LTC 400-2018 Natalie Nichols vs. City of Miami Beach, Florida, Dan Gelber, Micky Steinberg, Mark Samuelian, Michael Gongora, Kristen Rosen Gonzalez, Ricky Arriola, and JOhn Elizabeth Aleman. 11th Judicial Circuit Court Case No. 2018-021933 CA 01 l '
MIAMI BEACH
OFFICE OF THE CITY ATTORNEY LETTER TO COMMISSION
LTC No. 400-2018
TO: Mayor Dan Gelber
Members of the City Commission
City Manager Jimmy L. Morales
FROM: City Attorney Raul J. Aguilag.. .,
DATE: July 18, 2018
SUBJECT: Natalie Nichols vs. City of Miami Beach, Florida, Dan Gelber, Mickey Steinberg.
Mark Samuelian. Michel Gongora. Kristen Rosen Gonzalez. Ricky Arriola. and
John Elizabeth Aleman.
11th Judicial Circuit Court Case No. 2018-021933 CA 01
The purpose of this Letter to Commission is to provide formal notification to the Mayor and City
Commission that the above-subject lawsuit was served upon the City of Miami Beach (and each
individual Commissioner) on July 18, 2018.
The City Attorney's Office will be thoroughly reviewing those allegations set forth and identified
within the lawsuit, and will be providing further detailed information surrounding the
circumstances of this matter. Preliminarily, the City Attorney's Office considers any allegations
that seek to challenge the City's Ordinance(s) to be wholly improper. and would be devoid of
any legal merit. The lawsuit is a futile endeavor, which was inappropriately initiated. in order to
excuse the unlawful conduct of the Plaintiff.
Please direct any inquiries regarding this matter to Aleksandr Boksner. Chief Deputy City
Attorney, and it is hereby recommended that no further statements should be issued on the
subject lawsuit.
RJA/AB/sc