Exhibit 4

Case 1:22-cv-23196-PCH Document 46-4 Entered on FLSD Docket 08/16/2023 Page 1 of 47
1 UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

2

3 CASE NO. 22-cv-23196-PCH

4

5

 JOHN F. LABRIOLA,

6

Plaintiff,

7

 vs.

8

 MIAMI-DADE COUNTY,

9

Defendant.

10 ________________________________/

11

12

13 111 N.W. 1st Street

Miami, Florida

14 28th Floor

Thursday, June 1, 2023

15 10:32 a.m. - 3:25 p.m.

16

17

18

DEPOSITION OF JOHN F. LABRIOLA

19

20 Taken before IVETTE OVIEDO, RPR and Notary

21 Public For the State of Florida at Large, pursuant to

22 Notice of Taking Video Deposition filed in the above

23 cause.

24

25

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1 APPEARANCES:

2 PACIFIC JUSTICE INSTITUTE

BY: ALEXANDER A. BUMBU, ESQ.

3 1021 Ives Dairy Road

Suite 115

4 Miami, Florida 33179-2537

On behalf of the Plaintiff.

5 abumbu@pji.org

6 MIAMI-DADE COUNTY ATTORNEY'S OFFICE

BY: WILLIAM X. CANDELA, ESQ.

7 and ANDREA S. de ONA, ESQ.

111 N.W. 1st Street

8 Suite 2810

Miami, Florida 33128

9 On behalf of the Defendant.

wxc@miamidade.gov

10 andreadeona@miamidade.gov

11 ALSO PRESENT:

12 EDWIN ARAGON, VIDEOGRAPHER

13

14

15

16

17

18

19

20

21

22

23

24

25

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1 INDEX

 EXAMINATION

2

 Witness Name Page

3

 John F. Labriola

4

 Direct By Mr. Candela .................................... 4

5

 Cross By Mr. Bumbu ....................................... 150

6

7

8

9

10

11 EXHIBITS

12 Exhibit Description Identification

13 Exhibits 1 - Binder containing tabs 1 - 18 74

 18

14

 Exhibit A Job Description of County Commission 75

15 Media Aid.

16 Exhibit B Amended Complaint 76

17 Exhibit C Article written by Fred Hiers 135

18

(**Note: Exhibits not received at time of production.)

19

20

21

22

23

24

25

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1 THE VIDEOGRAPHER: We are now on the record.

2 The time is 10:33 a.m. Today's date is June 1st,

3 2023. This is the video deposition of John

4 Labriola in the matter of John Labriola versus

5 Miami-Dade County. The Videographer is Edwin

6 Aragon. The Court Reporter is Ivette Oviedo on

7 behalf of Veritext Legal Solutions. This video

8 deposition is taking place at 111 Northwest 1st

9 Street, 28th Floor, Miami, Florida 33128.

10 Counsel, please identify yourselves and

11 state whom you present.

12 MR. CANDELA: Bill Candela, Assistant County

13 Attorney on behalf of defendant, Miami-Dade

14 County.

15 MR. BUMBU: Alexander Bumbu of the Pacific

16 Justice Institute on behalf of the plaintiff, John

17 F. Labriola.

18 Thereupon:

19 JOHN F. LABRIOLA

20 was called as a witness and, having been first duly

21 sworn, was examined and testified on his oath as follows:

22 DIRECT EXAMINATION

23 BY MR. CANDELA:

24 Q Good morning. My name is Bill Candela. I'm

25 an Assistant County Attorney. I'm going to be asking you

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1 Vega was a commissions -- commission aid to Commissioner

2 Diaz, correct?

3 A I don't recall her exact title.

4 Q Okay.

5 A But she was working for Commissioner Diaz.

6 Q And she worked with you during that time on,

7 for example, press releases, correct?

8 A That's right. Yes.

9 Q She also told me that she worked with you

10 and collaborated with you in drafting articles for the

11 military newsletter; is that correct?

12 A Yes. Yes. That's correct.

13 Q Okay. Because Chairman Diaz was the head of

14 the Military Affairs Committee during that time?

15 A That's correct.

16 Q Okay. And -- and he was Commissioner Diaz

17 during that time, correct?

18 A Yes.

19 Q Okay. And Commissioner Diaz he was -- he

20 sat and was the Chair of the Military Affairs

21 Committee?

22 A Yes.

23 Q And one of duties and responsibility as the

24 Chair of Military Affairs Committee was to publish a

25 newsletter, correct?

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1 A I believe -- I believe so because -- because

2 I mean, the only information -- I mean, knowledge I have

3 of it was that Olga would ask me to write his column.

4 Q Right.

5 A I don't know exactly how that varied.

6 Q Okay.

7 A I don't know what his -- if that was

8 something that was a duty of his or it was something that

9 he decided to do, so that part I don't know.

10 Q All right. Fair enough.

11 But you worked on this newsletter with Olga

12 Vega?

13 A Just -- just that column.

14 Q Right. Okay. Just the column.

15 And how was your work in relation with Olga

16 Vega during that time?

17 A Oh, it was -- it was fine.

18 Q Okay. How was your work in relation with

19 Olga Vega in preparing this column for the newsletter?

20 MR. BUMBU: Objection. Ambiguity.

21 A It was fine.

22 BY MR. CANDELA:

23 Q Did you find her to be courteous?

24 MR. BUMBU: Objection. Relevance and

25 ambiguity.

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1 A Yes.

2 BY MR. CANDELA:

3 Q Okay. And to be professional at the work

4 place?

5 MR. BUMBU: Objection. Relevance and

6 ambiguity.

7 A I would -- I would say, yes.

8 BY MR. CANDELA:

9 Q Okay. And tell me what your roll was in

10 preparing this column for the -- is it called the

11 Military Affairs newsletter?

12 A That I don't recall. I don't recall the

13 name of it.

14 Q Okay. Tell me how you collaborated with

15 Olga in preparing these columns?

16 A I don't recall because it was so long ago.

17 But I do -- do remember that she was ask me to draft

18 something. I don't remember if it was -- she probably

19 gave me the topic.

20 Q Okay.

21 A I believe she probably gave me the topic and

22 more or less what she wanted --

23 Q Okay.

24 A -- and then she just asked me could you

25 write something along those lines.

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1 Q Okay. Olga Vega told me that you were a

2 very good writer.

3 A Okay.

4 Q Did she ever tell you that you were a very

5 good writer?

6 A I believe, I mean, it's been a long time

7 ago --

8 MR. BUMBU: Objection. Relevance, and I

9 would -- may I ask that you rephrase your

10 statement as questions.

11 THE WITNESS: But I don't remember if she

12 used those exact words, but I think she was happy

13 with --

14 MR. CANDELA: Okay. You can make whatever

15 objection you want. I will do whatever question I

16 want and the judge can sort it out later. Okay?

17 Thank you.

18 MR. BUMBU: Thank you.

19 BY MR. CANDELA:

20 Q So tell me about some of the topics that you

21 wrote columns about in this -- for the Military Affairs

22 newsletter?

23 A That I don't recall, I don't recall any of

24 them because it was so long ago. I just recall doing

25 it.

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1 Q Okay.

2 A Oh, wait. I mean, I think I do remember a

3 couple. So there were -- there were a couple that were

4 around specific military holidays. I think there was one

5 that I -- I don't remember the topic except other than it

6 was like Veterans Day.

7 Q Okay.

8 A And maybe one for Memorial Day. Something

9 like that.

10 Q All right. Were these columns weekly,

11 monthly?

12 A I -- I don't believe it was weekly. It was

13 something less than weekly.

14 Q During this period of time -- and I'm again,

15 we're going roughly 2017 to 2021 when you are a media aid

16 at BCC media division, did you write other columns for

17 other commissioners?

18 A Can you repeat the period again?

19 MR. BUMBU: Objection. Compound question.

20 BY MR. CANDELA:

21 Q Let's -- let's make the period 2015 to 2021.

22 A Yes. I did.

23 Q Okay. And I want to talk about those. What

24 other columns did you write? And if you can tell me the

25 commissioner?

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1 A Edmonson. She was Chair from 20- -- well,

2 prior to, it was just prior to Diaz. So those two years

3 before.

4 Q Okay. And what columns would you write for

5 then Chair Edmonson?

6 A I can't remember the name of the

7 publication, but she had -- I don't know if it was

8 monthly or quarterly. It may have been monthly. She had

9 -- they gave her the opportunity to do a monthly, I

10 believe it was monthly, column in the publication. Which

11 I don't recall the name of.

12 Q And this is a publication that the

13 Commissioner puts out with her picture on it?

14 A No, it was not. It was a publication it was

15 a private publication and she had the opportunity to

16 submit a column. So she took advantage of that

17 opportunity.

18 Q Do you -- do you remember what the topics

19 were that you wrote for Commissioner Edmonson in this

20 private publication?

21 A I remember maybe a few of them. I think

22 there was one that was about, there was one about science

23 careers for women. That was one of them I recall. STEM

24 careers for women.

25 Q How about other commissioners, did you end

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1 up writing columns for any of the other commissioners?

2 A Yeah. I'm pretty sure there were some

3 others that I wrote columns for.

4 Q Didn't you writ a column for Commissioner

5 Sosa?

6 A I believe -- yes, when she was -- when she

7 was Chair.

8 Q And tell me about the columns that you wrote

9 for Commissioner Sosa?

10 A Okay. I don't remember what -- it could

11 have been like the MPO publication, one of those that

12 does an annual edition and so she or whoever the Chair

13 was at the time, would submit a sort of -- like a sort of

14 introductory column or like a welcome-type of column.

15 Q So MPO, that's the -- that has to do with

16 transit; isn't that right?

17 A I think they -- yes. I think they changed

18 their name. I forget what the new name was. But...

19 Q Do you know what the acronym MPO stands

20 for?

21 A Metropolitan -- Metropolitan Planning

22 Association, but I know they changed their name.

23 Q Okay. In writing these columns, for -- for

24 example -- for example, then chair Edmonson you had to

25 collaborate with one of her staff members?

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1 A That's right.

2 Q Right. And who would be that staff member

3 for Commissioner Edmonson?

4 A I'm trying to remember her name, but I can't

5 think of her name.

6 Q Okay. What about Commissioner Sosa when you

7 would write the columns for her, you had to collaborate

8 with one of her staff members; isn't that right?

9 A Yes.

10 Q Was that --

11 A It was a long time ago.

12 Q -- Betty?

13 A I don't recall if it was her. Because she

14 had -- she had some staff changes over the time that I

15 was working there. So I don't remember if it was her or

16 somebody else.

17 Q All right. I'm going to ask you about a

18 couple of other commissioners. Commissioner Martinez,

19 did you end up writing columns for Commissioner

20 Martinez?

21 A No. That would have been many years -- many

22 years prior because I was working for the office of the

23 Chair the first time around was around 2005, '06. So it

24 would have been around that time.

25 Q Now, in 20- -- in January of 2021,

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1 Commissioner Diaz is elected to become the Chair and I

2 believe that -- that occurred in November of 2020,

3 approximately?

4 A I think so.

5 Q Okay. And first -- and as part of accepting

6 that position as the Chair he has to give a speech; isn't

7 that right?

8 MR. BUMBU: Objection. Relevance.

9 A I don't recall when the speech was. I do

10 remember there was a sort of like an inauguration --

11 BY MR. CANDELA:

12 Q Correct.

13 A -- inauguration thing that they did for him.

14 Q Correct.

15 A An induction or whatever they called it at

16 the time.

17 Q Right. Sorry for interrupting.

18 A Yeah, sure.

19 Q There was an inauguration event?

20 A Uh-huh.

21 Q Correct?

22 A Yes.

23 Q And was that held at Adrienne Arsht

24 building?

25 A I don't think it was. It was somewhere

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1 else. I think it was at the port --

2 Q Okay.

3 A -- or something. I don't recall exactly.

4 MR. BUMBU: I object to that question on

5 relevance.

6 BY MR. CANDELA:

7 Q And -- and Olga Vega worked with you in

8 preparing the acceptance speech for Chairman Diaz; isn't

9 that correct?

10 A So I don't, like, as far as the acceptance

11 speech. I don't remember if there was an acceptance

12 speech. I do remember there was a speech that he gave

13 when he assumed the office versus when he was elected to

14 it, which would have been before.

15 Q Okay. And that's a speech that I'm

16 referring to. You worked with Olga Vega in preparing

17 that speech for Commissioner Diaz, correct?

18 A Yes. And actually -- yes, and actually, I

19 think it was at the stadium. I think that was at the

20 stadium.

21 Q Correct. Thank you.

22 And you're talking about JRS?

23 A Whatever they call it now. Joe Robbie

24 event.

25 Q All right. Joe Robbie event.

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1 MR. BUMBU: Objection, relevance.

2 BY MR. CANDELA:

3 Q We go back a long way.

4 Okay. I want to talk about that speech.

5 You worked with Olga Vega in preparing that speech?

6 A I do recall working with her on that, yes.

7 Q And I want to talk about that speech writing

8 process. Would she give you the topics and then ask you

9 to prepare a speech along regarding these -- the topics

10 that she told you?

11 MR. BUMBU: Objection. Compound question

12 and ambiguity.

13 A Yeah, yeah. I think it was. I mean, it's

14 been a long time, but I think she basically gave me like

15 the outline of what she wanted to say.

16 BY MR. CANDELA:

17 Q Okay. So we are now in 2021. Okay. We're

18 in January 2021. Olga Vega becomes the head of the BCC

19 media division; is that correct?

20 A Yes.

21 Q She's appointed to that position by Chairman

22 Diaz?

23 A That's correct, yes.

24 Q And in the media division you worked with

25 two other media aids, correct?

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1 Q In fact, you earned a salary of

2 approximately $70,000 in 2021; isn't that correct?

3 A I mean, can you show me the -- I think so,

4 yeah.

5 Q You're the one that earned it, you know,

6 right?

7 A Yeah. I don't remember the exact amount.

8 Q Approximately. About $70,000, correct?

9 A Correct.

10 Q Okay. And in this position working for the

11 Chair sometimes you'd have to work on weekends,

12 correct?

13 A I do -- I do remember doing that on various

14 occasions prior to his chairmanship --

15 Q Okay.

16 A -- but the time I was with him was so short

17 I don't recall any particular weekends. I do recall that

18 with the prior Chair because it was a longer period.

19 Q Right. Because with -- with Chairman Diaz

20 you only worked with him from January of 2021 through

21 April of 2021 --

22 A Yes.

23 Q -- correct?

24 A Through April 14th.

25 Q Correct. But with Chairman Edmonson, you

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1 worked for her for two years?

2 A Yes.

3 Q Okay. Now, lets talk about when you worked

4 for Chairman Edmonson. As a media aid, do you work on

5 weekends?

6 A Not every weekend, but if there was an

7 event, mostly with her it was food giveaways on weekends.

8 Q And -- and sometimes you'd have to work

9 after 5:00 p.m. in the evenings?

10 A I don't recall any specific instances of

11 that, but it's possible. I do remember the weekends for

12 sure.

13 Q And these food events that you were talking

14 about with Chairman Edmonson, they would be in the north

15 part of town?

16 A They would be in her district.

17 Q In her district, okay. What -- what

18 district did she have?

19 A Three. It was three -- yeah, three.

20 Q Okay. And three and that constitutes the

21 Liberty -- what I'm going to call the northend of town?

22 A Yeah, I think it was Liberty City and

23 Allapattah.

24 Q Okay. And these food events would occur on

25 weekends?

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1 MR. BUMBU: Objection. Relevance.

2 A As far as I recall, I think they were all --

3 I think they were all on Saturdays, if not most. But I

4 believe all of them were on Saturdays.

5 BY MR. CANDELA:

6 Q You told me that they would occur at her

7 district?

8 A In her district.

9 Q In her district.

10 And it would require you to actually

11 physically go to that district?

12 A Right.

13 Q And in those food events when you were

14 actually physically in the district, would they hand out

15 parcels of food?

16 A That's right.

17 MR. BUMBU: Objection. Relevance.

18 BY MR. CANDELA:

19 Q And they would hand it out to the local

20 residents?

21 A Local or whoever came. I don't know if they

22 checked their IDs for their residency.

23 MR. BUMBU: Objection. Relevance.

24 BY MR. CANDELA:

25 Q And how many people from the media division

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1 other than yourself would have to physically go to these

2 event in the district?

3 MR. BUMBU: Objection. Calls for

4 speculation.

5 A I recall pretty much the entire staff being

6 there. The entire staff not just media division, but

7 everybody.

8 BY MR. CANDELA:

9 Q Who was your immediate supervisor at the

10 media division when Chairman Edmonson served her two year

11 term as Chair?

12 A That's the lady whose name I can't recall.

13 It may come to me later, but she was a young lady, I

14 don't -- I don't remember her name. Just at the moment.

15 Q Okay. Would these events take place on a

16 monthly basis? And we're talking about the events food

17 distribution in Commissioner Edmonson's district.

18 A Sometimes they were more frequent than

19 that.

20 Q I'm sorry. Did you say more frequent?

21 A I believe, sometimes they were more frequent

22 than monthly. I could be wrong about that but it seemed

23 like we were out there a lot. So I believe on occasion

24 it was more than once a month but I could be wrong about

25 that.

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1 Q And during those food events, in some of

2 them they would have music bands playing?

3 MR. BUMBU: Objection. Relevance, calls for

4 speculation.

5 A I don't -- I don't remember the music.

6 BY MR. CANDELA:

7 Q During these events -- food events when

8 you're distributing food to the public, you'd have to

9 interact with the public?

10 MR. BUMBU: Objection. Relevance.

11 A I think what I was doing was mostly like

12 helping the rest of the staff set up. And it was kind of

13 like, in some cases, it was like an assembly line type of

14 situation, where I would -- one of us would hand the box

15 to somebody else and that person would give the box to

16 the person in the car.

17 BY MR. CANDELA:

18 Q You were part of that assembly line?

19 A Yeah, or other things.

20 Q What other things?

21 A Other thinks like setting -- setting up --

22 Q As a -- as a made media aid you're given a

23 County cell phone?

24 A That's correct.

25 Q You were also given a laptop?

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1 Q Would you get reimbursed for the mileage?

2 MR. BUMBU: Objection. Relevance.

3 A No.

4 BY MR. CANDELA:

5 Q Other than the laptop, the cell phone, were

6 you given any other equipment to work -- to perform your

7 duties as a media aid?

8 A I don't recall in additional equipment.

9 Q Okay.

10 A I know the office had a camera.

11 Q And I was good ask you about that. Did you

12 ever have occasion to take photographs with the camera

13 over at -- as a media aid?

14 MR. BUMBU: Objection. Relevance.

15 A I used my cell phone. There was another

16 employee who occasionally used the camera. I think she

17 also mostly used her cell phone but there were occasion

18 when she used the camera as well.

19 BY MR. CANDELA:

20 Q All right. And you would use your cell

21 phone to take pictures or to take film?

22 A Well, my roll was mostly, you know, helping

23 with non-social media stuff but when the other employee

24 who did focus -- focus on social media, when she was not

25 available, I would do like, you know, like for example,

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1 at the food events, I would take a picture of the

2 Commissioner handing out food and post it on her Twitter

3 account.

4 Q Okay. Does each Commissioner have a Twitter

5 account?

6 A I don't know. I don't know.

7 Q But Edmonson had a Twitter account?

8 A Yes.

9 Q How about Commissioner Diaz, did he have a

10 Twitter account?

11 A I don't recall he might have.

12 MR. BUMBU: Objection. Relevance.

13 BY MR. CANDELA:

14 Q Okay --

15 A I don't recall handling his Twitter account.

16 I think that might have been Olga Vega who did that.

17 Q Did -- what other work did you do with

18 Chairman Edmonson as it relates to social media?

19 A She had a Facebook account also. She had an

20 Instagram, too, but I can't remember if I did anything on

21 the Instagram. I remember Facebook and -- and Twitter.

22 Q Okay. What would you do on Commissioner

23 Edmonson's Facebook account?

24 A The same thing, post a picture.

25 Q Would you write the caption?

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1 A Yeah, it was usually a very brief -- very

2 brief caption. You know, Edmonson -- Commissioner

3 Edmonson, or Chairwoman Edmonson, you know, is

4 distributing food at such and such a location until

5 whatever time.

6 Q While you worked as a County Commission

7 media aid from 2015 to 2021 approximately at that time,

8 did you ever have any outside employment during that

9 time?

10 A Not that I recall.

11 Q Okay. Did you ever -- during that time, did

12 you ever publish any books?

13 A Not that I recall, no.

14 Q Now, as a commission media aid, we talked

15 earlier that you worked on publishing press releases,

16 correct?

17 A Yes.

18 Q And you would publish press releases at the

19 request of individual commissioners; is that correct?

20 A Right. Well, it was the -- usually, what it

21 was the commissioners aid whoever that might be, who

22 would reach out to me.

23 Q Okay. And for these individual

24 commissioners as a media aid, you also published other

25 types of news releases?

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1 A Yes.

2 Q Like for example, for one of commissioners

3 you helped publish a press release after a shooting. I

4 believe it was Commissioner Monestime?

5 A Okay. I don't recall that specific

6 incident, but it possible.

7 Q Okay. Do you recall publishing any press

8 releases concerning shootings for any County

9 Commissioner?

10 A I think, yeah. Yes. I do. I don't

11 remember if it was Monestime. It may have been

12 Monestime, but I do recall there may have been at least

13 one.

14 Q And in these press releases, you, for

15 example, would create a quote for the Commissioner to be

16 published?

17 MR. BUMBU: Excuse me. May you please

18 rephrase that as a question?

19 BY MR. CANDELA:

20 Q Isn't that correct?

21 A So, yeah. Yeah, well, the quote would be

22 subject to the approval --

23 Q Right.

24 A -- but it would be along the lines of

25 something that they want him to say on that issue. And

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1 so I would prepare both the -- both the press release and

2 the quote according to what they wanted, and then they

3 might -- sometimes they would say "We don't like that

4 quote, change it to this" or whatever.

5 Q Right. You would collaborate with each

6 Commissioner's staff in order to get the right quote?

7 A Right.

8 Q And these press releases would be released

9 not only to the print media but they would be released to

10 television?

11 A Yes.

12 Q They would be released to NPR?

13 A I don't recall if NPR was included in

14 that.

15 Q Okay. They would be released to radio --

16 A Yes.

17 Q -- as well. Did you ever as a media aid,

18 did you ever work with Spanish media?

19 A Yes.

20 Q Okay. Do you speak Spanish?

21 A Yes.

22 Q Okay. How would you work with Spanish media

23 as a media aid?

24 A The same thing they would -- they would be

25 included in our media list and they would receive the

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1 press releases. If, you know, there was a public records

2 request from a member of the Spanish media we would

3 handle it just as if it were a member of the English

4 media.

5 Q Okay. Did you get to know any of the

6 Spanish media personalities as working with the -- with

7 the media in the media division?

8 A Not really like get to know. I mean, I

9 remember seeing them and recognizing them.

10 Q Were you introduced to them?

11 A I don't recall being introduced. It may

12 have happened but I don't recall a specific incident.

13 Q Okay. Because one of the duties working in

14 the media aid is to answer the phone, correct?

15 A Well, the -- the phone in our media office,

16 there was sort of universal line --

17 Q Right.

18 A -- and it all the phones would ring. So,

19 you know, it would be one line, I mean, but it would go

20 to all the phones in the -- also whoever was there would

21 pick up and a if it was a public records request, you

22 know, we would direct them to how to -- how to submit it

23 or whatever, whatever it was. It could have been

24 somebody from one of the commission offices calling.

25 Q Right. And on occasion you'd have to answer

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1 the phone from a media outlet, correct?

2 A Yes, occasionally.

3 Q And on occasion you would have to talk to

4 some reporter about some topic, correct?

5 A Well, when it came to reporters, it was

6 understood that I was not to be quoted --

7 Q Right.

8 A -- that -- that I was not the person that

9 represented the Commissioner.

10 Q Right.

11 A But if they wanted to get, for example, ask

12 for a public records request, I would help facilitate

13 that and if they wanted to arrange for an interview with

14 the Commissioner then I would contact not the

15 Commissioner directly, but one of my supervisors.

16 Q Did you ever -- as media aid, did you ever

17 work on any pamphlets?

18 A Can you be specific as far as what you mean

19 by "pamphlets"?

20 Q Well, for example, I know that Commissioners

21 -- the Chairs publish monthly, I call them pamphlets, but

22 a document letting -- something that says, to the

23 citizens of Miami-Dade County, this is what we are doing

24 here at Miami-Dade County. These are the upcoming

25 events. Okay. What would you call that publication?

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1 A Well, I'm trying to think back as to what

2 publications we had. Let's see, there was the Chamber

3 Gazette. There was the Chamber Gazette, for example.

4 Q Right.

5 A Yeah. There was a -- there were a couple of

6 different iterations of Chamber Gazette. The last one

7 that I recall was not published physically but it was

8 online, and that was just like a compilation of, you

9 know, each Commissioner -- Commissioner's aid submitted

10 one event and one piece of legislation that they want to

11 highlight and they submitted the descriptions themselves.

12 Like, there was very little editing that we

13 did on our end or that I did on my end. Usually, just

14 checking to see if there were any typos, grammatical

15 errors or things like that. That was the second or

16 whatever the final iteration of the Chamber Gazette. It

17 was greatly reduced in scope from what it had been

18 prior.

19 Q Okay. So the County Commission Chairperson

20 would publish the Chamber Gazette, correct?

21 A The -- well, it was -- it was the -- okay,

22 so there were a couple of different Chamber Gazettes.

23 Q Okay.

24 A So there was -- there was a physically

25 published version and then later on that was eliminated

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1 and I believe that was eliminated when Diaz became Chair.

2 And then we went to just an online thing that was greatly

3 reduced in -- in size and scope.

4 Q What other publications similar to the

5 Chamber Gazette would be published by the media

6 division?

7 A That -- let's see, so it was mostly the

8 press releases, that was the main -- main product that we

9 produced. I'm trying to think back, and then again, like

10 the columns and things like that. Those were the main

11 things.

12 Q Okay. Did you ever write speeches for

13 Commissioner Edmonson?

14 A Well, I worked on talking points, yes.

15 Q Okay.

16 A For her.

17 Q Can you give me an example of one of

18 those?

19 A I can't recall any specific one but -- well,

20 actually I -- there was -- there was, okay, I do remember

21 there was some kind of ribbon -- not ribbon cutting, but

22 there was a building that was renovated. I think a

23 government building that was renovated somewhere in her

24 district, and it was like grand reopening or something

25 like that and, you know, so we provided, talking -- I

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1 mean, I provided talking points for that.

2 Q Right. Was that the opening of what was

3 called Pork & Beans building at the time?

4 A Well, that was one of them but there was

5 also a government -- there was also a government building

6 that was I think renovated or something happened.

7 Q Okay.

8 A But, yeah, that Pork & Beans was also --

9 that -- that was the housing complex --

10 Q Correct.

11 A -- that was renovated.

12 Q And did -- and I remember Commissioner

13 Edmonson gave a speech regarding the opening of the Pork

14 & Beans complex that was renovated, correct?

15 A Right.

16 Q Okay. And did you collaborate in preparing

17 that speech for Commissioner Edmonson?

18 A That specific one, I can't recall, but it's

19 quite possible.

20 Q Okay. Were there other speeches that you

21 collaborated in preparing the speech for Commissioner

22 Edmonson?

23 A Yes. Yes. There was another -- like I

24 said, it was a government building. It was a government

25 office building I think. It was like a government office

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1 building and I just don't recall which --

2 Q Do you recall the name of government office

3 building?

4 A No.

5 Q Okay.

6 A It was a government office building that

7 also had like a public service component to it, but I

8 don't recall what services that they handled for the

9 public.

10 Q I wanted to go over some documents. So I

11 have a -- this is for you and I got copies for both of

12 you.

13 MR. BUMBU: John, I'm going to ask you to --

14 with the documents, take your time.

15 A Okay.

16 BY MR. CANDELA:

17 Q Okay. You were issued a disciplinary action

18 report in 2021, correct?

19 A Yes.

20 Q Okay. Just go to tab 10.

21 MR. CANDELA: How would you like to number

22 these as we go along? We can just stick with the

23 numbers that I'm saying because --

24 THE COURT REPORTER: That's better.

25 MR. CANDELA: -- I don't want to complicate

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1 period?

2 A I don't recall. Again, it's so long ago, I

3 don't even remember any specifics about that time.

4 Q In your lawsuit you are seeking

5 reinstatement to the position that you held as a media

6 aid?

7 A Yes.

8 Q Okay. And what was it about that position

9 as a media aid that you enjoyed when you worked here at

10 the County?

11 A Well, I enjoyed the, you know, the writing

12 and, you know, and, you know, crafting messages based

13 upon what was -- what I was asked to -- the message was

14 basically, you know, the message that I was given and

15 then I had to craft it to make it sound good. And also

16 taking legislation and being able to convert that into

17 language that was relatable to the public. That was a

18 lot of the stuff that I did, you know, as a media aid.

19 Q In other words, you were a wordsmith, for

20 lack of a better word?

21 A Yeah.

22 Q Okay. I want to talk a little bit what you

23 said that where you would get legislation and then put it

24 in language that would then be disseminated to the

25 public.

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1 particular one.

2 Q Okay. And in this e-mail Mr. Lopez is

3 letting you know that IO7-45 training is the subject of

4 the training you have been ordered to complete. Is that

5 correct?

6 A Yes.

7 Q Okay. You did not complete that training --

8 A Not at --

9 Q -- as request by Mr. Lopez?

10 A Not at that time. That's correct.

11 Q Okay. Have you seen -- okay, I know that

12 you were ordered to take the IO7-45 training and it was

13 to be done remotely, correct?

14 A That -- that was my understanding. Yeah,

15 via the computer.

16 Q Right. Via the computer. And that you

17 could do it at your home, correct?

18 A That I -- I don't recall specifically.

19 Q Okay. And that you were to do it while on

20 duty, correct?

21 A Yeah. Yes.

22 Q You would be -- you would be getting paid

23 while you were doing this training?

24 A That's my recollection.

25 Q And the training is a visual training,

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1 video that was that was -- that was referenced in later

2 discovery.

3 Q Right. But you didn't, we already

4 established that you never asked him about that?

5 A About -- about what specifically.

6 Q Right. Okay.

7 MR. CANDELA: I'd like -- I think I'm almost

8 done. I'd like to take a five-minute break.

9 THE VIDEOGRAPHER: We're going off the

10 record at 2:56.

11 (Whereupon, a break was taken.)

12 THE VIDEOGRAPHER: We're back on the record.

13 The time is 2:59.

14 MR. CANDELA: I don't have any further

15 questions. Thank you, Mr. Labriola.

16 MR. BUMBU: All right --

17 THE VIDEOGRAPHER: I need to change the

18 media. We're going off the record. The time is

19 2:59.

20 (Whereupon, a break was taken.)

21 THE VIDEOGRAPHER: We are on the record.

22 The time is 3:00.

23 CROSS-EXAMINATION

24 BY MR. BUMBU:

25 Q Good afternoon, Mr. Labriola. So this is

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1 A Yes.

2 Q And you say this happened in the gym?

3 A Right. And it was caught on video. So then

4 we went to -- so she -- so she actually filed this

5 lawsuit against me claiming stalking and so forth. And

6 the judge looked at the video and pretty much dismissed

7 the case almost as if like I think he laughed her out of

8 court, it was very, it was embarrassing I think to her.

9 Q Okay. So would it be true to say that she

10 walked up and struck you?

11 A Yes.

12 Q Okay. And was she criminally charged?

13 A She was.

14 Q Okay. And was she criminally charged for

15 striking you?

16 A Yes.

17 Q Okay. And you mentioned that she filed some

18 petition against you. Are you saying that it was

19 dismissed?

20 A That's right. I think it was -- she was

21 asking for -- what was it -- a restraining order or

22 something like that and it was dismissed.

23 Q Okay. I'm going to pivot to something else

24 that Mr. Candela asked you about earlier today. He asked

25 you about the military newsletter column for Chairman

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1 Diaz. Did your name appear on any of those columns?

2 A No, it did not.

3 Q Did your contact information appear on any

4 of those columns?

5 A No.

6 Q Did anyone direct you what to write on those

7 columns?

8 A Olga Vega told me basically what she wanted

9 and then I just took what her basic message that she

10 wanted to convey and turned it into a column of the

11 length that she wanted.

12 Q Did -- okay. Did anyone review what you

13 wrote?

14 A Yes. Olga Vega.

15 Q Okay. And just to clarify, was that a final

16 review before the column was published?

17 A I don't know. It may have been. I don't

18 know if she also showed it to Diaz before it was

19 published. It's possible she did. I don't know.

20 Q Okay. Did you act as chairman -- or then

21 Commissioner Diaz's spokesperson?

22 A No.

23 Q The next issue I will -- I will pivot to is

24 another thing that Mr. Candela asked you earlier today,

25 and that was -- I believe it was a private publication

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1 for then Chairman Audrey Edmonson; is that a correct

2 characterization of it?

3 A Yes, we were discussing a private

4 publication but it wasn't for Edmonson. She was offered

5 the opportunity to submit a column and she did and I

6 think it was monthly.

7 Q Okay. Did your name appear on any of those

8 columns?

9 A No, it did not.

10 Q Did your contact info appear on any of those

11 columns?

12 A No.

13 Q Did anyone direct you what to write in those

14 columns?

15 A Yes. Again, I can't remember. It was a

16 young lady that worked for Commissioner Edmonson. For

17 some reason, her name continues to escape me, but she

18 would basically tell me the topic that she wanted.

19 Q Okay. And did that -- that lady review what

20 you wrote?

21 A Yes.

22 Q Okay. Did you act as Chairman Edmonson's

23 spokesperson?

24 A No.

25 Q Okay. The next thing I will ask you about a

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1 column -- another thing that Mr. Candela asked about

2 earlier --

3 A I sorry. I just remembered her name Chelsea

4 -- Chelsea something. I just can't remember the last

5 name. I think it was Chelsea, but anyway, I could be

6 wrong about that, too.

7 Q Okay. He asked -- Mr. Candela asked you

8 about a column for Commissioner Sosa, correct?

9 A Yes.

10 Q Did your name appear on any of those

11 columns?

12 A No.

13 Q Did your contact info appear in any of those

14 column?

15 A No.

16 Q Did anyone direct you what to write in those

17 columns?

18 A Yes. I don't remember for Edmonson who it

19 was, but I was basically told more or less the message

20 and it would be like a greeting or something to that

21 effect.

22 Q Okay. I think -- and I'm referring to --

23 I'm referring to Commissioner Sosa. I think you

24 accidentally said Edmonson?

25 A Oh, I'm sorry. You said Sosa?

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1 Q I'm asking about Commissioner Sosa.

2 A Okay. So, yeah, same thing. It was

3 basically, I was told it needed to be some kind of, like

4 a introduction or a welcome type of message and that's

5 what I would write.

6 Q Okay. Mr. Candela also asked you about a

7 column for Commissioner -- then Commissioner Martinez,

8 correct?

9 A Yes.

10 Q Did your name appear on any of those

11 columns?

12 A I don't recall any specific column, but

13 whatever I did produce for him did not have my name --

14 you know, that I recall -- as a byline. Now, this --

15 this was so long ago, we're talking well over ten years

16 ago, so I don't recall that far back, but it would have

17 been before I was rehired in 2013 when I - when I worked

18 for him.

19 Q Do you remember if you're contact info

20 appeared on any of those -- any of those columns for then

21 chairman -- then Commissioner Martinez?

22 A I don't recall specific columns from that

23 far back but I don't believe it did.

24 Q Did anyone direct you what to write on those

25 columns?

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1 A Yes. It was Chairs -- well, at the time --

2 on staff.

3 Q Okay. Earlier Mr. Candela also asked you

4 about any social media work that you did for then

5 Commissioner Audrey Edmonson; didn't he ask you about

6 that?

7 A Yes. When she was Chair, yes.

8 Q Okay. Did you work on any social media post

9 for Edmonson?

10 A Yeah. Not too many. Very few actually

11 because it was not my primary function. There was

12 another lady -- a young lady in the office that -- whose

13 primary function was social media, so it would basically

14 only be when she was not available or she was on vacation

15 or whatever.

16 Q Did your name appear on any of social media

17 post?

18 A No.

19 Q Did any -- did your name appear on any

20 social media photographs?

21 A No.

22 Q When did you -- on what occasions would you

23 take photographs for Edmonson?

24 A The ones I recall were the food

25 distributions, so that would be when she -- during the

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1 COVID crisis.

2 Q Okay. Okay. Something else that

3 Mr. Candela asked you earlier was about Chairmen Diaz's

4 speech. Was it -- was it his inauguration speech as a

5 Commissioner?

6 A No, not as a commissioner, no, as chairman.

7 Q As chairman. Okay. And were you involved

8 in -- in preparing Diaz's speech?

9 A Yes. Along with Olga Vega.

10 Q Did your name appear on that speech?

11 A No. It was a speech. It wasn't printed

12 anywhere.

13 Q Okay. Did anyone direct you what to write

14 in that speech?

15 A Olga Vega basically, I think she provided

16 like a rough draft. I can't remember exactly but I do

17 remember working from some kind of draft that she

18 provided. If I remember correctly.

19 Q So your role was to edit the speech?

20 A Edit and I think expand it a little bit.

21 Q Okay. And was that the role that you were

22 -- that you played in any of the other writings -- in all

23 the other writings that you took part in when you worked

24 as a BCC media commissioner -- a BCC media aid? Excuse

25 me.

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1 A Yes.

2 Q I'm sorry. Were you answering my question

3 there?

4 A Yes.

5 Q So is your answer "yes" to my question?

6 A Yes.

7 Q Okay. So is it true to say that in March of

8 2021 that you were working remotely?

9 A I believe so. I think there were some days

10 when I went in. Some days I did not.

11 Q Did you -- when you worked on your opinion

12 piece, on what hours of the day were you working on it?

13 A I wasn't working. It was not during work

14 hours.

15 Q Not during work hours. Okay. Would you

16 work on it during the weekends?

17 A Would I?

18 Q Yes. Did you? I mean.

19 A Yes. Well, it was Friday night and -- yeah

20 Friday night, I believe.

21 Q Okay. And when you worked remotely --

22 additionally Mr. Candela mentioned earlier that you also

23 worked on speeches for then Commissioner Audrey Edmonson,

24 correct?

25 A Yes. When she was Chair.

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1 Q When she was Chair. So did -- were you

2 given -- were you directed on what to write for those

3 speeches?

4 A Yes.

5 Q And who directed you?

6 A Again, I think it was -- if I remember her

7 name correctly -- it was Chelsea.

8 Q Okay. And would you describe your role as a

9 -- as an editor of what your given?

10 A I was given a topic and then I had to expand

11 on that topic.

12 Q Would you do things like correct grammar or

13 syntax?

14 A Well, if there was something that was -- if

15 I was proof reading it and I saw something that was

16 grammatically wrong, yes.

17 Q And so would you say that for all the

18 writings that you were involved in, that you were a

19 proofreader.

20 A Partly.

21 Q Okay. So did you say when you would work

22 remotely during -- let me rephrase that.

23 When Mr. Candela asked you earlier if you

24 worked during -- if you worked remotely during the

25 weekend, the -- when you would -- when you worked

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1 CERTIFICATE OF OATH

2

3

4 STATE OF FLORIDA :

5 COUNTY OF MIAMI-DADE :

6

7

8 I, Ivette Oviedo, Shorthand Reporter and Notary

9 Public, State of Florida, certify that, JOHN F. LABRIOLA,

10 appeared before me on the 1st day of June, 2023, and was

11 duly sworn.

12

13

14 WITNESS my hand and official seal this 12th day of

15 June, 2023.

16

17 <%14034,Signature%>

Ivette Oviedo, RPR# 961103

18 Notary Public, State of Florida at Large:

Commission No.: HH 356470

19 Expiration date: March 7, 2027

20

21

22

23

24

25

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1 CERTIFICATE

2

3 STATE OF FLORIDA :

4 : SS.

5 COUNTY OF MIAMI-DADE :

6

7 I, IVETTE OVIEDO, RPR certify that I was

8 authorized to and did stenographically report the

9 deposition of JOHN F. LABRIOLA in the above-entitled

10 cause; that a review of the transcript was requested; and

11 that the transcript is a true and complete record of my

12 stenographic notes.

13 I further certify that I am not a relative,

14 employee, attorney or counsel of any of the parties, nor

15 am I a relative or employee of any of the parties'

16 attorney or counsel connected with the action, nor am I

17 financially interested in the action.

18

19 Dated at Miami-Dade County, Florida, this

20 12th day of June, 2023

21

22

23 <%14034,Signature%>

Ivette Oviedo, RPR# 961103

24

25

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7

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.fOHN F. LABRIOLA, VS. MIAMI-DADE COTINTY,

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.fOHN F. LABRIOLA

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800-726-7007

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