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R10A-City Attorneys Status ReportMIAMIBEACH City of Miomi Beoch, 1700 Convention Center Drive, Miomi Beoch, Florido 33,l 39, www.miomibeochfl.gov COMMISSION MEMORANDUM TO: Mayor Philip Levine and Members of the City Commission ( FRoM: Raul Aguila, City Attorn"rA.l_0yJ - DATE: September 2,2015 SUBJECT: City Attorney's Status Report LAWSUITS FILED BY OR AGAINST THE CITY OF MIAMI BEACH SINCE THE LAST REPORT 1. Pedro J. Garcia vs The Citv of Miami Beach, et al.. Case No. 15-14329 CA22 (Circuit Court - 11th Judicial Circuit in and for Miami-Dade County, Florida) This is an action for Declaratory Relief in connection with the V.A.B. adoption of the recommendation of the Special Magistrate's determination that the valuation of the real property located at 340 23 Street, Miami Beach, Florida is zero. The Summons and Complaint for Declaratory Relief were served on the City on July 29, 2015. The City's Answer, Affirmative Defenses and Counterclaim was timely filed. 2. Positive Solutions. LLC vs Jose Miquel Moreno. etc. et al.. Case No. 15-16703 luOiciai Circuit in and for Miami-Dade County, Florida) This is an action to foreclose a mortgage on real property located 15964 SW 102 Lane, Miami, Florida. The Summons and Verified Complaint were served on the City on July 29, 2015. The City's Answer and Affirmative Defense, asserting satisfaction of lien was filed on August 6,2015. 3. Rachel Fleischmann vs Cookies & Crackers, etc. et al., Case No. 15-15249 CA 21 (Circuit Court - 11th Judicial Circuit in and for Miami-Dade County, Florida) This is an action to quiet title on real property located 1680 NE 191 Street, Unit 209-2, North Miami Beach, Florida. The Summons and Complaint were served on the City on July 29, 2015. The City's Answer and Affirmative Defense was filed on August 6, 2015. Agenda ttem Rl0ADate cl -2-l{1101 City Attomey's Repoft September 2, 2015 Page 2 Case No. 15-016900 CA 01 (Circuit Court - 11 Miami-Dade County, Florida) RA\SR\EB\T F :\ATTO\MOFF\AAOFF\F I LE.#S\20 1 s\Status Report CAO 0902 1 5. docx vs Roosevelt Case No. 15-17439 CA 24 (Circuit Court - 11'n Judicial Circuit in and for Miami-Dade County, Florida) This is an action to foreclose a mortgage on real property located 750 Collins Avenue, Unit 203, Miami Beach, Florida. The Summons and Second Amended Verified Complaint were served on the City on August 6,2015. The City's Answer and Affirmative Defense, asserting priority for any special assessments, including, but not limited to, utility water and sewer services, demolition or board-up liens, and resort taxes was filed on August 13,2015. Trust 1. etc.. vs lnna Klavkina. et al., Case No. 15-17675 CA 13lsesv ls. vt gtr. vggv !!v. lv L v, v vi (Circuit Court - 11th Judicial Circuit in and for Miami-Dade County, Florida) This is an action to foreclose a mortgage on real property located 11655 NE 18 Drive, Miami, Florida. The Summons and Verified Complaint were served on the City on August 18, 2015. The City's Answer and Affirmative Defense, asserting priority for any special assessments, including, but not limited to, utility water and sewer services, demolition or board-up liens, and resort taxes will be timely filed. V. Judicial Circuit in and for Plaintiff is alleging that on December 12, 2014, a City of Miami Beach employee, was operating a 2011 ambulance at or near the intersection of Abbott Avenue (SR A1A) and 71"t Street (SR 934) in Miami Beach when he negligently operated and/or maintained said vehicle so that it collided with the Plaintiff, resulting in injury, wage loss and loss of consortium. We shall file our answer and propound discovery to the Plaintiffs. The police report of the crash indicates that the ambulance had its light and sirens on when it entered the intersection and the Plaintiff, driving a yellow cab, failed to yield the right of way to an emergency vehicle transporting a stabbing victim to Ryder Trauma Center. 1102