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The complaint asserts statutory jurisdiction under Florida law, identifies the named officials as Defendants, and alleges the property was her primary residence despite frequent 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LA MORA,as Miami-DadeCounty Tax Collector,and LEON M.BIEGALSKI,as the Executive Director ofthe Florida Department of Revenue,  \nDefendants.  \n## COMPLAINT\n\nCOMES NOW,the Plaintiff,ISABEL CRISTINA ECHEVERRI,(herein after“Plaintiff\"or\"ECHEVERRI”)by through undersigned counsel,and brings this action againstthe Defendants,PEDROJ.GARCIA,as Miami-Dade County Property Appraiser,MARCUSSAIZ DELA MORA as Miami-Dade County Tax Collector,and LEON M.BIEGALSKI,as theExecutive Director of the Florida Department of Revenue(herein after “Defendants”)and asgrounds thereof would allege as follows:  \n1.This is an action to contest the denial of and revocation of a homestead exemption for thetax years 2005-2011 and the subsequent reassessment of property taxes applicable to thesubject property.  \n2.The Court has jurisdiction pursuant to Chapter 194,Florida Statutes,and Article V,Sections 5 and 20 of the Florida Constitution.Venue is proper in Miami-Dade County,Florida pursuant to Section 194.171(1),Florida Statutes,since the subject property islocated in Miami-Dade County.  \n3.Appraiser Garcia is sued in his official capacity as the Miami-Dade County PropertyAppraiser and is a necessary party to this action pursuant to Florida Statutes section194.181(2).  \n4.Collector Saiz De La Mora is sued in his official capacity as the Miami-Dade County TaxCollector and is a necessary party to this action pursuant to Florida Statutes Section194.181(3).  \n5.Executive Director Biegalski is sued in his official capacity as Executive Director of theFlorida Department of Revenue and is a necessary party to this action pursuant to FloridaStatutes Section 194.181(5).  \n6.The relevant time periods are tax years of 2005-2011.  \n## ALLEGATIONS\n\n7.During the relevant time period,Plaintiff was the owner of property located in Miami-Dade County,Florida,having a Miami-Dade County Folio Number,02-3227-008-1080(referred to as the“Subject Property”)and having the legal description and address of:  \nLOT 4 IN BLOCK 14,OF AMENDED PLAT OF SUNSET LAKE SUBDIVISION OF MIAMIBEACH BAY SHORE COMPANY,ACCORDING TO THE PLAT THEREOF,ASRECORDED IN PLAT BOOK 8,AT PAGE 52,OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY,FLORIDA a/k/a 2132 Alton Road,Miami Beach,Florida 33140  \nA copy of the Warranty Deed vesting title in the Plaintiff is ttached hereto as Exhibit“A”.  \n8.On or about November 1,2012,the Office of the Property Appraiser sent Plaintiff a Noticeof Intent to Lien letter alleging that the Subject Property was not entitled to a homesteadexemption for the tax years 2005-2011.Included with this letter was an amount allegedlyowed for $127,063.96.A copy of the Notice of Intent to Lien letter is attached hereto asExhibit\"B\".  \n9.The Appraiser's stated basis for alleging the property was not entitled to an exemption was  \nbased on the incorrect determination that the Plaintiff did not occupy the Subject Propertyas her permanent residence to the exclusion of all others.  \n10.However,contrary to the Miami-Dade County Property Appraiser's conclusion,thePlaintiff has only resided in the Subject Property during the times material to this action.Moreover,the Plaintiff has not claimed a homestead exemption for any other property dueto the fact that the Subject Property is her primary residence when she is not traveling.  \n11.From 2005-2011,the Plaintiff was the owner of record for only one property,the SubjectProperty.  \n12.From 2005-2011,Plaintiff received only one homestead exemption.The homesteadexemption received by Plaintiff was for the Subject Property.Said property was thepermanent residence of Plaintiff,however,because Plaintiff travels frequently,Plaintiffhad her mailing address designated at the property of her sister,Maria E.Echeverri,to wit341N.E.92nd Street,Miami Shores,Florida","cbCailD2AuwIz0cu","https://ap.wps.com/l/cbCailD2AuwIz0cu","pdf",219705,"English","# COMPLAINT\n## ALLEGATIONS\n## COUNT I - ACTION FOR DECLARATORY RELIEF AGAINST ALL DEFENDANTS","[{\"question\":\"What legal issue does the complaint challenge for the tax years 2005–2011?\",\"answer\":\"The complaint challenges the denial and revocation of a homestead exemption and the subsequent reassessment of property taxes tied to the subject property.\"},{\"question\":\"Who are the defendants named in the action?\",\"answer\":\"The defendants include the Miami-Dade County Property Appraiser, the Miami-Dade County Tax Collector, and the Executive Director of the Florida Department of Revenue.\"},{\"question\":\"On what basis does the Plaintiff claim entitlement to the homestead exemption?\",\"answer\":\"The Plaintiff alleges the subject property was her permanent residence to the exclusion of all others, and disputes the finding that she did not occupy it as her primary home despite frequent travel.\"}]","IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT - COMPLAINT | PDF",1789530464]