestead,” In re Bratty, 202 B.R. 1008, 1010 (Bankr. S.D. Fla. 1996). “Courts have described
abandonment as occurring when the owner leaves the home with no intention of returning, takes
up permanent abode at another place, and pursues a livelihood in the new area.” In re Martinez,
595 B.R. 912, 920 (Bankr. S.D. Fla. 2019); see also In re Lloyd, 394 B.R. 605, 610-12 (Bankr.
S.D. Fla. 2008) (evaluating debtor's claim of homestead considering rental of property and debtor's
habitation elsewhere). Courts have also considered whether a debtor “fail[ed] to maintain the
Property's homestead property tax designation,” In re Martinez, 595 B.R. at 920–21, and the
address listed on the debtor's voter registration and driver's license as factors in its determination
of a debtor's abandonment of his homestead. See In re Alexander, 346 B.R. 546, 551 (Bankr. M.D.
Fla. 2006) (noting that the address listed on the debtor's driver's license, voter's registration card
and checking accounts are all factors to be considered); In re Middleton, 462 B.R. 832, 835 (Bankr.
N.D. Fla. 2011), aff'd sub nom. Middleton v. Phillips, No. 5:12-CV-10/RS-EMT, 2012 WL 764196
(N.D. Fla. Feb. 29, 2012) (“[T]he totality of the circumstances establishes that the Debtor and his
family do not intend to permanently reside on the Panama City property.”).
Here, Carollo’s actions and admissions clearly demonstrate that he abandoned the Morris
Lane Property and, with it, any homestead protections he could have used to protect it from
execution. First, Carollo expressed his intention to not live in the Morris Lane Property by moving
out of the property in September 2016 to meet the requirements of the City of Miami Charter to
run for the District 3 Commissioner seat. City of Miami Charter at § A.4(c). As detailed above,
14
Carollo expressed this intention in several binding judicial admissions. See supra 3-5. The lack of
the actual intention to live permanently in the Morris Lane Property and Carollo’s subsequent
residency in the Brickell Property and Little Havana Property establishes Carollo’s abandonment
of the Morris Lane Property. Hillsborough Investment Company, 152 Fla. at 895; In re Frederick,
183 B.R. at 971; In re Goode, 146 B.R. at 862.
Moreover, Carollo himself changed his voter registration and driver’s license addresses to
his new residence at the Brickell Property. See In re Alexander, 346 B.R. at 551 (noting that the
address listed on the debtor's driver's license, voter's registration card and checking accounts are
all factors to be considered); In re Middleton, 462 B.R. at 835. In addition, Carollo’s bank
statements (through March 2023), his retirement plan statements (through June 2023), and his
mortgage interest statements (through July 2023), all show the Little Havana Property as his
address. See supra 5-8.
Finally, Carollo’s “fail[ure] to maintain the [Morris Lane] Property's homestead property
tax designation” also demonstrates his abandonment of all homestead protections for the property.
In re Martinez, 595 B.R. at 920–21. Carollo himself proved this by attaching a document from the
Miami-Dade Property Appraiser’s website showing that the Morris Lane Property was not
processed for any homestead tax exemption commencing January 1, 2017. Id. at 71 (Attachment
C). And, as of last week, the Morris Lane Property still is not designated as homestead property
on the Property Appraiser’s website. Accord supra at 13-14 (explaining that the property
information that was once publicly available on the Miami-Dade Property Appraiser’s website has
since been blocked from public view).
2. Carollo’s Homestead Exemption Claim Is Derived from Disqualifying Egregious,
Bad-Faith, Fraudulent Misconduct
Moreover, even if Carollo had not abandoned the Morris Lane Property without
subsequently demonstrating any intent to permanently reside there, his egregious, bad-faith, and
fraudulent misconduct in creating the foundation for a homestead exemption claim would lead to
the same result. In other words, while the “homestead exemption is liberally construed,” it is “not
so liberally construed ‘so as to make it an instrument of fraud or imposition on creditors.’” In re
Bifani, 580 F. App'x 740 (11th Cir. 2014) (quoting Town of Lake Park v. Grimes, 963 So.2d 940,
942 (Fla. 4th DCA 2007)); accord id. (quoting Jones v. Carpenter, 106 So. 127, 130 (Fla. 1925)
(“Thus, Florida law is well-settled: A homestead ‘cannot be employed as a shield and defense after
fraudulently imposing on others.’”); In re Englander, 95 F.3d 1028, 1031 (11th Cir.1996)
15
(“Florida's homestead laws were designed to protect the family home; they were not designed to
be used as an instrumentality of fraud.”).
Thus, as one Florida court explained, the homestead exemption can only be extended to
cover “legitimate[ ]” activity creating a homestead, by which it “mean[s] that there is no
‘fraudulent or otherwise egregious act’ by the beneficiary of the homestead exemption.” Law v.
Law, 738 So. 2d 522, 525 (Fla. 4th DCA 1999) (citing Radin v. Radin, 593 So. 2d 1231, 1232-33
(Fla. 3d DCA 1992)) (“We affirm the imposition of the equitable lien” on “the former husband’s
homestead” based on findings that “the husband . . . had engaged in a pattern of egregious conduct
represented by significant nonpayment of alimony”). Although it does not appear that any court in
the country has ever had the occasion to consider whether an elected official who manipulates his
government authority to craft the framework for his own homestead exemption claim forfeits the
exemption, it would be consistent with the authorities that “invoke[ ] equitable principles” to limit
the reach of the exemption in cases where the “fraud or egregious conduct” bears a nexus to the
establishment of the homestead. Havoco of Am., Ltd. v. Hill, 790 So. 2d 1018, 1028 (Fla. 2001),
opinion after certified question answered, 255 F.3d 1321 (11th Cir. 2001).
Thus, in In re Sillinglaw, the Florida Supreme Court denied a debtor’s homestead claim,
holding that homestead protection “should not prevail against common sense and there is a limit
to the stupidity we should impute to those who” who enacted the homestead exemption into law
that it would apply in such a circumstance. Id., 81 B.R. 138, 140 (Bankr. S.D. Fla. 1987), aff'd
sub nom. Shillinglaw v. Lawson, 88 B.R. 406 (S.D. Fla. 1988). There, a property owner had rented
a portion of his property but, after the petition for bankruptcy was filed, claimed an intention to
evict the tenant and claim the entire property has his homestead. The judgment creditor argued
the homestead had been abandoned as to the leased portion. The Court noted that the “owner will
seldom admit an intent to abandon, but his intent may be inferred from his conduct. The issue here
is whether on the date of bankruptcy the debtor had abandoned his homestead use of the leased
portion of his property.” Id. (emphasis in original). The Court further noted that homestead “cannot
be employed as an instrument of fraud or a ‘city of refuge’ to escape payment of obligations made
in good faith.” Id., (quoting Anderson Mill & Lumber Co. v. Clements, 134 So. 588, 592
(Fla.1931)).
Likewise here, Carollo’s claim that he now intends to permanently reside in the Morris
Lane Property is not “legitimate” because it is imbued with a pattern of egregious, bad-faith, and
16
fraudulent misconduct that is inextricably intertwined with his homestead. After abandoning the
Morris Lane Property because it was located outside of District 3, he now seeks to claim it as his
homestead based on his own unconstitutional redrawing of the district maps and on the eve of a
devastating jury verdict containing punitive damages to deter his “shocking” conduct. As detailed
above, Carollo’s abuse of his authority as a City Commissioner to interfere with the redrawing of
the City of Miami Districts to serve his own personal pecuniary interests is not only egregious, but
also constituted unconstitutional and illegal gerrymandering confirmed by the testimony of the
person in charge of redrawing the boundaries.
To make matters worse, Carollo also misled his constituents, the public, and this Court by
misrepresenting that he would not be voting on the proposed redistricting maps, despite actually
going on to cast the deciding vote. Based on his fraudulent statements and egregious conduct,
Carollo was able to accomplish what no ordinary litigant would be able to do—to manufacture a
homestead protection claim by misusing and abusing his office and the political process. Granting
Carollo the right to protect the Morris Lane Property on the basis of a homestead exemption would
not only be contrary to the public policy underlying the constitutional protection, but would allow
Carollo to benefit from his unconstitutional, fraudulent, and bad faith conduct.
Moreover, Carollo’s attempt to quitclaim his property to his wife on May 16, 2023, a mere
16 days before the judgment constituted an actual fraud under Florida law. See Fla. Stat.
§§ 726.105 & 726.106. And the numerous “badges of fraud” relevant to determining actual
fraud—including “whether the transfer was to an insider, whether the debtor retained possession
or control of the property transferred after the transfer, . . . whether before the transfer was made
the debtor had been sued or threatened with suit, . . . whether the debtor was insolvent or became
insolvent shortly after the transfer, [and] whether the transfer occurred shortly before or after a
substantial debt was incurred—creates “a prima facie case and raise[s] a rebuttable presumption
that the transaction is void.” Nat’l Maritime Servs. v. Straub, 979 F. Supp. 2d 1322, 1328 (S.D.
Fla. 2013).
Because the conditions giving rise to Carollo’s homestead exemption claim are rotten to
the core, it is not necessary to determine whether these additional badges of fraud would be
sufficient to overcome any applicable homestead exemption standing alone. Rather, they merely
serve as additional evidence underscoring the egregious, bad-faith, and fraudulent conduct that
inhere in Carollo’s efforts to frustrate this Court’s Final Judgment and evade the consequences of
17
weaponizing the City government to retaliate against his constituents for exercising their First
Amendment rights. See Randazzo v. Randazzo, 980 So. 2d 1210, 1212-13 (Fla. 3d DCA 2008)
(“[W]e agree that the [debtor’s] conduct was sufficient to warrant the imposition of an equitable
lien” on her “newly-acquired homestead” and “we find that the court did not abuse its discretion
in denying the [her] exceptions” based on Florida’s homestead protections).
C. None of Carollo’s Remaining Formalistic Arguments Have Merit
Finally, Carollo cannot evade the execution of this Court’s Final Judgment by lodging a
series of meritless procedural objections.
First, Carollo first attempted to transfer the Morris Lane Property to himself and his wife,
Marjorie Carollo, as joint owners with a quit claim deed on May 16, 2023. This transfer was not
only ineffective due to an error that occurred when Carollo tried to record the deed on May 23,
2023, but also fraudulent, as it occurred during the pendency of the jury trial in this matter, which
concluded with a jury verdict finding Carollo liable for First Amendment retaliation a mere two
weeks later. Carollo did not record the “Corrective Quit Claim Deed” until February 5, 2024, which
was approximately eight months after the Final Judgment in this matter was entered by this Court
on June 1, 2023 and recorded by Plaintiffs on June 14, 2023 with the Miami-Dade Clerk of Court.
Based on Plaintiffs’ prior recording of the Final Judgment, Carollo’s ineffective quit claim deed
should not bar Plaintiffs’ execution of the judgment against the property.
Second, Carollo’s argument that he is entitled to relief because “the judgment is not final”
during the pendency of his motion for new trial is no longer relevant. DE 6238 at 13. This Court
recently denied Carollo’s post-trial motions in their entirety, underscoring the reprehensibility of
his misconduct and bolstering the public interest in the prompt and effective enforcement of its
Final Judgment. See DE 631.
Third, Carollo’s argument regarding the notice of sale is similarly outdated and misguided.
DE 628 at 10-11. The Court’s Final Judgment was recorded twice and the affidavit correctly
informs the recipient of the first recording in “OR Book 33749, Page 1086.” Additionally, even
though there was a typo in the page number for the second recording—the affidavit correctly
provides the recorded CFN of 20240083684, which enables the affidavits recipient to easily find
the judgment’s second recording. Despite the absence of any possible prejudicial error, Plaintiffs
have since issued an Amended Affidavit, and the United States Marshals Service confirmed the
expedited mailing out of the Amended Affidavit to all intended recipients on February 21, 2022.
18
WHEREFORE, Plaintiffs respectfully request that this Court deny Defendant Carollo’s
Motion in full or, in the alternative, permit Plaintiffs to take narrowly-tailored expedited discovery
to rebut the unsubstantiated factual assertions in Carollo’s Motion and set an evidentiary hearing.
Dated: February 22, 2024
Respectfully Submitted,
AXS LAW GROUP, PLLC

2121 NW 2nd Ave, Suite 201
Wynwood, Florida 33127
Telephone: (305) 297-1878
By: /s/ Jeffrey W. Gutchess

Jeffrey W. Gutchess, Esq.
FBN 702641
jeff@axslawgroup.com
eservice@axslawgroup.com
Counsel for Plaintiffs
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the forgoing was served via CM/ECF
on counsel of record of in this action on this 22nd day of February, 2024.
By: /s/ Jeffrey Gutchess

Jeffrey W. Gutchess, Esq.
Counsel for Plaintiffs
19
Case 1:18-cv-24190-RS Document 632-1 Entered on FLSD Docket 02/22/2024 Page 1 of 7
EXHIBIT A
1
1 UNITED STATES DISTRICT COURT

2 MIAMI DIVISION
CASE NO. 1:22-cv-24066-KMM
3
GRACE, Inc., et al., Miami, Florida
4
Plaintiff, January 30, 2024
5
vs. 8:25 a.m. - 1:49 p.m.
6
CITY OF MIAMI,
7
Defendant. Pages 1 to 167
8 ______________________________________________________________
9
BENCH TRIAL
10 BEFORE THE HONORABLE K. MICHAEL MOORE
UNITED STATES DISTRICT JUDGE
11
APPEARANCES:
12
13 FOR THE PLAINTIFF, ACLU,

Et al.:
14 CAROLINE ANDREWS MCNAMARA, ESQ.
American Civil Liberties Union
15 Of Florida
4343 West Flagler Street
16 Suite 400
Miami, FL 33134
17 Cmcnamara@aclufl.org
18 FOR THE PLAINTIFF: CHRISTOPHER J. MERKEN, ESQ.

Dechert LLP
19 Cira Centre
2929 Arch Street
20 Philadelphia, PA 19104
Christopher.merken@dechert.com
21
22
FOR THE PLAINTIFF: NEIL A. STEINER, ESQ.
23 Dechert LLP
Three Bryant Park
24 1095 Avenue of the Americas
New York, New York 10036
25 Neil.steiner@dechert.com
85
1 A. Yes, sir.
2 Q. But, you would say that his ownership of that house was a
3 minor consideration in drawing the entirety of District 3,
4 right?
5 A. In drawing the entirety of District 3, yes.
6 Q. Okay.
7 A. It was a consideration, though.
8 Q. Okay. A consideration with respect to moving this area
9 south of U.S. 1 into District 3?
10 A. That's correct.
11 Q. Okay. Now the Commission never gave a you public
12 instruction to redraw District 3 and extend it south of U.S. 1
13 to include Commissioner Carollo's house in the district, right?
14 A. No. The Commission gave instructions to go south of U.S.
15 1, as needed, to equalize population. There was never an
16 instruction of what -- if that's what you are referring to --
17 there wasn't an instruction of get Commissioner Carollo's house
18 and put it in 3.
19 Q. And in fact, the reason the Commission expressed publicly
20 for moving District 3 south of U.S. 1 was that you needed to
21 reach south of U.S. 1 because that's where the Hispanic voters
22 live, right?
23 A. No, sir.
24 Q. I will read from the transcript, which is Plaintiffs'
25 Exhibit 2, from one of the 2021 meetings, which is Commissioner

86
1 Diaz de la Portilla:
2 "Is there a problem with splitting Coconut Grove as an
3 entity based on where the Hispanic voters live? Is there an
4 issue with that?"
5 Do you remember him asking you that?
6 A. I have no recollection of that, but I wouldn't contest it.
7 Q. Okay. And you won't say whether Commissioner Carollo or
8 his staff privately instructed you to draw his home into
9 District 3, right?
10 A. I could not comment on attorney/client conversations. What
11 I could tell you -- it was very clear to me, because there was
12 a very public lawsuit with Ball and Chain, etcetera, where the
13 commissioner's house was, and whether the commissioner can
14 homestead the house or not. And, I was very aware that he
15 lived where he -- that he owned a house in that area right
16 there.
17 Q. And, you thought that moving that area would please him?
18 A. Basically, yes. I actually did not draw his home in my
19 first plan. My first plan did not go that far south. Later
20 on, when I saw all the newspaper accounts, etcetera, I thought
21 yes, that would make him happy.
22 Q. Okay. You also mentioned during the June 1, 2023,
23 commission meeting that you preserved Little Havana intact in
24 District 3. Do you remember that?
25 A. I believe so, yes.

87
1 Q. And you decided to preserve Little Havana in District 3
2 because it had previously been in District 3, right?
3 A. Yes, sir.
4 Q. So, you decided it was preferable to preserve Little Havana
5 in District 3 rather than moving it into a different district,
6 right?
7 A. I believe so, yes.
8 Q. Moving on to Page 10 of this exhibit, there is District 5
9 in Version 12. We have already gone through all of the border
10 with District 1. If we could zoom in on the southern portion
11 of the downtown area --
12 Now, this proposed District 5, the border is in District 2,
13 and downtown, you have the Miami River here, and then the
14 boundary runs north along Northeast or Southeast 2nd Avenue,
15 and then jogs inland a few blocks.
16 Other than to equalize population, you can't explain why
17 you decided to add that territory to District 5, right?
18 A. The territory that is highlighted in red?
19 Q. Yes, sir.
20 A. Other than to equalize population, no.
21 Q. All right. That area would not have been impacted by any
22 directive to move the Miami Riverside Center or the Wharf into
23 District 5, right?
24 A. No. In terms of equalizing population between 5 and 2, I
25 had to shed 28,000 folks from two, and the most logical is to
88
1 move west to east in the boundary between District 5 and
2 District 2.
3 Q. Okay. Now, we have already heard testimony that I believe
4 you were present in the courtroom for about Condo Canyon. Were
5 you here for that?
6 A. Yes, sir.
7 Q. And that is what we have been referring to as basically
8 this rectangle here that I have circled, right?
9 A. Yes.
10 Q. That is a couple of blocks north of where we are right now,
11 and I don't know the exact street, but it is a finger that in
12 the 2022 plan extended inland into District 5, right?
13 A. Yes.
14 Q. All right. This was the area actually that the magistrate
15 judge identified in her report and recommendation as
16 problematic, right?
17 A. I don't recall. But, I wouldn't contest it.
18 Q. Okay. At your deposition, you testified that this was the
19 area that the magistrate judge had identified as problematic.
20 Do you remember that?
21 A. As I said, I don't recall, but I wouldn't contest it.
22 MR. WARREN: Could we pull up Mr. De Grandy's
23 deposition at Page 87, lines 17 through 20.
24 BY MR. WARREN:
25 Q. So, this is your testimony from your deposition:

167
1 CERTIFICATE
3 I hereby certify that the foregoing is an
4 accurate transcription of the proceedings in the
5 above-entitled matter.
7 February 9, 2023 /s/Sharon Velazco _____

DATE SHARON VELAZCO, RPR, FPR
8 Official Court Reporter
United States District Court
9 400 North Miami Avenue
8th Floor
10 Miami, Florida 33128
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
EXHIBIT B
Filing# 65512511 E-Filed 12/18/2017 12: 17:34 PM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL

CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA
GENERAL CIVIL DIVISION
CASE NO. 2017-026678-CA-0l (13)
ALFONSO "ALFIE" LEON,

Plaintiff,
vs.
JOE CAROLLO; TODD HANNON;

CHRISTINA WHITE; and THE CITY OF
MIAMI CANVASSING BOARD,
Defendants.
- - - - - - - - - - - - - - - ~I
COMMISSIONER CAROLLO'S ANSWER, AFFIRMATIVE

DEFENSES, AND JURISDICTIONAL OBJECTIONS TO
EMERGENCY AMENDED VERIFIED COMPLAINT TO CONTEST
THE RESULTS OF AN ELECTION, WITH INCORPORATED
MEMORANDUM OF LAW
Commissioner Joe Carollo, pursuant to the requirements of
§102.168, Florida Statutes (2016), opposes the election contest submitted
by losing candidate Alfonso "Alfie" Leon. Not only is the contest devoid of
merit, but it is jurisdictionally time barred and initiated by a plaintiff
whose own voting and residency documents reflect that he has lied on
multiple occasions in connection with his actual residency and voting
eligibility .. The court should enter a judgment in favor of the City of Miami
voters who elected Commissioner Carollo as City of Miami District 3
Commissioner with 52.76% of the vote, a margin of 5.5%.
Page 1 of 30
I. INTRODUCTION.
A. City of Miami Run-Off Election on November 21, 2017.
1. On November 21, 2017, City of Miami voters elected Joe Carollo
as City of Miami District 3 Commissioner. According to the official results,
as certified by the City of Miami Canvassing Board on November 27, 2017,
Commissioner Carollo received 52. 76% of the vote, for a margin of 5.5%.
Attachment A is the official Certification of the November 21, 2017 City of
Miami Run-Off Election, signed by the City of Miami Canvassing Board
and Supervisor of Elections Christina White. Because this is an official
public record, it is an admissible document pursuant to §90.803(8), Florida
Statutes (2016), and is properly judicially noticed as authorized by §90.202
and §90.203, Florida Statutes (2016).
B. Declaratory Action Filed Day Before Run-Off Election.
2. The day before that run-off election, plaintiff Leon filed his
Emergency Complaint for Declaratory and Injunctive Relief on November
20, 2017, claiming then-candidate Carollo was ineligible to seek the
Commission District 3 position because he did not meet the residency
qualification period of one year before qualifying to run for office. But the
plaintiff sat on his lawsuit, even though it was styled as an "Emergency''
Page 2 of 30
action, and refused to prosecute it, strategically waiting instead to
ascertain the results of the run-off election before pursuing the residency
claim. In so doing, the plaintiff purposely and deviously, in violation of
clear Florida precedent, attempted to hold his lawsuit in abeyance unless
he did not prevail in the run-off.
3. By the time of plaintiffs November 20, 2017 filing of his
declaratory relief action, absentee ballots had already been distributed and
were being returned to the Supervisor of Elections. Additionally, early
voting had already taken place, resulting in hundreds of ballots having
been cast for the run-off candidates in advance of Election Day.
C. Contest Complaint Filed After Election Certification.
4. Only after being rejected by a substantial majority of the
District 3 voters in the November 21, 2017 run-off, the plaintiff sought to
contest the election results after certification by the Canvassing Board
through the filing of the Emergency Amended Verified Complaint to
Contest the Results of an Election on December 5, 2017. At the time of
filing his Emergency Amended Verified Complaint, the plaintiff did not pay
"the fees prescribed in chapter 28" as required by §102.168(2) of the
election contest statute.
Page 3 of 30
D. Commissioner Carollo Established Residency on

September 22, 2016, in Commission District 3.
5. The contest lawsuit challenges Commissioner Carollo' s
residency in Commission District 3 as a qualification for office, despite the
public records establishing Commissioner Carollo obtained and executed a
Residential Lease for his tenancy at the Brickell Station Lofts apartments
commencing September 22, 2016, a period that is one year before he
qualified to run for Commission District 3. Commissioner Carollo' s
Residential Lease and Cashier's Check deposit were filed with the City of
Miami Clerk at the time of qualifying on September 23, 2017, and are
attached as Attachment B. As publicly filed documents, these documents
are and have been public records available for access and inspection since
September 23, 2017, including by the plaintiff. As documents filed with the
City of Miami, they are properly judicially noticed by the court.
6. The Residential Lease identifies the Brickell Station Lofts at
100 S.W. 10th Street, Miami, Florida 33130.
7. According to official Miami-Dade County public records, the
Brickell Station Lofts apartment building occupies five (5) City of Miami
lots, of which the primary address is 110 S.W. 10th Street, Miami, Florida
33130-4008. The official property Folio is 01-0207-050-1011. Attached as
Page 4 of 30
Attachment C is the official Miami-Dade County Property Appraiser
Summary Report for the Brickell Station Lofts at 110 S.W. 10th Street,
Miami, Florida. This court is authorized to take judicial notice of this
publicly filed and maintained document. As publicly filed records, these
documents are and have been public records available for access and
inspection by the plaintiff.
8. As documented 1n Miami-Dade County Official Records, a
Unity of Title was obtained for the five (5) lots comprising what became the
Brickell Station Lofts. The property addresses for the five lots encompass
100 - 142 S.W. 10th Street, Miami, Florida. Attached as Attachment Dis
the Unity of Title Official Record recorded at Official Records Book
23491/Pages 2835-2837, CFN #20050633852, recorded on June 20, 2005.
This court is authorized to take judicial notice of this official public record.
These documents are and have been public records available for access and
9. In furtherance of the development of the combined property
that became Brickell Station Lofts, a Covenant Running with the Land was
recorded in the Miami-Dade County Official Records for the same five (5)
lots, identifying the primary address as 110 S.W. 10 Street, Miami, Florida
Page 5 of 30
33130. Attachment Eis the Covenant Running with the Land recorded in
the Miami-Dade County Official Records at Book 26574/Pages 3233-2340,
CFN #20090112907, recorded on February 17, 2009. This court is
authorized to take judicial notice of this official public record. As publicly
filed records, these documents are and have been public records available
for access and inspection by the plaintiff.
10. The City of Miami Zoning Details for the Brickell Station Lofts
document the property address as 110 S.W. 10 Street, Miami, Florida.
Attached as Exhibit F is the City of Miami Zoning Details printout for that
property. This court is authorized to take judicial notice of this official
public record. As publicly filed records, these documents are and have been
public records available for access and inspection by the plaintiff.
11. The City of Miami Building Permit for the Brickell Station
Lofts property similarly documents the property portfolio address as 110
S.W. 10 Street, Miami, Florida. Attached as Exhibit G is the City of Miami
Building Certificate for that property. This court is authorized to take
judicial notice of this official public record. As publicly filed records, these
documents are and have been public records available for access and
Page 6 of 30
12. At all time during Commissioner Carollo' s residency at the
Brickell Station Lofts, the primary property address according to Miami-
Dade County Official Records was and is 110 S.W. 10 Street, Miami,
Florida, while the Brickell Station Lofts utilizes the street address of 100
S.W. 10 Street, Miami, Florida as its descriptive address. The two
addresses reference the same property. A Google Search for both property
addresses, attached as Attachment H, results in the same search results
for either address.
E. Plaintiff Failed to Pursue a Challenge to Commissioner

Carollo's Residency In Advance of the General or Run-
Off Elections on November 7 and 21, 2017.
13. The City of Miami General Election, including the election for
Commission District 3, was scheduled on November 7, 2017.
14. Despite Commissioner Carollo having qualified for office on
September 23, 2017, and having filed his Residential Lease with the City
Clerk one year earlier on September 23, 2016, plaintiff failed to pursue a
pre-election challenge to Commissioner Carollo's residency or
qualifications for office.
15. Plaintiff strategically and tactically failed and refused to
initiate a pre-election challenge to Commissioner Carollo' s qualifications
Page 7 of 30
or residency status, despite being aware of Commissioner Carollo having
qualified for office on September 23, 2017. Instead, plaintiff purposely and
intentionally proceeded to the November 7, 2017 General Election, at
which seven candidates vied for Commission District 3.
16. The General Election results for Commission District 3, as
certified by the Canvassing Board, included Commissioner Carollo as the
first place finisher with 30.23% of the vote, while the plaintiff trailed as the
second place finisher with 20.30%. The official General Election results for
Commission District 3 are attached as Attachment I, for which this court
is authorized to take judicial notice.
17. On November 20, 2017, one day before the Run-off Election,
plaintiff filed his Emergency Complaint for Declaratory and Injunctive
Relief in this case number. This court is authorized to take judicial notice
of all records of proceedings in this case number. §90.202(6). Fla. Stat.
(2016). That complaint challenged Commissioner Carollo's qualifications
and residency for Commission District 3, based on Commissioner Carollo' s
Affidavit of Candidate filed with the City Clerk on September 23, 2017,
nearly two months earlier.
18. Plaintiff intentionally failed and refused to pursue this
Page 8 of 30
Case 1:18-cv-24190-RS Document 632-2 Entered on FLSD Docket 02/22/2024 Page 10 of
133
residency claim in advance of the Run-off Election, instead preferring to
compete for that office with the intent of challenging Commissioner
Carollo' s candidacy in the event the plaintiff lost the runoff, as actually
happened.
19. Plaintiff knew, in advance of the November 7, 2017 General
Election, of Commissioner Carollo' s statement of his residency in
Commission District 3 at 100 S.W. 10th Street, Apartment 504, Miami,
Florida 33130.
20. Plaintiff purposely failed and refused to pursue any challenge
to Commissioner Carollo' s residency or qualifications for office until his
filing of the Emergency Amended Verified Complaint to Contest the
Results of an Election on December 5, 201 7.
F. Plaintiff Has a Documented History of Voter Fraud.
21. Plaintiff filed his candidate qualifying documents for City of
Miami Commission District 3 on September 22, 2017. Included as part of
his qualifying package was his Affidavit of Candidate, attached as
Attachment J. This court is authorized to take judicial notice of this official
public record.
22. In his Affidavit of Candidate, plaintiff swears he "resided at the
Page 9 of 30
133
hereinbelow listed addresses for the cited periods of time": "1861 N.W. S.
River Drive #1006, Miami Florida 3125" for the period from "June 2012 -
March 2016." Attachment J, page 1. That same Affidavit identified the
plaintiffs current residence from April 4, 2016 to the present as 2368 S.W.
4th Street, Miami, FL 33135.
23. But contrary to his sworn statement of residency in the City of
Miami from June 2012 through the present, the plaintiff has fraudulently
and illegally voted in Miami-Dade County elections, using an
unincorporated Miami-Dade County address, for the August and
November 2012 and the August 2014 elections. He did not change his Voter
Registration address to the City of Miami until October 23, 2015, according
to the official records of the Miami-Dade County Supervisor of Elections,
attached as Attachment K, for which this court is authorized to take
judicial notice. Attachment L is the plaintiffs voting history in Miami-
Dade County, for which this court is authorized to take judicial notice.
Plaintiffs change in voter registration came nearly three and one-half (3
1/2) years after he claims to have resided in the City of Miami.
24. That same voter registration record (Attachment K) reveals the
plaintiff did not change his voter registration address into Commission
Page 10 of 30
133
District 3 until June 15, 2016, even though he claimed to have moved into
District 3 on April 4, 2016, a delay of more than two (2) months.
25. To the same effect is plaintiffs drivers license address, with
plaintiff not notifying the Florida Department of Highway Safety and
Motor Vehicles of his City of Miami address until January 14, 2013, more
than seven (7) months after the date he swore he lived in the City of Miami.
Attached as Attachment Mis plaintiffs Florida Driver Record, for which
this court is authorized to take judicial notice.
II. THIS COURT LACKS JURISDICTION OVER THE

ELECTION CONTEST.
1. The Complaint is Time Barred.
26. The plaintiffs contest complaint is time barred due to its
untimely filing.
27. Florida's election contest statute, for which strict construction
is required, specifies the allowable process for initiating an election contest
at §102.168(2):
(2) Such contestant shall file a complaint, together with the

fees prescribed in chapter 28, with the clerk of the circuit court
within 10 days after midnight of the date the last board
responsible for certifying the results officially certifies the
results of the election being contested.
28. Plaintiff did not file the required complaint or the filing fees
Page 11 of 30
133
within 10 days of the certification. Instead, he filed his Emergency
Amended Verified Complaint to Contest the Results of an Election on
December 5, 2017. While that filing was within 10 days of the final
certification, it was not the contest complaint required by § 102.168.
Instead, it was an amendment of a declaratory relief complaint originally
filed on November 20, 2017, that was not an election contest complaint.
29. Moreover, the plaintiff did not file the "complaint, together with
the fees prescribed in chapter 28'' at that time. The case docket reflect that
no filing fees were paid "within 10 days" of the final certification.
30. Florida law recognizes that the election contest statute must be
strictly construed in conformity with the actual statutory language. Burns
v. Tondreau, 139 So. 3d 481, 486 (Fla. 3d DCA), rev. dismissed, 153 So. 3d
902 (Fla. 2014).
31. That statutory language does not allow an election contest by
the filing of an amended complaint from an action initiated as a declaratory
relief claim. Nowhere does the statute refer to amending a non-contest
lawsuit to include a contest action.
32. Furthermore, the plaintiffs failure to submit the required filing
fees at the time of the filing of a contest complaint, within 10 days after the
Page 12 of 30
133
certification, renders this entire action fundamentally defective and time
barred.
33. Consequently, this court has no jurisdiction to proceed with this
action. A judgment should be entered in Commissioner Carollo's favor.
2. Plaintiff's Failure to Pursue a Pre-Election Challenge

Precludes this Action.
34. Plaintiff was well aware of Commissioner Carollo' s residency in
advance of the Run-off Election. Indeed, he filed, but did not pursue, a
declaratory relief action the day before the Run-off Election.
35. Plaintiff knew and should have known before the November 7,
201 7 General Election, and at least as early as the time of qualifying on
September 23, 2017, that Commissioner Carollo stated his residence to be
in Commission District 3 as early as September 22, 2016.
36. Plaintiffs delay in bringing this residency challenge until after
the Run-off Election precludes this litigation on the grounds of
untimeliness, estoppel, waiver, and laches.
37. Florida courts have repeatedly warned that "extreme care must
be given to post-election challenges to avoid disenfranchising Florida's
voters." Levey v. Dijols, 990 So. 2d 688, 692 (Fla. 4th DCA 2008). Indeed,
"barring fraud, unfairness, disfranchisement of voters, etc., it is too late to
Page 13 of 30
133
attack the validity of an election after the people have voted." Baker v. State
ex rel. Caldwell, 122 So. 2d 816, 826 (Fla. 2d DCA 1960).
38. McPherson v. Flynn, 397 So. 2d 665 (Fla. 1981), sets out the
rule that losing candidates cannot seek to unseat the winning candidate
based on a qualification deficiency made during the qualification period.
While McPherson involved a different version of the election contest
statute, the Florida Supreme Court stated, at 668:
Since there is no common law right to contest elections, any

statutory grant must necessarily be construed to grant only
such rights as are explicitly set out. The statutory election
contest has been interpreted as referring only to consideration
of the balloting and counting process. The balloting process is
distinct from the legal qualifications of the candidates, and we
can find no authority for extending an election contest to areas
outside the balloting process.
39. The decision in Marina v. Leahy, 578 So. 2d 382 (Fla. 3d DCA
1991), is instructive, because that challenge to a candidate's residency
was made "approximately one and a half months before the election" and
before early voting had begun and the polls had opened.
40. In Winterfield v. Town of Palm Beach, 455 So. 2d 359, 362
(Fla. 1984), the Supreme Court of Florida observed:
In preserving elections in the face of post-election challenges

to pre-election irregularities, this Court has found that a
party is estopped from voiding an election where he was on
Page 14 of 30
133
notice of the irregularity before the election. 'The aggrieved

party cannot await the outcome of the election and then assail
preceding deficiencies which he might have complained of to
the proper authorities before the election.' Pearson v. Taylor,
159 Fla. 775, 776, 32 So. 2d 826, 827 (194 7) (postelection
challenge to sufficiency of petition which lead to election). Id.
at 362.
See also Speigel v. Knight, 224 So. 2d 703, 706 (Fla. 3d DCA 1969).
41. The plaintiffs awareness of Commissioner Carollo's residency
before the election, and his strategic refusal to pursue an available
challenge pre-election, precludes this election contest on the grounds of
untimeliness, laches, waiver, and estoppel. A judgment in Commissioner
Carollo's favor is required.
3. All Doubts About Residency Must Be Resolved In Favor

of the Voters' Decision.
42. Commissioner Carollo established his residency in Commission
District 3 on September 22, 2016. He did so by his intent to establish
residency in District 3 as corroborated by his objective conduct of obtaining
a valid lease effective September 22, 2016, paying for that lease with a
Cashier's Check on September 22, 2016, and moving into the apartment
unit with his wife on September 22, 2016. He soon thereafter changed his
voter registration and drivers license address to his new residence, did not
Page 15 of 30
133
vote in any election thereafter from any different address, and maintained
no other residence. Indeed, his separately owned property in Coconut
Grove was not processed for 2017 homestead exemption purposes
commencing January 1, 2017, because Commissioner Carollo did not live
at that property on January 1, 2017.
43. As the First District stated in Smith v. Crawford, 645 So. 2d
513, 520 (Fla. 1st DCA 1994):
[Any] doubt [as to residency] should be resolved in favor of

holding a free and competitive election. The right to vote is
among the most important rights we all share as Floridians
and as Americans. Judges must be very careful in
determining whether a candidate ... is legally qualified to
run for office because the effect of a mistake could
disenfranchise a large segment of the population.
44. Thus, Florida law requires judges to resolve doubts about
qualifications of any political candidate in favor of the candidate. Id.
45. In Perez v. Marti, 770 So. 2d 176, 178 (Fla. 3d DCA 2000), the
Third District addressed the well-settled principle under Florida election
law that:
The right to vote freely for the candidate of one's choice is of

the essence of democratic society, and any restrictions on that
right strike at the heart of representative government. Id.
(citing Reynolds v. Sims, 377 U.S. 533, 555 (1964)).
Page 16 of 30
133
46. Even if doubts or ambiguities exist as to a candidate's
eligibility, they must be resolved in favor of the people's right to select
their officials. It is the "sovereign n
public officials, so the prevailing rule opposes imposing disqualifications
to run. This is in keeping with principles espoused by the U.S. Supreme
Court of the United States. Florida continues to demand that the right to
hold office is a valuable one that cannot be abridged except for unusual
reason or by plain provision of law. Perez, 770 So. 2d at 176 (quoting
Ervin v. Collins, 85 So. 2d 852, 858 (Fla. 1956)); see also Schurr v.
Sanchez-Gronlier, 937 So. 2d 1166, 1170 (Fla. 3d DCA 2006) ("If two
equally reasonable constructions might be found, this Court in the past
has chosen the one which enhances the elective process by providing
voters with greater choice in exercising their democratic rights.").
47. In Winterfield v. Town of Palm Beach, 455 So. 2d 359 (Fla.
1984), the Supreme Court of Florida observed:
In preserving elections in the face of post-election challenges

to pre-election irregularities, this Court has found that a
party is estopped from voiding an election where he was on
notice of the irregularity before the election. 'The aggrieved
party cannot await the outcome of the election and then assail
preceding deficiencies which he might have complained of to
the proper authorities before the election.' Pearson v. Taylor,
Page 17 of 30
133
159 Fla. 775, 776, 32 So. 2d 826, 827 (194 7) (postelection

challenge to sufficiency of petition which lead to election). Id.
at 362. See also Speigel v. Knight, 224 So. 2d 703, 706 (Fla. 3d
DCA 1969).
III. ANSWER.
A. Jurisdiction and Venue.
48. Paragraph 1 states a legal conclusion for which no answer is
required. To the extent the paragraph alleges facts, Commissioner Carollo
denies the allegations, and affirmatively denies the plaintiff complied with
the requirements of the election contest statute, §102.168(2), Florida
Statutes (2016).
denies the allegations, and affirmatively states injunctive relief is not an
allowable remedy in an election contest brought pursuant to §102.168,
Florida Statutes (2016).
denies the allegations, and affirmatively states the plaintiff has not
brought a valid election contest.
51. Paragraph 4 states legal conclusions for which no answer is
Page 18 of 30
133
denies the allegations, and affirmatively states the plaintiff is and has been
engaged in election and voter fraud by means of voting in elections for
which he is not eligible, according to the information contained in his sworn
Affidavit of Candidate. In this respect, the plaintiffs eligibility to seek the
position of City of Miami Commission District 3 is substantially in
question. Furthermore, according to the plaintiffs Application for
Employment with the City of Miami, submitted to the City in March 2016,
the plaintiff claimed an address of 10760 S.W. 24 Street, Miami, Florida
33176, an address not within the City of Miami. That application is
attached as Attachment N, and is an official City document for which
judicial notice is proper by this court. This application contradicts the
plaintiffs Affidavit of Candidate (Attachment J) that asserts under oath
the plaintiff resided in the City of Miami continuously since June 2012.
admits to his candidacy and being certified the winner of the Commission
District 3 position, and denies the false allegation of his ineligibility and
all other factual allegations.
Page 19 of 30
133
admits Christina White's status as the Supervisor of Elections, and denies
all other factual allegations.
admits the status of Todd Hannon as City of Miami Clerk, and denies all
other allegations.
admits the status of the City of Miami Canvassing Board, and denies all
other allegations.
B. Factual Allegations.
admits only the existence of the City of Miami Charter and the contents of
that Charter in whole.
57. Commissioner Carollo admits the allegations of Paragraph 10.
58. Commissioner Carollo admits the allegations of Paragraph 11
Page 20 of 30
133
only in part, and denies the allegations are complete as to all qualifying
papers filed by Commissioner Carollo.
denies the allegations.
admits only to submitting a Residential Lease, a copy of which is attached
as Attachment A, and denies all other allegations.
denies all allegations and affirmatively asserts the allegations are
knowingly and intentionally false and constitute perjury.
admits only to the official records of the Miami-Dade County Supervisor of
Elections, and denies all other allegations.
Page 21 of 30
133
admits only to the official records of the Miami-Dade County Supervisor of
Elections, and denies all other allegations.
admits only to the official records of the Florida Department of Highway
Safety and Motor Vehicles, and denies all other allegations.
denies all allegations.
admits only to the official records of the City of Miami Canvassing Board,
and denies all other allegations.
admits only to the official records of the City of Miami Canvassing Board
and the Miami-Dade County Supervisor of Elections, and denies all other
allegations.
Page 22 of 30
133
C. Count 1: Contest of Election.
incorporates his answers and responses to each identified paragraph.
admits only to the language of §102.168, Florida Statutes, as codified in
Florida law.
admits only the existence of the City of Miami Charter and the contents of
that Charter in whole, and denies all other allegations.
denies the allegations constitute a complete statement of Florida law
concerning residency.
denies all allegations and affirmatively asserts the allegations are
Page 23 of 30
133
denies the allegations constitute a complete or accurate statement of
Florida law concerning residency. To the contrary, the cited decision in
Paragraph 26 does not hold that the "act of not changing his voter
registration and drivers license information is an essential element to
establishing the lack of legal intent to change his residence from one
address to another."
denies the allegations in full, and affirmatively states the allegations are
Florida or City of Miami law concerning residency, and affirmatively states
the allegations are knowingly and intentionally false and constitute
perJury.
Page 24 of 30
133
Florida law concerning residency, and otherwise denies the allegations in
all respects.
Florida law concerning residency, and otherwise denies the allegations.
denies the allegations, and affirmatively states the allegations are
denies the allegations, and affirmatively states the allegations are
Page 25 of 30
133
denies the allegations.
IV. AFFIRMATIVE DEFENSES.
81. Affirmative Defense 1. The Emergency Amended Verified
Complaint to Contest the Results of an Election fails to state a cause of
action for an election contest.
action for injunctive relief as claimed in Paragraph 2.
Complaint to Contest the Results of an Election is jurisdictionally
untimely.
Complaint to Contest the Results of an Election fails to comply with the
express requirements of §102.168(2), Florida Statutes (2016), and is
therefore barred.
Complaint to Contest the Results of an Election fails to demonstrate
subject matter jurisdiction over this case and the claims asserted.
Page 26 of 30
133
action challenging the determination of candidate qualifications.
Complaint to Contest the Results of an Election is barred by the doctrine
of unclean hands, due to the plaintiffs repeated fraudulent actions in
connection with his voting history.
of laches, as more fully described above.
of estoppel, as more fully described above.
Complaint to Contest the Results of an Election is barred by the plaintiffs
failure to challenge the City of Miami's administrative determination of
qualification for office, and therefore the plaintiff has failed to exhaust
available administrative remedies as a mandatory precondition to judicial
review.
Page 27 of 30
133
Complaint to Contest the Results of an Election is barred by the plaintiffs
failure to timely challenge Commissioner Carollo's qualification for office,
and therefore the plaintiff has failed to exhaust available administrative
remedies as a mandatory precondition to judicial review.
92. Affirmative Defense 12. Commissioner Carollo substantially
complied with the City of Miami Charter provisions governing candidate
qualifications.
complied with the City of Miami Code provisions governing candidate
qualifications.
complied with all legal requirements governing candidate qualifications.
95. Affirmative Defense 15. Plaintiffs claims are barred by the
doctrine of waiver, as more fully described above.
96. Affirmative Defense 16. Plaintiffs claims are barred by the
doctrine of acquiescence, as more fully described above.
97. Commissioner Carollo reserves the right to amend and/or
supplement any and all affirmative defenses during this litigation.
Page 28 of 30
133
V. CONCLUSION.
Commissioner Carollo seeks a judgment in his favor, entry of an
order confirming the vote of the Citizens of Miami who elected him District
3 Commissioner by a 52. 76% majority, and confirmation of the decision of
the Canvassing Board.
Respectfully submitted,
BENEDICT P. KUEHNE
MICHAELT. DAVIS
KUEHNE DAVIS LAW, P.A.
Miami Tower, Suite 3550
100 S.E. 2 St.
Miami, FL 33131-2154
efiling@kuehne@kuehnelaw.com
ben.kuehne@kuehnelaw.com
mdavis@kuehnelaw.com
By: SI Benedict P. Kuehne

BENEDICT P. KUEHNE
Page 29 of 30
133
I certify the foregoing was emailed on December 18, 201 7, to
Juan-Carlos "J.C." Planas Victoria Mendez, City Attorney

KYMP Forrest L. Andrews, Jr., Assist. City
Brickell World Plaza, Suite 1715 Attorney
600 Brickell Ave. George K. Wysong, III, Assist. City
Miami, FL 33131 Attorney
jcplanas@kymplaw.com 444 S.W. 2nd Avenue, Suite 945
Miami, FL 33130-1910
Oren Rosenthal Tel.: (305) 416-1800
Michael B. Valdes Fax: (305) 416-1801
Assistant County Attorneys flandrewsjr@miamigov.com
Attorneys for Christina White GKWysong@miamigov.com
111 N.W. 1st Street, Suite 2810 aidagarcia@miamigov.com
Miami, Florida 33128 pcabrera@miami-police.org
orosent@miamidade.gov vmendez@miamigov.com
mbv@miamidade.gov

BENEDICT P. KUEHNE
Page 30 of 30
133
ATTACHMENT A
133
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Mi.;imi, Florid,! :u l 72
CERTIFICATION
STATE OF FLORIDA)
COUNTY OF rv11AM!-DADE)
I, Christina White, Supervisor of Elections for Miarni-Dade County, Florida, do hereby certify
that the attached is a true and correct copy of the Official Results for the rnunicipal office
listed below in the Miami Run--Off Election conducted on November 21, .2017:
Commissioner - District 3
VVITN ESS MY HAND AND
OFFICIAL SEAL, AT MIAMI,
MIAMI-DADE COUNTY, FLORIDA,
ON THIS 27th DAY OF NOVEMBER, .2017
Enclosure
Attachment A, page 1
133
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VOTER WRNOlJT • TOTAL 11.67
MIAM!: COMMISSIONER · nISTRlCT 3

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MlN-H: CQt-!HlS::,IONER • DIST!UCT 3

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~HAMI. FLORIDA
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f':IN-lJ, flJ)RIOA
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HlAMf. FH1!UDA
RUN DATE:ll/27/17 02:29 P!1 REPORT ·EL30A PAGE 567i'.J.Cl1
[;i}7D PREC~NC"f 567 .0
TOTAL VOTES ;;: rn 05S rn IVQ VBM EV OSS EV IVO PROV
FEGlSTERHl VOTERS TOTAL 2,BO
HALLGfS CA.ST , HJrAL 3M 140 i} 172 72 0 0
VOTER TURNOUT T TGTJ.\l HUJ:3
Ml!\Ml>: C(»tM! $SI ONER ., D! STRlCT 3

VQte for l
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f!REC REPCf<T fl<HUP DETAtL }1llit-H RI.JN-OfT {-:u:cnw C,fTICits.L RESULTS
N(J~'EHOER l1. 201/
Ml N-H , clORWA
RUN DATE: 11/27/17 02 •29 P~~'. R£PDKT·EL1GA PN>E E-7GG·tl1
S:?~}0 P~E.CINCT ~3"10, D
TG"i}\L VOT}:$ ,,1/ ED OSS ED iVD VBM EV OSS EV IVO PROV
REGISTERED VOTER'S • rmt-,L l,949
PJ~LLiJfS CAST ., TOTAL., 324 141 D 136 47 () D
VOTf.R TUR1'i@T • 10l"M. K62
MiNH: COMMISSWNER DlS"1RlU '.l

Vute for .1
Jo<:< Ci.lral1o. 141 43.52 5$ D FJ l.6 (l D
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rm::c ,{fJ'{Jr!. GfWUi' nnAI i.. !-HAMI RiJN-01-l HfCrlGN OFFICIAL RESULTS
NOVEm~rn 21, 20.17
N!AMI, fLORWA
HUN DATE: 11 /?.7 /1 i' ()2:; ?.9 i'H REPORT· El.30/s. PAGE 58.l!HH
fX{ll} PRECINCT 581~ 0
nxrM. vore; J~ ED OSS fD IVO \/8M EV OS$ EV iVO PROV
REGI5Trn.rn VOTE~;;?. 10TH. 1.sm
8ALLOTS CAST • TOTAL. 331 111 i} 183 3? ;) "
).-·
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RfC REP,)U GROUP onAlL
~1 MlNH flJJN·OFF ELECT10N GFFIClAL RESUl TS
NOVf}l8rR 21 . 201;;
mN-H, FLORIDA
RUN D/\Tf::1li21/17 {12:29 PM REPORT·EL30A PAGE 593\i-Ol
5930 PRECINCT 593.0 ,.
TOTAL VOTES ,4 r:n oss F.D IVO \/8M tV OSS E\/ IVO PRO\/
RfGISTFRED V{HFRS · TGTt\t 2,571
BALLOTS CAST· TOTAl.. :n2 97 {} 177 JS 0 0
V{HtR TURNOUT · TOTAl 12,14
Ml.PJ~l: (OMM!SSJONER • DISTRICT 3

Vote ft;r J
Joi? Ccrol lo. u:n
,,.,., ~i9;03 56 {} 1D3 2.4 0 0
A1 fOrt~{J .,;A1 fif1··· Leor1~ J.< . .i' 4Q 91 41 0 n 14 0 (}
I,)ta1 310 97 n 175 3.8 D 0
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rm:c REPORT (,R(l{!P Df.TAH. MU\Ml :lllN-rn·T El!::CTIDN OFT!f.IAL R[f;u1.·1s
NGVrnBrn 21 . ?.ll1 l
M!AMl . FLORIDA
Ri.,!N DME :Jl/27117 G?.:29 FM i<.EPOiH ·H.30A PAGE 5-960-01
5960 PRtC!NCT 596.Q

TOTAL VOTES .% FO OSS ED PIO Vfll1 EV GSS FV IVO PROV
RFGlSfff{!j) vmrHS • HHAl 2,4N
8AtLOTS CAST • TOTAL. 3~0 1.39 0 179 22 0 a
V01l\'l. TU!lJ{O:._iT • TOTAL 13.77
MlAHI: crn1mssrnM-:R · D!STR.!CT J

Vote for l
~ksP. Carr;11tL 147 43,35 ~"
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mrc REPf;RT-GROUF f.iFTAiL Mltt,Mf RUN-OFF E!JCrrnN CWFJUAL RESULTS
NOVEMBER 21 . 2017
M!AML rlORIUA
HUN D.AJE: H!?."l ! 17 C2: 29 FM REPORT-EL3DA PAGE 9910-iH
'}970 PRECINCT 997 .0
F..HJ\L VOTE"$ .%: rn oss ED lVO VBM EV OS'S EV JVO PROV
RfGlSlERf.D VOTERS • TOTAL 441
BALLOTS CAST · TDTAL~ 61 23 (} 36 2 (l C
\/QTf.R HJRNLm • l"Gl'AL 13Jl3
MiN·H: COMNlSSIONER • DlSTRlCT 3

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Joe C<lt·u·i ftt 31 Sfl.&2 12 ti 19 (l 0 C
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ATTACHMENT B
0066298 11-24 133 CHECK
CASHIER'S SERiAL #; 6629902844
Office AU# 1210(8t
Remitter.· JOE CAROLLO

ACCOUNT#:
Purcha,sr.- JOE CAROLLO
Purcha,ser A~ccunt
Operator LO.: u488194 u33~·!7J
Funding Soun:e: Paper ltems{sl September 22, 2016
PAYTOTHEORDEROF *'/;'*MOR REAL "ESTATE, LLC***
***Seven thousand dollars and no cents*** **$7,000.00**

Payee Address:
Memo: RENTAL
1/010 IF DI/ER US S 7,000.00
WELLS FARGO BANK, N.A. NOTiCE TO PJRGHASE!HF Tl-':~; ,M-9TRU!1F.NT IS LOST,
1699 CORAL WAY c,~r.
STC-LEN OR llE,: fRC"f::U_ Y'.)U ,,lt.Y Rl:C'.t c,_;: CELLATION
MIAMI, FL 33145 AND REISSU1\NCE. AS A CONDl,ION TO CA~CELLATlO11 ANO NON~NEGOTIABLE
FOR INQUIRIES CALL (~00) 394-3122 P.EISSUANCE, WELLS FARGO & COM"ANY MA'f iMPOSE A
FE:: AND R::::QUIRE AN IMDEM,IlY AGREEl,!ENT ANO BOND.
Purcht1i::ilfH Copy
F8004 11o1,~s 12096343
-- ··- --- ---- --··-··--
~&i-ialli§:i3,Jj.ja~m~r;!+j,jdliY\iJ#l;tilt•IM,jpfj~(,-{ljji:ffitlTTfiMli;;i~E,1;1l1t•j~1ji.3~,ig1rnau#filr;i¥,Eit-i:@,j$
. : .. .. . . •
-- 006629S: • .11·24 ·•
,12J0(8;_
CASH~EIFCS CHECK .6629802844
Offic~AU # - -
Ramiiier: JOE CA~OLLO •

Operator I.D.: u488194- u38J'17J
***Seven thousand dollars and no cents'"** **$7 lOOO.OO**

Payee Address:
Memo: RENTAL
WELLS FARGO BANK, N.A. vo;o :-= OVER us $ 1,000.00 .

1699CORALWAY
MIAMI, FL33145
FOR INQUIRIES CALL 14!!0) 394-3122
µ_J;(~
CONTROLLER
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Attachment B, page 1
133
RESIDENTIAi.. LEASE AGREEMENT SUMMARY OF TERMS
EFFECTIVE DA TE: This Lease is effective as of September 22 2016_ (the "Effective Date").
APARTMENT COMMUNITY: The Brickell Station Lofts located at 100 SW 10 Street, Miami, FL 33130 (the
"Community").
PREMISES: The leased unit in the Community is Apartment Number _ ___,5~0~4_ _ (the "Premises").
LANDLORD: MDR REAL ESTATE, LLC ("Landlord") whose address is 1200 Brickell Avenue, PH 2010, Miami,
Florida 3 313 1.
PROPERTY MANAGER: MDR REAL ESTATE, LLC, ("Manager") whose address is 1200 Brickell Avenue, PH 2010,
Miami, Florida 33131. For emergencies, please dial 911; otherwise, ifthe emergency is not life threatening, please call 800-
377~0031.
TENANTS: The following persons are the tenants and are hereinafter collectively referred to as "Resident(s)":
Name Date of Birth Social Security Number
Joe Carollo 3/12/1955
Any change in tenants must be communicated to management immediately.
The following person(s) are permitted occupants of the Premises: Marjorie Teresa Carollo (the
"Occupant"}.
LEASE TERM: Beginning Date of this Lease: -~9~/=22~_ _ _ _20 I 6_ ("Move-In Date")
Ending Date of this ~ease: 11/30 2017_ ("Move-Out Date")
The time between the Move-In Date and the Move-Out Date, inclusive, shall be referred to as the "Term".
PARKING/ STORAGE: The Resident is assigned the following parking spaces and storage space:
Number Monthly Cost
Parking Space Number 19 Included in the Rent
Parking Space Number $ _ _ _ _ _ _ __
Parking Space Number $_ _ _ _ _ _ _ _ _

Storage Unit Number $_____________
Brickell Station Lofts, I00 SW 10th Street, Miami, FL 33130

4874113-5
133and as set forth below, all additional parking spaces are paid
One (I) parking space is included in the Rent (as defined below),
for on a monthly basis. All vehicles must be registered with the Manager. As set forth in this Lease, Landlord makes no
guarantees regarding the availability of parking in the Community or the safety of persons or property.
RENT: The total monthly rent for the Premises is:$ 2,300.00 (the "Rent"), which Rent is comprised of the following:
Base Rent: $,,_2,=3-., __00=..,,__00"--_ _ paid on a monthly basis

Storage: $ paid on a monthly basis
Parking: $ paid on a monthly basis
Total Monthly Rent: $2,300.00
ALL RENT PAYMENTS SHALL BE MADE OUT TO "MDR REAL ESTATE, LLC" AND FORWARDED TO
1200 BRICKELL AVENUE, PH 2010, MIAMI, FLORIDA 33131.
PET FEE: A non-refundable pet fee in the amount of $500.00 shall be paid by the Resident for the privilege of having a pet
in the Premises (the "Pet Fee"). Only non-aggressive dogs and cats are permitted. There is a two (2) pet maximum and each
pet cannot exceed a weight of thirty pounds (30 lbs.).
SECURITY DEPOSIT: The security deposit for the Premises is$ 4 600.00 (the "Security Deposit"}.
ACCESS CONTROL FEES/DEPOSITS:
CONTROL HOW MANY KEYS/CARDS/REMOTE DEPOSIT REPLACEMENT COST

NUMBER ISSUED CONTROLS TORE-KEY OR
REPLACE
2 Apartment Keys $25.00 per key $175.00
1 Mail Box Keys $25.00 per key $75.00
44231/44233 2 Magnetic Access Key $25. 00 per key $100.00
1 Parking Remote $25 .00 per remote $100.00
TOTAL PAYMENT ON THE EFFECTIVE DATE: Resident shall pay Landlord the following as of the Effective Date:
$ -0- First Month's Rent, prorated if necessary; $ 4,600.00 Security Deposit;
$,_ _ _ _ _ _ _ _ _ Pet Fee, if necessary.
LATE FEE: Failure to pay Rent as set forth in Paragraph 4 of the Tease shall result in a late fee of$ l00.00 pefi3~cc>11Uif-l°lrrepemnc"l'e~.- - - - - - - - - c
ARMED SERVICES: By initialing as follows, Resident acknowledges that Resident is NOT currently a member of the
United States Anned Forces _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __, _ _ _ _ __
PREPARATION OF THE LEASE: This Lease was prepared by: --"'M,..,a,.,.n...,·a,_,E-C""er...,v..,,an""t""es,,___ _ _ _ _ _ _ _ _ __

See the Non-Lawyer Disclosure form attached to this Lease as Schedule 1.
Brickell Station Lofts, 100 SW 10 th Street, Miami, FL 33130
Page 2
4874113-5
133
RESIDENTIAL LEASE AGREE1\1ENT
This Residential Lease Agreement (this "Lease") is made and entered into as of the Effective Date, by
and between Landlord and Resident. All Residents are jointly and severalJy liable for complying with the terms
and conditions of this Lease, including the payments of monies owed to Landlord.
1. DEMISE. In exchange for valuable consideration including, without limitation, the promise by
Resident to pay Landlord the Rent (as set forth on the first page of this Lease), and the performance by Resident
of a!J other terms, conditions and covenants contained in this Lease as well as schedules attached to this Lease (all
such schedules and the summary of terms are incorporated herein by reference and made a part of this Lease),
Landlord agrees to lease to Resident and Resident agrees to lease from Landlord the Premises.
2. TERM. The Term of this Lease shall be for the period set forth on the first page of this Lease. In
the event that the Premises is not available to Resident for occupancy on the Move-In Date due to any reason,
including construction delays or the failure of a prior resident to timely vacate the Premises, Landlord shall not be
liable to Resident for any damages arising from same, and this Lease shall remain in full force and effect.
However, Resident shall not be responsible for paying Rent to Landlord on a prorated basis for those days during
the first calendar month of occupancy that the Premises was not available for occupancy by Resident. Upon the
failure of Landlord to deliver possession of the Premises to Resident within fourteen (14) days after written
demand by Resident (written demand shall not include the execution of this Lease), Resident may declare this
Lease null and void and of no force or effect from its inception and Landlord shall refund to Resident any Security
Deposit and/or other amounts paid Landlord by Resident in conjunction with this Lease only.
3. RENT. Resident agrees to pay to Landlord in advance on the Effective Date of this Lease and
thereafter on the first day of each and every consecutive calendar month thereafter, by personal check, money
order or cashier's check, the monthly Rent as set forth on page one of this Lease. Prior to the Move-In Date,
Resident shall pay to Landlord the Rent (prorated if necessary), the Security Deposit, the Access Control Deposit,
and the non~refundable Pet Fee (if applicable). It is agreed that at no time shall cash be accepted by Manager or
Landlord for payment of the Rent. For purposes of this Lease, it shall be irrefutably presumed that Resident has
not paid the Rent unless Resident can produce a canceled check or money order purporting to prove the Rent was
paid to Landlord. If this Lease commences on a date other than the first day of the month, Resident shall be
responsible for paying Landlord a prorated amount of the Rent based upon the actual number of days in the first
month of the tenancy that Resident occupied the Premises. This amount shall be payable in advance to Landlord.
All late fees and returned or dishonored check fees referred to in Paragraph 4 of this Lease shall be deemed as
Additional Rent for the purposes of this Lease. Landlord may proceed with an action for possession and breach of
contract at the expiration of the three day notice. If Resident will be absent from the Premises for
ourteen ays, esr ent must notify Landlord in writing. For purposes of this Lease, the term "Additional
Rent" means all money owed to Landlord accruing as a result of this Lease, excluding Rent. Resident shall pay
the Additional Rent in the same manner as Rent, and failure to timely pay any Additional Rent shall enable
Landlord to declare a default and breach of this Lease in the same manner as if Rent was not paid.
4. LATE PAYMENT AND RETURNED CHECKS AND CHARGES:
A. Rent is due on the first day of each month and Rent is late if not received by 5:00 pm on
the 51h calendar day of the month. If Rent is late, then Resident shall pay a late fee equal to One Hundred Dollars
and no/100 ($ 100.00). Late fees will be due even if Rent remains unpaid and Landlord proceeds with an eviction
•
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Brickell Station Lofts, 100 SW 10 th Street, Miami, FL 33130 ~ I i
Page3
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4874113-5 1-:-;, N-
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133
B. Seventy-Five Dollars and no/100 ($75.00) will be due for each dishonored check. Late
fees will also be applied if Rent is paid with a dishonored check.
C. Landlord reserves the right to require all payments received after the date Rent is due by
money order, cashier's check or certified check.
D. Resident agrees that any check dishonored by the bank shall be redeemed from Landlord
by Resident in full, including all charges as aforesaid, by cashier's check, money order or certified check within
twenty-four (24) hours of delivery of written demand by Landlord. Any dishonored check which is returned
and/or redeemed after the date Rent is due under this Lease shall be deemed delinquent and such Rent shall be
subject to the late fee and penalties set forth herein. 1n addition, Resident shall pay to Landlord any and all costs
incurred by Landlord in the collection of any dishonored check. Returned checks shall not be re- deposited.
E. In the event one (1) check is dishonored, Resident agrees to pay all future Rent and other
charges by cashier's check, certified check, or money order. Landlord shall not accept personal checks from
Resident thereafter.
F. All such charges set forth in the preceding sections of this Paragraph 4 shall be deemed
Additional Rent for purposes of this Lease and Landlord shall be required to give Resident statutory three day
notice and not a seven day notice for payment of same. It is agreed and understood that Landlord is under no
obligation to accept payment of Rent and/or Additional Rent after expiration of the statutory three-day notice
period for nonpayment of Rent.
5. SECURITY DEPOSIT. Resident agrees to pay to Landlord the Security Deposit on or before the
Effective Date as set forth in the first page of this Lease. The Security Deposit will be returned to Resident within
thirty (30) days after the Premises is -vacated provided the following tenns and conditions are satisfied:
A. Complete vacation of the entire Premises by Resident and Occupant on or before the Move-Out
Date together with Resident providing to Landlord a list of damages and defects to the Premises.
B. Payment by Resident of all Rent required under this Lease, up to and including the date of
expiration or termination of the Term of this Lease.
C. Thorough cleaning of the Premises, including, but not limited to, all kitchen appliances
(refrigerator, oven, range, dishwasher), baths, carpet, tile, walls, closets/storage areas, balconies, etc., so as to be
in the same condition as same were in on the Move-In Date, normal wear and tear excepted.
D. An absence of defect in or damage to the Premises, whether caused by Resident, Occupant, their
Pets, or otherwise, unless included on the written list of damages and defects as set forth in this Lease.
E. Observance and performance by Resident of aH of the other covenants and obligations of
Resident under this Lease, from the date of commencement of this Lease up to and includin the date of
• • • • is ease, or up to and including the final day of this Lease.
F. Observance and performance by Resident of all Rules and Regulations (as defined in Paragraph
20) pertaining to the occupancy and use of the Premises and Community by Resident, Occupant and their agents,
guests and invitees, including the Rules and Regulations regarding Pets.
G. Provision by Resident to Landlord in writing of Resident's forwarding address. The Security
Deposit may be applied by Landlord to satisfy all or part of Resident's obligations hereunder and such application
shall not prevent Landlord from claiming damages in excess of the Security Deposit. Jt is hereby expressly
understood that no part of the Security Deposit is to be construed as a prepayment of Rent by Resident.
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Brickell Station Lofts, 100 SW 10 Street, Miami, FL 33130 ~ . -
Page4
4874113-5 0·1 f'\_JI
;/ -.J
133
Notice to Resident Pursuant To Section 83.49(2), Florida Statutes:
l, Landlord has deposited the Security Deposit in a non-interest bearing account at the
following Florida banking institution: Chase Bank, 1450 Brickell Avenue, Suite 150, Miami, Florida 3313 l.
2. Resident is NOT entitled to interest on the Security Deposit.
3. Disclosure:
YOUR LEASE REQUIRES PAYMENT OF CERTAIN DEPOSITS. LANDLORD MAY TRANSFER

ADVANCE RENTS TO THE LANDLORD'S ACCOUNT AS THEY ARE DUE AND WITHOUT NOTICE.
WHEN YOU MOVE OUT, YOU MUST GIVE THE LANDLORD YOUR NEW ADDRESS SO THAT THE
LANDLORD CAN SEND YOU NOTICES REGARDING YOUR SECURITY DEPOSIT. LANDLORD MUST
MAIL YOU NOTICE, WITHIN 30 DAYS AFTER YOU MOVE OUT, OF LANDLORD'S INTENT TO
IMPOSE A CLAIM AGAINST THE SECURITY DEPOSIT. IF YOU DO NOT REPLY TO LANDLORD
STATING YOUR OBJECTION TO THE CLAIM WITHIN 15 DAYS AFTER RECEIPT OF LANDLORD'S
NOTICE, LANDLORD WILL COLLECT THE CLAIM AND MUST MAIL YOU THE REMAINING
DEPOSIT, IF ANY.
IF LANDLORD FAILS TO TIMELY MAIL YOU NOTICE, LANDLORD MUST RETURN THE SECURITY
DEPOSIT BUT MAY LATER FILE A LAWSUIT AGAINST YOU FOR DAMAGES. IF YOU FAIL TO
TIMELY OBJECT TO A CLAIM, LANDLORD MAY COLLECT FROM THE SECURITY DEPOSIT, BUT
YOU MAY LATER FILE A LAWSUIT CLAIMING A REFUND.
YOU SHOULD ATTE:r-.1PT TO INFORMALLY RESOLVE ANY DISPUTE BEFORE FILING A LAWSUIT.
GENERALLY, THE PARTY IN WHOSE FAVOR A JUDGMENT IS RENDERED WILL BE AWARDED
COSTS AND ATTORNEY FEES PAY ABLE BY THE LOSING PARTY.
TH1S DISCLOSURE IS BASIC. PLEASE REFER TO PART II OF CHAPTER 83, FLORIDA STATUTES, TO
DETERMINE YOUR LEGAL RIGHTS AND OBLIGATIONS.
By executing this Lease, Resident hereby acknowledges receiving the foregoing notice as required by
Section 83.49(2), Florida Statutes. Furthennore, Resident hereby acknowledges that Resident has been made
aware of and has received a copy of Section 83.49(3), Florida Statutes, by way of the following:
"" ':.:'.: Section 83.49(3), Florida Statutes

(¾.I lu
,n rJ .. (a) Upon the vacating of the premises for termination of the lease, if the landlord
- 0- t:~idoes not intend to impose a claim on the security deposit, the landlord shall have
u... :~. 'J.:I 5 days to return the security deposit together with interest if otherwise required,
("'J :i;):3ir the landlord shall have 30 days to give the tenant written notice by certified
C'.J ':-~ ;::.mail to the tenant's last known mailing address of his or her intention to impose a
W-
~ .:.Jelaim on the deposit and the reason for imposing the claim. The notice shall
i-- :~~ contain a statement in substantially the following form:
This is a notice of my intentioq to impose a claim for damages in the amount of

upon your security deposit, due to _ _ _ _ _ . It is sent to you as required by
s. 83.49(3 ), Florida Statutes. You are hereby notified that you must object in
writing to this deduction from your security deposit within 15 days from the time
Page 5
48741ll-5
you receive this notice or I will be 133
authorized to deduct my claim from your
security deposit. Your objection must be sent to (landlord's address).
If the landlord fails to give the required notice within the 30-day period, he or she
forfeits the right to impose a claim upon the security deposit and my not seek a
setoff against the deposit but may file an action for damages after return of the
deposit.
(b) Unless the tenant objects to the imposition of the landlord's claim or the
amount thereof within 15 days after receipt of the landlord's notice of intention to
impose a claim, the landlord may then deduct the amount of his or her claim and
shall remit the balance of the deposit to the tenant within 30 days after the date of
the notice of intention to impose a claim for damages. The failure of the tenant to
make a timely objection does not waive any rights of the tenant to seek darnage&_.7
in a separate.action. ...,,
(c) If either party institutes an action in a court of competent jurisdiction ti( 01
:
adjudicate the party's right to the security deposit, the prevailing party is entitleif,:,
to receive his or her court costs plus a reasonable fee for his or her attorney. Thf.~ l i
court shall advance the cause on the calendar.

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(d) Compliance with this section by an individual or business entity authorize£·, <:·?
to conduct business in this state, including Florida-licensed real estate brokers ~~ r<>
and sales associates, constitutes compliance with all other relevant Florida ~ -J
Statutes pertaining to security deposits held pursuant to a rental agreement or
other landlord-tenant relationship. Enforcement personnel shall look solely to this
section to determine compliance. This section prevails over any conflicting
provisions in chapter 4 75 and in other sections of the Florida Statutes, and shall
operate to permit licensed real estate brokers to disburse security deposits and
deposit money without having to comply with the notice and settlement
procedures contained ins. 475.25(1)(d).
6. FAIL URE TO COMPLY, Resident agrees that Resident shall be responsible to Landlord for the Rent
accruing hereafter even if Resident fails to occupy the Premises. Resident further acknowledges that Resident
consents to the application of the Security Deposit by Landlord in the event that Resident does not occupy the
Premises, to cover Landlord's costs in preparing the Premises for rental and re-renting the Premises together with
any and all damages for unpaid Rent accruing from the Move-In Date through the date that Landlord is able to
relet the Premises, provided, however, that re-letting is on terms equal to or more favorable to Landlord than the
terms and conditions set forth in this Lease. •
7. CONDITION OF THE PREMISES UPON MOVE-IN. Resident agrees that prior to Resident taking
possession of the Premises, Resident shall make an initial walk through of the Premises with an agent of Landlord
and at such time Resident and Landlord shall so note on the move-in report attached to this Lease as Schedule 2
(the "Move-In Report") any and all problems or deficiencies in the Premises that need to be identified and that
Landlord shall be reasonably required to repair. Resident agrees that other than those items set forth on the Move-
[n Report, Resident shall accept the Premises in its "AS IS WHERE AS" condition. Reasonable repairs for
purposes of this Paragraph shall be those repairs that are required in order to render the Premises habitable, as
required by Florida law. Landlord shall make all such repairs, if required, with reasonable promptness after the
execution of this Lease. In the event that the Move-In Report is not completed on the Effective Date but
completed on or prior to the Move-In Date, Resident agrees that such Move-In Report shall be attached as
Schedule 2 and shall be deemed a part of this Lease.
Brickell Station Lofts, 100 SW I oui Street, Miami, FL 33130
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4874113-5
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8. EXPIRATION OF THE LEASE I HOLDOVER. This Lease shall expire on the Move-Out Date, and if
Resident fails to vacate the Premises by the Move-Out Date, then Resident understands, acknowledges and agrees
that Resident shall be deemed a hold-over tenant. In such event, this Lease will be extended on a month-to-month
basis upon the same terms and conditions as contained in this Lease, except that the Rent payable hereunder shall
be one hundred twenty-five percent (125%) of the monthly Rent. Either party may terminate a month-to-month
tenancy by giving the other party written notice of tennination no later than fifteen ( I 5) days prior to the end of
the monthly rental period. Failure of Resident to give notice to vacate the Premises as a month-to-month Resident
as required under this Lease or the Florida Statutes will result in Resident being charged an amount equal to an
additional one month's Rent which shall not be considered a penalty but shall be considered liquidated damages.
Ail month-to-month fees under this Lease shall be considered Additional Rent. Landlord shall have the right
during the last sixty (60) days of the Term and during any month-to-month tenancy to enter the Premises without
notice at all reasonable times in order to show the Premises to prospective residents. If Landlord is showing the
Community to a prospective buyer or lender, Landlord shall have the right at any time during the Term and during
any month-to-month tenancy to enter the Premises without notice at all reasonable times in order to show the
Premises.
9. SUBLET/ASSIGNMENT. Resident may not sublet the Premises or assign this Lease without the prior
written consent of Landlord, which consent may be withheld for any reason. In the event Landlord allows
subletting or an assignment of Resident1s rights and interest hereunder, Resident shall nevertheless remain liable
to Landlord for all tenns, conditions and covenants of this Lease, including, but not limited to, the payment of
Rent and the observation of the Rules and Regulations. Landlord may assign this Lease without the prior written
consent of Resident. This Lease is binding on the successors and (pennitted) assigns of both Landlord and
Resident.
10. UTILITIES. Landlord shall furnish, as part of this Lease, basic cable, Internet service, garbage remov~l
and water only (the "Utilities"). If the cost to Landlord of providing any of such Utilities increases for any reason
during the term of this Lease, Resident shall pay as Additional Rent its share of such increase allocable to the
Premises commencing thirty (30) days after delivery to Resident by Landlord of written notice for same. Under
no circumstances shall Landlord be responsible to Resident for any interruption in furnishing such Utilities, and
Resident, Occupant and their guests, agents and invitees shall use such Utilities in a reasonable manner and in
compliance with all laws, rules and regulations. Resident is responsible for changing the electrical service into
Resident's name prior to the Move-In Date. If such is not completed, Resident authorizes Landlord to deduct any
utility charges paid on Resident's behalf from the Security Deposit, which shall be promptly reimbursed by
Resident.
Landlord may modify the method by which any utilities, including the Utilities, are furnished to the
Premises and/or billed to Resident during the Term of this Lease, including, but not limited to, submetering of the
Premises for certain utility services or billing Resident for utilities reviousl included within the
even an or c ooses to so mo I utility service to the Premises, Landlord shall give Resident not less than
thirty (30) days prior written notice of such modification. Nothing contained herein shall be deemed a waiver of
any rights of Resident arising under law based upon the wrongful failure of Landlord to furnish utility services as
required herein.
I 1. PROPERTY LOSS. Landlord shall not be liable for any damages or losses to person or property caused
by persons other than caused directly by the gross negligence or willful misconduct of Landlord. Landlord shall
not be liable for personal injury or damage or loss to Resident's personal property (furniture, jewelry, clothing,
etc.) from theft, vandalism, fire, water, rain storms, smoke, explosions, sonic booms, or other causes whatsoever,
whether caused by negligent acts of Landlord, Manager or their agents or otherwise. Landlord strongly
recomQWnd~that Resident secures insurance to protect Resident and Resident1s property. Landlord's property
insura~1, if{~~• does NOT cover risk of loss to any of Resident 1s property. Also, if any of Landlord's employees
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or agents, including Manager, are requested to render any services such as moving automobiles, handling of
furniture, cleaning, delivering packages, or any other service not required of Landlord under this Lease, such
person or entity shall be deemed as an agent of Resident only regardless of whether or not payment is made by
Resident for such service. Resident agrees to hold harmless and indemnify and defend Landlord from any and all
liability arising in any way whatsoever from the rendering of such service.
12. RIGHT TO ACCESS. Landlord shall have the right to enter the Premises for inspection, maintenance and
pest control with twelve (12) hours notice to tenant and between the hours of 7:3 0 AM and 8:00 PM. In case of an
emergency, Landlord may enter the Premises at any time to protect life and prevent damage to property.
13. USE/OCCUPANCY. The Premises shall be used for residential purposes only and shall be occupied only
by Resident and Occupant. By executing this Lease, Resident understands, acknowledges and agrees that
Resident shall be responsible for Occupant's breach or violation of this Lease or the Rules and Regulations.
Resident agrees not to permit any person not listed on this Lease to occupy the Premises for more than fourteen
(14) days and nights during the Term of this Lease. Resident agrees to abide by all municipal and state laws and
ordinances so as not to create a nuisance and not to conduct or initiate activities which would increase the rate of
insurance on the Premises. Resident shall be responsible for the conduct of Resident, any and all Occupants of the
Premises, as well as Resident's agents, invitees and guests. In its sole discretion, Landlord may request any guest
or invitee of Resident to leave the Community (as set forth on the first page of this Lease) if Landlord believes, in
its sole opinion, that the guest or invitee is creating a nuisance. Any prior resident or occupant that leaves the
Community while still owing money to Landlord or who has been evicted from the Premises is not permitted to
return to the Community. Any such person shall be considered unauthorized and any Resident that permits the
presence of such person shall be in material violation of this Lease.
14. INDEMNIFICATION. Resident agrees to reimburse Landlord promptly for the cost to Landlord for
property damage to the Premises and the Community, including, without limitation, the cost of repairs or service
(including repairs or service to the plumbing) caused by the negligence, misconduct, intentional acts and improper
use of Resident, Occupant and their invitees, guests and agents. Resident shall be responsible for any such
damage resulting from windows or doors left open. Payment of all amounts due Landlord under this provision or
this Lease is due and payable within five (5) days of delivery of written notice to Resident. All amounts due
hereunder are deemed Additional Rent.
15. MAINTENANCE. Resident agrees to make maintenance checks at proper intervals on the Premises,
including checking the smoke alanns in the Premises, and immediately report any and all defects in writing to
Landlord. In the event hot water, heating, air conditioning, plumbing or other equipment shall need repair, and
Resident does not notify Landlord in writing of the needed repair or for any reason that is beyond the control of
Landlord, and any such utilities require reduction or cut off, Landlord shall not be liable for any damage arising
out of Landlord's failure to furnish such services. Resident shall maintain the Premises includin the fixture
, ean an sam ary con 1tlon. es, ent shall not, without the prior written consent of Landlord, which
may be withheld for any or no reason whatsoever, alter, remodel or otherwise change the appearance and/or
structure of the Premises or the Community.
16. EARLY LEASE TERMINATION BY UNITED STATES ARMED FORCES MEMBERS. In the event
Resident is a member of the United States Armed Forces and chooses to terminate this Lease in accordance with
Section 83 .682, Florida Statute, Resident must provide no less than thirty (30) days written notice of Resident's
intent to fijm~illte this Lease. Furthermore, such notice must be accompanied by a copy of Resident's military
tr¥}sfer ~J!§ler~~or a letter from Resident's superior officer. Full compliance with the notice requirements of
Se2lfon 8J~682,;-FJorida Statute, is required.
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Brickell Station Lofts, 100 SW 10th Street, Miami, FL 33130
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4874113-5
133
17. DEFAULT BY RESIDENT. If Resident fails to pay Rent or Additional Rents when due, or if Resident
fails to reimburse or indemnify Landlord for damages, repairs or plumbing service costs when due under this
Lease, or if Resident, Occupant or their guests, agents or invitees materially or repeatedly violates this Lease, the
Rules and Regulations or applicable state and local laws, or if Resident abandons or surrenders the Premises prior
to the termination date of this Lease, without fully exercising the cancellation provision contained in Paragraphs 5
and 16, then Resident shall be considered in default of this Lease and where applicable Landlord may terminate
Resident's right of occupancy by giving Resident notice in writing. Notice may be by mail, posting or personal
delivery to the Premises. Such termination does not release Resident from any obligation· or liability for the Rent
owed for the Term of this Lease. If any amounts due Landlord are delinquent, Landlord shall not be obligated to
continue utilities, which are furnished and paid for by Landlord. In the event that Resident defaults under the
terms of this Lease as provided in this Paragraph, Resident shall be responsible to Landlord for damages for
unpaid rent, late charges, concession received, attorney's fees, and/or fee paid to any collection agency, costs and
other special and general damages appertaining thereto. Resident will be responsible for Rent and late fees due to
Landlord until the Premises is relet. Resident will also be responsible for any difference in Rent charged to new
resident and for paying any concession offered to the new resident. Landlord, its successors and assigns, are
hereby given the right to recover such damages from Resident by use of any appropriate legal means. These
charges are in addition to all other amounts accruing under this Lease, including, without limitation, non-sufficient
fund (NSF) check charges, utility charges and/or charges for the cost of repair and cleaning of the Premises for
wear and tear, damages above normal wear and tear, attorney's fees and costs, and collection expenses and costs.
18. PETS. Resident may only keep cats and dogs (the "Pet") in the Premises. There is a two (2) Pet
maximum and each Pet cannot exceed a weight of thirty pounds (30 lbs.). Aggressive breeds are not allowed in
the Community. Visiting pets are not permitted under any circumstances. Residents must pick up after their
respective Pets. Pets are not allowed in the common areas of the Community, and Pets must always be on a leash
or carried by Resident. If a pet is brought in during the lease term, the tenant must notify management and pay the
non-refundable fee of$ 500.00.
19. RIGHT TO POSSESSION. Whenever under the terms hereof Landlord is entitled to possession of the
Premises, Resident will immediately surrender the Premises to Landlord in as good condition as at the
commencement of this Lease, normal wear and tear excepted.
20. RULES AND REGULATIONS. It is agreed and understood by Resident that Landlord may, in its sole
discretion, hereafter, reasonably amend, or alter, the rules and regulations of the Community, attached to this
Lease as Schedule 3 (the "Rules and Regulations"), without the prior consent of Resident, and that Resident
agrees to be bound· thereby after receiving written notice of such amendments. All subsequent amendments to the
Rules and Regulations shall be deemed incorporated in this Lease by reference immediately upon the delivery of
same to Resident or the posting of same in the common areas of the Community. Resident, Occupant and their
agents, guests and invitees shall comply with the Rules and Re ulations now or hereaft
an or . es1 en agrees to a 1 e y all federal, state, and local laws and ordinances and agrees not to engage in
any activity in or about the Community, including common areas, of an illegal nature, purpose or intent. Resident
further agrees that Resident, Occupant and their agents, guests and invitees shall not be loud, boisterous,
disorderly, nor shall they individually or collectively in any way whatsoever disturb the rights, comforts and
conveniences of Landlord, its agents, representatives and/or employees nor of other residents, guest(s) or
invitee(s) at the Community. Resident shall neither interfere with Landlord or the Manager in the perfonnance of
their duties, nor shall Resident make any threats to any agent, employee or personnel of the Manager or Landlord.
Violation of this provision shall be considered a material breach of this Lease entitling Landlord to terminate
Resident's right of occupancy immediately.
21. RADON GAS. Landlord provides the following notification as required by Section 404.056(5), Florida
Statutes:
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8? :f" fJd C'., d"JBrickell Station Lofts, 100 SW 10 Street, Miami, FL 33130
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4874.113-5
Attachment B, page 1O
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RADON GAS: Radon is a naturally occurring radioactive gas that, when it has
accumulated in a building in sufficient quantities, may present health risks to
persons who are exposed to it over time. Levels of radon that exceed federal and
state guidelines have been found in buildings in Florida. Additional information
regarding radon and radon testing may be obtained from your county heaJth
department.
22. MOLD AND MILDEW. Resident acknowledges that the Premises is located in Florida, which has a
climate conducive to the growth of mold and mildew, and that it is necessary to provide proper ventilation and
dehumidification of the Premises to retard or prevent the growth of mold and mildew. Resident agrees to be
responsible for properly running the.air conditioning, ventilating and dehumidifying the Premises and the contents
to retard and prevent mold and mildew. Landlord shall not be responsible for damage to the Premises or the
personal property contained therein for damages caused by mold and mildew.
23. PARKING. All parking spaces are assigned, and all vehicles must be registered with the Manager.
Resident, Occupant, and their agents, guests and invitees must observe all parking regulations as posted or
indicated by Landlord and/or local authorities. Parking of vehicles in other than designated parking areas is
prohibited. No boats, trailers, large trucks (defined as having more than (4) wheels), buses, limousines or
commercial vehicles will be permitted on the parking lots, driveways or garages without the prior written
permission of Landlord or Manager. Motorcycles, motor scooters and bicycles must be parked in areas designated
for parking these devices. Parking and/or driving on grass or the placement of any type vehicle, motorcycle or
motor scooter inside the Premises is strictly prohibited. Resident will not affix any type of vehicle, motorcycle,
motor scooter or bicycle to light or signposts or stairwells any place in the Community. The repair, washing
and/or testing of motor vehicles and/or their engines anywhere in the Community is strictly prohibited. Resident
agrees to remove his/her vehicles from the parking areas or garage promptly upon the expiration or termination of
this Lease. The parking areas are for use only by properly registered, functioning and authorized motor vehicles.
To the extent Resident's vehicle is not properly registered and/or licensed, or generally appears to be in an
inoperable condition (including, but not limited to, vehicles with flat or missing tires), Landlord will provide
written notice to Resident of such violations. To the extent the violations are not corrected within forty-eight (48)
hours of receipt of written notice, Resident hereby appoints Landlord as their agent to have the vehicle towed
from the Community. However, non-compliance with all other Rules and Regulations respecting parking shall
entitle Landlord to have the vehicle towed immediately, without notice, at owner's risk and expense. In addition, if
the vehicle is parked in a manner which is dangerous, unlawful or which otherwise constitutes a nuisance or
inconvenience, Landlord may immediately cause such vehicle to be towed, without notice, at owner's risk and
expense.
Resident hereby irrevocably appoints Landlord as his/her attorney-in-fact to remove any vehicle arked in
o is ease an o s ore e ve 1c e at t e cost and expense of Resident, in such place or places as
Landlord, in its sole discretion, may deem proper, or to dispose of the vehicle in the manner provided by
applicable law. If Landlord uses the services of a private tow operator to relocate Resident's vehicle from the
Community, Resident agrees to pay the fee associated with such relocation within seven (7) days of the
presentation of a bill. Failure of Resident to pay such bill to Landlord shall constitute a material breach of this
Lease. To the extent a private towing company is requested to ensure compliance with this Lease or the Rules and
Regulations, Resident acknowledges that the towing company is an independent contractor engaged in a non-
hazardous occupation, and, therefore, Landlord has no liability resulting from the acts or omissions of the towing
company. Resident agrees to indemnify and hold harmless from claims and all costs and expenses incurred,
including, but not limited to, attorney's fees and costs resulting from the towing of motor vehicles belonging to
Resident, Occupant or their invitees, agents or guests where such motor vehicles are parked in violation of this
Lease.
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.r- Lld r? '"'JI'.' E~i;kell Station Lofts, 100 SW 10 Street, Miami. FL 33130
87v .. ~ !('L' Wwd..1~l1Ul
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Landlord reserves the right to make rules for the use of all parking spaces; to pface .limitations upon use of
parking spaces at any time after the beginning of the Term of this Lease; to institute a reasonable charge for such
use at any time after the beginning of the term; and to niake changes in the rules and charges from time to time.
Resident understands that if Landlord provides garage accommodations or assigns reserved parking spaces, such
garage accommodations or reserved parking spaces are optional facilities and may not be included in the Rent.
No representation is made that sufficient garage or parking space is available for all Residents, or that the present
number of parking spaces will always be available. Landlord may modify the method by which parking is
furnished at the Community or billed to Resident during the Term of this Lease. Landlord may choose also to
incorporate assigned parking areas or eliminate any areas currently assigned. In the event Landlord chooses to so
modify parking on the Community, Landlord shall give Resident not less than thirty (30) days prior written notice
of such modification.
24. NO SECURITY SERVICES. Landlord shall not provide nor does Landlord have any duty to provide for
Resident, security services for the protection of Resident, Occupant, and their guests, invitees, and agents or the
property of any of the foregoing persons. Resident hereby acknowledges that Resident understands the foregoing,
and Resident shall look solely to the law enforcement agencies of the county or municipality in which the
Community is located for protection. It is agreed and understood that Landlord shall not be liable to Resident for
any damages, injuries or wrongs sustained by others, or property of same from criminal or wrongful acts of
Landlord, its representatives, agents, employees, or any other persons or entities that may cause harm to Resident
resulting from a tortious, criminal or wrongful act by same. In the event that Landlord elects to hire a security
service to patrol or monitor the Community, it is understood and agreed that such services are provided
exclusively for the protection of Landlord's property and in no way whatsoever shall it be intended or construed as
a waiver by Landlord of the foregoing, 'nor in any way whatsoever shall it be construed as creating a duty of
Landlord to protect Resident, Occupant and their guests, invitees, and agents or the property of any of the
foregoing persons.
25. ATTORNEY'S FEES. In the event legal action is instituted to enforce this Lease, the prevailing party
shall be responsible for the non-prevailing party's attorney's fees, in addition to court and other costs, including,
without limitation, fees and costs incurred in conjunction with any proceeding before any appellate tribunal. In
the event Landlord employs the services of a collection agency or attorney to collect any money owed Landlord
by Resident, Resident shall be responsible to reimburse Landlord upon demand for all costs and fees, whether or
not contingent, incurred by Landlord, in addition to all other amounts owed.
26. MORTGAGEE'S RIGHTS. Resident's rights under this Lease shall at all times be automatically
subordinate and junior to any existing or future mortgage, deed, trust or other lien applicable to the Premises or its
contents, which is now or shall hereafter be placed on the real property comprising the Community. If requested,
Resident shall execute promptly any document that Landlord may request to verify this subordination agreement.
y no rce require y t 1s ease s a e m wntmg an s a e paste , an e rvere

and/or mailed by registered or certified mail to both Landlord and Manager at their respective addresses set forth
in the first page of this Lease and to Resident at the Premises.
28. WAIYER. Failure of Landlord to insist upon strict or timely compliance by Resident with any term of
this Lease shall not amount to nor be construed as nor otherwise constitute a waiver by Landlord of Landlord's
right thereafter to insist upon strict and timely compliance by Resident of any and al! terms and conditions of this
Lease, including, without limitation, any term that may not have been enforced strictly by Landlord previously.
Acceptance by Landlord of Rent after knowledge of any breach of this Lease by Resident shall not be a waiver of
Landlord's right nor construed as an election by Landlord not to enforce the provisions of this Lease pursuant to
such a breach. Landlord's failure or delay in demanding damage reimbursement, late payment charges, returned
check charges, or other sums due Landlord, shall not be a waiver of Landlord's right to insist on payment thereof.
X~31Jr~::T
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Landlord may demand same at any time, including move-out or thereafter. Resident hereby waives Resident's
right to demand a jury trial in any cause of action arising between Landlord and Resident concerning this Lease.
29. ENTIRE AGREEMENT. This Lease and the schedules attached to this Lease constitute the entire
agreement between the parties and no oral statements shall be binding. Resident hereby acknowledges and agrees
that at no time during the course of discussions. and/or negotiation leading up to and including the time of
execution of this Lease did any representative, agent, or employee or Manager or Landlord make any
representations, engage in any discussions of this Lease, or otherwise communicate with Resident, anything that
in any way whatsoever contradicts any written term or condition of this Lease, nor did any representative, agent,
or employee or Manager or Landlord make any statements or communications or representations of any nature
whatsoever that supplement or in any way whatsoever amend or add any terms or provisions to this Lease as
written. This Lease comprises all terms, conditions and agreements of the parties with respect to the subject
matter hereof, superseding all· prior arrangements or agreements, and except as provided in the Rules and
Regulations may not be altered or amended except in writing and signed by authorized representatives of each
party to this Lease. This Lease shall not be construed more strongly against any party hereto regardless of who
was more responsible for its preparation. Resident acknowledges that it has had an opportunity to consult legal
counsel before executing this Lease. This Lease shall be construed by and enforced with, and the validity and
performance hereof shall be governed by, the laws of the State of Florida. Venue for any proceeding shall be in
Miami-Dade County, Florida.
30. SEVERABILITY. If any term of this Lease is found to be contrary to the laws of the State ofFiorida, or
it is found that any term is void or voidable, then such term shall not apply and this Lease shall be construed as if
such term were not present, and there shall be no effect on the remainder of this Lease as a result of the removal of
such term, provided that the general intent of this Lease is not changed.
31. DAMAGE OR DESTRUCTION OF PREMISES. In the event of damage or destruction to the Premises
by fire, water, or other hazard, including as a result of a natural or man-made disaster or in the event of
malfunction of equipment or utilities, Resident shall immediately notify Landlord. If the damages are such that
occupancy of the Premises as a whole can be continued, Landlord shall make repairs as needed with reasonable
promptness and Rent shall not abate during the period of such repairs. If only part of the Premises is rendered
unusable by the damage or destruction, Resident may vacate only that portion of the Premises rendered unusable
and Resident's Rent shall be reduced by the proportionate value of the unusable portion of the Premises during the
period of partial vacancy, provided the damage or destruction was not caused by Resident, Occupant, or their
guests, agents or invitees but in all other respects the terms and provisions of this Lease shall continue in full force
and effect. In either event, if the damages resulted from the wrongful or negligent acts of Resident, Landlord may
pursue all of its remedies against Resident provided under Florida law. If, in Landlord's sole and absolute
opinion, the Premises are so damaged or destroyed other than by the wrongful or negligent acts of Resident,
Occupant, or their guests, agents or invitees so as to substantially impair Resident's enjoyment of the Premises,
this Lease may be tenninated by either Landlord or Resident in which event Resident shall vacate the Premises
within seven (7) days of receiving notice by the other party. In the event the Premises is damaged or destroyed so
as to substantially impair Resident's enjoyment of the Premises due to wrongful or negligent acts of Resident,
Occupant, or their guests, agents or invitees, Landlord may, in addition to Landlord's other remedies under Florida
law, terminate this Lease by providing Resident with a seven (7) day notice to vacate, in which event Resident
shall vacate the Premises within seven (7) days of receipt of the notice. Notwithstanding the foregoing, in the
event of a casualty resulting in damage or destruction to the Premises, Landlord shall have the unilateral right to
declare that this Lease is not terminated and require Resident to accept a comparable premises in the Community
for the remaining term of this Lease, in which event all of the terms and provisions of this Lease shall continue in
full force and effect in relation to such comparable premises, and Resident shall immediately vacate the Premises
and take possession of such comparable premises.
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Page 12
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32. RESIDENT INFORMATION. If Resident has supplied infonnation to Manager by means of a rental
application or similar instrument, Resident covenants that Resident knowingly and voluntarily gave all such
information, and if such information proves to be false or misleading, Resident shall have committed a material
breach of this Lease that Resident shall not be pennitted to cure.
33. CRIME-FREE HOUSING CLAUSE
a. Resident, any member of Resident's household, or a guest or other person under

Resident's control, shall not engage in or facilitate criminal activity on or near the Community, including, but not
limited to, violent activity or drug-related _criminal activity.
b. Resident or any member of Resident's household shall not permit the Premises to be used
for, or facilitate, criminal activity, including, but not limited to, violent criminal activity or drug related criminal
activity.
c. "Violent criminal activity" means any felonious criminal activity that has one of its
elements the use, attempted use or threatened use of physical force against the person or property of another.
d. "Drug related criminal activity" means the illegal manufacture, sales, distribution, or
use, or possession with intent to manufacture, sell, distribute or use, of a controlled substance (as defined in
Section 102 of the Controlled Substances Act or any other Federal or Florida law governing controlled
substances).
e. Resident, Occupant, and their guests, agents or invitees shall not engage in any illegal
activity including prostitution, criminal street gang activity, threats or intimidation, assault, including, but not
limited to the unlawful possession or discharge of firearms or illegal weapons on or near the Community, or any
other violation of the criminal statutes of the Federal government or the State of Florida or any breach of this
Lease that otherwise jeopardizes the health, safety and welfare of Landlord, Manager, their agents, other residents,
or guests or that which involves imminent or actual serious property damage.
f. Resident represents that neither Resident nor any Occupant has ever been convicted of
any felony or misdemeanor, including sexual misconduct or controlled substance, and that to the best of
Resident's knowledge, neither Resident nor any Occupant is the subject of a criminal investigation or arrest
warrant. Resident hereby further represents that neither Resident nor any Occupant has any criminal charges of a
sexual nature pending adjudication as of the Effective Date. Resident agrees that Landlord may terminate this
Lease if it ever comes to the attention of Landlord that Resident, Occupant, or their guests, agents or invitees have
been convicted of any sexual criminal activity or placed on probation with adjudication withheld at any time.
Resident authorizes Landlord to perfonn a criminal background investigation of Resident or any Occupant.
g. One or more violations of this Paragraph constitute a substantial violation of this Lease
and a material noncompliance with this Lease for which Resident shall not be given the o ortuni to cure. An
• • • r ermma 10n o tenancy an eviction from the Premises.
h. Proof of violation shall be by a preponderance of evidence, unless otherwise provided by
law.
i. In case of any conflict between the provisions of this clause and any other provisions of
this Lease, the provisions of this clause shall govern.
34. CORPORATIONS, COI'v1PANIES OR PARTNERSHIPS. If Resident is a corporation, company or a

partnership, the person signing this Lease on behalf of such entity hereby warrants that he has full authority from
such entity hereunder and such person and entity shall be jointly and severally liable for compliance with this
Lease, including the payment of all Rent and any and all other amounts that may be due and owing to Landlord
under the terms of this Lease, including attorney's fees and costs.
8?,,, ~r- !£ I 0z ,...,,.,, 1,... Brickell Station Lofts, 100 SW 10th Street, Miami, FL 33130
•v lie c, c;.:1~ uul
Page 13
4874113-5
35. 133have no power or authority to permit construction,
NO CONSTRUCTION LIENS. Resident shaB
mechanics, material men's or other liens to be placed upon the Premises or the Community for any reason,
including in connection with maintenance, alterations, modifications or otherwise. The interest of Landlord shall
not be subject to liens for improvements made by Resident. Landlord shall not be liable for any work, labor or
materials furnished to the Premises by or through Resident or anyone claiming through Resident. No construction
liens or other liens for any such work, labor or materials shall attach or affect the interest of Landlord in and to the
Premises or Community. Landlord intends to record a notice as set forth in Section 713.10, Florida Statutes. This
Lease itself shall not be recorded in the public records.
36. AMENITIES. Resident agrees that Resident is renting only the Premises. Rent includes Resident's use
of any amenities in the Community, such as the pool, pool deck, gym and all other common areas (collectively,
the "Recreational Facilities"). The Recreational Facilities may be used only by Resident, Occupant, and their
guests and invitees. Landlord may from time to time issue new or amended Rules and Regulations to govern the
use of such amenities. Such Rules and Regulations may call for the payment of fees, either on a seasonal,
monthly or annual basis, for membership. Fees for use by Resident' guests of the Recreational Facilities may be
charged. The use of any Recreational Facility may be allowed or revoked in Landlord's sole and absolute
discretion. A Recreational Facility may be removed from service by Landlord on a permanent or part-time basis
without compensating Resident and Resident may not withhold Rent or terminate this Lease based on such action.
Landlord makes,and specifically disclaims, representations or warranties of any kind, whether expressed or
implied, regarding the Community, including the Recreational Facilities, or the use thereof. Specifically, no .
representations or warranties are made regarding ·the fitness of any of the Recreational Facilities for a particular
purpose.
37. RELEASE. Resident assumes full responsibility and risk for any injury or damage which Resident,
Occupant and their guests, invitees and agent might cause or sustain which is related in any way to their
occupancy of the Premises or the use or existence of the Community, including the use and enjoyment of the
Recreational Facilities. Such assumption of responsibility shall include, but not be limited to, any injury or
damage caused, either in whole or in part, by the negligence or fault of Landlord, the Manager and/or their
respective successors, heirs, assigns, agents, directors, officers, members, partners, employees, stockholders,
representatives, attorneys and all persons acting by, through, under or in concert with them, or any of them
(collectively, the "Affiliated Persons"). Resident agrees to hold Landlord, Manager and all Affiliated Persons,
harmless from any and all claims. related to the loss of or damage to all personal property and Resident assumes
full responsibility and risk for the loss or theft thereof.
By executing this Lease, Resident hereby releases and forever discharges Landlord, Manager and all
Affiliated Persons of and from any and all claims, demands, controversies, rights, damages, costs, expenses,
attorneys' fees, actions and/or causes of action of any kind and nature whatsoever, at law or in equity, know or
unknown, fixed or contingent (collectively, the "Claims"), which Resident now has or may hereafter have a ainst
1 ia e ersons y reasons o any matter, cause or thing whatsoever, whether
directly or indirectly related to the occupancy of the Premises and the use or existence of the Recreational
Facilities or otherwise and whether caused in whole or in part by the sole, concurrent or contributing fault or
negligence of Landlord, Manager or any Affiliated Persons. By releasing and forever discharging any Claims,
Resident may have, as above provide, Resident expressly waives any rights Resident has under the law to recover
damages for any Claim against Landlord, Manager or Affiliated Persons. Resident further agrees to indemnify
and hold Landlord, Manager and all Affiliated Persons harmless from and against any and all Claims and damages
of every kind and nature whatsoever, for injury to or death of any person or persons and for damage to or loss of
properly, including theft, which either Landlord, Manager or Affiliated Persons may incur, arising out of or
attributed, directly or indirectly, to Resident's breach of this Lease, the use of any Recreational Facilities or
occupancy of the Premises by Resident, Occupant or their guests, invitees. or agents, or otherwise, including,
th
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Station Lofts, 100 SW 10 Street, Miami, FL 33130
Page 14
4874113-5
133 of whether such injury, loss, claim, damage, cost or
without limitation, attorney's fees and court costs, regardless
expense was caused by the sole, concurrent or contributing negligence or fault of Landlord, Manager or Affiliated
Persons.
38. WAIVER OF JURY TRIAL. LANDLORD AND RESIDENT HEREBY EXPRESSLY COVENANT
AND AGREE TO WANE THE RIGHT TO TRIAL BY JURY IN CONNECTION WITH ANY LITIGATION
OR JUDICIAL PROCEEDING RELATING TO, DIRECTLY OR INDIRECTLY, OR CONCERNING THIS
LEASE OR THE CONDUCT, OMISSION, ACTION, OBLIGATION, DUTY, RIGHT, BENEFIT, PRNILEGE
OR LIABILITY OF A PARTY UNDER THIS LEASE TO THE FULL EXTENT PERMITTED BY LAW. THIS
WAIVER OF RIGHT TO TRIAL BY JURY IS SEPARATELY GIVEN _AND IS KNOWINGLY,
INTENTIONALLY AND VOLUNTARILY MADE BY LANDLORD AND RESIDENT. LANDLORD AND
RESIDENT HA VE HAD AN OPPORTUNITY TO SEEK LEGAL COUNSEL CONCERNING THIS WANER.
THIS WAIVER IS INTENDED TO AND DOES ENCOMPASS EACH INSTANCE AND EACH ISSUE AS TO
WHICH THE RIGHT TO A JURY TRIAL WOULD OTHERWISE ACCRUE. LANDLORD AND RESIDENT
FURTHER CERTfFY AND REPRESENT TO EACH OTHER THAT NO PARTY, REPRESENTATIVE OR
AGENT OF LANDLORD AND RESIDENT (INCLUDING, BUT NOT L~UTED TO, THEIR RESPECTNE
COUNSEL) HAS REPRESENTED, EXPRESSLY OR OTHERWISE TO LANDLORD AND RESIDENT OR
TO ANY AGENT OR REPRESENTATIVE OF LANDLORD AND RESIDENT (INCLUDING, BUT NOT
LIMITED TO, THEIR RESPECTNE COUNSEL) THAT THEY WILL NOT SEEK TO ENFORCE THIS
WANER OF RIGHT TO JURY TRIAL. THIS PROVISION IS A MATERIAL INDUCEMENT OF ALL
PARTIES ENTERING INTO THIS LEASE. THIS WANER SHALL APPLY TO THIS LEASE AND ANY
FUTURE AMENDMENTS, SUPPLEMENTS OR MODIFICATIONS OF THIS LEASE. THIS PROVISION
SHALL SURVIVE ANY TERMINATION OR CANCELLATION OF THIS LEASE.
39. TIME OF THE ESSENCE. Time is of the essence with respect to all time or notice deadlines set forth in
this Lease; however, this provision shall not affect the rights of any defauiting party hereunder to cure such
default within the time periods (if any) explicitly set forth herein, if and as so permitted pursuant to the terms of
this Lease.
40. OFAC. Executive Order 13224 requires all United_ States entities and persons to block assets and not
transact business with entities, countries and persons (specifically designated nationals) set forth by the Office of
Foreign Asset Control ("OFAC"). This requirement applies to Landlord. Accordingly, Landlord will check
current OFAC lists and other publications_ in connection with this Lease. In order to check the OF AC list,
Resident and Occupant must provide to Landlord a government issued identification card (this might include a
driver's license, birth certificate, passport or resident alien card). To the extent Resident or Occupant (or any
single person or entity constituting a part of Resident or Occupant) matches a name or entity on any such OF AC
list or publication, this Lease will be immediately suspended, and Resident and/or Occupant shall be reported as
. instructed by the OFAC.
[ADDITIONAL TEXT AND SIGNATURES APPEAR ON THE FOLLOWING P~~] ~

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Page 15
4874113-5
133 UPON SURRENDER OR ABANDONMENT~ AS
BY SIGNING THIS LEASE, RESIDENT AGREES THAT
DEFINED BY CHAPTER 83, FLORIDA STATUTES, LANDLORD SHALL NOT BE LIABLE OR
RESPONSIBLE FOR STORAGE OR DISPOSITION OF RESIDENT'S PERSONAL PROPERTY.
IN WITNESS ¥/HEREOF, the parties have executed these the day and year first above written. The
signature of Resident(s) indicates they have read the entire Lease.
WITNESSES: RESIDENT: ~
Signature: ~ ~
Print Name: _ _ _ _ _ _ _ __ Print: J$e_!if;(<--0 LC O
Date: / ,;il,
I
Print Name: _ _ _ _ _ _ _ __ I"--~

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WITNESSES: RESIDENT: --. p.,)

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Print Name: _ _ _ _ _ _ _ __ Print: _ _ _ _ _ _ _ _ _ _ _ _: . _,",_--:___
:
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Date:_ _ _ _ _ _ _ _~----·-.,.,..... r~
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Print Name: _ _ _ _ _ _ _ __
WITNESSES: RESIDENT:
Signature:_ _ _ _ _ _ _ _ _ _ _ __
Print Name: Print: _ _ _ _ _ _ _ _ _ _ _ _ __
---------
Date:·----------~---
Print Name: _ _ _ _ _ _ _ __
WITNESSES: RESIDENT·
Signature: _ _ _ _ _ _ _ _ _ _ __
Print Name: _ _ _ _ _ _ _ __ Print: _ _ _ _ _ _ _ _ _ _ _ _ __
Date: _ _ _ _ _ _ _ _ _ _ _ _ __
Print Name:
---------
[ADDITIONAL SIGNATURES APPEAR ON THE FOLLOWING PAGE]
Brickell Station Lofts, I 00 SW 10th Street, Miami, FL 33130
Page 16
4874113-5
133
WITNESSES: LANDLORD'S AGENT:
By: _ __!...:.::::::~~:::::::--=:.._::~.::::::::::::::=:!:::::!~
Print Name: _ _ _ _ _ _ _ __ Name:_ _ _= = c = - : = . . . c = = ' - - - - - - ' -
Title: _ _ _-=M=a=na=g=e~r_ _ _ _ _ __
Date:_ _ _-<9.:. . :/2=2"--'/l'-='6_ _ _ _ _ _ __
Pri.nt Name:. _ _ _ _ _ _ _ __
G, ~
•""'-(; G.:;:J
C
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LIST OF SCHEDULES ATTACHED TO THIS LEASE :::, ~-' -•~'J
-·,-_.
!
,-•, N
Schedule 1: Disclosure from Non-Lawyer \,.::)
Schedule 2: Move-In Report

Schedule 3: Rules and Regulations
Schedule 4: Carbon Monoxide Warning
Schedule 5: Mold and Mildew Disclosure
Schedule 6: Control Access Disclosure
Schedule 7: Apartment Security Disclosure
Brickell Station Lofts, 100 SW 10th Street, Miami, FL 33130
Page 17
4874113-5
133
ATTACHMENT C
12/7/2017 Property Search Application - Miami-Dade County
133
OFFICE OF THE PROPER

Summary Report
Generated On : 12/7/2017
Property Information
Folio: 01-0207-050-1011
110 SW 10 ST
Property Address:
Miami, FL 33130-4008
Owner MOR REAL ESTATE LLC

1200 BRICKELL AVE STE PH2010
Mailing Address
MIAMI, FL 33131 USA
PA Primary Zone 6402 MIX USE-BORDERS CBD
0303 MULTIFAMILY 10 UNITS PLUS
Primary Land Use
: MULTIFAMILY 3 OR MORE UNITS
Beds/ Baths I Half 136 / 126 / 63
Floors 12
Living Units 63
Actual Area 159,708 Sq.Ft
Living Area 159,708 Sq.Ft
Adjusted Area 145,704 Sq.Ft
Lot Size 29,866 Sq.Ft Taxable Value Information
Year Built 2009 2017 2016 2015
County
Assessment Information
Exemption Value $0 $0 $0
Year 2017 2016 2015 Taxable Value $13,200,000 $12,000,000 $12,248,500
Land Value $8,959,800 $8,950,000 $6,460,020 School Board
Building Value $5,040,200 $3,050,000 $5,983,500 Exemption Value $0 $0 $0
XF Value $0 $0 $0 Taxable Value $14,000,000 $12,000,000 $12,443,520
- .,....,.__,-~
Market Value $14,000,000 $12,000,000 $12,443,520 City J
Assessed Value $13,200,000 $12,000,000 $12,248,500 Exemption Value $0 $0 $0

Taxable Value $13,200,000 $12,000,000 $12,248,500
Benefits Information
Regional
Benefit Type 2017 2016 2015
Exemption Value $0 $0 $0
Non-Homestead Cap Assessment Reduction $800,000 $195,020
Taxable Value $12,000,000
$13,200,000 $12,248,500
Note: Not all benefits are applicable to all Taxable Values (i.e. County, School
Board, City, Regional), Sales Information
OR
Short Legal Description Previous
Price Book- Qualification Description
Sale
CITY OF MIAMI SOUTH PB B-41 Page
LOTS 2 & 3 LESS EXT AREA OF
27956-
CURVE IN NE COR FOR R/W & LOTS 01/09/2012 $17,000,000 Oual by exam of deed
1534
4 THRU 6 LESS SS0FT
LOT SIZE 29866 SQ FT 26984- Not exposed to open-market; atypical
08/17/2009 $10,240,000
2782 motivation
21539-
08/01/2003 $3,300,000 Deeds that include more than one parcel
3364
09743- Sales which are disqualified as a result
07/01/1977 $50,000
0592 of examination of the deed
_The Office of the Property Appraiser is continually editing and upc;fating the tax roll. This website may not reflect the most current information on record. The Property Appraiser
and Miami-Dade County assumes no liability, see full disclaimer and User Agreement at http://www.miamidade.gov/info/disclaimer.asp
Verslon:
Attachment C, page 1
133
. Tv;,~
.Q034 llOSW 10:ST p°""' Pf
42005:
42
1125W lli'ST
Hl:2 SW 1-1:l ST ,._.
Alt-Mme
,._.
PF
NP
Hl'li38l lOO SW 10 ST
'"""'
Attachment C, page 2
133
ATTACHMENT D
Case 1:18-cv-24190-RS Document
12/11/20,17
632-2 Entered on FLSD Docket 02/22/2024 Page 75 of
Miami-Dade Official Records - Print Document
133
I_
cm 2005R063Jss2 OR BKIIIJJU1HJ!! l!f3l5ll!IIJVJlf~~tlJ\II Hlf 111I

RECORDED 06/20/2005 11:04:08
HARVEY JWIJlth CLERK OF COURT , tlI AMI -OAOE COUNTY, FLORIDA
UNITY OF TITLE
WHEREAS, the undersigned is the owner of that property described~:
EXHIBIT"A''
also known as 100-142 SW 10 Street, Miami-Dade County. Florida, and
The undersigned recognizes and acknowledges that for the public health, welfare, safety
or morals, the herein-describe4. propeny should not be divided into separate parcels
owned by several owners so long as the same is put to the hereinafter use, and
In consideration of the issuance of a pemrlt for a 63 unit condominium building and for
other good and valuable consideratiQns, the undersigned hereby agrees to restrict the use
of the subject property in the following manner:
1. That said property shall be considered as one plot and parcel ofland and that
no portion of said plot and parcel and land shall be sold, transferred, devised
or assigned separately, except in its entirety as one plot or parcel of land.
2. The undersigned further agrees that thi$ condition, restriction and limitation
shall be deemed a covenant running with the land and shall . remain in full
force and effect and be binding upon the µndersigned, their heirs, successors,
personal representatives arid assigns and upon all mortgagees or lessees until
such time as the same may be released in writing by the Director of the City of
Miami Building and Zonin,g Depa,tment or the executive officer of the
successor of such Department, or in _the absence of such director or executive
officer, by his assistant in charge ofthe office in his absence.
Provided, however, that a release wm be executed when the premises are made to
conform with applicable zoning regulations or t:he µse or structure is removed from the
premises and there is no further reason to maintain the Unity of Title on the public
records.
Signed, sealed, executed and acknowledged on this 16th day of June, 2005.
IN WI1NESS WHEREOF~ ROYAL EXPLORER DEVELOPMENT~ LLC has caused

these prese[!ts to be signed in its name by its proper officials.
ROYAL EXPLORER DEVELOPMENT, LLC

a Florida Limited Lia\>ility Company
By: Y. ewJ _
Patricio ~
Book23491 /Page2835 CFN#20050633852 Page 1 of 3
Attachment D, page 1
https://www2.miami-<ladeclerk.com/OfficialRecords/PrintDocument.aspx?QS=YaoUfOzxry3Rz9CvspSsSMOrKSOGQXN%2bWT0%2bKOm8Wtn%2bSi... 1/3
12/11/2017
133
State of Florida
Cowity of Miami-Dade
I hereby certify that on this day. before me, a Notary Public duly authorized in the state
and county named above to talce acknowledgments, personally appeared Patricio
Cervantc,,s described as Manager of ROYAL EXPLORER DEVELOPMENT. LLC, a
Florida Limited Liability Company who executed the foregoing instrument, and
acknowledged before me that such person executed the said instrument in the name of the
company and that the foregoing instrument is the act of the company.
Witness my hand and official seal in the county and state limned above this 16th day of
June,2005.
vJL:......'J#.
Notary Public
My commission expires:
,,••~l''', William M. Lapsley
g~~~~ Commission #D01630!1
~;,:. "f!i.E Expires: Dec 12, 2006
~-.ff· .~$' Bonded Tbru
,,,,:r,,,,,, Adant~Boni3ills Co., Inc.
Book23491/Page2836 C FN#20050633852 Page 2 of 3

htlps://www2.miami-dadecrerk.com/OfficialRecords/PrintDocument.aspx?QS=YaoUfOzxry3Rz9CvspSsSM0rKSOGQXN%2bWT0%2bKOm8Wtn%2bSJ... 2/3
Miami-Dade Official Records • Print Document
133
BOOK 23491 PAGE 28~7

LAST PAGE
EXHIBIT "A"
Parcel 1
The East 60 feet of Lot 2 and the East 60 feet of Lot 3, Block 75-S, MAP OF MIAMI,
according to the map or plat thereof as recorded in Plat BookB, Page(s) 41, Public
Records of Miami-Dade County, Florida.
Parcell
Lots 2 and 3. less the East 60 feet and the West 30 feet thereof; Block 75-S, MAP OF
MIAMI. according to the map or plat thereof as recorded in Plat Book B, Page(s) 41,
Public Records of Miami-Dade County, Florida.
Parcel 3
The West 30 feet of Lots 2 and 3and the East 30 feet of Lot 4, less the South 50 feet
thereof, Block 75-S, MAP OF MIAMI, according to the map or plat thereof as recorded
in Plat Book B, Page(s) 41, Public Records of Miami-Dade County, Florida.
Parcel 4
The West 20 feet of Lot 4. less the South SO feet thereofand the East 40 feet of Lot S,
less the South 50 feet thereof, Block 75-S, MAP OF MIAMI, according to the map or
plat thereof as recorded in Plat Book B, Page($) 41, Public Records of Miami-Dade
County, Florida, •
Parcel 5
The West 10 feet- of Lot 5. Jess the South 50 feet thereof and Lot 6, less the South 50 feet
thereof, Block 75-S~ MAP OF MIAMI, according-to the map or plat thereof as recorded
in Plat Book B, Page(s) 41, Public Records_ofMiami~Dade County, Florida.
Book23491 /Page2837 CF N#20050633852 Page 3 of 3
https://www2.miami-dadeclerk.com/Officia1Records/PrintDocument.aspx?QS=YaoUf0zxry3Rz9CvspSsSM0rKS0GQXN%2bWT0%2bKOm8Wtn%2bSj... 3/3
133
ATTACHMENT E
12/11 /20',17 Miami-Dade Official Records - Print Document
133
-. 11111111111111111 11111 11111111111111111111111

CFN 2009R0112907
OR 8k 2675{ Pss 3233 - 32tOF {8Pts}
RECORDED 02/17/2009 15130:24-
LOCATION: 110 SW 10 STREET HAR\IEY RUVIN, CLERK OF COURT
NIANI-DADE COUNTY, FLORIDA
MIAMI, FL 33130
COVENANT RUNNING WITH THE LAND

THIS COVENANT (hereinafter the "Covenant"), made and entered into this _1_ day of
~ 0 0 8 by and between ROYAL EXPWltER DEVELOPMENT. LLC, a Florida
limited liability company, party of the first part, its successors or assigns (hereinafter called
COVENANTOR), and the CITY OF MIAMI, FLORIDA, a lllUDicipal corporation of the State of
Florida, in the County ofMiami•Dade, party of the second part. (hereinafter called "CITY"):
WHEREAS. COVENANTOR is the fee OWNER of: See attached Exhibit "N'
hereinafter called PROPERTY; and
WHEREAS, COVENANTOll has requested permission from CITY to construct and
•mmntain nonstandard improvements within the public right-of-way described in Exhibit "B",
(hereinafter collectively called "Improvements").
WHEREAS, the CITY has required the COVENANTOR to execute and deliver to CITY
this instrument as a condition precedent to the granting of said permission.
NOW TIIEREFORE, in consideration .of the permission by CITY to allow the

construction and maintenance of the ..IMPROVEMENTS" within the dedicated publi~ right of
way by COVENANTOR and in the further consideration of t h e ~ COVENANTOR does
hereby covenant and agree with CITY that COVENANTOR shall,, at no cost to the CITY,
remove the aforementioned ..IMPROVEMENTS" whenever requested by, and upon thirty (30)
days written notice from, the Director of the Department ofPublic Wotks of CITY.
Book26754/Page3233 CFN#20090112907 Page 1 of 8
Attachment E, page 1
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12/11/2017 133
•-
LOCATION: 110 SW 10 STREET

MIAMI. FL 33130
In the event that COVENANTOR,. its successors, or assigns fails to remove the
"IMPROVEMENTS" when so requested,. the Director of the Department of Public Works of
CITY shaJI cause the aforementioned "IMPROVEMENTS" to be removed at the expense of
COVENANTOR; the amount of such removal cost shall be declared and established as a lien on
the property of such defaulting COVENANTOR and enforced as any lien of materials furnished
and work and labor done provided under the Statutes of the State of Florida, and the
COVENANTOR covenants and agrees that all recourse against CITYis hereby expressly waived
as to any damage caused. consequential or otherwise, to any portion. in whole or in part. of the
remainder of COVENANTOR's improvements, resulting from the removal of the aforesaid
"IMPROVEMENTS" from said public-Right-of,.Way.
COVENANTOR shall provide maintenance of the "IMPROVEMENTS", in accordance
with the CITY'S standards and specifications.
COVENANTOR shall indemnify, defend.· and hold CITY, its offici~s and employees,
harmless from any claims, demand~ liabilities. losses or causes of action of any nature
whatsoever arising out of the aeceptance by the CITY of this Covenant and/or the use,
construction, maintenance and/or removal of the "1MPROVEMENTS", or any part hereof: from
and against any orders, judgments or decrees that may be entered and from and against all coits,
attorneys· fees, expenses and liabilities -incurred in the defense of such claim or in the
investigation thereof
COVENANTORS shall indemnify, defend and save CITY, its officials and employees,
harmless 'ftom. and against any and all claims. liability, losses and causes of action, of any nature
whatsoever that may arise out of the granting of this Covenant or out of COVENANTORS' •
httos://www2.miami-dadeclerk.com/OfficialRecords/PrintDocumerit.asox?OS=YaoUfOzxrv3cWOrH79xaDMzQ8UCOzCJhmtG5v7P5bAEocoCo5Fi%2fH... 2/8
Miami-Dade Official
133 Records - Print Document
12/11/2017
,'
LOCATION: 110 SW IO STREET

MIAMI. FL 33130
ac:tivities under this Covenant. including all other acts or omissions to act on the part of
COVENANTOR or any person acting for or on COVENANTOR'S behal( and from and against
any orders, judgments or decrees that may be entered and from and against all costs, attorneys•
fees, expenses and liabilities incurred in the defense of any such claims c:>r in the investigation
thereof.
COVENANTOR shall keep in full force and effect, at all times during the exercise of this
Covenant. a commercial general liability policy of insurance of at least $1,000!000 per
occurrence and $2,000.000 aggregate for bodily btjury and property damage and insurance
provider shall be authorized to do business in the State of Florida.
The insuranc:e and Covenant shall be subject to the approval of the CITY' s Risk
Manager and the CITY Attorney. The insurance policy shall be prow.red and premiums paid by
COVENANTOR. The effective date of the policy shall be the effective date of the Covenant,
and the policy term or any renewals thereof shall remain in effect for the term ofthe Covenant.
The insurance carrier for the policy must be rated no less than A as to management and
no less than Class V as to strength by the latest edition of Best's Insurance Guide and must be
approved by the CITY's Risk Manager. CITY shall be named as Additional Insured under the
policy. Proof of insurance shall be supplied _to the satisfaction of CITY prior to the issuance of
any permits. A Certificate of Insurance bearing CITY as ''Additional Insured" shall in no way
relieve COVENANTOR of the obligation to add CITY as "Additional Insured" to the actual
insurance policy. The insurance policy shall provide that CITY be given at least thirty (30) days ·
advance written notice of any material changes, cancellation or non-renewal notification of any
policy and, in the event of such material change, cancellation or non-renewal notification.
https://www2.miami-dadeclerk.com/OfficialRecords/PrintDocument.aspx?OS=YaoUfOzxry3cWOrH79xqDMzQBUCOzCJhmtG5y7P5bAEocoCp5Fj%2fH... 3/8
Miami-Dade Official133
Records - Print Document
12/11/2017
LOCATION: llO SW IO STREET

MIAMI. FL 33130
COVENAN'l'OR shall immediately replace said policy with another policy to the satisfaction of
CITY with the receipt of a certificate of insurance for such policy by CITY at least ten (l 0) days
prior to the effective date of the material changes. cancellation or non-renewal of any policy. In
the event that CITY is not in possession of same by such date, then CITY shall have the right to
immediately secure a similar insurance policy in its name with the total cost of the premium and
all monies that may become due during the term of the Covenant being cruuged to
COVENANTOR and CITY shall have the right to declare and establish said costs as a lien on
the PROPER1Y of COVENANTOR. enforced as any lien provided for under the statutes of the
State of Florida. COVENANTOR agrees to increase :from time to time. as required by the City's
Code, the limits ofthe comprehensive liability insUrance policy required to be provided pursuant
to this Covenant, upon the written request of CITY.
It is expressly understood and agreed that this instrument shall be binding upon
COVENANTOR, and also upon heirs, succes$0rs-in-interest or assigns of COVENANTORS,
and shall be a condition-implied in any conveyance or other instrument affecting the title to the
aforesaid property or any portion thereof.
Any notice. request, demand, approval or consent given, or required to be given, under
this Covenant shall be in writing and shall be deemed as having been Biven when mailed by
United States registered or certified mail (return receipt requested). postage paid. to the other
parties at the addresses stated below or at the last changed address given by the party to be
notified as hereinafter specified:
CFN#20090112907 Page 4 of 8
Book26754/Page3236
https://www2.miami-dadeclerk.com/OfficialRecords/PrintDocument.aspx?QS=YaoUfOzxry3cWOrH79xqDMzQ8UCOzCJhmtG5y7P5bAEocoCp5Fj%2fH... 4/8
Miami-Dade Official
133 Records - Print Document
12/11/2(,)17
LOCATION: 110 SW IO STREET

MIAMI, FL 33130
COVENANTOR: GAMMA CONSTRUCTION, INC

Attn: Patricio Cervantes, President
9840 SW 77 Avenue
Miami, Fl 33156
CITY: TIIECITY OF MIAMI

Attention: Director, Department of Public Works
444 S.W. 2nd Avenue, 8111 Floor
Miami, Florida 33130
COVENANTOR herein expressly acknowledges that (a) permission granted by the CITY
to construct the "IMPROVEMENTS" on CITY public right of way is solely for the limited
purposes set forth herein and does not constitute a lease and that the rights of the
COVENANTOR hereunder are not those of a tenant but is a mere personal privilege to do
certain acts on CITY public right of way, (b)the CITY retains dominion, possession and control
of the CITY public right of way and ean unilaterally end the permission granted herein to
COVENANTOR in the event of default by COVENANTOR, without fault or breach or cause
whatsoever provided, however. that notice is given to COVENANTOR and COVENANTOR has
not cured the event of defiwlt within the period of time specified herein after receipt of notice
and (c) COVENANTOR does not and shall not claim at any time any interest or est.ate of any
kind or extent whatsoever in the CITY public right of way by virtue of its use hereunder or by
virtue of any expenditures incurred in connection herewith.
https://www2.miami-dadeclerk.com/Officia1Records/PrintDocument.aspx?QS=YaoUf0zxry3cWOrH79xqDMz08UCOzCJhmtG5y7P5bAEocoCp5Fj%2fH... 5/8
12/11/2017
133
•,
LOCATION: 110 SW 10 STREET

MIAMI, FL 33130
ane~ioaAled and Delivered in the COVENANTOR:
ROYAL EXPWRERDEVELOPMENT,
LLC. a Florida limited liability company
Print 03::.
Address: t:
Mt""'"\ ,(4.,, '31&.t'3-
SECOND WITNESS SIGN: By Q ~-
Patricio Cervantes, Manager
STATE OF FLORIDA )
} ss
COUNTY OF MIAMI-DADE )
The foregoing instrument was acknowledged before me this g TH day of DE~Bcll.

2008, by Patricio Cervantes, Manager of ROYAL EXPLORER DEVELOPMENT, LLC, a '
Florida limited partnership on behalf of said company. He is personally known to me or
presented . . as identification JUld
did I did not take an oath.
N TARY PUBUC STATE OF FLO

Print Name:
Commission No.:
Commission Expires: M.LAPSLEY
l\fY C'OMMISSION II DDS90644
EXPIRSS: Docombs 12. 201
I Ml'
[SEAL]
httpsJ/www2.miarni-dadeclerk.com/OfficialRecords/PrintDocument.aspx?QS=YaoUfOzxry3cW0rH79xqDMzQ8UC0zCJhmtG5y7P5bAEocoCp5Fj%2fH... 6/8
Case
12/11/2017 1:18-cv-24190-RS Document 632-2 Official
Miami-Dade Entered
Recordson FLSD
- Print Docket 02/22/2024 Page 85 of
Document
133
LOCATION: 110 SW lOSTREET

MIAMI, FL 33130
CITY OF MIAMI
APPROVED AS TO CONTENT:
~ ~ l \ ~ \ UJIU!.,
Stephanie N. Grindell, P.E.
Director, Department of Public ,v,n.......-.. fll/'!1- t0g
1111011
LeeAnnBrehm,
Director ofRisk
~
https://www2 .miami-dadeclerk.com/OfficialRecords/PrintDocument.aspx?QS=YaoUfOzxry3cW0rH79xqD Mz:Q8U C0z:CJhmtG5y7P5bAEocoC p5Fj %2fH... 7/8
12/11/2017 133
·• ·opt • 'BK : ~~75'~"-• PG 3 2 4 0 .. •

-1,c.-AST F'~GE::,.i. . . .. •
EXHIBIT A•.
BRfCKELL OAKS · •-: -·
100-142 S.W.10 Street
M~ami, FL 33130_
1
Parcel 1--~
The East 60 feet of Lot 2 and the East 60 feet of Lot 3, Block 75-S, MAP. OF MIAMI, •
according to the map or plat thereof as recorded in _Plat Book B, Page 41, Public
Records of Mi~mi-Dade County, Florida. •:·._ •
·. )· . -
Parcel6 ·:·'"=··.
Lots 2 and 3, l~ss the East 60 feet and the West 30 feet thereof, Block 75-S, MAP OF
MIAMI, according to the map or plat thereof as recorded in Plat Book B, Page_4>1, Public
Records of Miami-Dade Co1;1nty, Florida...
. ~: . . ~-
• • •
..
>· •.
i; ~- ,,
Pa.reef 3
The West 30 feet of Lots 2 and 3 and the East 30 feet of Lot 4, less the South 50 feet
thereof, Block 75-S, •MAP OF MIAMI, according to the map or plat thereof as recorded
in Plat Book B, Page 41, Public Records of Miami-Dade County, Florida.
Parce14
The West 20 feet of Lot 4, ress the South 50 feet thereof and the East 40 feet of Lot 5
less the South 50 feet thereof, Block 75-S; MAP Of IVlfAMI, according to the map or plat
thereofas·recorded in"Plat Book B. Page 41, Public Records of Miami-Dade County,
Florida.
The West 10 feet of Lot 5, less the South 50 feet thereof and Lot 6, less the South 50
feet thereof, Block 75-S, MAP OF MIAMI, according to the map or plat thereof as
recorded in Plat Book B, Page 41, Public Records of Miami-Dade County. Florida.
EXHIBITB
DESCRIPTION OF NON-STANDARD IMPROVM'.ENTS
l. !1Tigation in the right of" way
2
https ://www2 .miami-dadeclerk.com/OfficialRecords/Pri ntDocument.aspx?QS=YaoUfOzxry3cW0rH79xq DMzO8U C0zCJhmtG 5y7P5bAEocoCp5 Fi% fH ••• 8/8
133
ATTACHMENT F
133
Miami Zoning Details for Address: 110 SW 10 ST
•➔ Established Setbacks
□ n SUB-URBAN
liJr4 GENERAL URBAN
BDrs URBAN CENTER

i&JT6-8 URBAN CENTER
filT6-12 URBAN CORE
8JT6·24 URBAN CORE
IIJT6· 36 URBAN CORE

liJT6-48 URBAN CORE
Ill cs CIVIC SPACE/PARKS

lllJCl CIVIC INSTITUTIONAL
Enactment
13114
i
!section !Area lsubArea IDescri12tion 'l;
j,o [ Descrle!ion Ienactment L
Im IDescrletion Ienactment I:
Owner IPhysical Address IBilling Address
0102070501011 f 4651 SHERIDAN ST STE 335 HOLLYWOOD FL 3302! !BRICKELL STATION LOFTS LLC
Leaal Description !
I
CITY OF MIAMI SOUTH PB 8-41 lOTS 2 & 3 tESS eXT AREA OF CURVE IN NE COR FOR R'W & LOTS 4 THRU 6 LESS S50FTl0T SIZE 29866 SQ FT
·····-·· •···· · · ii l
11,
.,_,
-(i
1,
-,~
Attachment F, page 1
133
ATTACHMENT G
.. 133
.·. ..) • • ••
·-
Occupancy Completion
City of Miami
BUILDING OEfUIFICATE
Ti!o
.
,•
Numbor
•
OCCUPANCY 09-10831
Own.er l'olio
ROYAL EXPLOYER LLC 01-0201-0'so-1011 I 0000

'
Permit Holder Addresa
GAMMA CONSTRUCTION INC 110 SW 10 ST

63UNITS
Legal Subcl(visian
CITY OF MIAMI SOUTH PB 8-4 t
CITY OF MlAMJ SOUTH PB 8-41
E60FT OF W9DFT OF LOTS 2 & 3
BLK 75
Bp I 06-5003098
LOT SIZE 6000 SQ FT
PURPOSE: NEW CONSTRUCTION OF APARTMENT BUILDING
Use Teo Expires
003 MULTIFAMILY NIA
Th;i~s ,;.,.,..,e ,s· ued to the above-named permit holder for the building and premises at the above-described
lac ion, and ceilifi fthat the work has been completed.
v .
~ 09 11 09
. Mariano ~andez, P.E.
Buildina Official /or Designee --'-'-
Dale
0 GS/AO 007 Rev. 08/2008 I
;,
Attachment G, page 1
133
ATTACHMENT H
Case 1:18-cv-24190-RS
110 sw Document
I 0th st miami fl 33130 632-2 Entered on FLSD Docket 02/22/2024 Page
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110 sw1:18-cv-24190-RS
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Case 1:18-cv-24190-RS
100 Southwest Document
10th Street, Miami, 632-2Search
FL - Google Entered on FLSD Docket 02/22/2024Page
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133
ATTACHMENT I
133
1\.-\1,m,i, Horida :rn n

MIAMIO.DE T 30':,-4'-J•,HH,iB F lOS-499-,3547
tBli TTY: '.l()::;.499.848()
CERTIFICATION
STATE OF FLORIDA)
COUNTY OF MIAMI-DADE}
!. Christina White, Supervisor of Elections for Miami-Dade County, Florida, do hereby certify that the
attached is a true and correct copy of the Official Results, including the recounted results for
Commissioner -- District 3, for the municipal offices listed below in the Miami General Municipal
and Special Elections conducted on November 7, 2017:
Mayor
Coconut Grove Village Council Members
Proposals
"'....,.... ·:- ,~--~--~ .... ·····- •.
WITNESS MY HAND AND
OFFICIAL SEAL, AT MIAMI,

!.~~:::~~>
MIAMI-DADE COUNTY, FLORIDA, •• "ChrtAfina White
Supervisor of Elections
ON THIS 10th DAY OF NOVEMBER, 20·17 Mlarni-Dade County
Endosure
Attachment I, page 1
133
MIAMI Fall Municipal Election OFFICIAL RESULTS
NOV<:'ll:bi?r' 7, 2017
M'iar,ri -Dade County. FL
Run Date: 11/10/17 01 :49 PM Report EL4~'>A
TOTAL VOTES ED OSS rn !VO VBM EV OSS EV IVO PROV
PRFUNCTS COUNTED WF 146), 146 1.00.00

REGISTERED VOTERS • T(HAl. 193.335
BALLOTS CAST · TOTAL. 26,860 9,121 3 14,4()(:. 3,'.l26 0 5
\/Olli-I TURNOUT • TOTAL . l3.H9
MIAMI; 1-':AYOR
Vote for l
~J-i ·! l 1,n,s A'! fred J\rmbn ster Sr. 1)392 5,47 519 () 672 200 {) 1
Christiar. CanKhe. 829 3.2$ 250 ,,0 471 108 0 0
Cynthia Jaquith . 1,.394 5.47 559 t,·r.1 1.73 0 1
..;
"~
Francis X. Suarez. 21)856 85.81 7,338 2 11,862 2,651 !} 3
Toto·! ?S.4'71 8,666,. 2 13,666 3,132 0 5
Over Votes 37 0 0 30 1 0 0
Under Votes . 1,352 448 1 :?09 193 !} {)
MIAMI: COMMISSIONER • OI'.31R[CT 3

*'' SEE ADDENDUM **
Vote for 1
Zora•i;Ji} A Barr<:~iro . 1 >204 20,03 273 () 6'16 255 0 {)
Joe Caro11o. . 1.81/3 30.2.4 l'.'"'"1
:>~t} 0 1,0()7 'll3 0 1
A1ex Oorr.1 ngue.z. 182 3.03 63 0 79 40 ,,(, 0
Alfonso "A.! r1..,·• LE?Dn. 1,221 20.31 417 {) 616 187 ,,0 ~
r,'.)mus Regaludo. 935 15. 5:-i 316 0 490 129 ..; 0

Miq,wl So11rniln. 357 5.94 104 0 165 88 ('I 0
Jose Suarez. 2'.·h 4.91 114 0 105 76 0 0
fotul 6.012 1.H?.4 0 3,138 1.048 G 2
Ov0f' Vo t~:s ,j(J 11 0 25 4 0 0
Under Votes 9() 28 0 57 5 0 0
MIMI: COMMISSIONER • DISTIHCT 4

Vote for l
Mano·1<J Reyes . 4,263 S6.74 1.420 0 2,339 502 0 2
Ra1ph r~osado , . . 2~716 36.15 919 0 1.464 332 0 1
(};?ri°l Si? Galvez forros. 534 7,11 162 {} 3.13 59 0 D
Totu! 7,513 ?.Sm Q 4,116 893 0 3
Over Votes 14 2 0 12 0 () 0
Und;~r Votes 171 56 D 103 12 0 !}
Attachment I,
133
ATTACHMENT J
133
AFFIDAVIT OF CANDIDA'fE
CITY OF MIA.Ml, FLORIDA
STATE OF FLORIDA )
COUNTY OF MIAMJ~DAPE )
CITY OF MIAMl )
_.:_o___,{h..,.___•~L~··_u-n...._
_fh'--'--·~""'"·-· ___ (hereinaftcr "affiant''), being first duly sworn, deposes and says:
l. My name is --1--IJ-=-·.....,{-k,,s.-=-··
""'-""'-,;1___
;.&..l. /h-"-·
.L.-'.'---""L-=---e4>?c=·....__.__________
2. For those candidates seeking the office of Mayor, please check the appropriate subsection (a) below.
Those candidates seeking th:e office of Commissioner please check and fill in the blank in subs~ction
(b)below:
_(a) 1 am offering myself as a candidate for the office of Mayor of the City Qf Miami, Florida. If
•elected, I folly understand that I must maintain an actual and real residence within the City of Miami for
the duration of my tenn of office. .
✓(b) I am offering myself as a candidate for the office of Commissioner in District Number
of the City of Miamj, Flori~. If elected, I fully understand that I must maintain an actual and real
2
.residence within the district for the duration of my term of office.
3. l have resided in the City of Miami for a minimum of one year before qualifying ff applying for Mayor,
and ~me year in the disf:ict if ~pl~ng f~r the Commi.ssi~n, and I am a.regist:red voter aJ.d .flJiuly
quahfied elector of the City of Mtam1, Flonda, presently registered to vote m Precmct No. . 5 fh .
I presently reside at the following address (must include zip code):
23~£?' s-w Lf1'k
.
S-t. [Y?,'·a..rn:. J . ti: 33,13~-
.
which is my legal address, and I have resided continually at said address from the _!j_ day of
Jt1,,£ J Z.c:> / G, to the present.
4. Immediately prior to residing at the above-stated address, J have resided at the hereinbelow listed
addresses for the cited periods of time (list herein:betow all addresses at which you have resided for the
past five years, as well as the length of time at each address):
Prior Addresses For the Period
/g(pJ ,J~ ~. &vef \)l1\t4..~~ ;fi.14 '201'2. - {)1,t,Ych 20l'1

(n 1\ aJ)v~ fi_ "3:!, I2 ~
i
5. lrt addition to the residence that 1 have listed as my present address, I also reside at the following listed
addresses on a temporary basis as a secondary domicile or domiciles:
6; Affiant's spouse resides at the following address (must include city1 state and zip code):
23&.~ ~N '--Ji'h ~+. (?1,W,.~ 3313~---
CM~AG{Rev. 08/17) Page 1
Attachment J, page 1
I Case 1:18-cv-24190-RS Document 632-2 Entered on FLSD Docket 02/22/2024 Page 101 of
133
7. Affiant's minor chlldren reside at the following address (must include city, state and zlp code):
8. A~ the pre.sent time, affiant (i~gistered to vote in any city; county or state other than as
stipulated m subparagraph 3 a b ~
9. Name and business address ofaffiant's employer:
IO. Affilmt's occupation: /PH4a~ _
Affiant's business telephone nutnbet(s): 7.Ku .3'1S .<J94-f

11. Affiant has been employed in the above-cited capacity for the following period of time:
8nc. zrf ar ~' ;'_

• ~.):'~ [\;
(Note: In the event the octupation of affiarit has been for a period of less than one yeaf;' or the
employment period with the same employer has been for ~ period of less than one year, affi~t
shall give the name{s) and address(es) of his/her employer(s) and occupation(s)for the period of
one year prlor1o the date of this •~davit), _ e . '
~ .I-• f1,'c.P4 3soo a:,, {l....u,c....., 'bt,v(.__
C-h · • al, · lfl~er
12. Affiant represents that he/she (is is not) ently holding another elective or appointive office -
whether city, county or municipal"" • r.111 of which or any part thereof runs concurrently with that of
•the office he/she seeks, and that he/she has resigned from any office from wh.icb he/she is tequirl;ld to
resign pursuant to F.S. 99:012 and/or the City of Miami Charter.
13. Affiant represents that. as of this date, he/she (is (is not seeking to qualify for public office which is
currently held by ar.1 Qfficer who has authority to point, employ, promote, or othetwise supervise
hhn!het and who has qualified as a candidate for reelection to that office.
Note: If affiant is an employee of the City of Miami, affiant shall take a leave of absence, without
pay froin his/her employment during the period in which affiant has become a candidate for
electfve public office. This subsection does not apply to the Commissioners and Mayor, City
Manager, City Attorney, City Clerk, and Independent Auditor General. Such leave of absence
shall be effective upon whichever 9ccurs first:
(a) Such employee receives contrib:uttons or make!l expenditures, or gives her or his consent for
any other per$on to receive coiitributlons or make expenditures, with a view to bringing about
his or her nomination or election to public office; or
(b) At the time such employee appoints a campaign treasurer and designates a primary
depository; Qr •
(c) At the time such employee files qualification papers and subscribes to a candidate's oath as
required by law. ••
CM~AC{Rev. 08/17) Pagc2
133
14. Affiant's campaign headquarters address and telephone number:
..2:¼8 S-pj Y~ s+ {YHuA..tfi ~JdS ( /ift. 7f"ct 3'1-1./:&

I I
Affiant's campaign treasurer's name:
n.0 /:) .. J.
t, J IT lC.. h . ~• f\ 71).,,#!'La,.
Affi3ant'2sca;.ai~.·
,;J }'✓ (.•r~ ;'
ar.e,..r·.s-a.d:.ss:
·.tre..7....... /l. ~b
g-rv,._,.
!
l- (rJ,'a,,,J ,t fi:. $ 3/ 3'f
Telephone numbers: (work)_~/V.__,_~-'-._A
_ _ _~--'---'---'----"
15, Affiant represents that, if elected, he/she shall serve in the elective office to which he/she seeks
election.
16. Following is the exact way in which affiant would like to have his/her name printed on the official
ballot Bllzmso t..t /tl+rfl /, VU/YJ
s10NE0 THIS 2 2. oAv OF 5e, t!!:,,., b"'c
BEFORE ME, the undersigned authority, personally appeared A\::\(:¥\SQ •ti\ Leon '
who, after first being duly sworn, deposes and states that . he, . executed the foregoing to the best
of Y\\S . knowledge and belief.
. SANORAFORGES
Nolaly Publit'-Sla\e Qf flortja
~wr2jE~ . Commission #GG 084618
ti. CITY OF MIAMf, FLORlDA My Comm. Expires l4r 19, 2021
80!lllid~~tl$yAstll.
(SEAL)
PJ
N
/ Did tal."e an oath
./ . Produced identification 'fl
Type of identification produced:_\}.~· ~"~S_,_n_··~u_s_~--lpo_·.....rt_.____ r:~ w
.):;;,,.,..,.._,.
CM-AC (Rev. 08117) Page3
133
. AFFIDAVIT OF NICKNAME
~
--1 \ol
STATE OF--=--J-•• ••·-'!.·.

_t'l.f.__
.~....,...:.\-•
- ..-... _,_i_
COUNTY OF_,....~!,,),.,..,,,.,....,.~-.....----
BEFORE ME, the undersigned, personally appeared:
Alli> h.>O (}} ~ ./2-,tp f) . .

(write legal name of candidate)
who being first duly sworn ot placed under affirmation says:
l. My legal name is:

•
f] ~ (n • L-lUfh
1 am overthe l,!.ge of eighteen (18) and the contents of this affidavit are true l'l.i:ld correct.
3. My nickname is;_ __,(t,_:

•........,-+fl
.....:• ....
e..,..,_ _ _~ - - - - ~ - - - - ~ - - ~ ~ - - -
I am generally known by this nickname or have used it as part ofmy legal name. I have not created the
nickname to mislead voters, l plan to designate this nickname on my candidate <>ath as the same name
I wish to have printed on the ballot when l submit th.e candidate oath form during the qualifying :period
for the above office.
4, Attached ~e documents that show that my nickname (s one by .yhich I am generally know-n or one that
J have used as a part ofmy legal ruune. [List the title of any document$ or affidavits from other persons
reflectirtg that the candidate is generally known by the nickname or that it has been used as part of the
candidate's legal name.] •• •• •
Printed /Typed Name of;Affiant •
SAND PA FORGES
Notary PijbJiC -Staled Rll!!da
Qimmlsslon IIGG 084iJl8
My C®m!. Expire$ Mam. 2021
~hcuj,NmllllMoiaiyAm.
March 19 aori \
~rsonally known @ r Produced Identification
Type of Identification Produced: U S,., t £b $ $ ~

133
. ALFONSO "ALFIE" LEON

Legislative Aide
OFFICE OF COM!vUSSIONER FRANK CAROLLO

3500 Pan American Drive, Miami, FL 33133
(305) 250-5380 I E-Mail: aleon@miamigov.com
~........:;
f; V2 .-__J
.;o-•::+,.,"
tc:-'
;::.>:; ~
133
'. ' :l;-M,

ii,
f'I
Ci~ t-HAhl
.,._~
,.i--~.:i...-.
-,,,~;
''" ~-
CONSORTI.UM
FOR.A
HEALTHIER
Attachment J, page
MIAMI-DADE
6;,;;,,·,:c:;,-,:;e:,, ",:, ·• : ,,,:.-,· •-i,' - :· • ,. -·,,,., ::~,.-,,, ,:~;rty
133
J, page 7
133
Florida Department .of Health in Miami-Dade County

Lillian Rivera, RN, MSN, PhD
Administrator
Consortium Executive Board
Alina Soto Nelly Rubio

Department of Children ·and Families CBS Television
Co-Chair, Executive Boord
Chair, Children Issues
Jeffrey HlJrst
Karen Hamilton Department of Children and Families
South Flodda Regional Planning Council Vice-Choir, Marketing and Membership
Co-Chair, Executive Board
Choir, Health o:?d th2 Bui!t E,'r;, ironr:;rnt Nancy Hernandez
Florida International University
Alfieleon Chair, Tobacco-Free Workgroup
Florida International University
Vice-Choir, Children Issues Georgette Baeza Kores
Royal Caribbean Cruiseline
David Saltman Vice-Chair, Tobacco~Free Wcrkgroup
Florida International l,Jn·iversity
Marlene Rodriguez
Bayview Asset Management,
Beatiz Jimenez Chair, Worksite Wel!ness
Miami-Dade County
Vice-Chair, Elder Jssuf:5 Or. M. Enrique Flores
Shin Wellness
Cheryl Jacobs Vice-Chair, V✓orksite l/velhiess
Centerfor Archltecture & Design
Vice-Chair, Health and Built Envfronment Marisel losa
Health Council of Sovth Florida
Leyanee Perez President & CEO at Health Coundf of South Florido
The American Healthy Werght Alliance
Chair, Health Promotion and Disease Prevention Ann-Karen Weller
Florid.a Department of Health in Miami-Dade County
l(atiana Diaz Director, Off;ce of Comrnunity Health arid Planning
YWCA- Greater Miami-Dade
Valerie Turner
Florida Department of Health in Miami-Dade County
t/ch·,tuJerr:ent Revievi 5pecfo:/js t, Office of Cornmunity
ff-.:.~i1/th c:.r;d Planning
27 Attachment J, page 8
133
J
Robert WoodJbhnsoo foundation
Alfie Leon
Miami-Dade County
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133
FORMl STATEMENT OF 2016

Please prlnt<irtypvc your name, maR!ng .FINANCIAL INTERESTS
,, .. . ' . . . ,· ' . . -~ . FOR OFFICE USE ONLYJ
.address, agency 11ame, and position botow; ~ ,;~ Al"',\, _;.,l:<sr\~.,.~\
NAME OF O ICE ORPOSITION HELD OR SOUGHT :

eoMl>'llU~ . "b,
You are not limited to ihe ~~aiie on th& lines on this fonn. Attach !iddltlcni/1 ;heetti, If ~eceaaary.
,.
ill
CHECKONLYW CANDIDATE OR Q NEW EMPLOYEE OR APPOINTEE
, . .. '
*~ BOTH PARTS OF THIS SECTION MUST BE COMPLETED *tt* •

DISCLOSURE PERIOD: . .
•THIS STATEMENT REFLECTS YOUR FJNANCIAl lNTERE$TS FOR THE PRECEDll':IGTAX YEAR; WHETHER BASED ON A CALENDAR
YEAR OR ON AflSCAL YEAR .. PLEASE STATE BELOW WHETHER THIS STATEMENT IS FOR THE PRECEDING TAX YEAR ENbJNG
EITHER (must che<;k one); • • • • •• • •
~ DECEMEl~R31, 2016 QR O SPECIFYTAXYEARIFOTHERTHANTHECALENDARYEAR:_ _ __
MANNER OF CALCULATING REPORTABLE ·INTERESTS:

FILERS HAVE THE OPTION OF USING f<EPORTING THRESHOLOS THAT ARE ABSOLUTE DOLLAR VALUES, WHICH REQUIRES FEWER
CALCULATIONS, OR USING COMPARATIVE THRESHOLDS, WHICH ARE USUALLY BASED ON PERCENTAGE VALUES (s~e instructfons
forfurther details). CHECK THE ONE YOU ARE USING (must check one):
□ COMPARATIVE (PERCENTAGE)TH'RESHC>LDS QB. K DOLLAR VALUE THRESHOLDS •. •
PART A ... PRIMARY SOURCES OF !NCOME •[Major sources of Income to the reporting peroon - See i11structions]
(If you !)ave nothing to report, write "none" or "nfa")
NAME OF $0l)RCI:: SOURCE'S OESCRIPTlONOF THE. SOURCE'S

..OF INCOME ADDRESS • 'PRINCIPAL BUSINESS ACTIVITY
PART B - SECONDARY SOURCES OF IWCOME

fMaJor customers, clJents, and 'ol)lersources olincome lo businesses owned by llle reporting person• See instructlons]
(If you have nothing to report,
. write "none"
. or nn/a")
NAME OF NAME OF MAJOR SOURCES ADDRESS PRINCIPAL BUSINESS
'BUSINESS ENTITY OF BUSINESS' INCOME OF~pURCE ACT]VITY OF SOURCE
PART C - REA,L PROPERTY (Land, bulldings owned by Jhe reporting ptirson • See inst,ructiona.1
• (If you have nothing tp repol't, write "none" or "n/a") • FILING .INSTRUCTIONS for when
and where to file this form are
located at the bottom of page 2.
INSTRUCTIONS oh who musHHe
th I$ form and how to fill it out
begin on page 3.
•CE FOAAI 1-Elrecllv$'. Janua,y .1, 2017

lr,co,~ia!ed by ret•rance Jn Rule 34·U02(1), FAC,
Attachment J, page 1O
133
PART D- INTANGIBLE PERSONAL PROPERTY [Stocks, bonds, certificates of deposit, etc. -See instructions]
(If you have nothing to report, write "none" or "n/a")
TYPE OF .INTANGIBLE
C.hw
PART E - LIABILITIES [Major debts • See instructlonsJ
(ff you have nothing to report, write. "none" or ''nfa")
NAME OF CRECirtbR ADDRESS OF CREDITOR
PART F -INTERESTS IN SPECIFIED BUSINESSES [Ownership or positions In certain types of buslnessei':.s~b ~ristriuitonsf' •
{lfyou have nothing to report, write "none" or "n/a''l.
NAME OF BUSINESS ENTITY

ADDRESS OF BUSINESS ENTITY
PRINCIPAL BUSINESS /\CTIVITY
POSITION HELD WITH ENTITY
I OWN MORE THAN A 5% INTEREST IN THE 13USINESS
NATURE OF MY OWNERSHIP INTEREST
PARTG -TRAINING
For eiected municipal .officers required to complete .annual elhics tra1riirig pursuant to secitibil 112,3142, F.S.
□ I CERTIFY. THAT I .HAVE COMPLETED .THE REQUIRED

. TRAINING,r;-
.. ·~ w
IF ANY. OF PARTS A THROUGH G ARE CONTINUED ON A SEPARATE 'SHEET, PLEASE CHECK MERE •□
If a c~rtified public accountant licensed under Chapter 473, or attorney

Signature: in good standing with the Florida Bar prepared this form for you, he w
she .mus\ complet1; the f<:>llowing statement •
I, ~ ' - - - - - - - - - - - - . . . ; . . . . - • prepared the CE
Form 1 In .accordance with Section 112,3145, Flortda Statutes, cllncl the
iristri:Jctions to the form, Upon my reasonable knowledge and belief, lhe
disclosure herein is true and correct
Date Signed: , .. , : . -. .1;\ •
. ~;· ', i:• ,.· '.
·: /" ; ~~~ • •
CfNAltorrey Sil}llat1.1re:
. . .• ·,7_/ca2-//7 .£;" • -. •
L 1 Date Signed:
Ji'ILING INSTRUCTIONS;
WHAT TO FILE: WHERE to FILE: WHEN TO FIL~:
After completing all parts of this form, including lf you were mailed the form by the Commission Jnitlaily, eacli local officerfemployee, state officer,
sJgnlng and dating it, send back only the first on Ethics ora County Supervisor of Eleotions for and specified state employ@ must fife within
sheet (pages 1 and 2) for filing. your annual disclosure filing, return the form to 30 days Qf the date of hfs or her appointment
that location. or of the beginning of employment. Appointees
If you have il6Uling to ~port ln a, particular who must be confirmed by the Senate must fiie
Local offlcers!empfoyees file with the
section, write "none" or "n/a" in that section(s). Supervisor of Elections of the county tnwhlch they prior tel CQnfinnation, even if tha~ is less than
30 days .from the date of lhl!!i~ 'appqintrnent.
permaner,tly reslde. (If you do no! permanently
NOTE; reside in Florida, file with the Supervisor of the Candidates must file at the same tlm~ they file
MULTIPLE FILING UNNECESSARY: county where your agency has Its headquarters.) 1helrqualifylng papers.
a
A candidate who files Form 1 with a qualifying Sta~ officm or lfi~l#fled lfitate employees
Theroan,,, file by July 1 followtng each calendar
officer ls not required to file wiih the Comn,fssion yE!c')r fn v.ihich they hcild their positions.
file with the Commission on .Ethics, P.o: Drawer
or Supervisor of Elections. 15709, Tailahassea, FL 3231.7-5709; physical Finally, file a final disclosure fotm (Form 1F}.
address: 325 John Knox Road, Building E, Suite within 60 days Of leaving office or employment..
Facsimiles wm not be accepted, 200, Tallahassee, FL 32303. • .. Filing a CE Form 1F (Final Statemenl •.ciar
' • : '" '.
, lolerest,s) ~Qi!,s Jl!it•rl:ilieve the filer of
J; ~-
'GI;
CandldatliS file this,ifonn togethi!lriWl!h Ihi:iir' Form 1 if the filer was iri his or her position on
qualifying papers. ' December 31, 2016.
To determfne what Ci;ltegory your position falls
under, see page 3 of instructions.
CE FORM 1-Effecfive: JMuary·1, 2017, . . .Pi\GE2

ln@(potaled by rofetence in Rule 34-11,202(1), F.A.C:
133
CANDIDATE OATH -
NONPARTISAN OFFICE
(Not for use by .Judicial or

·School Board Candidates)
OFFICE USE ONLY
OATH OF CANDIDATE
(Section 99.021, Florida Statutes)
I. Alf,()SD \\ AlRll.. /I' U4h

(PLEASE PRINT NAME AS YOU WISH JT TO APPEAR ON THE BALLOT• - NAME MAY NOT BE CHANGED AFTER THE END OF QUALIFYING).
am a candidate for the nonpartisan office of {Yl'a.1¥Lt .u-mflhs,;J~

{office) •
3
• (distrlc:t#)
_ _ _ _ _ _ ; I am a qualified elector-of m.-o.,n.i .... b Je,_, County, Florida;

(circuit#) (group or seat#)
I :am qualified under the Constitution and the Laws of Florida to hold the office to which I desire to be nomiMted or
elected; I have qualified for no other public office In the state, the term of which office or any p1:1rt thereof runs
concurrent with the office l seek; and .I have resigned from any office .from which I am required to resign pursuant to
Section 99.012, Florida Statutes; and I will support the Constitution of the United States and the Constitution of the
State of Florida,
_x___ £ ___ <~_)1_s-D_._3't..;;._'-"__,,,_&1______Li=·

Telaphone N u m b e r ~ s s
/-)··""'""'d~e.::,..=lea,~•--"--"Co>-n.'--'---'•-.
. .......,'.C.__'l)~
•
Address City
liState
3?J1as
.ZIP Code
Candidate's Florida Voter Registration Number (located on your voter informettion card): // 01J 12,13
• Please print name phonetlcally on ttie line below as ye>u wish it to be pronounced on the audio ballot for persons
with disabilities {see instructions on page ,2 of this form):
t3tl. ~ . .
~~-L-t-OV-tJ--.s--tJ ~'" ~H-
11 . L- F-€6' ✓/ L -c.r...r:Jv-,v
· 1 .ii
STATE OF FLORI0A
couNTYoF t:A1Droi-tnde.
Swomto (or affirmed) and subscribed before me this
Personally Known: _ _ _ or
~~d;G~«<
Signat11re of Notary Public
Produced identification: ✓ Print, Type, or Stamp Commlssloned Name of Notary Publlc •
Type of Identification Produced: \ 1. S,. Y~:\:

DS-OE25 (Rev,5111)
133
LOYALTY OATH
SiATE OF Fl..ORIDA
COUNTY OF MIAMI-DADE
I, ibEN~ 6lv1
' t ..
First Name Mlddfe Initial Last Name
a citizen of the State of Florida and of the United States of America, ... and a candi for public office ... do
hereby solemnly swear or affirm that I will support the Constitution of tn nited State tl of the Stale of Florida,
Signature of Canclidate c~; f
·~,
CITY OF MIAMI OATH OF C NblDATE

0\.,'} ·\
OFFICE OF CITY OF MIAMI COMMISSIONER j'.,) 'fi
Before me, an officer authorized to administer oaths, personally appeared ••c,,

_,,,,
. ftl:Gm&d OJ. Li@.

{PLEASE PRINT NAME)
;::::>
~>';
V!
who, being sworn, says he/she is a 'Cahdldate for the office. of City of Miami Commissioner, District for ..3_,
the City of Miami, Florida; that he/she is a qualified elector of the City of Miami, Florida; that he/she Is qualified
under the Constitution, the Laws of Florida, and City of Miami Charter to hold the office to which he/she desires to
be elected; that he/she has taken the oath required by Section 99.021, Florida Statutes; that he/she has qualified
for no other public office in the State, the tenn of which office or a11y pEirt thereof runs concurrent with that of the
office he/she seeks; and that he/she ha$ resigned or taken a leave of absence from any office from Which he/she
Is required to resign or lake.a leave of absonco, pursuant ID Secl:ion 99.012, F £ s .
Signature of Candidate
Address City
ft
State
33J3S"'
ZIP Code
The Loyalty Oath and Oath of Candidate are sworn to (or affirmed) and subsc,ribed before me this
•
cz:/}
"l nd- day
of ~ ~ L . l l l o : : ; . l - J . : ; : l , ~ . L - . - - - _ . . , 20 11
Sig
Personaliy Known:...;..·_ _ _ OR Produced ldentiije;iltion: -✓"--'·-- MMlflAFOROES
Type of Identification Produced: lj, s 1 ~QS.sptx-t

N:i!aryP~•Slaleo!Aorida
. Commiulon#GG08'16!8
MyComm,~res Mai 19,2021
~~Hl~NM'/Alill
133
City of Miami
OFFICIAL RECEIPT
No. 4'85050
Date; • Id-d-J i l
I !
C FN1TM 40~ Rav. 03/03 Oistrlbutioi,: Whit.a • Customer: C;,nary ... Finan.be: Pink - Js;,uing Department
133
x.f1n1ty Ac~ount Number

Billing Date 09/11/17
TotalAmount Due $71.99
Pi=!yment Due By 10(02/17
Page 1 of4
Contact us:cm) xfinlty;comlcustomersupport
Alfonso Leon
FQr seivfce a!:

236B SW 4TH ST
MIAMI FL 33135-3134
Tt)anks for choosing XFINITY from Comcast
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all of your XFINITY s1:1rvices,
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~.1n1ty Account Number

Payment Due By . 10/02/17
lfµndeliVflrabte, please return to:
141 NW 16TH ST POMPANO BEACH FL 33060"5250 Total Amount Due
8495 6000 NO RP 11 01ll22017 NNNNNYNN Oi il051i86 0020
Amount Enclosed
ALFONSO LEON
2368 SW 4TH ST
MiAMI, FL33135•3134
Make checks payable to Corncast,·and remit tQ address below
COMCAST
PO BOX 530098
ATLANTA GA 30353'0098
ol11ll11lu1ll1l1lll1l1ul1lt'h1111lllrliluli1llt11l1di11ll1
133
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BlllingDate 09/11/17
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Page 2 of4
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,
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Premium Channel, 1V E3ox and Perforrnance
Internet
Important Account Information
Service .Discount -24,96
For closed cl'iptioning concerns and other accessiblliiyissues
Total Bundied Services $49.99 .affecting customers with dlsabilities, can 855-270-0379, go . ~.:
. .•.
online for a 1iv1;1 chat at
https://www.xfinity.com/supporUaccount/accessibilily.services or . r
.
email accessibi!ity@comcast.com or write to Com~st n·or
John F Kennedy Blvd., Phila . .PA 19103-2838 Attn: S. Adams, or
Showtime 09/15 -10/14 0.00 fax: 1-866-599-4268. •
Included in Bundle.
Service To Addi()onal TV 09/15 -10/14 9.95 Accounts that are not paid in full by the due date are subject to a
$9.50fee.
\iVithTVBcix
TotalAdditional TV Service$ $9.95
Broadcast TV Fee
Total Other Charges & Credits $7.00
rv
State Communications SefVice Tax 2.62.
Local Communications.Service Tax 2.02
Sales Tax 0.32
1111111ml IIHllllllllllll 111
We're ready to help you When you need us.

Onflne
1111111m1111111111111111111~
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133
Account Number
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Totat Amount Due $71;99
Payment Due BY 09/01117
Page 1 of 2
Contact us:Ca) Xfinity.com/customersupport
Alfonso Leon
·For WNice at
2368 SW 4TH ST
MIAMI FL33135-31~4
Thanks for choosing XFINITY from Comcast
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all 9f your XFINliY .services.
For quick and convenient ways to manage your account, view

and pay your bill, please visit www.Xfinlty,com/myaccount
Detach and enelose this ooupon With your paymertt. Please Write yoor account hlimberon your check or money order. Do not send cash .
.>xf1n1ty Account Number

Payment Due ~Y 09/()1/11
If undeliverable, please return to:
141 ·NW 16TH ST POMPANO BeACH FL 33060-,:5250 Total Amount Due $71.99
.8495 eooo No RP 11.oatuoi'r NYNNNYNN Ol 002215 0011 Amount Enclosed $
ALFONSO LEON
2368 SW 4TH ST
MIAMI, FL33135-3134
Make checks payable to Comcast, and remit to address below
COMCAST
PO BOX 530098
ATLANTA GA 30353,0098
i'•11•ld'1''l'1•'1'''"1i1·1nlu·'•l'11''l•1'l'•h•Ptl1'l'1a1,
133
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B!lling·oate 08/11/17
Service Details Payment Oue By 09/01/17
Page2 of 2.
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, . • . . . ; : ; · ~ • - ; " " ' ~ ~ - - - ~ ·~ - - - - ·
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includes Limited Basie, Streampix, Selected Total Taxes, Surcharges & Fees $5.05
Premium Channel, TV Box and Performance
!nteml:lt
ta.npoiwnt Account Information
I
·Service Discount ,,24.96
For closed captioning concerns and other accessibility issues
Total Bundled Services $49.99 affecting customers With disabilities, call 855~270-0379, go
qnli ne for.a live chat at wwv, ;comcastsupport.com/accessibilijy
or email accessibility@comcast.com or write to Comcast 1701
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Service ToAdditlonal TV 08/15 "'09/14 9.95 be found at http:f/my.x~nity.com/contractrenewals/
W!th1VBox
Accounts that are not paid In full by the due date are subject to a
iotal Additiom1°! TV Services $9.95 $9,50fee.
Broadcast TV Fee 7.00

Total Other Charges & Cred[ts $7.00
i\l
State ·Communications Service Tax 2.62 --
• ~-- • ¥ ~-HH ·+ .:-~~~~;,,;u,-.:~~"~ ·, G' _,,.~~ •. _,....,,.,, .. ·~ •~• ,, ,· -.-. ·-~~ • ~· ·,,,. ."~ •• -~~~ ·,.~,,... : ,.,,_ '•""•" . ; •• .•: .-... , • • . •, ~-•••~~••• ·•n•• • ., .... _,,;;o.
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Local Commuhicalions Service Tax 2.02
Sales Tax 0.32
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We're ready to help you when you need us.

Online !11~111 ml 111! 111111111111H
xfinity.com/support
Bycapp Hearing/Speech Impaired Call 711

Use the My Account app. Download at xfinity.com/apps
By Phone
Call 1s800-934-6489 (H!OO XFINITY)
In Store
At your nearest XFINITY store
Find one atxfinity.com/storelocator
~Y chat
Visft xfinity.comfchat
133
@omcast~ Account Number

Billing Date 08/11/16
P1;1yment Dµe ay 09/01/16
Page 1 of2
Contact us: .xfinlty.coril -800-XFINITY (1-800-934-6489)
Alfonso Leon
'Previo
Fc,r seMce at: o°'i~ir
.,
2368 SW 4TH ST
MIAMI FL 33135.;a134
News from Comcast •. • -11·.
For quick anl:1 CQnvenient ways to rm~nage your account ~mi;! pay "'""~ -1~~~,/· •
~our bill, please Visit WWW:Xfinity.com/trlyaccount
4-1
Detach and enclose this coupon· wlth your payment Please write your account number on yoµr check cir money order, Do not $end ~s11.
@omcast Account Number

Pf3.Yrrient tlue .By 09/01/16
lf undeliverable, please return to:
141 NW 16TH ST. POMPANO BEACH,.Fl '33060-5250 Total Amount Due $53.37
&4!J!;i $QpQ NQ RP 11 {16122016 NNNNNNNN oi 8~9471 Amount Enclosed
ALFONSO LEON
2368 SW 4TH ST
MIAMI, FL 33135-3134
COMCAST
PO BOX 530098
ATl,.ANTA GA 30353..()098
133
@omcast~ Account Number

SillingOate 08111/16
•Total Amount bue $53.37
Service Details Payment Due By 09/01/16
Page 2ofZ
XFINl1Y 2175 Latino 08/15 • 09/14 69.95

Bundle Includes XFlNITY TV 150 Latino,
..... Digital.Converter and. Perrorm arice Internet···········-········~··· .......... .
Promo W/self Serve Dscnt ~24.96
Total 'XFiNITY Bundled Services $44.99
Broadcast TV Fee 5,00

Total Other Charges & Credits $5.00
TV
State Communications Service T.ax 1.79
Local Communication$ Service Tax 0
•-••••••••••••••••••••••••••••-••h••••"-••••• ••••••----••••••• •>•n••' ono••••••• •••••••••• ••••hH~ • ...... •-• H~•• ••••, ••••••h•
1.38
Sales Tax 0.13
~ - • • ? • • • · • • h • • , • - - - n - • • - - • o u • o n • • • n • • • - - - • - - • • • • • • • • • - - • • • " ••• ,• , • p r n • • • • n o n n n o n o H n n , h . n n o o ~ U • U u h • • • • • - - ~ •
. FCC Regulatory Fee. 0.08

Total Taxes, Surcharges & Fees $3.38
Important Account Information

The Broadcast TV .fee recovers a portion of the costs of
retransmitting television broadcastsslgnals.
Accounts that are not paid in full by the due date are subject to a
$9.S0fee.
llllfllllDlllllllllll lllllllll
For closed captioning concerns and other accessibility

issues affecting customers with disabilities, call
855-270-0379, go online for a Jive chat at
lllllllllllllllllll!lllllllll
www.corncastsupport.com/i;1ccessip1(ity or email
accessibility@comcastcom or write to Comcast, For Service Center locations near you, visit
1701 JohnF. Kennedy Blvd., Phila., PA 19103-2838 http ://customer.xfinity.com/service-center-locations
Attn: K. Wilkinson, or fax: 1-88:!:H312·'7402.
Hearing/Speecn l111p,3ired Call 711
133
ATTACHMENT K
133
Christina White
Date 11/13/2017 Supervisor of Elections Miami-Dade County, FL
Time 09:59 AM Voter Audit Report

VoterID 110117223 Leon, Alfonso M
Date Last Record ChangE Operator Number Audit Field Name Audit NewVal Audit OldVal
10/29/20 17 8:40: 27 AM elecfab4 ActyDt 10/29/2017 8 :40:27 AM 11/8/2016 12:00:00AM
6/15/2016 12:32:59PM ctejeda ActyDt 6/15/2016 12:32:59 PM 6/15/2016 12:00:00 AM
6/15/2016 12:32:5IPM ctejeda Numbr 2368111 187IIIAPTl2-1006
6/15/2016 12:32:51PM ctejeda CtyZp 20133135 20133125
6/15/2016 12:32:51PM ctejeda Stret SWl4Th1Stl NWISouth RiverlDrl
6/15/2016 12:32:51PM ctejeda ActyDt 6/15/2016 12:32:51 PM 3/15/2016 12:00:00 AM
6/15/2016 12:32:51PM ctejeda ,! Usps 86 76
6/15/2016 12:32:51PM ctejeda RePrc 596.0 _ 545.0
6/15/2016 12:32:51PM ctejeda FvrsLCD 06/15/2016 12:32:5 l:00(RG05) 10/23/2015 14:47:13:00 "('"""
5/24/2016 l:16:27AM GYURUBI CtyWd I 0)

0)
3/1/2016 I :50:41PM elecfab4 ActyDt 3/1/2016 1:50:41 PM l l /3/2015 12:00:00 AM
ro
12/15/2015 7:2 l:52PM ANGIER 584/8 Petn-Sig Accepted :VOTING RESTORATION AMEN a.
10/23/2015 2:47:12PM ROSELIN FvrsLCD 10/23/2015 14:47:13:00(RG05) 10/23/2015 14:45:36:00
10/23/2015 2:45:35PM ROSELIN CtyZp 20133125 34133176 ~
+-'
10/23/2015 2:45:35PM ROSELIN Stret NWJSouth RiverJDrl SWl124Th1Stl C
10/23/2015 2:45:35PM ROSELIN Numbr I 871IIAPTJ2-1006 0)
!0760111
l0/23/2015 2:45:35PM ROSELIN Usps 76 116 E
10/23/2015 2:45:35PM ROSELIN RePrc 545.0 756.0 ..c
u
10/23/2015 2:45:35PM ROSELIN FvrsLCD 10/23/2015 l 4:45:36:00(RG05) 05/26/2012 22:38: 16:00 ro
+-'
8/23/2014 l:05:25PM elecfab4 ActyDt 8/23/2014 1:05 :23 PM 11/6/2012 12:00:00 AM +-'
<(
5/26/2012 10:38: 17PM elecfab4 FvrsLCD 05/26/2012 22:38:16:00(BU0l) 05/09/2012 10:10:16:00
5/9/2012 I0:10:16AM elecfab4 FvrsLCD 05/09/201210:I0:16:00(BU0I) 04/29/2012 11 :07:34:00
4/29/2012 l l:07:35AM elecfab4 FvrsLCD 04/29/2012 11:07:34:00(BUOl) iiiiiiil3:14:l 7:00
8/26/2009 12:48:1 lAM FVRS/DAD SocSc ----
8/25/2009 11: 14: 17PM elecfab4 FvrsLCD 08/25/2009 23: 14: l 7:00(RG05) 07/09/2008 13 :3 0: 22: 00
7/9/2008 1:30:23PM watsond FvrsLCD 07/09/2008 13 :30:22:00(BU0 I) 05/19/2008 17: 16: 10:00
5/19/2008 5:16:1 lPM watsond FvrsLCD 05/19/2008 17: 16: 10:00(BU0 1) 02/17/2008 03: 17:37:00
Page
133
ATTACHMENT L
133
110117223, Leon, Alfonso M (Elections)
DAD 110117223 L+:Ol). J\!fon.s O f/ 236~\ SVV 4Th St, \-tarnL ~)3135
Elec# Date Name EViDSig Status/History
739 12/5/2017 EShore/EShore 1st Add Sec Grd N Voter's Precinct not voting
STDE
740 11/21/2017 Miami Run-Off Election N Eligible (MIDS)
737 11/7/2017 Miami General Municipal Election y Voted Early
715 11/8/2016 2016 General Election y Voted
714 8/30/2016 2016 Primary Election y Voted
699 3/15/2016 2016 Pres Preference Primary y Voted Early =··

0)
698 11/3/2015 Miami General Municipal Election y Voted u,
~
679 8/26/2014 2014 Primary Election y Voled Early ~
640 11/6/2012 2012 General Election N Voled -"'-=-

~
639 8/14/2012 2012 Primary Election N Voted
~
629 1/31/2012 Pres Preference Primary 2012 N Voted C:
..c
545 11/4/2008 2008 General Election N Voted u
ro
521 1/29/2008 PRESIDENTIAL PREF PRIMARY N Voted +-'
~-
483 11/7/2006 GENERAL ELECTION N Voted
479 9/5/2006 PRIMARY ELECTION N Voted
437 11/2/2004 GENERAL ELECTION N Voted
433 8/31/2004 PRIMARY ELECTION N Voted
\fetsi~.1r: '. 6DJ1~!(Ci

133
ATTACHMENT M
133
STATE OF FLORIDA
DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES
(DHSMV)
www.flhsmv.gov
•Driver Record # LS00-000-85-264-0

ALFONSO LEON
As of December OB, 2017 at 11:15:28 AM, Driver Privilege LS00-000-85-264-0 is VALID.
Personal Information Is Protected Pursuant To The Driver Privacy Protection Act~ Entries Below Are A Complete Record.
First Middle Last Suffix Date Of Birth Sex Height Race
ALFONSO LEON 07-24-1985 M 6' 0 11 Hispanic/
Latino
Residential Address County Mailing Address County
Unavailable 2368 SW 4TH ST MIAMI-DADE
MIAMI, FL 33135
"('"""
Current License Type
0)
Class E - Any non-commercial motor vehicles with Gross Vehicle Weight Rating less than 26,001 pounds, or any RV. 0)
Original License Issued Original CDL Issued Prior State and Driver License Number
ro
a.
08-10-2001 -
License Type Status Issue Date Expiration Date ~
License (Class E) Valid 08-23-2012 07-24-2020 +-'
C
Issuance History 0)
Class E Replacement Class E CDR/CDT Clearance 10-02-2006 Class E Address Change 01-14-2013
10-03-2002
Class E Replacement 07-02-2010 Class E Replacement 04-27-2016
E
Class E Replacement 04-30-2003 ..c
u
Exams ro
Vision Signs Rules Driving Motorcycle Rules Motorcycle Skills
:::::
<(
1 Attempt 1 Attempt 1 Attempt 1 Attempt 0 Attempts 0 Attempts
Pass Pass Pass Pass
08-23-2012 08-10-2001 08-10-2001 10-03-2002
Special Driver Information

REAL ID Compliant
Safe Driver
us Citizen
Blocked Personal Information
Blocked for Mailing List
Person has a Digital Image
Eligible to elect driver school. Driver has made 1 elections. Last election was on 04-26-2003. Violations committed while a
CDL Holder or in a CMV vehicle are not eligible for driving school election.
Correspondences
Action Date County State Citation Number Description
05-10-2003 MIAMI-DADE ADJUDICATION WITHHELD-CLERK CT (9)
CONV DATE: 04-26-2003
Page 1 of2
133
AMFER STATE OF FLORIDA

DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES
DA (DHSMV)
www.flhsmv.gov
Driver Record # LS00-000-85-264-0

ALFONSO LEON
Any Out Of State Traffic Violations Reported Will Be Reflected On The Driver Record And Points Assessed In Accordance With Florida Statutes.
Operation Of A Motor Vehicle Constitutes Consent To Any Sobriety Test Required By Law.
Replacement License Required Within 30 Days Of Address Or Name Change.
In Compliance With Section 322.201, F.S., J Robert R. Kynoch, Director, Division Of Motorist Services, Department Of Highway Safety And Motor Vehicles, State Of Florida, Do Hereby Certify
That I Am The Custodian Of The Records Of Said Division Of Motorist Services And That This Is A True And Correct Transcript Of The Above Named Subject's Driving Record As Taken
From The Official Records On File In This Department. N
0)
i2o1.lc R Wr~l~ : Director

0)
ro
a.
-
For Information On How To Read This Transcript Please Go To http://www.flhsmv.gov/ddl/readingfldriverrecord.pdf ~
+-'
For Frequently Asked Questions, Please Go To http://www.flhsmv.gov/ddl/abstract_questions.html C
0)
E
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ro
~
Page 2 of 2
133
ATTACHMENT N
133
City of Miami
APPLICATION FOR EMPLOYMENT
444 SW 2nd Ave., Suite 12~/Miami, Fl9rida 331_30
24-hour job hotline (305) 416-2050
VfWW, miamigov, i;:om/employment
Social Security t,io: Job Code/Position Applied For:

<~..'f 31 ) CHI 6 F ?vL-t (. l A};.V l so K
First Narne: Middle lnit.: Last Name: Former Surname (If Applicable):
At..Fo/JSo M L,£otJ Tir
Address (Stree1 Number and Name): City: State: Zip Code:
07(,p,O {..) 12- t'J,. ST. fY\ I A tn I FL. . :33i
Home Phone: Alternate Phone: E-Mail Address:
r-r (7S-(fJ.3'1-S·,og ,q ALEo·tJ@ f¾.1/\M I Gov, Cc>M
• Driver's License data rs only required·for jobs that require the operation of a motor vehicle.
Driver's.L[cense: 1)1 Yes O No 'Driver's License Number: _ "State: ~Typ_e of Ucense:
L- 50 o - 000 - 8fi - UJ 4- -o fl, UASSE-
Can you, ~ubmit proof of your legal right io won< in the United States? O Yes [J No
&1<'-Y~'•,,;'•'"tjil;il!t~:{f,"ffiiW,.i#;lt,l"'"°' ....,...."*-., •• t!l;.'"•····,w,,wiu,.;''·~,l<!'ll""~~---.---· ._ ...... .,"·='""' -,,,w,~;:.•fr\'/,,'>l,l,;;:'.(!;'-r.'i!i:\~•"'.il#i~f'@~~~----,o-tI.,7.i.ey

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Preferred Salary: Are you willing to relocate: ·vas □ No □ Maybe What type of job·are you looking for? ~ Regular Q Temporary
-- -- · -- · ~ ---· - -- - - - .. -- - .. _ _ ____ . . . ··- ....._.J~t§§aio..of!LO .!i:itirn~l\ip_
Types of work·you will accept: Full-time □ Part-time Cl Per Diem What shift are you available to work? UJ Day _!Iii Evening /iD Night
Jg) Rotating l?l Wslike_ric;l On call flJ
~11J~'.i"~IAffftW.t.~~~-if.ffl~?fr~'°t:~l!Wilf~lit~EDIJ'C~{l1oNrt!:'41~if.:1J,lll,ffl~i&i~~._.i~igjffi~~:'@i
F·ore\gn degrees IJ!U&t Ile accompanied by lranscrlpl evaluations performed by ac~rediled iJnils,
American.colleges or universities, or NACES approved credential evaluallon services, Earneq_
High School: City/State:
&>~L GA-BL ,.;_c f-(. S. G:,-ef\(.... ·:ABL _
Coltegii/Uriiversity:. City/State:
J\1 FL
FR_
TO: 'cOi 4-
'FROM:
TO: .
~~ :' ·--: '&~~-~~~~~fiWo'A~lEiP.ER'iENCE~~w,~J!rt.l[t'.~it~"'§~ii-1
Please list your work experience starting. wUh your presenter most recent employer, in as much deiait as possible. Ii you have held various positions
with the same employer, make a separate e·n1ry for each position held so that your application may b·e accurately evaluated. Please account for any
periods of no_n.-employmant graatenhan 3 mori~hs. Resumes may not be substlluted for appllcatlon forms, NOTE: Previous employers may be
qontaqted to verify information provided. •
Employer (Comp/lny/Agency name): Website,
C.1 o;:.
Malling Address of Employer: City: State: Zip Code:,
3600 Pit.Al l'MGf!.-lCl+/J hi2l 1/5 Ft..- 33133
Hrs, Per We_ek: Starting Sal;uy; Ending Salary: Dates-Employed:.
·From:
i{Q $ 55. O<!>Q $ --- mo.
Reason·fqr Leaving:·
t.., tbG (J}N,.
Sµpervisor's .NamefTitle:
/lllft1, Fi<ANI<. ~Ll-t>
Duties:, ·
bP-AH11v6-- Le&tSL-fl 1T'OJ\J I ';:<€:v1ew1/J6-C0114fl,1.t$51 'CJN At:GNDA-)
r,~112:Fuv&- a;,.1 lo.M1t1,5$rp-/J A&&J\/nPr .r.-reMS 'beve/..OP, 1\J6- Po.ue-ie 5
t;eve-u::i f' 11\J b ~e::sc,L,1.lrt .:,7',11 1 b·&,lBLJ>Pi N b-ofa:J I fV N'JCG-! 1 CR,,,AF-<1 Af&- 1
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u,f"IJVLl)/Vlry ·r;e.o&flAfw, 6-rccTee-A .
C HR/AL 023 Rev. 06109
Attachment N, page 1
133
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Employer (Company/Agency name}: Websile:
Ci TY D ,-::: /IA. I Af\,L/ -c1TY ATro P-Ne Vs oFPic.__6 j\A. i }\- IM-1 GOV, C,jM
Mailing Address of Employer: (
444
Phone Number:
S'w z. ,u:: AvG
I 3o--t- I
Hrs. Per Wee.k: s;arting Salary:
1Ci1~.
I
AM,
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Stale:
FL-
Dates Employed;.$
! Zip Code;
33i"'30
(~) I.fl~. 1000 From:

mo..
li•.3
year
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mo.
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.Job Code/Position TIiie: Reason for Leaving:
C.GfZ-Tt Pt Eb L..6"<::-AL- I tJTE,j?.,N !t.l6F-I.< 5TUt.:)\/ fof.?- L-lCeN~'G: 6KA1t--1
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, F£JJ6w Le&i s l---A--r,o/J / 1<eu,2w o t::-P I N A-N l€:;;.!i I 1/46-A L· "f!ES"€McCHi

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Empl9yer [Ccimp~ny/Agency name): Website:
Malling Address of Employer: State:

... -- - - ." - ... I Gil~: -. ····· -
~ ~ .. . 1-l_i~-~o~:: ·- .
Phone NLirr,~er:
( )
I firs. Per Week: I Stting·Salary: I
E;ding Salary: Dates Employ·ed:
Fiom;
mo.
I year To:
mo.
I
year
Job Code/fosition l)t_le: .Reason :for Le~virig:
Super.,lspfs Name/Tille:
DL!ties:
Employer (Company/Agency namEI): .Website:
Mailing Ad.dress of Employer: I City: Slate: • 1ZipCod~:
P~Pfl!! l'Ju.mber:
( )
I Hrs. Per WE!ek:
l ~tarting ~alary:
"$
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-$
Da\es Employed_:
Rrdm:
mo.
I vear To:
mo.
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·Job Code/Position Tille: Reason for Leaving:
Super.1isor's Name/Title;
Duties:
-·
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Page 2 ol 7
133
~~mr~1!ft~~~'W£1fr~i~~~~~~.i1.WPR.~E~f,Ef3IE~~-~J(?!;i.nJ.;)'.t~l~~~~~$~f,~~~11$~~~
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Mailing Address of E m , - I City: State: I Zip _CQ(le:
Phon(I Number:
( )
IHrs.PEil"-~
I Starling Salaiy:
$
I
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From:
mo,
1 year
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mo.
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~
JOQ Code/PQSilion Tille: Rea son for Leaving:
"'
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Duties:
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Type: l Avv L-1reNSE
Date issued: iO
mo,
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Date expi_res: --i-__
mo. :yea,~
License number Issuing agency:
J1q5·4-K rwTZ-1bA BAR
Typ·e; Date issued: I Date·expires:.
mo. voar
I mo,
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License number Issuing agency:
Type': Date Issued:

mo.
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mo~
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-~t~~~~~t~Ia.~te:a~~cei:r@i'siffli'fe:ii~f.s1~,-~-~K@'tfi6'sta:T~1'.iw1!riia1_1v'.~~itf1~J;~~~~~i&~
Reference type:: Jil Personal _O Piofessional
•
I bz. Vlcrni'<. r{,(J NI.ANO
Name: Posi_tion:
~Fc~S-9 R /cH1t,R
Address: (Stree1,. City, Slate, Zip C_ode) I
Phone:
E,Mail Address:. Vf!O/i/t/tAJo@BA~RY. EbU
78{.c . 3 3K". 102--7
Reference type: ~ Personal 9f. Professional IName: Position:
.;;:r, ·b1ANA V1ZLA-t/l.XJ .::JJDk:e
Address: (S1raat, City, State, Zip Code)
/6S§5 '5 i:5C:/t'I N 6 B LVb- M1 A-tl'll i="L 331~0
E-MaiLAddress: Phone:
hV iZ.Cth f\}a:;;;J..r,)b:J:!... Ft..-cot.l ,e,n . oR...6- t'.3()5. ?,5"1..j· S7'7Z...
Reference type:· ~Person·ar~ Professional j NaAme: PoslUon:
- . -1,..,1NA SOTO S7J4-rew,~':>8 ANA-L-.Ysr
Address: (Street, Ci!~, .Slate, Zip Code)
·.••' . ,, •< ,, . ., .. .. c"- ~ • .... •1
:
E-Mail Address: '~-1•
Phone:·
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Page 3 of7
133
t~,~.JM1J%1f.®~,J~ffilil~J¥?~~~~'kfft~G'ir~·¢'iiWi"Q~t9J.ie"Sffii.~§E~+rb~~r~~~~~~~~~~
1. Pleas·e enter your fomier name {If applicable} In its entirety, starting with the last name first. (e.g. Last Name, First Name}
2._Are you a Citize'n"of the U.S.A.? ~Yes Cl No ..,

(Som6 Qity o1 Mi,ml Jobs w_quire·citizenshipf
3. Drivers license issue date: 4. Driver's license expiration date:
?S' - Z."3 -z...a I],.. 7 - Z..4 - 2--0#0
. 5. Driver's l!clinse ri:istricllon·s: 6. Driver's license e[Jd9rseinent_s: SAFE
}Yi?-l Ve--12
7. Are you presently employed by the City of Miami? ~ Vas O No 8. Employee .Number: 4 Zt'.P 4;)-;!'i
mployee·Numbe, oan be lound on your CHy of 18ml paycheck. If you !Jo not.lmow your Employee
~ umber~ please conlact Y()ur 0.epartmenl Personnel.Liaison.] •
9, Have you ever worked for the Cily of Miami? □ Yes □ No 10. If you-answered. "Yes", please state the last date and departme·nt for which
Se;6- -r.f x·. you were employed: S f36 ; , /(:,.
11. Have ydu ever been tenninated from the City of Miami for cause? □ Yes I') No I
12. Florida Stale Statute 119.07 provides ce·rtain ·exemptions from public inspection of records for active amj_ former la~ ·enforcernei:it personnel, and
other calligorie·s outlined In Section 119.07 of the Florida State Statutes.
Do you,_ your spo~se or pare_n1(s) fall into one ofthe aforementioned categories? b Yes >('No
13•15; Do you haiie-any relative(s}, either by blood or by marriage who is/are employed by the City of Miami? :0 Yes~N□
Relatives include: lather, mother, son, daughier, brother, sister, uncle. aunt, first cousin, nephew. niece, husband, wife, father-in-law, ~ct~er,in•law.
son-in..faw, daughter-in-law, brolher-in-law, sister-in-law, stepfather, stepmother, stepson, siepdaughler, stepbro1her, stepsister, half broth"er or half ·s1sler:
Name:. Relation to You: Departmen1 Employed:
- . -- - . . - . -- ..... .. .. - -- ·- . .... --- - . -.
16. Have,you servad on active duty in the United States Mililary and received an tionorable discharge? 0 Yes~No
NliilCf. YOU MUST SUBMIT ALEGIBLE FORM DD-2H ANO OTHER RELEVANT DOCUMENTS CONCERNING Et.lGIBILITY FOR
VETERANS PREFERENCE. VETERAN'S PREFERENCE w·1LL_ BEA~ARDED ONLY IF YOU sus!-'i1T. WITH youR ll.PPLICATJON, A
LEGIBLE FORM DD-214 AND, JF APPLICABLE. PROOF OF A SERVICE-CONNECTED DISABILITY FROM A STATE APPROVED
AUTHOf'!ITY LESS THAN ONE. YEAR_ OLD [UNLESS A PERMANENT DISABILITY), BY THE JOB POSTING CLOSiNG DATE.
17: VETERAN'S PREFERENCE:
Under Section·295.07, Florida State Statutes eKtends ve1eran's preference to:
• A veteran with a servi~e-connacted disability who Is eligible tor or receiving _compensation, disability retiremenl, or p_ension under- public
laws admirifslered by lhe U.S. Department of Veterans Affairs and the Depallmenl of DefE.lnse.
• The-spouse oi. a veteran who cannot qualify for employment becausa of a total and permanent service-connecle.d disability, or l!l!l spo_us·e of a
veteran missing in- action, captured, or forcibly detained by a foreign power.
• A veteran of any war whQ has serve.d on active duty for one day or more during a wartime perio_d, excluqing a"c!ive duly lor training, and who
was discharged under honorable conditions from the Armed Forces or the United States of America.
... A veter~n-..vhq served honorably but who has no! met the criteria"for the award ol a campaign or expedltlonal)' medal-for sarvlce.lri Operation
End_uring Freedom (OEF) or Operation Iraqi Freedom (OIFJ, qualifies for preference in appoinlment. efreclive.July'1, 2007. This service.dates are
delin"ed as follows:
• Operation Enduring Freedom: October 7, 2001 to date to be determined.

- Operation lraqi Freedom: March 19, 2003 to date to be determined.
• The unmarri.ed widow or widower.of a veteran who died.of a:service connacted di~ability.
• Any armed forces E~peditionary Medal, as well as the Global War on Terrorism Expadi1io_naty Medal.
·oo you qualify for veteran's preference bas'ed on the categories oullined in this question? □ Yes .0 No
18. If you answered "'i'es\ Please select which category Is applicable to.yol.l.
0 EligiblE! for disabled veteran's preference • 30% or more

0 Ellgl~le for di~bled vele,rans preference • Less than 30"1~
□ Eiigible for non-disabi ed veteran's praference
:,,,,:'·-□··Spousa-ofa,permanently"disabled veteran,cor person-missing fn action (MIA) or-the unmarried :,vldcw[er) of,a veteran whose death was
' service conne"bted.
'
Pag~ 4 of 7
_j
iI Attachment N, page 4
I
I
133
lf~~.,,~Jlif.if..fu'®.~tl-Wftt.~l~~~~~~~t~Jf~.o~·Nc.;t{w.lP··)llO:~s;t,lPN~ri-a.'fiiJ·~~l'~le4.fi&~itl!f,ii_-~~
1_9 .. Have you·ever been convicted (found guilty) of a clime? □ YES NO
~A conviction does _not autom,atica(ly disqualily you from employment with t e ily of Ml~ml, Tha nature 9f the oHense, how long 1!90 1! occur,rey, relationship to \his
Job, ate., are taker Into con~iperat1on.)
2_0·22. NATURE OF OFFENSE(S). NAME &.LOCATION OF COURT DATE OF CON~ICTION{S)
#A
7
IAL0/\(6- ),I/A-
• II JtkJN'G iJ/g
I I, I /J()NF
23-25, Language proficiency: (check all that apply)
Language No proficiency Proficient in speakin_g Proll_climl"!n ~eadlng Proficient In w"ritlrig

Creole
Spanish
Other:
I h~reby certify tha! ~)I !he s!a!ements• made in this llPPlicatioh are true· and correct. I um;lerslarid tha_t t_tjis is an official docum~nt
open to public-inspec·tion, pursuant lo Floricla State Statute 119.07. I understand 1ha1 f must dem!:>nStrate that I meet the rilinimuin
re~uirements of the job, and futher understand th·at any exaggerated or false s1atement(s) or omission of requested informalion may
••• be :Cause for: my ~ppITcatfon fo b'e"rejectecf ?r, fiTiiave-b-een ·eii11iloyed:niaf be· ci:iuse· for.my teniiiriati6n~ or ·actiol'! ··purjuant"lp
Florida State Statute 838.022. By signing this application, I agree to authorize the use of any information ih this application to. verify
my s!_al!¾ments, and I authorize al! past employers, past educators-and references to release any and all information concerning my
previous employment and educatipnal records. By signing this documerit I authorjze.\ierification of my·bacligrbund and conviction
record, and I understand that in orderfor the City of Miami to comply with the Immigration Reform and Control Act cif 1986, any job
offered to me is conditional upon my·ability to establish identity and employment eligibilty under such Act. I andersiand that the.
appllc;ation and corresp_onding documents submitted as a part of the application process for employment with the City of Miami_.shall
become the property of the City of Miami.
.:3 I / l.t>
SIGNATURE 0 / AIIIT DATE
The City of Miaml is ari equal opportunity employer.
Page 5 of 7
133
You.r completion of this form will assist 1he City In compiling required Information for Equal Employment Opportunity (EEO)_, This data will
not be kept with the app!Jcation fo~m. no.r used in the decision to ·hire, Please complete ahd return with your ernJiloYment application.
Name: Last 4 Digils ·of Social-Security Number:

,A1..,foNSo /L1. Lh:5N 1TL 5Ta3Lf
Posllion Applied For: Dale f Applic,lion:
CH 1€F ?o L,.J CY
26. What is your ethnicity?
AbVISO R.
27. What is your gender? 28. What is your Age Group?
I3 / - ,lift
I
0 White (not of Hispanic Origin) OFemare 0 Under 15 years of age

0 f!lac~ (not of Hispanic O!'igln) .z$'Male 0 15•17 years of age
ja"Hisp_anic· 0 18 years of ·ag·e
0.A.slafVPacttlc Islander ,Al' 19.40 years of age
0 f\me'rican lnaian 0 41 years or age or more
29. What.is your national origin? /

Afl,16f2...1L,A-j\) Cl:JBA-AJ -A-M·~P..:.t (]t-N
30. Howwere you informed abouflhe vacancy for which yo..{are applying? {check cma)
0 Community Agency 0 Newspaper 0 Friend (non-City of-Miami employee).

0 Miamigov:com- .- - . 0. Careerbuilder.com 0-Job.Notilicalion Card..
Q City Employment Office/Jo~ Hornne 0 Joblng.cbril 0 Other _ _ _ _ _ _ _ __
0 0th·er Cily D~partment □ Governmentjobs.com
)ir'city of Miami Employee 0 Radio Station

0 Job Fair □ Billboard
Page 6 of7
EXHIBIT C
- -- - TIil LAW 01-n C or - --

RAMON J. DIEGO, PA
THll PRESTO B UILDI NG
5001 SOUTIIW EST 74 m COUR1', S UI"! l: 103
MlAl\11, l't.ORIDA 33155
RAMON J. D IEGO, l:SQ. T f;Ll:l'IIONf. 305-350-3102

ALE\JS A. F ERRO, ESQ. J!ACSIMILE 305-350-3103
Al l;XAN ORA CASALS, E SQ. RAMOi'.i ERJ DI t GOI.A \'\".C0\-1
April 14.2023
Invitation Homes Emailed to: efernandez@invationhomes.com

600 N. Pine Island Road, Suite I 00 Mailed: Regular & Ce11ified
Plantation, Florida 33324
Attn: Liz Fernandez
RE: Notice of Termination of Tenancy Without Specific Notice

Property Address: 1521 SW 10th Street
This firm represents Joseph and Maijo rie Carollo. They are month-to-month tenants of the above-
described premises with a rental period beg inning on the Is, of each month.
As you are aware and were notified, the property is in dire need of repair for damages caused by past
water intrusion. Said damages include, but are not limited to, mold, swelling of the walls and interior paint
peeling from excess humidity. Invitation homes has not addressed or repaired the damages since my clients are
living in the premises. Mr. Caro llo, who has not suffered from asthma since he was 7 years old, is now suffering
from asthma due to the described conditions inside. While you should have evidence of the above through
pictures your representative took, we are more than able to provide more.
Pursuant to Florida Statue Section 83.57, you are hereby notified that as tenants they are hereby
terminating their tenancy, vacating the premises, and surrendering same to you as the landlord, o r agent for
same on or before April 29, 2023.
Please be advised, and take this letter as official notice, that we are hereby demanding my client' s
security deposit be returned upon your ins pection of the property to our firm upon vacancy of the premises.
EXHIBIT D
Filing# 66899579 E-Filed 01/23/2018 01:02: 19 PM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL

CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA
GENERAL CIVIL DIVISION
CASE NO. 2017-026678-CA-0l (13)
ALFONSO "ALFIE" LEON,

Plaintiff,
vs.
JOE CAROLLO; TODD HANNON;

CHRISTINA WHITE; and THE CITY OF
MIAMI CANVASSING BOARD,
Defendants.
- - - - - - - - - - - - - - - ~I
NOTICE OF FILING TRANSCRIPT OF COURT FINAL RULING

ON JANUARY 22, 2018
Commissioner Joe Carollo submits this notice attaching the
transcript of the complete court proceedings on January 22, 2018,
containing the Court's final ruling announced in open court.
Respectfully submitted,
BENEDICT P. KUEHNE
MICHAELT. DAVIS
KUEHNE DAVIS LAW, P.A.
100 S.E. 2 St., Suite 3550
Miami, FL 33131-2154
efiling@kuehne@kuehnelaw.com
ben.kuehne@kuehnelaw.com
mdavis@kuehnelaw.com

BENEDICT P. KUEHNE
Page 1 of 2
I certify the foregoing was emailed on January 23, 2018, to
Juan-Carlos "J.C." Planas Victoria Mendez, City Attorney

Matthew Sarelson Forrest L. Andrews, Jr., Assist. City
Justin Kaplan Attorney
KYMP George K. Wysong, III, Assist. City
Brickell World Plaza, Suite 1715 Attorney
600 Brickell Ave. 444 S.W. 2nd Avenue, Suite 945
Miami, FL 33131 Miami, FL 33130-1910
jcplanas@kymplaw.com Tel.: (305) 416-1800
msarelson@kymplaw.com Fax: (305) 416-1801
jkaplan@kymplaw.com flandrewsjr@miamigov.com
GKWysong@miamigov.com
Oren Rosenthal aidagarcia@miamigov.com
Michael B. Valdes pcabrera@miami-police.org
Assistant County Attorneys vmendez@miamigov.com
Attorneys for Christina White
111 N.W. 1st Street, Suite 2810
orosent@miamidade.gov
mbv@miamidade.gov

BENEDICT P. KUEHNE
Page 2 of 2
613
1 certified the winner of that election on
2 November 27, 2017.
3 On December 5th, Mr. Leon filed what
4 is now this election contest, turning this
5 case into an election contest. However, as
6 I've indicated, the only way that I can
7 construe this case is a challenge to the
8 qualifications of Mr. Carollo, which cannot
9 be brought post election.
10 There has been no challenge. And even
11 if there was a challenge to his eligibility
12 to hold the office of city commissioner, it
13 is undisputed that certainly as of the time
14 he was sworn in, he has resided in the
15 district.
16 So I will dismiss Mr. Leon's amended
17 complaint for lack of subject matter
18 jurisdiction under Burns versus Tondreau.
19 It is clear that post-election challenges
20 even absent Burns versus Tondreau are
21 disfavored and the time to bring them is
22 prior to the election.
23 In the event that the Third District
24 Court of Appeal disagrees with me with
25 respect to my finding that this amended
BRICKELL, GOMBERG & ASSOCIATES, INC.

954.522.0067 bgsupport@aol .com 305.949.5814
621
1 STATE OF FLORIDA
2 COUNTY OF MIAMI-DADE
4 I, RHONDA BONNER, a Registered
5 Professional Reporter, Florida Professional
6 Reporter, was hereby authorized to take in
7 Shorthand the aforementioned hearing before THE
8 HONORABLE THOMAS J. REBULL; and that the foregoing
9 pages, numbers 1 through 16, inclusive, constitute
10 a true and correct transcript of my shorthand
11 notes.
12 I further certify that I am not of
13 counsel, I am not employed by nor related to an
14 attorney to this suit, and I am not financially
15 interested in the outcome thereof.
16
17
18
19 RHONDA BONNER
REGISTERED PROFESSIONAL REPORTER
20 FLORIDA PROFESSIONAL REPORTER
21
22
23
24
25
BRICKELL, GOMBERG & ASSOCIATES, INC.

954.522.0067 bgsupport@aol .com 305.949.5814
EXHIBIT E
1 5

2 (FORT LAUDERDALE)
CASE NO. 18-CV-24190
3
4 WILLIAM FULLER and

MARTIN PINILLA, II,
5 Plaintiffs, Fort Lauderdale, Florida
vs. May 3, 2023
6
JOE CAROLLO,
7 Defendant.
--------------------------------------------------------
8 Trial Day 12
BEFORE THE HONORABLE RODNEY SMITH
9 UNITED STATES DISTRICT JUDGE
10 APPEARANCES:
FOR THE PLAINTIFFS: AXS LAW GROUP, by:
11 Jeffrey W. Gutchess, Esq.,
Courtney Anne Caprio, Esq.,
12 Joanna Niworowski, Esq.
Amanda Suarez, Esq.
13 2121 NW 2nd Avenue, Suite 201
14
15 FOR THE DEFENDANT: KRINZMAN, HUSS,

LUBETSKY, FELDMAN & HOTTE, by:
16 Mason A. Pertnoy, Esq.,
169 E. Flagler Street, Suite 500
18 KUEHNE DAVIS LAW, by:

Benedict P. Kuehne, Esq.
19 100 S.E. 2nd Street, Suite 3105
20
SHUTTS & BOWEN, by:
21 Marc D. Sarnoff, Esq.
200 S. Biscayne Blvd., Suite 4100
23
24
25
Case 1:18-cv-24190-RS Document 632-5 Entered on FLSD Docket 02/22/2024 Page 312
of 5
1 Q. Did FDLE ask for any followup, if you recall?
2 A. I believe they did, but I'm not all sure of what they
3 asked for, but there were extra things that I was asked for.
4 Q. And did you leave it to FDLE to do whatever its job was?
5 A. Absolutely did.
6 Q. And now you were asked about the -- about your, if you
7 remember walking through the district, being in the district,
8 being with city are officials and others. Do you recall that?
9 A. Yes.
10 Q. How unusual was that, if at all, walking through the
11 district?
12 A. None whatsoever. I was living in the district. In fact,
13 from Calle Ocho, the main business district, my wife had found
14 a pretty little small house that she decided that's where she
15 wanted to move to, and we rented it and that was only a block
16 and a half from 8th Street.
17 Q. Was it common for you to be in the district as a
18 District 3 representative?
19 A. Very much so. I would eat in the same places that my
20 constituents would eat, I would shop in the same shopping, the
21 supermarkets there.
22 Q. Would you talk to voters as well as business people?
23 A. Oh, certainly. I mean, every time I went out, voters,
24 residents were approaching me and talking to me, giving me
25 information about this, about that, praising, complaining, the

Case 1:18-cv-24190-RS Document 632-5 Entered on FLSD Docket 02/22/2024 Page 413
of 5
1 usual.
2 Q. Was that aspect important to your service to the district?
3 A. Very much so. Because that's how you know what is
4 happening into your neighborhood by being part of it. By, you
5 know, eating, shopping, using the different services that
6 everyone in your district uses, where they shop at, where they
7 eat at. That's where we receive the most impact, most
8 information from your residents in the district.
9 Q. Did you, as a result of what you described, your
10 involvement in the district, pass along information to city
11 officials?
12 A. Yes. Information was passed to city officials sometimes
13 through me, sometimes I told my office to pass it along to
14 them.
15 Q. Why did you do that?
16 A. Well, that's a part of what I'm supposed to do. That's
17 part of your duty as a commissioner. If you're not doing that,
18 then you're not doing your job. You're not listening to the
19 people that elected you.
20 Q. Did you pass along good things as well as not so good
21 things?
22 A. Yes. For the most part, what you're going to pass along
23 are going to be complaints from residents. But, yes, I would
24 imagine at different times, there were praises too that were
25 given on different things.

Case 1:18-cv-24190-RS Document 632-5 Entered on FLSD Docket 02/22/2024 Page117
5 of 5
1 looks like.
2 THE COURT: Thank you.
3 MR. GUTCHESS: I'm not exactly sure, Your Honor. Let
4 me look at my notes as to who would be next.
5 THE COURT: Okay.
6 MR. GUTCHESS: We have Martin Pinilla next, but maybe
7 we'll call City Attorney Vicky Mendez.
8 THE COURT: And who else?
9 MR. GUTCHESS: Then we have Mr. Fuller, Ms. Bernheim
10 and Joe Napoli, the Assistant City Manager.
11 THE COURT: Those are your remaining witnesses?
12 MR. GUTCHESS: Yep.
13 THE COURT: All right. Thank you.
14 (Thereupon, this proceeding was adjourned at 12:02 p.m.)
15 - - -
16 C-E-R-T-I-F-I-C-A-T-E
17
18 I hereby certify that the foregoing is an accurate
19 transcription of the proceedings in the above-entitled matter.
20
21 JULY 20, 2023 /s:/Ellen A. Rassie___________________

ELLEN A. RASSIE, RMR-CRR
22 Official Court Reporter
To the Honorable Rodney Smith
23 299 East Broward Blvd., Room 202B
Fort Lauderdale, Florida 33301
24 (954)769-5448
25
EXHIBIT F
Commissioner Joseph Carollo· Confidential
February 06, 2023
U.S. Legal Support | www.uslegalsupport.com ·

February 06, 2023
10:15AM ·1· · · · · · ·MS. FEHRETDINOV:· Is there anyone on Zoom?· If
10:15AM ·2· · · · you can please announce for the record.
10:15AM ·3· · · · · · ·MS. MCNULTY:· This is Kerri McNulty on behalf
10:15AM ·4· · · · of the City of Miami.
10:15AM ·5· · · · · · ·MS. GRALIA:· Maria Gralia with Stearns,
10:15AM ·6· · · · Weaver, Miller.
10:15AM ·7· · · · · · ·MR. THORNTON:· Ryan Thornton, Stearns, Weaver,
10:15AM ·8· · · · Miller.
10:15AM ·9· · · · · · ·MS. BERNHEIM:· Melissa Bernheim, non-party.
10:15AM 10· · · · · · ·MS. MENDEZ:· Victoria Mendez, City of Miami.
10:15AM 11· · · · · · ·MS. FEHRETDINOV:· Is there anyone else on the
10:15AM 12· · · · Zoom?
10:15AM 13· · · · · · ·MR. GUTCHESS:· Jeff Gutchess on behalf of Bill
10:16AM 14· · · · Fuller.
10:16AM 15· · · · · · · · · · · · -· - -
10:16AM 16· ·Thereupon,
10:16AM 17· · · · · · · · (COMMISSIONER JOSEPH CAROLLO)
10:16AM 18· · · · · · ·having been first duly sworn or affirmed,
10:16AM 19· ·was examined and testified as follows:
10:16AM 20· · · · · · · · · · · DIRECT EXAMINATION
10:16AM 21· ·BY MS. FEHRETDINOV
10:16AM 22· · · · Q.· ·Mr. Carollo, could you please state your full
10:16AM 23· ·name for the record?
10:16AM 24· · · · A.· ·Joe Carollo.
10:16AM 25· · · · Q.· ·Joseph Javier Carollo?
U.S. Legal Support | www.uslegalsupport.com 7

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EXHIBIT G
Page 1

2
CASE NO. 1:18-cv-24190
3
4 WILLIAM O. FULLER, and
MARTIN PINILLA, II,
5
Plaintiffs,
6
vs.
7
JOE CAROLLO,
8
Defendant.
9 _________________________________________
10
11 VIDEOTAPED DEPOSITION OF
12 JOSEPH X. CAROLLO
13
14
15 Tuesday, March 21st, 2023
10:16 a.m. to 6:33 p.m.
16 2121 Northwest 2nd Avenue
Suite 201
18
19
20
21
22 Taken on behalf of the Plaintiffs before
23 Mayra Texeira, Shorthand Reporter and Notary Public
24 in and for the State of Florida at Large, pursuant
25 to Notice of Taking Deposition in the above cause.
Veritext Legal Solutions

800-726-7007 305-376-8800
Page 42
1 A. Sir, we live in America. Thank God we're

2 here. Everyone has a right to support whoever they
3 want to support.
4 Q. And it's wrong to retaliate against them
5 for that. Right?
6 MR. PERTNOY: Object to form.
7 A. I've stated already I have not retaliated,
8 targeted, as you stated, your clients.
9 Q. Do you own a home?
10 A. I own a property, sir.
11 Q. What is the address?
12 A. I'm trying to remember the address. It's
13 on Morris Lane. I'm sorry. I can't remember the
14 numbers right now.
15 Q. What year did you purchase it?
16 A. To the best of my recollection, it was
17 2002, in the beginning. I don't know if it was
18 January or February 2002.
19 Q. And how long did you reside there?
20 A. I resided there until 2016.
21 Q. And you then rented an apartment on
22 Brickell Avenue for purposes of running for city
23 commissioner?
25 A. Yes, sir.

800-726-7007 305-376-8800
Page 43
1 Q. Okay. And when you ran for city

2 commissioner where did you reside?
4 A. I'm --
5 Q. Just in what building?
6 A. Okay. You want the address? It was an
7 apartment building on 10th Street in West Brickell.
8 I don't remember the address.
9 Q. And are you aware of anyone else who might
10 have owned a home outside of District 3 who also
11 owned a home inside District 3 during that election?
13 A. I don't understand what the question is.
14 Q. You had your homestead, which was out --
15 which district was it in, District 2?
16 A. District 2 is where I had the homestead.
17 Q. Right.
18 A. But homestead, you get it at the beginning
19 of the year even if you move later on in the year.
20 Q. Right.
21 A. As long as you're residing there in the
22 first of the year you get homestead. If you move any
23 time after you're still gonna get it.
24 Q. I understand that. But you owned a house
25 in District 2 and you rented in District 3. Correct?

800-726-7007 305-376-8800
Page 44
1 A. I did. Yes. For the purpose of running for

2 commissioner in District 3.
3 Q. And you voted in District 3. Correct?
4 A. Yes.
5 Q. Who did you vote for?
6 A. You really want me to answer that?
7 Q. Please.
8 A. Well --
10 Q. Who is Bill Fuller?
11 A. Your client.
12 Q. And did you first meet Bill Fuller when
13 you were running for commissioner?
14 A. That's correct.
15 Q. Did you want Bill Fuller's vote?
16 A. I didn't know that Mr. Fuller resided in
17 my district when I met with him. I didn't know where
18 he resided period. And most of the owners of
19 business in my district, for the most part, don't
20 reside in my district.
21 Q. Did you want Mr. Fuller's support for your
22 political campaign?
24 A. Politics is the art of adding, not
25 subtracting. Whether you're running for office,

800-726-7007 305-376-8800
Page 269
1 CERTIFICATE OF OATH
2
3 STATE OF FLORIDA )
4
5
6 I, Mayra Texeira, Court Reporter and Notary
7 Public in and for the State of Florida at Large,
8 certify that the witness, JOSEPH X. CAROLLO,
9 personally appeared before me on March 21st, 2023
10 and was duly sworn by me.
11
12 Signed this 29th day of March, 2023.
13
14
15
16
<%20039,Signature%>
17
________________________________
18 MAYRA TEXEIRA, Court Reporter
19 Notary Public - State of Florida
20 COMMISSION NO. HH 12099
21 EXPIRES JUNE 26, 2024
22
23
24
25

800-726-7007 305-376-8800
Page 270
1 CERTIFICATE OF REPORTER
2
3 STATE OF FLORIDA )
4
5 I, MAYRA TEXEIRA, Court Reporter, do hereby
6 certify that I was authorized to and did
7 stenographically report the deposition of
8 JOSEPH X. CAROLLO; that a review of the transcript
9 was not waived; and that the foregoing transcript,
10 pages 1 through 265, is a true and complete record
11 of my stenographic notes.
12 I FURTHER CERTIFY that I am not a relative,
13 employee, attorney or counsel of any of the parties,
14 nor am I a relative or employee of any of the
15 parties' attorney or counsel connected with the
16 action, nor am I financially interested in the
17 action.
18 Dated this 29th day of March, 2023.
19
20 <%20039,Signature%>
21 ________________________________
22 MAYRA TEXEIRA, Court Reporter
23
24
25

800-726-7007 305-376-8800
EXHIBIT H

Response Re Motion To Stay

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Case 1:18-cv-24190-RS Document 632 Entered on FLSD Docket 02/22/2024 Page 1 of 19

UNITED STATES DISTRICT COURT

WILLIAM O. FULLER, and

PLAINTIFFS’ OPPOSITION TO DEFENDANT’S

A. Carollo Abandons the Morris Lane Property as His Homestead

Q. What year did you purchase it?

documents will be produced or a certificate of completion issue[d],” merely indicating in vague

Dated: February 22, 2024

AXS LAW GROUP, PLLC

By: /s/ Jeffrey W. Gutchess

Counsel for Plaintiffs

By: /s/ Jeffrey Gutchess

Counsel for Plaintiffs

1 UNITED STATES DISTRICT COURT

13 FOR THE PLAINTIFF, ACLU,

18 FOR THE PLAINTIFF: CHRISTOPHER J. MERKEN, ESQ.

3 minor consideration in drawing the entirety of District 3,

5 A. In drawing the entirety of District 3, yes.

7 A. It was a consideration, though.

8 Q. Okay. A consideration with respect to moving this area

9 south of U.S. 1 into District 3?

11 Q. Okay. Now the Commission never gave a you public

12 instruction to redraw District 3 and extend it south of U.S. 1

13 to include Commissioner Carollo's house in the district, right?

14 A. No. The Commission gave instructions to go south of U.S.

15 1, as needed, to equalize population. There was never an

16 instruction of what -- if that's what you are referring to --

17 there wasn't an instruction of get Commissioner Carollo's house

19 Q. And in fact, the reason the Commission expressed publicly

20 for moving District 3 south of U.S. 1 was that you needed to

21 reach south of U.S. 1 because that's where the Hispanic voters

24 Q. I will read from the transcript, which is Plaintiffs'

25 Exhibit 2, from one of the 2021 meetings, which is Commissioner

2 "Is there a problem with splitting Coconut Grove as an

3 entity based on where the Hispanic voters live? Is there an

4 issue with that?"

5 Do you remember him asking you that?

6 A. I have no recollection of that, but I wouldn't contest it.

7 Q. Okay. And you won't say whether Commissioner Carollo or

8 his staff privately instructed you to draw his home into

10 A. I could not comment on attorney/client conversations. What

13 commissioner's house was, and whether the commissioner can

14 homestead the house or not. And, I was very aware that he

15 lived where he -- that he owned a house in that area right

18 A. Basically, yes. I actually did not draw his home in my

20 on, when I saw all the newspaper accounts, etcetera, I thought

21 yes, that would make him happy.

22 Q. Okay. You also mentioned during the June 1, 2023,

23 commission meeting that you preserved Little Havana intact in

24 District 3. Do you remember that?

25 A. I believe so, yes.

1 Q. And you decided to preserve Little Havana in District 3

2 because it had previously been in District 3, right?

4 Q. So, you decided it was preferable to preserve Little Havana

5 in District 3 rather than moving it into a different district,

7 A. I believe so, yes.

8 Q. Moving on to Page 10 of this exhibit, there is District 5

9 in Version 12. We have already gone through all of the border

10 with District 1. If we could zoom in on the southern portion

11 of the downtown area --

12 Now, this proposed District 5, the border is in District 2,

14 boundary runs north along Northeast or Southeast 2nd Avenue,

15 and then jogs inland a few blocks.