IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1:22-cv-24066-KMM

GRACE, INC., et al.,

Plaintiffs,

vs.

CITY OF MIAMI,

Defendant.

________________________________________/

4343 W. Flagler Street

Suite 400

Miami, Florida

Friday, 2:05 a.m.

October 6, 2023

DEPOSITION

OF 

LARRY SPRING

Taken on behalf of the Plaintiffs

Pursuant to a Notice of Taking Deposition

___

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Case 1:22-cv-24066-KMM Document 166-3 Entered on FLSD Docket 01/29/2024 Page 1 of 48
APPEARANCES:

ACLU FOUNDATION OF FLORIDA, by

CAROLINE A. MCNAMARA, ESQ.,

NICHOLAS L.V. WARREN, ESQ., and

DANIEL B. TILLEY, ESQ., and

On behalf of the Plaintiffs.

DECHERT, LLP, by

CHRISTOPHER J. MERKEN, ESQ.,

Co-Counsel for the Plaintiffs.

GRAY ROBINSON, by

CHRISTOPHER N. JOHNSON, ESQ., and

On behalf of the Defendant.

WITNESS

LARRY SPRING

Direct Examination (By Ms. McNamara) 3

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Case 1:22-cv-24066-KMM Document 166-3 Entered on FLSD Docket 01/29/2024 Page 2 of 48
THEREUPON:

LARRY SPRING

was called as a witness by the Plaintiffs and, having 

first been duly sworn, was examined and testified as 

follows:

THE WITNESS: Yes.

DIRECT EXAMINATION

BY MS. MCNAMARA:

Q. Can you state your name, for the record, 

please? 

A. Larry Spring.

Q. And I'm Caroline McNamara. I'm doing the 

deposition. We already did all of the intros, so we can 

skip over that. 

You said you have been deposed before?

A. Yes, I have.

Q. About how many times? 

A. Too many to count, actually.

Q. Are those in this representative role for the 

City or -- 

A. A number of them, yes.

Q. Have you done them in a context other than in 

your role with the City of Miami?

A. My context has been City Manager in other 

cities.

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Case 1:22-cv-24066-KMM Document 166-3 Entered on FLSD Docket 01/29/2024 Page 3 of 48
Q. Okay. What is your job title?

A. I am the Chief Financial Officer and Assistant 

City Manager.

Q. And when did you start that job?

A. Most recently, June of 2022.

Q. Did you hold that job previously, before that 

period?

A. I did.

Q. Okay. When were the previous period when you 

held that?

A. I was with the City from January of 2003 to 

June of 2011. During that tenure, I served as Assistant 

City Manager, initially over budget, strategy and 

grants, and then was promoted in 2006 to Chief Financial 

Officer, literally that same job that I'm in now.

Q. What did you do, during the period when you 

weren't in the City, between them?

A. I started my own company, consulting company, 

which I continue to operate. I was Corporate Director 

of Productivity and Decision Support for Jackson Health 

Systems, so I was a County employee. And I was City 

Manager of the City of North Miami.

Q. And, then, did you leave the position at the 

City of North Miami to come back to the City of Miami?

A. I did not.

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Case 1:22-cv-24066-KMM Document 166-3 Entered on FLSD Docket 01/29/2024 Page 4 of 48
Q. What was in between?

A. I continued to run my consulting company.

Q. And how did it end up that you came back to the 

City of Miami in your current position?

A. City of Miami was one of my consulting clients, 

and my predecessor, Fernando Casamayor, left to go back 

to the County, and the City Manager asked me, since I 

was familiar with the role, to step back in the role.

Q. Were you happy to do that?

A. I love the City, so, yes.

Q. Have you enjoyed working for the City 

throughout your tenure, the various years?

A. Overall, yes, I'd say I have.

Q. Okay. All right. I do want to back up a 

little bit, just to go over -- you did say you've been 

deposed before. You're familiar with the format, with 

the fact that you're under oath?

A. Uh-huh. Sorry, yes.

Q. Do you have any reason you're unable to testify 

truthfully today?

A. No.

Q. And no medication or you ate a big lunch and -- 

A. Those red beans were good, but, you know, no 

reason. 

Q. All right. And you understand that if you need 

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Case 1:22-cv-24066-KMM Document 166-3 Entered on FLSD Docket 01/29/2024 Page 5 of 48
a break, you can ask for a break -- 

A. Absolutely. 

Q. -- if you need me to repeat a question, all of 

that stuff. 

Have you ever testified, outside the context of 

a deposition? 

A. In court, yes.

Q. What were the circumstances of that?

A. Probably the biggest I can recall is the SEC 

matter with the City of Miami.

Q. Were you at trial testifying?

A. I testified at trial, yes.

Q. And that was in your role as -- 

A. At that point, I guess, as CFO, but I was no 

longer with the City when I was asked to testify.

Q. Are there other times that you've testified in 

trials?

A. Not in trials, no. No.

Q. Do you know the name of the case that was that 

SEC case?

A. It was SEC versus City of Miami.

Q. And what year was that?

A. I think that case finally made it to court in 

2013. I couldn't tell you the month. I believe that 

was the time frame.

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Case 1:22-cv-24066-KMM Document 166-3 Entered on FLSD Docket 01/29/2024 Page 6 of 48
Q. Have you ever been a party in a lawsuit?

A. No.

Q. Have you ever been a party in a criminal case?

A. No.

Q. Have you ever been arrested?

A. No.

Q. So you have no criminal background?

A. No.

Q. Do you have any professional certifications?

A. Yes. I'm a licensed CPA. I am a licensed real 

estate broker and realtor. Those are my official 

certifications.

Q. When did you obtain your CPA?

A. Oh, my goodness, a long, long time ago. I 

think, around 1999, 2000.

Q. Have you maintained that consistently since 

then?

A. Yes, I have.

Q. Are you subject to any disciplinary 

authorities?

A. Never.

Q. Anyone ever file a complaint against you for 

your CPA work?

A. No.

Q. When did you become a licensed realtor?

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Case 1:22-cv-24066-KMM Document 166-3 Entered on FLSD Docket 01/29/2024 Page 7 of 48
A. In June of 2020.

Q. Have you maintained that consistently since 

then?

A. Yes, I have.

Q. Are you subject to any, you know, ethical or 

professional standards as a realtor?

A. None whatsoever.

Q. Has anyone ever brought a complaint about you 

as a realtor?

A. Just that I sell houses really fast.

Q. Please, put that in. 

And do you understand that you've been 

designated by the City of Miami to speak on its behalf 

today?

A. Yes.

Q. Are you happy about this fact? 

A. I'm here to serve. I'm here to serve.

MS. MCNAMARA: Do we still have the same 

exhibits from before? Can I use --

THE REPORTER: I am going to give you all 

of them. 

BY MS. MCNAMARA:

Q. So Plaintiffs' Exhibit 7, which I believe is 

the one on the bottom, the deposition notice -- 

A. Yes.

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Case 1:22-cv-24066-KMM Document 166-3 Entered on FLSD Docket 01/29/2024 Page 8 of 48
Q. -- do you recognize this document?

A. Yes, I do.

Q. And you've looked at it before?

A. Yes.

Q. Are you aware of which of those topics you're 

designated to testify for?

A. My understanding, I'm here to answer questions 

regarding the third topic.

Q. Can you read the third topic off of that 

document?

A. Sure. "The ordinary processes of City 

Commission business and administration, including the 

development and adoption of the annual budget." 

Q. When did you learn that you would be testifying 

in this capacity?

A. Maybe a week ago, maybe ten days. 

Q. What did you do to prepare for today?

A. Nothing.

Q. Is that because we're talking about what you do 

every day and you know it?

A. Yes.

Q. Are there other people who know more about this 

topic than you?

A. I will say, no.

Q. Do you have anybody who reports to you?

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Case 1:22-cv-24066-KMM Document 166-3 Entered on FLSD Docket 01/29/2024 Page 9 of 48
A. Yes.

Q. Did you talk to any of them about what they're 

working on, in preparation for this?

A. No.

Q. Do they give regular reports on what they're 

working on?

A. I have bi-weekly staff meetings. So it's not 

specific to this case, it's just in general.

Q. Did you meet with any other City Officials to 

prepare for this meeting?

A. Absolutely not.

Q. Do you regularly meet with any of the 

Commissioners?

A. At least an hour every week.

Q. Is that in individual sessions?

A. Yes.

Q. And that's every week, so does that mean you 

spend -- 

A. It could be 30 minutes, could be 45, it could 

be an hour and a half, but -- 

Q. And that's for -- 

A. For general business.

Q. And that's for each Commissioner?

A. Yes.

Q. So if we add, five Commissioners, an hour, it 

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might be five hours a week, in theory?

A. Yes.

Q. Do you meet with their staff separately?

A. Sometimes, yes, but generally they're in the 

other discussion.

Q. Do you work at City Hall in person?

A. I have two work locations, 444 Southwest 2nd 

Avenue, which is the administration building, and I have 

an office at Pan American Drive, at City Hall.

Q. Do you go into City Hall regularly?

A. I would say, probably two days a week, on 

average, a little bit more on a Commission week.

Q. Do you ever meet with the full Commission, like 

in a meeting, publicly? 

A. Only at Commission Meetings.

Q. Have you ever spoken publicly at the meetings 

to the Commission in public?

A. Too many times to count.

Q. What do you generally discuss with the 

Commissioners in your weekly meetings?

A. Typically those discussions are regarding the 

general agenda of the City, that is, you know, 

forthcoming. They'll be some drill downs on, you know, 

specific initiatives they may have. One of the 

departments that reports to me is Community Development. 

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That's a department -- as an example, that's the 

department that oversees all of our entitlement grant 

funding from the Federal Government, that's the money we 

deploy out to the community. So, you know, each 

Commissioner gets to set policy around that. 

So, you know, we specify, you know, what are 

their desires. We talk about how we're performing, that 

type of thing, for the most part.

Q. Do you interact with other City Officials, 

other than the City Commissioners?

A. I interact with the Mayor. I interact with 

the -- I still call him a City Official, the City 

Manager, who is my boss, I interact with the City Clerk, 

and I interact with the other constitutional officer, 

the City Attorney.

Q. So you stated that the City Manager is your 

boss. Is that your direct report, is the City manager?

A. Yes, it is.

Q. And who's that?

A. Art Noriega.

Q. And how's your relationship with him?

A. I'd say, very good.

Q. What is the nature of how you interact with him 

on a regular basis?

A. We probably talk every day, you know, or five 

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business days at least a week. I'm generally in charge 

of, you know, finance, budget, procurement, a lot of the 

internal services, in addition to asset management. So 

I have a number of initiatives going on. So I'll talk 

to him, like I said, at least once a day, if not several 

times a day.

Q. Does he dictate what you work on?

A. Yeah. I mean, generally, yes. He provides me 

with my assignments.

Q. Do you have any discretion on how you choose 

what you wish to work on?

A. I have a large area of responsibility, so 

within the context of that, no, but I do get special 

projects from time to time that will be, you know, 

assignments that he'd like for me to pursue or lead.

Q. Preparing for this, did you review any written 

documents? 

A. I did nothing to prepare.

Q. Okay. Your life is your preparation for this. 

A. I guess. I will tell you, I don't know nothing 

about this, but -- the subject matter, the litigation 

subject matter.

Q. Okay. So you have not looked at any court 

filings in this case?

A. No. It's not my area.

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Q. Okay. Do you live in the City of Miami?

A. I do.

Q. Do you know what district you live in?

A. I live in District 2.

Q. What neighborhood?

A. Omni. 

Q. How long have you lived there?

A. I've lived there now for eight years.

Q. Did you live in the City of Miami prior to 

that?

A. Yes.

Q. And where was that?

A. I lived in Brickell and in the Roads.

Q. Is that in District 3?

A. So, in Brickell, District 2; in the Roads, it 

was District 3 or it is District 3 still.

Q. Have you live continuously -- like when did you 

first move to the City of Miami?

A. In February of 2003, when I first joined the 

City.

Q. And where were you before then?

A. In South Dade, so the Colonial Drive area. 

Q. So how did you choose to come to the City of 

Miami for work? 

A. I got divorced, and the Mayor said, "We pay you 

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enough that you should be living in the City." So I 

found an apartment that day.

Q. There you go. 

A. And never left.

Q. You mentioned your consulting work. Have you 

had professional employment for another entity, other 

than a government entity, in your career?

A. Oh, absolutely.

Q. What was the last private entity that you 

worked for?

A. With my consulting? 

Q. Separate from your consulting. 

A. Oh, last prior -- 

Q. If you were an employee. 

A. Oh, if I was an employee? The last private 

employer I had was to TotalBank, which was a financial 

institution here, based in Miami.

Q. And when was that? What was the period?

A. That period was from 1997 until 2003 or the end 

of 2002.

Q. And what is your educational background?

A. I hold a Bachelor's of Science in Management, 

with a Major in Accounting from Tulane University, and I 

have matriculated through certificate programs at the 

University of Columbia -- or Columbia University School 

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of Engineering and Harvard School of Business.

Q. Do you have any advanced like degrees or 

certificates?

A. I do have a certificate in entrepreneurialship 

from Harvard University.

Q. So, going back to Topic Number 3, how often 

does the City Commission develop a budget?

A. So we -- and I'm bifurcating my answer. So we 

have an annual budget development process, that results 

in the annual budget appropriation every year, that is 

due -- has to be approved and forwarded to the State and 

the County by September 30th every year. During the 

fiscal year, we will have amendments to that budget from 

time to time, as may be necessary, but typically, at 

least, you know -- you'll have at least two amendments 

every fiscal year, a mid year, and then a close-out 

amendment, and then you have the original appropriation. 

Q. The two amendments, those are planned ahead of 

time to happen every year?

A. Time-wise, yes. We know generally when we want 

to bring those forward. 

Q. And what is the purpose of having those 

amendments?

A. To account for additional revenues or grants we 

may receive during the fiscal year and to deal with 

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additional expenditures that may need to be addressed 

from time to time via an appropriation action by the 

City Commission.

Q. And do you ever have other amendments, other 

than those, the mid year and the -- 

A. No.

Q. Could it come up that you needed to, if there 

was some significant concern about the budgeting or the 

finances?

A. Yes.

Q. Has that ever happened before?

A. In my 20 odd years of my involvement with the 

City, not really.

Q. Would you say, in general, that the City is run 

fiscally soundly? 

A. I absolutely would.

Q. Have there ever been periods when you were 

concerned about that?

A. Yes.

Q. When was the last time you had a concern about 

that?

A. 2008 to 2010.

Q. Just generally speaking, what was the basis for 

that?

A. We were in a financial environment in this 

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country where there was a huge real estate bust. The 

City of Miami and the Miami region happened to be the 

epicenter of that. Simultaneous to that, we have two 

pension plans -- two, you know, employee pension plans, 

that were suffering losses that, by contract, the City 

had to fill in the gap, if you will, financially. All 

of that came together at one time. So we were eating 

into our reserves. 

The result of that was a declaration of 

financial urgency by the City, which is a State 

designation, which allowed us to actually impose Union 

contracts and make changes to the pension, in order to 

ride through that financial kind of crisis period.

Q. Was the SEC case that you testified in arising 

out of that period of time?

A. Timing-wise -- no. It occurred -- it arose out 

of bond transactions that occurred after that time 

period.

Q. So it wasn't connected to that -- 

A. No, it was not.

Q. Was there ever any allegations of impropriety 

or mismanagement in the period of the downturn that you 

talked about?

A. No. 

Q. It was just a matter of, everyone was suffering 

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and it was happening here?

A. Right. Yes.

Q. You talked about the updating to the current 

fiscal year budget. Setting that aside, what is the 

timeline on the annual budgeting process?

A. So, typically, we will start our preparation 

process between January and February. What that entails 

is us sending out communications to the various 

departments, please start readying yourself to, you 

know, make your request. We also align our strategy -- 

general strategy, to the budget allocation. So we're 

asking for your goals and objectives. 

The Budget Analyst and Budget Department, that 

report to me, start doing their forecasting for the next 

fiscal year. So they're gathering financial data from 

numerous sources, so that they can kind of come up with 

a methodical formulate means of supporting one of those 

forecasts.

Q. You say you talk to people about what you're 

expecting. Is that talking to the Commissioners or is 

that talking to the staff of the City, who are operating 

it?

A. So, typically, the commencement of that process 

is just talking to staff, you know, talking to police 

operations, fire, GSA, you know, what are, you know, our 

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car replacement needs. You know, we're literally 

gathering all of the information. 

Probably, as we get into the June time frame is 

when we formally engage with the City Commissioners and 

the Mayor. By Charter, the budget is actually the 

Mayor's presentation. So, at that point, we have, you 

know -- through the City Manager, of course, we've kind 

of formulated what our recommendation is with regards to 

the millage setting, fee setting, those matters, and we 

present that information, initially, individually, to 

the Elected Officials and get their feedback. We 

synthesize it and then we come up with a final proposed 

budget that is shared with the community. 

There is also community impact. We do public 

meetings. We do several of those during that process, 

as well, to kind of see what citizens are concerned with 

or what financial priorities there are, and we try to 

include all of that in the final proposed budget that 

gets presented in September for consideration and 

approved by the City Commission.

Q. And once you've submitted it in September, is 

it, you've handed it off to the Commission and now 

they're responsible for it?

A. At that point, by our Charter, they have line 

item authority to change the budget in any way, shape or 

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form they choose.

Q. If they do that, do they ask you to change it 

on their behalf?

A. It's a directive to the City Manager or through 

the City Manager, to make whatever those changes are.

Q. And you just completed that process for this 

year?

A. Yes, we did.

Q. How did that process go?

A. Fairly -- well, minus a couple of things that 

everyone knows has occurred with one of our 

Commissioners, it was a fairly smooth process.

Q. How long does it take to work out that process, 

starting from when you submitted it to the point -- 

A. Nine months.

Q. Okay. And so that's, essentially, from January 

1st to September 30th?

A. Correct.

Q. Do you ever finish early?

A. No. We were changing that final proposed 

literally up to an hour before the actual meeting 

occurred.

Q. When you're designing the budget, before you 

submit it, do you take into account potential new 

projects or Ordinances that the Commission is working on 

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or is it just based on what was already under the law 

and you were going to be doing anyway?

A. We try to be very forward thinking and take 

into account any and every input that we can. So that 

will include Federal law changes, State law changes, 

some pending, City Commission Ordinance changes, 

potential policy changes that they are intending to 

make, requests that they make, priorities that they 

share. So, yes, everything.

Q. If a Commissioner is thinking -- let's say, 

it's April and one of the Commissioners is thinking 

about trying to pursue a new initiative or create 

something that would have a budget impact, would you 

expect the Commissioner or their staff to reach out to 

you to discuss the potential budget impacts at that 

point?

A. Yes, but I will tell you, we're a little bit 

more proactive, so we're constantly going to them 

engaging. And when I say, "We," myself, the Manager, 

the Budget Director, and, you know, the staff, and, in 

some cases, some of my colleagues, you know, the other 

Assistant City Managers, as well, in their engagement 

with the Elected Officials in their areas.

Q. And that's part of what you talked about, say, 

the hour a week or whatever with each one?

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A. Yes. Yes.

Q. You're just meeting with them and asking them 

what they're working on, do you have anything that's 

budget-wise, let's talk about it?

A. Right. They'll tell us.

Q. Do they ever ask, is this something that looks 

good to you or do they ask -- 

A. Well, no. They're like, I want to do this, 

please add it, make sure it's in the budget.

Q. Do they ever ask your advice? 

A. Yeah, they do. They don't listen to it, but -- 

Q. I was going to say, do they listen to your 

advice?

A. I'm like the five-year senior in the 

organization. I've developed a lot of respect. I think 

it's earned. And so they tend to, you know, take 

counsel from me when it comes to financial matters. 

Q. Do you ever tell them something, you say, 

"That's not a good idea" or "That's going to be a real 

big issue"?

A. As with any relationship, absolutely. 

Q. Does that happen often? 

A. No, not often, but it does happen.

Q. Have there been situations where you gave 

advice not to do something and they did it anyway?

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A. Yes.

Q. Does it ever cause problems for you?

A. No.

Q. It just comes with the territory?

A. Yes.

Q. How much City staff work time would you say is 

spent on the budgeting process?

A. Oh, my God, thousands of hours.

Q. Do you have an estimate of like what percentage 

of the staff time, of your staff, that you oversee, that 

is dedicated just to the budget?

A. 20 people, times 1,600 hours, somewhere 

probably in there.

Q. What are the other major tasks that you and 

your department are responsible for, separate from 

budgeting?

A. I have finance, which is the accounting 

function of the City. I have community development, 

which is the grants entitlement. I have grants 

administration. I have risk management. And I'm 

missing -- I have procurement, and I have asset dream or 

asset management, the department of real estate.

Q. Are you involved with municipal bond offerings?

A. I lead every one of them myself.

Q. How much staff do you have that support that?

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A. So we have both, internal and external staff 

supplements. So PFM is our financial advisor. We 

engage five underwriting banks, so all of their staff, 

outside bond counsel, internal bond counsel, and 

typically I have my Finance Director and my Treasurer 

that work on that.

Q. Is the Commission involved in the bond 

underwriting or issuing process?

A. They're part of the process, because they 

provide the authorization for me to proceed with the 

transaction. So there's a Commission -- so there's a 

bond ordinance passed for each offering.

Q. How many bond offerings have you done in 2023?

A. None.

Q. How many have you done in 2022?

A. None.

Q. Is that normal? 

A. It can be, yes.

Q. When was the last time you did a bond offering, 

that you recall?

A. My last one was for the Marlins garage, the 

Marlins Stadium garage, and I think that had to have 

been 2010.

Q. So it is not a regular occurrence every year?

A. It kind of depends on what's -- you know, 

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what's happening. So, for instance, the City citizens 

approved a bond referendum authorizing the City to issue 

up to 400 million dollars in bond proceeds for four 

different categories. I can go issue that debt at any 

time, with the limitation of the millage rate I can 

assess in order to pay the debt service on an annual 

basis. 

So, right now, and you asked about 2023, I'm 

doing a bond issuance in two weeks for 285 million, 

which was just approved by the City Commission. We are 

already planning to do another, at least, probably 200 

million of that same referendum. I'm trying to push 

them before the end of the calendar year, but it looks 

like it will be January of 2024. So it's a little wacky 

right now.

Q. Are the Commissioners involved in that? 

A. Only with regards to prioritizing the projects 

that are being funded and authorizing the bond 

ordinance, and if we wanted to do another referendum, 

they would have to approve that referendum to go out to 

the voting constituency to be considered. 

They're not involved in the mechanics of the 

actual issuance of the debt.

Q. Are the Commissioners involved in the oversight 

of the finances of the City?

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A. From the budgetary standpoint, policy setting, 

yes. They do not get involved in the day-to-day 

operations.

Q. Outside of the budgeting process, what specific 

interactions or duties do you have with the Commission 

that you have to work with regularly?

A. I mean, I have to keep it in the context of my 

position. I'm an Assistant City Manager, so I assist 

the Manager in running the day-to-day operations of the 

City. So picking up garbage, policing, public safety, 

parks, all of that. I could be assigned to do any -- to 

oversee any portion of that, based on the Manager's 

will. So, basically, anything associated with 

implementing or operating any of the policy decisions 

that the City Commission has and directs the Manager to 

follow, I could be responsible for, you know, 

implementing or overseeing. 

Q. When there is a Commission -- whenever the 

Commission is down a Commissioner, like right now we 

only have four Commissioners, do you notice it in your 

work? Does it impact your work?

A. Given that I've gone through this at the City 

like five or six times, no, it doesn't. We are here 

to -- you know, the City Commission is the board. You 

know, I'm the Chief Financial Officer. So we have a 

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business to run and we run the business.

Q. So you were in the office and doing your work 

in early 2023 When Commissioner Russell resigned; is 

that correct?

A. Yes, I was.

Q. What was the impact to your work during the 

period between when Commissioner Russell resigned and 

when Commissioner Covo took that seat?

A. No impact to my work.

Q. Has there been any impact to your work, during 

the current time, since Former Commissioner Diaz de la 

Portilla was suspended?

A. No impact to my work.

Q. Was there any period this summer, when 

Commissioner Carollo was unavailable, due to outside 

obligations?

A. No impact to my work.

Q. Is that true, in general, in these situations?

A. Yes, it is.

Q. When was the last time you recall a reduction 

in the number of Commissioners impacting your work in a 

significant way?

A. The period, I think it was either '08, '09, 

between -- the administrative change between Mayor Diaz 

and Mayor Regalado. We had two Commissioners removed 

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simultaneously from office, and then we had an election, 

a special election, and I recall, during that time, we 

probably had a six-week period where we couldn't 

actually hold a meeting, because there was a runoff. So 

we only had like one -- I think two duly elected, 

certified Commissioners, and the others were in the 

process, if you will. So that was the only time I 

recall that we just couldn't have a board meeting. 

Still did day-to-day operations, you know, all of that 

stuff did take place.

Q. What is the quorum requirement for the City 

Commission to have a meeting?

A. Three.

Q. And so as long as there are three active 

Commissioners, they can act and bind the Commission?

A. Yes.

Q. And that would be through a vote of two of 

them?

A. It's actually a vote of three of them.

Q. Like are they required to be unanimous?

A. No. 

Q. It's just the three of them act, and however 

they get there?

A. Correct.

Q. Had there been any preparations or 

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considerations for the possibility currently, while we 

only we have four active Commissioners, what would 

happen if another one were to leave?

A. No. No.

Q. Do you have any concern that that would happen?

A. No.

Q. Since the time when that you discussed, you 

know, the 2008 era, when two of the Commissioners left 

at once, has there ever been a time when you thought 

that it was possible that there would be that level of 

disruption of the Commission?

A. No. 

Q. Do you worry about that now at all?

A. I don't.

Q. What about the staff of the Commissioners, 

like, for example, does the staff for the District 1 

Commissioner stay in place when the Commissioner is 

gone?

A. As an operating concern, we do our best as, you 

know, I'll call it, swift management, to not disrupt 

those individuals, you know. Those are employees of the 

City, that have families and count on their paychecks, 

and so we leave them in place. They're still doing 

things. You know, they're working. They're not sitting 

at home. So they're working, waiting on the elected 

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position to be filled, and, you know, then, whatever 

decisions will be made, will be made.

Q. Does that staff still perform constituent 

services?

A. Yes, they do.

Q. Have you heard any complaints about lack of 

constituent services in District 1 since the 

Commissioner was removed?

A. I have not.

Q. Did you hear anything along those lines related 

to District 2, during the time between Commissioner 

Russell and Commissioner Covo?

A. I did not. 

Q. Have you ever had concerns that you've heard 

expressed to you -- concerns from other people, 

expressed to you, about constituent services in any 

district in Miami?

A. I mean, the normal -- in the normal course of 

business, of course, but not in relation to someone not 

being there to serve -- not being present in the elected 

seat.

Q. How does the fact that it's an election year 

impact the work that you do with the Commission related 

to budget?

A. You know, again, I've been doing this for a 

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very long time. In my view, the only thing I've ever 

seen is that there tends to be more conservatism when it 

comes to assessment of the millage and of setting of 

fees. It seems there will be a prioritization of 

projects, you know, that we need to get them done, so 

there's, you know, a push to really broadcast and really 

show results. So that's the biggest thing I see ever.

Q. Was that true for this year's budgeting 

process?

A. It absolutely was.

Q. Do you see a difference between the 

Commissioners who are up for re-election and the ones 

who aren't, during this process, when you work with them 

individually?

A. No. 

Q. Would you say that a Commissioner that's up for 

re-election is less engaged in the budgeting process 

than the one that isn't?

A. No, they're very well engaged in the budget 

process. 

Q. If you didn't know it was an election year and 

you were just -- but you had done your job for many 

years and you were dropped in, would you be able to tell 

whether a Commissioner was up for re-election or not, 

based on your interactions and request --

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A. With my eyes closed.

Q. You would know that they were up for 

re-election? 

A. Yes. 

Q. Is that based, you're saying, on like the 

conservatism of how careful they want to be with things?

A. That's a portion of it.

Q. Is it also like their body language?

A. No. They're very focused on constituent 

services. Not to say they're not focused all of the 

time, but there's a heightened level of focus during 

re-election time, because they are typically trying to, 

oh, yeah, I did this already, I did this already, you 

need to know.

Q. Has there ever been a situation where there was 

something that needed to be done in the City, you know, 

related to the Commission and the administration, and 

because it was an election year, that was unable to be 

done?

A. No.

Q. Is there ever anything that the Commission or 

the City is supposed to do, that they don't do because 

of what you would assess as like fear of political 

impacts in the election?

A. No. 

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Q. Would you say that the budget process runs 

similarly whether it's an election year or non-election 

year?

A. The process, absolutely runs the same every 

year.

Q. Do you prefer it election years or non-election 

years? 

A. It doesn't matter to me. The information that 

I provide, the feedback that I give, is always focused 

on the running of the business. So I will make -- you 

know, not that they're always accepted, but we will make 

professional recommendations with regards to, again, fee 

setting, dollar allocations to certain things that we 

know need to be addressed the same way every year, 

regardless of whether it's an election year or not.

Q. Does the staffing of your department change 

whether it's an election year or not?

A. No.

Q. Is that true across the City? 

A. Yes. 

Q. There's never any, oh, it's an election year, 

so we need to get more people working?

A. No. You know, there's a hard line between 

their political staff and our staff. So that stuff 

is -- I don't even know -- that's their private stuff. 

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We have our 4,600 employees and they're here. 

Q. Is there any impact of a special election, 

outside of the regular course, on this work?

A. No, not really. I mean, you know, other than 

an invoice, no.

Q. You haven't had an experience where, let's say, 

you were going to go and work on the budget, and one of 

the Commissioners said, you know what, I've got a 

special election coming up. I know no one else is 

dealing with it, but just don't anything, don't talk to 

me right now?

A. Never.

Q. They always meet with you, when you want to 

meet with them? 

A. Every time.

Q. That's nice. 

A. No, it's not, for the record.

Q. What is the procedure that the City follows 

before holding a public meeting?

A. Generally speaking, I don't know the specific 

mechanics, you know, of that detail. I couldn't one, 

two, three, four it, but there's always -- the biggest 

thing, there's a public notice requirement before every 

public meeting.

Q. Are you involved in that process?

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A. Thank God, not at all.

Q. You don't contribute any language that gets put 

into it?

A. Never.

Q. That's probably good. 

Do you see the agendas for the public meetings 

before they're finalized?

A. I'm part of a draft agenda, and this is related 

to the general City Commission agenda, specifically. So 

I see that agenda, and we review it usually 30 days 

before it is to be published.

Q. Are there any types of public meetings in which 

that process is not followed?

A. None that I'm aware of. 

Q. Are there any like emergency justifications for 

not following those processes? 

A. No. You always have to give notice. Even if 

it's 24 hours, you have to give notice.

Q. Do you consider the elections part of the 

ordinary business administration of the City Commission?

A. I consider it part of the ordinary course of 

the City's business, yes. It doesn't -- it is not a 

part of the administration's business.

Q. Are you involved at all in the planning of 

elections?

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A. No.

Q. Are you involved at all in the administration 

of the elections?

A. No.

Q. Do you have any inside knowledge of what 

happens, before the rest of the public, as to what 

happens in elections?

A. No.

Q. You sit and watch the results just like 

everyone else?

A. Well, as a citizen of Miami, I'm a voter, so 

I'm being at the polls. 

MR. JOHNSON: It's a little concerning if 

you see the results before the election.

BY MS. MCNAMARA:

Q. I can't imagine that you'd be like, oh, yeah, 

they run it by me, and I say, yeah, change it -- 

A. And, remember, that data and all of that stuff 

is with the County's Elections Department.

Q. Oh, right. Absolutely. 

Do you have any relationships with the County 

in your work?

A. Plenty.

Q. What kind of interactions do you have with the 

County? 

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A. I interact with my counterparts at the County 

quite often with regards to intergovernmental issues, 

typically, you know, obviously, more focused on 

financial matters, but could be a property or, you know, 

we need to do something in collaboration, because it's 

in the City, but it's their street. You know, it could 

be a number of things.

Q. Are you involved in the invoicing and payment 

of invoice processed for the elections to the County?

A. I am charged with overseeing finance, so they 

process the invoice.

Q. Have you ever had an issue with an invoice for 

the City -- a City invoice from the County Elections?

A. No.

Q. Do you foresee that it's likely that you would 

ever have an issue with that?

A. No.

Q. How significant is the cost of running 

elections to the City's budget?

A. Fairly minute. 

Q. So how much is the annual budget for this year?

A. One billion sixty-eight million. 

Q. What was last year's budget?

A. 965 hundred million, so just shy of a billion. 

Q. What about 2021?

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A. I don't know that one right off the top of my 

head.

Q. Would you say it's going up -- 

A. It's absolutely going up.

Q. Always goes up?

A. Yeah. Yeah, it always goes up.

Q. Would you attribute that to inflation or -- 

A. No. No. No. There is a natural increase in 

fees and costs, also, so, you know, you have to offset 

that. So, yes, it always goes up.

Q. Have you ever been told that you need to 

significantly lower the budget to get it back down?

A. People have used those words with me, but then 

I have to give them context, and so significant might 

be, I'll cut a million dollars over here, but that's not 

significant.

Q. If you had to guess the percentage of the 

annual budget that's dedicated to elections, what would 

you guess?

A. .0001, something like that. It's a very small 

number. And, remember, it's not every year, so -- and, 

then, we save money, I know, when we do have election 

cycles that fall within the County's election cycle. So 

that's a little bit cheaper, but, yeah, it's very 

insignificant. 

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Q. Is there an approval process for expenditures 

that need to be signed off by someone within the City?

A. Yeah. We use the Oracle ERP system, that has 

the approval hierarchies already built into the system. 

So say you initiated an invoice and you were a part of 

my organization. It will go through whatever the 

hierarchy is. I won't necessarily approve it. It may 

be -- depending on the dollar amount, it will go to your 

supervisor and that's all that's needed for it. If 

you're a manager, and that's all that's needed, or the 

Finance Director, that's all that's needed, but not 

necessarily to me. 

I think the only expenditures I really approve 

on a regular basis is that of the City Manager.

Q. And why do you approve the expenses of the City 

Manager?

A. Because he can't approve it himself, and he's 

the number one person in our organization, and it can't 

be approved by the Elected Officials, because they're 

not part of the day-to-day operations. 

Q. Are there thresholds for amounts that influence 

the level of approval needed?

A. Absolutely.

Q. What is the lowest threshold? 

A. I couldn't tell you.

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Q. What is the high threshold? 

A. A billion dollars, whatever that appropriation 

is.

Q. Where would you put election expenses on that 

continuum of very small to very high?

A. I mean, I know it tends to be in between 200 to 

maybe a half million bucks, so probably not that high.

MS. MCNAMARA: It's approaching 3:00. Do 

you want to stop and talk? 

Do you want to take a break? 

THE WITNESS: If you need to take a caucus, 

I'm definitely for that, if you need to. 

(Short recess taken.)

BY MS. MCNAMARA:

Q. So, at the earlier portion, you testified that 

the impact of election years on the performance of the 

Commission during the budgeting process mostly reflects, 

you know, more interesting constituent services?

A. Conservatism and results.

Q. Yeah. Are there any other impacts that you see 

to the budgeting process as a result of it being an 

election year?

A. No.

Q. In an average election year, can you tell the 

difference -- let's cut that off. 

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Can you tell the difference between an election 

year in which there's two Commissioners and the Mayor 

up, versus an election year where there's three 

Commissioners up?

A. No. 

Q. What if all five of the Commissioners happen to 

be up for election, do you think that would change it?

A. It's going to be an interesting year.

Q. Why do you say that?

A. This is a personal response. You have the 

opportunity to have 100 percent turnover in elected 

officials, which would undoubtedly result in a hundred 

percent potential change in how policy is derived and 

implemented, and, you know, that would be a lot, a lot 

of change at one time, without having, you know, some 

historical, political knowledge, on the dais, and, you 

know, potentially some level of balance, but that's a 

personal thing.

Q. Do you think that a Commissioner whose up for 

re-election, and, therefore, uncertain whether they will 

still be in the position six months from now, behaves 

differently in the budget process from one who is in the 

middle of their term and is not concerned about whether 

they're going to be there in six months?

A. No, because, generally -- and the reason why I 

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said it doesn't change a lot, remember, this is their 

one and only time a year that they get to really have an 

impact on the operations via the money. So they can 

say, only hire -- I'm only going to give you money to 

hire five people, or they can eliminate a specific 

position, you know. So they're always engaged, because 

it's that one and only opportunity to do so, you know, 

the big time to do so.

Q. Does the presence of it being an election year 

negatively impact the ordinary operations of the 

Commission?

A. No.

Q. Is that true regardless of the number of 

Commissioners who are up for re-election?

A. Yes.

Q. If there happens to be all five Commissioners 

up for re-election, let's say, right now, in November of 

2023, do you think that would have negatively impacted 

the budgeting process that you just completed?

A. No.

Q. Do you think it would negatively impact any 

other administration processes that you're involved in? 

A. I mean, I might quit, but -- 

Q. It would negatively impact you, because you 

would leave. 

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A. Again, it's a personal thing. I've been 

through this. I've been a City Manager in a city. I've 

gone through political change, a lot of it, here, in my 

tenure here. So, for me, personally, yeah, I'll 

probably make some different decisions for me, but I'm 

also the guy who's been through five City Managers, and 

I've been through a lot, change-wise, not negative, but 

budget process-wise. No, they're still going to, I want 

five of these, you know, I want two of this, I want this 

to happen, I want to support this CBO. All of those 

things are still going to be there. And, again, I go 

back to the same thing, the only thing I know generally 

happens is, they're very conservative with regards to 

the millage assessment. By that I mean, they typically 

want to reduce taxes during that time, and that's what 

happens. Like last year, it happened, and you saw, this 

year, it happened again. 

MS. MCNAMARA: No further questions from 

us. 

MR. JOHNSON: No Cross. Read. 

(Thereupon, the reading and signing not 

being duly waived, the deposition was concluded 

at 3:07 p.m.)

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_______________________

DEPONENT

Sworn to and subscribed before me this _____ 

day of __________________, 2023.

 

_______________________

NOTARY PUBLIC

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CERTIFICATE OF OATH

STATE OF FLORIDA :

 SS

COUNTY OF MIAMI-DADE:

I, NIEVES SANCHEZ, Court Reporter, and a 

Notary Public for the State of Florida at Large, do 

hereby certify that LARRY SPRING personally appeared 

before me and was duly sworn.

WITNESS my hand and official seal in the 

City of Miami, County of Miami-Dade, State of Florida, 

this 17th day of October, 2023. 

__________________________

NIEVES SANCHEZ

Notary Commission Number HH 385498

My Notary Commission expires August 11, 2027

REPORTER'S DEPOSITION CERTIFICATE

STATE OF FLORIDA :

 SS 

COUNTY OF MIAMI-DADE:

I, NIEVES SANCHEZ, Court Reporter and a Notary 

Public for the State of Florida at Large, do hereby 

certify that I was authorized to and did report the 

deposition of LARRY SPRING; that a review of the 

transcript was requested; and that the transcript is a 

true and complete record of my stenographic notes. 

I further certify that I am not a relative, 

employee, attorney, or counsel of any of the parties, 

nor am I a relative or employee of any of the parties' 

attorney or counsel, nor am I financially interested in 

the action.

DATED this 17th day of October, 2023.

_________________________

NIEVES SANCHEZ

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Case 1:22-cv-24066-KMM Document 166-3 Entered on FLSD Docket 01/29/2024 Page 46 of

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BAILEY & SANCHEZ COURT REPORTING, INC.

(305) 358-2829

October 17, 2023 

Larry Spring

c/o Christopher N. Johnson

Gray Robinson

333 S.E. 2nd Avenue

Suite 3200

Miami, Florida 33131

RE: Grace, Inc. vs. City of Miami

Dear Mr. Spring:

The transcript of your deposition, taken in the 

above-styled cause on October 6, 2023, is at my office 

awaiting your examination and signature. PLEASE 

TELEPHONE BEFORE COMING IN so that we may arrange a 

convenient time.

Please be advised that unless I hear from you by 

November 17, 2023, I will forward the original of your 

deposition to the deposing attorney, as though you had 

read and signed your deposition.

IN THE EVENT a copy of the transcript is being sent to 

the witness by counsel, kindly instruct the witness to 

make any changes thereto on a separate sheet of paper 

and refer to the page number and line number which 

corresponds to the change desired. DO NOT MAKE THE 

CORRECTIONS ON THE TRANSCRIPT. If you have any 

questions, please call.

Very truly yours,

NIEVES SANCHEZ

Court Reporter

cc: Caroline A. McNamara, Esq.

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Case 1:22-cv-24066-KMM Document 166-3 Entered on FLSD Docket 01/29/2024 Page 47 of

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ERRATA SHEET

IN RE: GRACE, INC., ET AL. vs. CITY OF MIAMI 

DEPOSITION OF LARRY SPRING

TAKEN OCTOBER 6, 2023

DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE

PAGE # LINE# CHANGE

________________________________________

________________________________________

________________________________________

________________________________________

________________________________________

_______________________________________

_______________________________________

_______________________________________

_______________________________________

_______________________________________

_______________________________________

___________________

SIGNATURE

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