Exhibit 5

Case 1:22-cv-23196-PCH Document 46-5 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.

/

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

PRODUCTION OF DOCUMENTS

Plaintiff John F. Labriola (“Plaintiff”), pursuant to Fed. R. Civ. P. 34, hereby serves his 

Responses and Objections to Defendant’s Requests for Production of Documents. 

Dated: May 22, 2023

Respectfully submitted,

Alexander Bumbu

Alexander Bumbu

Florida Bar No. 1024989

Southern District of Florida Bar No. 1024989

PACIFIC JUSTICE INSTITUTE

1021 Ives Dairy Rd.

Bldg. 3, Ste. 115

Miami, FL 33179

Tel: (786) 496-3946

Email: abumbu@pji.org

No facsimile number

Counsel for Plaintiff

Case 1:22-cv-23196-PCH Document 46-5 Entered on FLSD Docket 08/16/2023 Page 2 of 4
CERTIFICATE OF SERVICE

I hereby certify that on the 22nd day of May, 2023, a true and correct copy of the 

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

/s/ Alexander Bumbu

SERVICE LIST

Alexander Bumbu

Florida Bar No. 1024989

Southern District of Florida Bar No. 1024989

PACIFIC JUSTICE INSTITUTE

1021 Ives Dairy Rd.

Bldg. 3, Ste. 115

Miami, FL 33179

Tel: (786) 496-3946

Email: abumbu@pji.org

No facsimile number

Counsel for Plaintiff

William X. Candela

Assistant County Attorney

Florida Bar No. 759317

Southern District of Florida Bar No. 759317

Miami-Dade County Attorney’s Office

Stephen P. Clark Center

111 N.W. 1st St.

Ste. 2810

Miami, FL 33128

Tel: (305) 375-5151

Fax: (305) 375-5634

Email: wxc@miamidade.gov

Counsel for Defendant

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 St.

Ste. 2810

Miami, FL 33128

Tel: (305) 375-5151

Case 1:22-cv-23196-PCH Document 46-5 Entered on FLSD Docket 08/16/2023 Page 3 of 4
Subject to the objections above and without waiving them, Plaintiff states that he already 

disclosed the documents which this Request seeks in Exhibits 7, 10, and 11 of his Amended 

Complaint. See also Amended Complaint ¶ 76. Plaintiff further disclosed the documents in 

his Initial Disclosures, and the documents were in the Defendant’s possession in the first 

place because the Plaintiff got them from the Defendant through public records requests.

Therefore, it would be unduly burdensome for the Plaintiff to produce those documents 

again.

14. All documents that support, refer or relate to your allegations in Paragraph 45 of 

the Complaint that you “wrote the opinion piece on your own time (not during work 

hours).”

ANSWER: Plaintiff objects to this Request because the phrase “refer or relate to” is vague 

and ambiguous. That phrase is not limited, defined, or explained in any way.

Furthermore, Plaintiff objects to this Request because its use of the words “you” and “your” 

makes it objectionable for all of the reasons stated in Plaintiff’s General Objection to 

Definition “H.”

Subject to the objections above and without waiving them, Plaintiff states that the relevant 

document is produced in the document JL_000725-726.

15. All documents that support, refer or relate to your allegations in Paragraph 55 of 

the Complaint that Chairman Diaz “required [you] to undergo extra (and punitive)

diversity training, all in retaliation for the Opinion-Piece.”

ANSWER: Plaintiff objects to this Request because the phrase “refer or relate to” is vague 

and ambiguous. That phrase is not limited, defined, or explained in any way.

Furthermore, Plaintiff objects to this Request because its use of the words “you” and “your” 

makes it objectionable for all of the reasons stated in Plaintiff’s General Objection to 

Definition “H.”

Subject to the objections above and without waiving them, Plaintiff states that he already 

disclosed the documents which this Request seeks in the Exhibits to his Amended Complaint 

and in his Initial Disclosures. Additionally, the documents were in the Defendant’s 

possession in the first place because the Plaintiff got them from the Defendant through public 

records requests. Therefore, it would be unduly burdensome for the Plaintiff to produce those 

documents again.

16. All documents that support, refer or relate to your allegations in Paragraph 68 of 

the Complaint that the County singled you out with your suspension.

ANSWER: Plaintiff objects to this Request because the phrase “refer or relate to” is vague 

and ambiguous. That phrase is not limited, defined, or explained in any way.

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