Filing # 105838994 E-Filed 04/03/2020 12:41:23 PM

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT

IN AND FOR MIAMI-DADE COUNTY, FLORIDA
Case No.: 2019-030366

STEVEN MIRO

Plaintiff,
v.

CITY OF MIAMI

Defendant.
_______________________________________/

PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S UNVERIFIED

FRIVOLOUS MOTION FOR A PROTECTIVE TO STOP THE DEPOSITIONS OF
NON-PARTIES JOE CAROLLO AND ALEX DE LA PORTILLA
& PLAINTIFF’S CROSS-MOTION FOR SANCTIONS

Plaintiff Steven Miro hereby files response in opposition to the City of

Miami’s unverified frivolous motion for a protective order to stop the

depositions of non-parties Joe Carollo and Alex Diaz de la Portilla, and

Plaintiff’s Cross-Motion for Sanctions.

Introduction

This is a public whistleblower lawsuit brought by a former City employee

who worked for Commissioner Joe Carollo. Plaintiff Steven Miro was

terminated two days after Joe Carollo and his staff learned that Carollo was

under investigation by the Miami-Dade State Attorney’s Office Public

Corruption Unit. A massive cover-up by the City, Joe Carollo and the City

Attorney’s Office then ensued (and continues to this day).

The underlying allegation (detailed in the Corrected Complaint and

Plaintiff’s verified presuit complaint to the City that is attached to the Corrected

Complaint) is that Joe Carollo illegally used City of Miami funds to support the
then-candidacy of Alex Diaz de la Portilla during his unsuccessful run for

County Commission. Steven Miro “blew the whistle” when he reported this

illegal activity to the SAO. The SAO investigated, but declined to press charges

and closed the account in October 2019, before this lawsuit was even filed.

See Exhibit A.

Now, without so much as an affidavit from either witness, the City of

Miami seeks to prevent Joe Carollo and Alex Diaz de la Portilla from testifying.

The City Lacks Standing

Joe Carollo and Alex Diaz de la Portilla are not parties to this lawsuit.

The motion was filed on behalf of the City, not these two commissioners. The

City has not explained how it even has authority to seek protection on behalf of

and for the benefit of non-party witnesses. Joe Carollo was at least employed

by the City at the time his misconduct occurred. But Alex Diaz de la Portilla

was not employed by the City in any capacity at all material times.

The City has explained that it has a policy of representing commissioners

when their legal needs arise from their role as commissioners. But the City

Attorneys refuse to clearly explain whether there is an attorney-client

relationship between Joe Carollo and the City Attorney and between Alex Diaz

de la Portilla and the City Attorney. Are they serving the interests of the City of

Miami or the interests of two individual commissioners who likely have a

conflict with the City of Miami? Unless the City Attorneys have a fiduciary duty

to these non-witnesses, they cannot be seeking affirmative relief in this Court

on their behalf.

2
 The City’s History of Abuse

Virtually nothing has happened in this case because the City has

engaged in various attempts to stall the proceedings. The first scheduled

deposition was cancelled by the City due to some unidentified scheduling

issues. The two most important depositions (Joe Carollo and Alex Diaz de la

Portilla) have been postponed due to this motion.1

The City filed a last-minute, unverified and completely frivolous motion

to disqualify David Winker, an attorney for non-party witness Tanja Quintana.

The deposition was stopped literally moments before its scheduled start time

following an emergency hearing. Under threat of sanctions pursuant to Section

57.105 and the Court’s inherent authority (which remain pending), the City

voluntarily withdrew its motion to disqualify David Winker. (Ms. Quintana

should have been deposed a month ago, but who knows when she will be

deposed now and whether her putative testimony has been coerced or altered.).

It was a completely frivolous, bad faith motion designed to prevent Ms.

Quintana from testifying. The City is literally terrified of witness testimony in

this case and will stop at nothing to preclude discovery.

Carollo’s Underlying Misconduct is Highly Relevant

First, the City wants to prevent Joe Carollo from testifying about the

underlying allegations on the theory that the Plaintiff does not need to prove

actual illegal activity. It is true that the tort requires only a good faith belief

1
While Joe Carollo and Alex Diaz de la Portilla have every right to assert their Fifth
Amendment rights against self-incrimination, the fact that they may have to do so is not a basis
for them to not be deposed.
3
that the City is engaged in illegal activity. Unlike the private whistleblower act,

Plaintiff has no obligation to prove an actual violation of law. But this issue

concerns the first element of the tort, i.e., is the employee or former employee

“protected” by the statute. Plaintiff appreciates the City of Miami’s concession

as to the first element, but it isn’t relevant here.

The City overlooks another element of the tort – causation. Did the

Plaintiff’s engagement in protected activity cause his termination? Here, the

truthfulness of the underlying allegation (i.e., did the City actually engage in

misconduct or did the Plaintiff simply believe the City was engaged in

misconduct when it actually was not) is highly relevant. If the allegations of

misconduct were substantively baseless, then the City would have an easier

time showing that Plaintiff’s termination was wholly unrelated to his

accusation of misconduct. If the allegations of misconduct had merit because

the City was actually engaged in misconduct, then the Plaintiff would have an

easier time showing that Plaintiff’s termination was causally related to his

accusation.

Put another way, was Joe Carollo more motivated to terminate Steven

Miro because Miro’s allegations that Carollo was using City funds to support

Alex Diaz de la Portilla had legs? The truthfulness of Miro’s allegations is

directly related to the causation element of the tort – and this requires Miro to

obtain discovery from the two witnesses to the underlying allegation, Carollo

and Diaz de la Portilla.

4
 Argument

“A party may obtain discovery regarding any matter, not privileged, that

is relevant to the subject matter of the pending action, whether it relates to the

claim or defense of the party seeking discovery or the claim or defense of any

other party.” Nucci v. Target Corp., 162 So. 3d 146, 152 (Fla. 4th DCA 2015).

“It is not ground for objection that the information sought will be inadmissible

at the trial if the information sought appears reasonably calculated to lead to

the discovery of admissible evidence.” Id. Discovery under the Florida Rules of

Civil Procedure permit discovery into anything relevant, without regard to its

admissibility at trial. See Amente v. Newman, 653 So. 2d 1030, 1032 (Fla.

1995).

“The burden of showing good cause is on the party seeking the protective

order.” Bush v. Schiavo, 866 So. 2d 136, 138 (Fla. 2d DCA 2004) (quashing

protective order that precluded the taking of seven depositions of persons with

knowledge). “A strong showing is required before a party will be denied entirely

the right to take a deposition.” Id. “Florida courts have disapproved the entry

of protective orders prohibiting the taking of depositions generally and orders

providing for lengthy postponements of discovery.” Id.

Discovery is framed by the pleadings. The crux of this lawsuit is that Joe

Carollo and Alex Diaz de la Portilla engaged in criminal activity when public

funds were used to support a campaign. Steven Miro was present for these law

violations and he will testify extensively about what occurred. He even brought

receipts. He was fired almost immediately after Joe Carollo and his staff

5
members were notified of the criminal investigation arising from Miro’s

accusations. The City’s defense is that Miro’s termination was unrelated to the

criminal investigation, and was instead the result of staff members accusing

Miro of workplace misconduct the day after Carollo learned of the criminal

investigation. The timing of Miro’s termination was, purely coincidental,

according to Carollo.

Not only are underlying allegations relevant for the Plaintiff to prove his

case, they are highly relevant for the Plaintiff to disprove the City of Miami’s

alternative causation defense. These issues also go to the credibility of Joe

Carollo. His testimony that Miro was fired for reasons unrelated to the

criminal investigation into him are undercut by the existence, extent and

accuracy of underlying violations themselves. Plaintiff is entitled to prove that

Joe Carollo is lying. The underlying facts are highly probative.

The City’s Alternative Request for a Gag Order is Un-American & Comical

As an alternative, the City is requesting an order precluding the parties

from speaking with the media about the depositions of two city commissioners

and from disclosing the actual transcript to the media. Without any evidence,

the City claims, “this case has, and will continue to, attract a high media

presence.” Plaintiff has no idea what constitutes “a high media presence.”

(Would a gag order be appropriate if this case had a “medium” or “small” media

presence?).

It is true that the Miami Herald ran an article on Miro’s termination and

the City’s response in June 2018. The City’s many statements to the Miami

6
Herald were false and malicious, and may result in additional litigation. But

the sole article, attached as Exhibit B, contains statements and quotes from the

City. Miro’s counsel specifically told the Miami Herald he would not play this

lawsuit out in the media. Id.

On Friday, April 3, 2020, the City filed exhibits it intends to use at the

hearing. This is an untimely bad faith filing. The City’s unverified,

unsupported motion was filed on February 11, 2020, yet they waited until April

3, 2020 to file supporting documents for an April 8, 2020 special set hearing.

This is either a bad faith tactic by the City or just bush league lawyering.

Ironically, the City’s April 3, 2020 filing constitutes multiple Miami

Herald articles that discuss a new and pending effort to recall Joe Carollo due

to his gross misconduct and City Attorney Victoria Mendez’ history of

corruption in support of her unofficial client Joe Carollo. These Miami Herald

articles have nothing to do with Steven Miro’s termination or this pending

lawsuit. (Nor is undersigned counsel a lawyer for any party in the recall

lawsuit). The City is just pointing out that the Miami Herald covers the City’s

misconduct. This is precisely what the Miami Herald is supposed to do.2

So, the City wants protection from its own misconduct!

2
The City also included emails from David Winker (not undersigned counsel) to various
members of the press. David Winker is not Steven Miro’s attorney; Mr. Winker represents a
non-party witness to this lawsuit. If the City has a problem with Mr. Winker, it can take it up
with Mr. Winker.
Perhaps even more interesting is that the City has not asked for a gag order in connection
with any other pending litigation that arises from Joe Carollo’s misconduct, specifically the
unrelated recall lawsuit pending before Judge Alan Fine that the City recently lost.
Nor did it request a gag order in the two prior public records act lawsuits filed by Steven
Miro. Those lawsuits – the City lost both – concerned the underlying facts in this lawsuit.
7
 The City of Miami is – spoiler alert – a public municipality. It is required

to operate in the sunshine. It sues and is sued, daily. Misconduct at the City

of Miami makes the paper, daily. The City of Miami is a notoriously corrupt

public entity. The City of Miami cannot credible claim – and indeed it doesn’t

actually make the claim – that it cannot receive a fair trial in this matter

because of widespread negative press coverage. Put another way, the City of

Miami wants this Court to rule that it cannot receive a fair trial if the public

learns of the (presumably truthful) testimony of Commissioner Joe Carollo and

Commissioner Alex Diaz da la Portilla.

The City relies exclusively on E.I. Du Pont De Nemours & Co. v. Aquamar,

33 So. 3d 839 (Fla. 4th DCA 2010). But there the Fourth District actually

quashed a gag order on grounds similar to the facts here:

In Florida, the limitations imposed by the court on

communications between the media and lawyers and/or litigants
must be for good cause to assure fair trials. Rodriguez ex rel.
Posso-Rodriguez v. Feinstein, 734 So.2d 1162, 1164 (Fla. 3d DCA
1999). Thus, a gag order should be supported by evidence and
findings that any extrajudicial statements made by counsel or the
parties pose a substantial or imminent threat to a fair trial. Id; see
also News-Press Publ'g Co. v. Hayes, 493 So.2d 1, 2 (Fla. 2d DCA
1986) (quashing order restricting extrajudicial statements because
it was entered sua sponte without a proper evidentiary hearing). As
in Rodriguez, the order on review was not supported by any
showing that it was necessary to preclude a substantial likelihood
of material prejudice to the trial of the case. Furthermore, there
was no evidence presented and there were no findings made that
any out-of-court publicity posed a substantial and imminent threat
to the fairness of the trial proceedings.

Id. at 841 (reversing gag order). Here, the City has presented no evidence to

support its motion. It is unfounded rank speculation.

8
 Finally, it hardly needs repeating that we have open court system in the

United States:

[B]ecause of the presumption of openness in court proceedings,

denial of access “ ‘may not be based solely upon the wishes of the
parties to the litigation.’ ” BDO Seidman, LLP v. Banco Espirito
Santo Intern., Ltd., –––So.3d ––––, 34 Fla. L. Weekly D739, 2009 WL
928484, *1 & *2 n. * (Fla. 3d DCA Apr.8, 2009) (quoting Friend v.
Friend,866 So.2d 116, 117 (Fla. 3d DCA 2004)); Barron v. Fla.
Freedom Newspapers, Inc.,531 So.2d 113, 118–19 (Fla.1988). And
even if a court allows confidential documents to be filed under seal,
such an order merely establishes a way to file them pending the
trial court's determination that they are entitled to be exempt from
public disclosure.

Rocket Group, LLC v. Jatib, 114 So. 3d 398, 400-1 (Fla. 4th DCA 2013).

“Except as provided in Florida Rule of Judicial Administration 2.420,

concerning "Public Access to Judicial Branch Records," "[t]he public shall have

access to all records of the judicial branch of government." Fla. R. Jud. Admin.

2.420(a).” Hotel Ass'n, Inc. v. Airbnb, Inc., --- So. 3d ---; No. 3D19-1222, at *3

(Fla. 3d DCA Mar. 4, 2020).

After Joe Carollo and Alex Diaz de la Portilla are deposed, the City is free

to ask this Court to seal certain specific portions of the depositions based upon

a specific showing. (And Plaintiff will object because nothing in this lawsuit

warrants sealing). But a pre-deposition blanket gag order based upon the City’s

own decision to publicly bash Steven Miro in the press days after it illegally

fired him is completely frivolous.

9
 Conclusion

For the reasons stated above, Plaintiff requests the City’s Motion for a

Protective Order be denied in its entirety and that Plaintiff be awarded fees and

costs necessarily incurred in defending against the unverified frivolous motion.

Respectfully submitted,

_/s/ Matthew Sarelson

Matthew Seth Sarelson, Esq.
Florida Bar 888281
MATTHEW SETH SARELSON, P.A.
Attorneys for Plaintiff Steven Miro
2100 Ponce de Leon, Suite 1290
Coral Gables, Florida 33134
305.773.1952
msarelson@sarelson.com

I hereby certify that on April 3, 2020, I served this document via email on

Victoria Mendez, Kevin Jones and Stephanie Parnoff.

/s/ Matthew Sarelson

Matthew Sarelson

10
 CLOSE-OUT MEMO

Public Corruption. Un.it

A..SA.: IsisPe~ INQUIRY#

: 64-19-17

'--,J~ DATE: 10/0812019

::[ri::.l
SIGNATURE:

fa- . DATE: /P- 2, / .. I'/

DivisiooC~tion

HowardRoseo
ChiefAssistant,SpecialProsecutions

SUBJECT(S):JosephCarollo EMPLOYMENT: Ci of MiamiCommissioner

INVESTIGATOR:M. Ambre INTERNALAFFAIRS

INVESTIGATOR:
AGENCY: SAOPCTF AGENCY:
PHONE: PHONE:

Sl'ATOTE DEGREE
CRIME Misdemeanor111
PoliticalActivitiesof municipalemployees )04.31
812.014 Felony3rd
Theft

CONCLUSION

The complaintreceivedby the MiamiDadeStatesAttorney'sOfficePublicCo tion Unit allegedthat

as City of Miami Commissioner(District 3) Joseph Xavier Car~was active engagedin political

0
PleaseReoycle EXHIBIT A
 ~paigning for anotherpoliticalcandidate ·~entifiedas Alejandro
(Alex)Diazde la Portillafurthe Miami
DadeCountyCommission District5 office idusinghis currentCityof MiamiCommissioner SpecialEvent
Fund(allocatedpublicmoney)allotmenttoe oorse,campaignforandprovidefoodgiveawayundertheguise
of it beinga City of MiamiCommissioner ollo event. Theallegationsrelateto constituent eventsthat
Commissioner Carollowashostingatvarious nioractivitycentersites.

Severalof Commissioner Carolloeve ts were scheduledduringthe timeof the MiamiDadeCounty

Commission District5 run off specialelectio set for May2211d, 2018. Theevidencealsoindicatedthatthe
eventsinquestionwerescheduled hastilyrigh beforethe eventstookplacewhichmadeitseemthattheevents
werebeingscheduledbecauseof the special ection.Cityof Mlamifundswereexpendedin thepurchase of
food anddrink to be givenawayto the co ·tuentsat the variousseniorcentersiteswithinCommissioner
Carollo's DistrictTheissuewaswhetherCo ·ssionerCarollowashavingcampaign eventsfor de la Portilla
underthe guiseof constituenteventsorwere "eventsconstituenteventsthathappened to includeparticipation
by de la Portilla,a candidate
.

Alex Diaz de la Portillawas the onl candidatethat participatedin theseeventsand his campaign
workerswerethe onlyonesthere.fromany aign. Furthezmore,de JaPortilla's campaignpaida musician
to performat one of the events. However,tbol~ ~Is alonedo not in themselves maketheeventsa campaign
event The issue is not if Alex Diaz de la P ~a was using his campaign funds at events that he or his
campaign workers attended. The use of campai n funds to pay musiciansor campaignworkers at these eventsis
not necessarilydeterminative of whetherCo · sioner Carollo and his st.affhosted a political campaignevent
wnh Cityof Miami public funds.

Candidatesare ofteninvitedto events are not campaignevents. This can be for reasonssuch as to
inform vot.ersand introduce candidatesso witthe voting public will have knowledgeof the candidate.
Swve~ footage ~at investigators we": ~!e to re~eve ~1? the various locations does n?t show
Co~1oner Carollo s staffmembersengagmt m campaignactmties. Some staff memberswore city attire
and did such thing.sas handingout food,talking o constituentsand socializingwiththe constituents. Through
witness testimony and surveillance,the eviden establishedthat CommissionerCaroJJodiscussedvarious
district (constituent)issues with the attendees the events which is what would be expectedat a constituent
event.

While it is stronglycoincidentalthatthee ents werecompressedintoa shorttime frame right beforethe

run-offspecialelectionand that de I.aPortilla's paignwas the only campaignthat attendedthe events, the
evidence obtained during this investigationis · cient to prove that the events were scheduled and
conductedfor the singularpurposeof campaignin for de la Portilla.

Staff membersexplainedth.alCmnmissio er CatoUo wanted to bold Mother's Day events during that
time that the events included djscus.'>ionof ru;tituent issue:. by Commissio ner Carollo aod that the
corr:nussioner's staff did not participate in cam ·g,1activities while al I.he events. All those ciroumstances
reflect 8 constituent event truJ.t
would fall within elected official's dutiC$. Therefore, there is insufficient
evidence to establish beyond a reasonable doubt tb the event'>were something other than constituent events.

As sue~ no chargeswill be filc::d.Thising · is now closed.

In Miami, Joe Carollo's fired aide sparks political drama | Miami Herald 4/2/20, 10:59 AM

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MIAMI-DADE COUNTY

Drama deepens in Miami City Hall after Joe Carollo

fires staffer amid criminal inquiry
BY JOEY FLECHAS
! " # $
JUNE 08, 2018 06:30 AM, UPDATED JUNE 08, 2018 10:21 AM

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VIDEOS
Steven Miro, one of Commissioner Joe Carollo's former staffers, was fired Monday. He faces allegations of misconduct at City
$
Hall. FACEBOOK

The melodrama at Miami City Hall is getting ugly.

Commissioner Joe Carollo's newly fired aide is facing allegations of harassment and misconduct
within City Hall — a new development a day after controversy spilled out of Carollo's office amid a
criminal investigation into a city-funded paella lunch for seniors that may have doubled as a Series will take viewers on guided
campaign event for former county commission candidate Alex Diaz de la Portilla. tours of Zoo Miami and county parks
during quarantine

According to interviews with City Hall staffers and records obtained by the Miami Herald, the $

https://www.miamiherald.com/news/local/community/miami-dade/article212725789.html Page 1 of 6
In Miami, Joe Carollo's fired aide sparks political drama | Miami Herald 4/2/20, 10:59 AM

former staffer, Steven Miro, was accused of making a sexually inappropriate comment to a female
colleague, highjacking Carollo's city email to authorize a $1,500 raise for himself and repeatedly
making phone calls for outside political work on the city's time.

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"This is behavior that cannot be corrected," said Richard Blom, a former Doral police chief who hasn’t advised it
was recently hired as Carollo's chief of staff. Blom said he pushed to fire Miro after the aide made MARCH 31, 2020 8:08 PM

multiple women uncomfortable around the office, creating what Blom called "an atmosphere of
gender-based hostility." Blom made the final decision to fire him Monday. SPONSORED CONTENT

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In Miami, Joe Carollo's fired aide sparks political drama | Miami Herald 4/2/20, 10:59 AM

Former Miami mayor Joe Carollo accused his political opponents of mail fraud Tuesday, capping an ugly month of mud-slinging
From Fido to Finances
in the race for the city’s District 3 commission seat. BY C.M. GUERRERO
Seaside National Bank & Trust

That atmosphere allegedly spread into Commissioner Ken Russell's office in February. Miro was Ready for a bank that gets to know you & provides
accused of making inappropriate remarks to one of Russell's staffers, which Russell confirmed custom solutions? Get started with us.

Thursday in a statement to the Herald.

"Learning of Mr. Miro's firing was no surprise except that we had expected it sooner and for other
reasons," he said. "He was no longer welcome in our office after making lewd comments to my
staff. I called human resources to let them know of the concern." WEBSITE DIRECTIONS

Russell cited the privacy of his staff when he declined to go into specifics. It's unclear what action
human resources took, but the department hastily called all city commissioners and their staffers
into mandatory diversity and sexual harassment training sessions on Wednesday — months after
the complaint and two days after Miro was fired. Other sources told the Herald that Miro faced
allegations that he had harassed women at City Hall.

Blom said Miro had a habit of violating people's personal space and aggressively questioning
women who work in Carollo's office about what they were doing, who they were calling and what
they were looking at on their computers. One of those women, Blom said, was planning to quit
because she was tired of Miro's behavior.

Then there was the question of whether Miro tried to approve a raise for himself.

Hired in December after working on Carollo's campaign, Miro was the commissioner's first staffer.
And for a time, he was the only one. Carollo had held off on hiring more employees while he
awaited the outcome of a legal challenge to his election — a challenge he would later win in trial
and on appeal.

Blom said in February Miro sent an email from Carollo's account authorizing a $1,500 salary
increase. Emails in Miro's personnel file, obtained through a public records request, show some
back-and-forth between human resources staffers regarding the raise. At one point, an employee
relations staffer wrote he had to manually deliver a "personnel action form," required to approve a
raise, to Carollo's office because "Steven Miro cannot approve his own PAF."

City spokesman Eugene Ramirez said the human resources department had no comment on the
incident, directing inquiries to Carollo's office.

Blom said Miro was verbally reprimanded afterward.

Miro was accused of political shenanigans as well. On Thursday, Carollo said Miro repeatedly took
phone calls from Zoraida Barreiro's county commission campaign while he was on city time. They
were the same kind of accusations someone had made against Carollo for the paella lunches he
sponsored at several senior citizen centers — paid for with city money — where Diaz de la Portilla
campaigned for the same post as Barreiro.

"The only person who worked in my office and used city time to work on the political campaign of
another is Mr. Miro," Carollo said.

Barreiro said she recalled seeing Miro walk neighborhoods knocking on doors for her campaign
only once. That was on a Saturday early on, in late April — when she says she was under the
impression Carollo was backing her. As for the phone calls, she said she had no knowledge of them.

"I don't even think I have Miro's number," she said.

Miro's attorney, Matthew Sarelson, dismissed all of the allegations while declining to go into
details because they plan to sue. Sarelson, who has faced Carollo in court before, said Miro would
not "play this out in the media."

https://www.miamiherald.com/news/local/community/miami-dade/article212725789.html Page 3 of 6
In Miami, Joe Carollo's fired aide sparks political drama | Miami Herald 4/2/20, 10:59 AM

"There is absolutely no merit to any of these allegations," Sarelson said. "These appear to be
arguments being contrived by Commissioner Carollo at the proverbial 11th hour and after he
illegally terminated my client in an effort to save face with the public."

If Miro did have behavioral issues at work, it wouldn't be the first time.

Between 2008 and 2009, Miro spent seven months working for Key Biscayne police. In that short
time, he drew complaints from multiple colleagues about his behavior and was reprimanded for
falling asleep while on duty three times, according to his personnel records.

In a memo filed two days before Miro resigned from the department, a female dispatcher
complained that Miro displayed "disrespectful behavior," made her feel uncomfortable and
created a "hostile work place" because of his attitude.

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