Exhibit 9

Case 1:22-cv-23196-PCH Document 46-9 Entered on FLSD Docket 08/16/2023 Page 1 of 4
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

Case No. 1:22-CV-23196-HUCK/Becerra

JOHN F. LABRIOLA

 Plaintiff,

v.

MIAMI-DADE COUNTY,

 

 Defendant.

_____________________________/

DEFENDANT’S RESPONSES AND OBJECTIONS TO PLAINTIFF’S REQUESTS FOR 

PRODUCTION OF DOCUMENTS

Defendant, Miami-Dade County (“Defendant” and/or “MDC”), pursuant to Rule 34 of the 

Federal Rules of Civil Procedure, hereby serves its Responses and Objections to Plaintiffs’ First 

Request for Production of Documents.

Dated: April 24, 2023 Respectfully submitted,

GERALDINE BONZON-KEENAN

Miami-Dade County Attorney

Stephen P. Clark Center

111 N.W. 1st Street, Suite 2810

Miami, FL 33128

By: /s/ William X. Candela

William X. Candela 

Florida Bar No. 759317

E-mail: wxc@miamidade.gov

Assistant County Attorney

Andrea S. de Oña

Assistant County Attorney 

Florida Bar No. 1019568

Email: Andrea.deona@miamidade.gov

Case 1:22-cv-23196-PCH Document 46-9 Entered on FLSD Docket 08/16/2023 Page 2 of 4
2

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the date shown above a true and correct copy of the 

foregoing was served on all counsel of record via electronic mail. 

/s/ William X. Candela

William X. Candela 

SERVICE LIST

Alexander Bumbu, Esq.

Florida Bar No. 1024989

1021 Ives Dairy Road

Bldg. 3, Suite 115

Miami, FL 33131

Tel: (786) 496-3946

Email: abumbu@pji.org

Attorneys for Plaintiff

Served via electronic mail 

William X. Candela 

Assistant County Attorney

Florida Bar No. 759317

Miami-Dade County Attorney’s Office

Stephen P. Clark Center

111 N.W. 1st Street, Suite 2810

Miami, FL 33128

Tel: (305) 375-5151

Fax: (305) 375-5634

Email: wxc@miamidade.gov

Attorney for Defendant

No Service Made 

Andrea S. de Oña 

Assistant County Attorney

Florida Bar No. 1019568

Miami-Dade County Attorney’s Office

Stephen P. Clark Center

111 N.W. 1st Street, Suite 2810

Miami, FL 33128

Tel: (305) 375-5151

Fax: (305) 375-5634

Email: andreadeona@miamidade.gov 

Attorney for Defendant

No Service Made

Case 1:22-cv-23196-PCH Document 46-9 Entered on FLSD Docket 08/16/2023 Page 3 of 4
5

REQUESTS FOR PRODUCTION OF DOCUMENTS

1. On March 5, 2021, Labriola was issued a Disciplinary Action Report (DAR) wherein he 

was ordered by then-Chairman Díaz to participate in anti-discrimination training. Please produce:

a. All documents showing the specific kind(s) of anti-discrimination training that 

Labriola would have had to undergo, including questions, answers, and the training

module(s) for that/those kind(s) of anti-discrimination training.

b. All documents showing the kinds of anti-discrimination training that Labriola has 

participated in in the past, including questions, answers, and the training module(s) 

for that/those kind(s) of anti-discrimination training.

c. The training modules for each type of anti-discrimination training that the County 

conducts.

RESPONSE: Defendant objects to this Request to the extent that it is overly broad, unduly 

burdensome, not reasonably limited in temporal scope, and not reasonably calculated to 

lead to admissible evidence because the Request asks for “all documents” and “each type 

of anti-discrimination training” with no time and no limitation that would make these 

records relevant to the lawsuit. Subject to the above objections, Defendant refers Plaintiff 

to MDC_000001-31.

2. Please produce documents showing all the County employees who were required to 

undergo “diversity training” or “anti-discrimination training” between March 1, 2021 (inclusive) 

and April 14, 2021 (inclusive) and the reason(s) they were required to do so.

RESPONSE: Defendant objects to this Request to the extent that it is overly broad and 

unduly burdensome given the fact that it requires documents related to “all the County 

employees" and Defendant is Miami-Dade County which has a work force of over 30,000 

employees spread over twenty-five different Departments, and Plaintiff did not work at any 

of these Departments. 

3. Please produce all documents showing which anti-discrimination trainings were regularly 

scheduled for County employees during the period of March 2021 until April 2021.

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