Exhibit 8

Case 1:22-cv-23196-PCH Document 46-8 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 FIRST SET OF 

INTERROGATORIES 

Defendant, Miami-Dade County (“Defendant” and/or “MDC”), pursuant to Rule 33 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 46-8 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 46-8 Entered on FLSD Docket 08/16/2023 Page 3 of 4
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Djuro Gargurevich 111 NW 1st Street, 20th 

Floor

Miami, FL 33128

Miami-Dade County’s Employee 

Personnel Files and Payroll Records

Jose“Pepe” Diaz

Former Chairman 

of the Miami-Dade 

County Board of 

County 

Commissioners

111 N.W. 1st Street

Miami, FL 33128

Chairman Diaz is familiar with the 

circumstances surrounding the 

Plaintiff’s suspension and termination.

Chairman Diaz is familiar with 

Plaintiff’s duties and responsibilities. 

Isidoro Lopez

Former Chief of 

Staff to Chairman 

Diaz

111 N.W. 1st Street

Miami, FL 33128 

Mr. Lopez is familiar with the 

circumstances surrounding the 

Plaintiff’s suspension and termination.

Ms. Lopez is also familiar with the 

Plaintiff’s duties and responsibilities. 

Elda Green 111 N.W. 1st Street 

Suite 320 

Miami, FL 33128 

Ms. Green is familiar with the policies 

and procedures for the Board of County 

Commissioners.

Arleene Cuellar

HR Director 

111 N.W. 1st Street, 21st

Floor

Miami, FL 33128

Director Cuellar is familiar with MiamiDade County Policies and Procedures.

Olga Vega 111 N.W. 1st Street, 25th

Floor

Miami, FL 33128

Ms. Vega attended some meetings 

wherein Plaintiff was present. 

3. Identify by title the extra diversity training session(s) that Plaintiff would have had to 

undergo and produce the document(s) for that/those session(s).

ANSWER: Defendant objects to this Interrogatory to the extent that it is vague and ambiguous as 

to its use of the word “extra” which is not limited, defined or explained in any way. Defendant 

further objects to this Interrogatory to the to the extent it assumes fact not in evidence (i.e. it 

assumes the existence of an “extra” diversity training.) Subject to the above objections, Defendant 

states on March 5, 2021, Plaintiff was issued a Disciplinary Action Report for violation of the 

County Rules, and Plaintiff was mandated to participate in training regarding the County’s antidiscrimination policies. Implementing Order 7-45 was approved by the Board of County 

Commissioners in December 2019, replacing previous anti-discrimination policies. All county 

employees are required to take Implementing Order 7-45: Discrimination, Harassment and 

Retaliation. Plaintiff was ordered to complete Implementing Order 7-45: Discrimination, 

Harassment and Retaliation located on Miami-Dade County’s e-learning portal: e-Learning 

(miamidade.gov). See Defendant’s Responses to Plaintiff’s Request for Production No. 1. 

Case 1:22-cv-23196-PCH Document 46-8 Entered on FLSD Docket 08/16/2023 Page 4 of 4