Filing # 51178784 E-Filed 01/13/2017 03:58:39 PM

IN THE CIRCUIT COURT OF THE

11th JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CIVIL DIVISION
CASE NO: 2016-026031-CA-01
GRANT STERN,
Plaintiff
v.
CITY OF MIAMI BEACH,
a political subdivision
of the State of Florida, and
PHILIP LEVINE,
Mayor, City of Miami Beach
Defendants.
_______________________________/
AMENDED COMPLAINT TO ENFORCE THE FLORIDA PUBLIC RECORDS
LAW AND ARTICLE 1, SECTION 24 OF THE FLORIDA CONSTITUTION
Plaintiff, Grant Stern, a resident and citizen of Miami-Dade County, Florida sues
the City of Miami Beach (City) and Mayor Philip Levine , and states:
Summary of Action
1.

This is an action for injunctive and declaratory relief to enforce Plaintiffs

rights to inspect and copy public records pursuant to the provisions of the Public Records
Act, section 119, Florida Statutes and Article I, section 24 of the Florida Constitution.1
Plaintiff also requests an expedited hearing as required by section 119.011, Florida
Statutes.

I think the objective of the Sunshine Law, of course - is to make sure that everything is out in the open,
and I believe that assuming youre doing the right thing for your constituents and for the people that youre
serving, its a wonderful thing. Most people - I believe - appreciate the fact that
everything you do as it relates to the business of the city is public information, and it should be.- Mayor
Philip Levine. See http://bit.ly/2dKErm6.
1

Jurisdiction and Venue

2.

This Court has jurisdiction over the subject matter of this case pursuant to

sections 26.012, 86.011, and 119.11, Florida Statutes.

3.

Venue is proper in this Court pursuant to section 47.011, Florida Statutes.

4.

All conditions precedent to the bringing of this action has occurred.

Parties

5.

Stern is a resident of Miami-Dade County. At all times relevant, Stern was

entitled to inspect and copy public records requested pursuant to section 119, Florida
Statutes and Article I, section 24 of the Florida Constitution.
6.

City of Miami Beach is a political subdivision of the State of Florida and

at all times relevant to this case was an agency under Section 119.011(2), Florida
Statutes (2016).
7.

Levine is the mayor of the City of Miami Beach and at all times relevant

to this case was an agency under section 119.011(2), Florida Statutes.

Statement of Facts
8.

Levine is a 21st century mayor who employs various digital mediums

including social media to communicate official business.

9.

Levines Twitter account identifies him as the mayor of Miami Beach.

Levines account name is Mayor Philip Levine and his Twitter handle is
@MayorLevine. The self-description section on Levines account states that Levine is:

Proudly serving as Mayor of Miami Beach. This page expresses the views
and opinions of Mayor Levine and not those of the City of MB.
#MBMayor #MiamiBeach.
See Exhibit 1.
10.

Similarly, Levine utilizes Facebook to communicate the official acts and

businesses of the City of Miami Beach to his constituents. Levines Facebook account
addresses him as a governmental official and that his current office is the mayor of
Miami Beach, Florida. Levines account states that he is: Making Miami Beach the city
that works...for its people. See Exhibit 2.
11.

After a cursory review of Levines Twitter and Facebook, theres no

question that Levine utilizes social media to communicate the City of Miami Beachs
official business. Levines communications include posts such as renaming a Miami
Beach street after Muhammad Ali2 to informing residents of the Zika virus outbreak in
the city. See Exhibit 3.
12.

Levine has two other Facebook accounts in which he does not conduct

official business, which are his personal page and his political campaign page, neither of
which is noted as government official.
13.

Lastly, Mayor Levine hosts a weekly satellite radio program on SiriusXM

called, The Mayor. As described by Mayor Levine in the shows pre-launch press
release, The Mayor provides listeners the insiders perspective on everyday
A day after the Levines Muhammad Alis post, the City of Miami Beach unanimously approved the
renaming of the street after Muhammad Ali. See http://bit.ly/1alimb and http://bit.ly/ali2mb and
http://www.local10.com/sports/miami-beach-commission-unanimously-votes-to-rename-street-aftermuhammad-ali.
2

government decision-making. The show focuses on issues that directly involve the City
of Miami Beach such as lobbying the U.S. Congress for Zika virus funding in his official
role as mayor.
14.

On July 23, 2016, Levine posted a photograph on Twitter where Levine

is seen greeting Hillary Clinton and Tim Kaine, who formerly ran for President and VicePresident of the United States of America. See Exhibit 1. Stern responded to Levines
post by sharing a recent article he wrote on Huffington Post entitled, Florida Senate
Candidate Slams Miami Beach for Fouling Biscayne Bay, Sunshine Law Failures. In
addition to the shared article, Stern stated, @MayorLevine hope that @HillaryClinton
@timkaine advised you fix the #MiamiBeach water pollution problem you caused. Id.
After said statement, Levine blocks3 Stern on Twitter. See Exhibit 4.
15.

Stern proceeded to Levines Facebook account (which is self-categorized

as a government official and is a verified page with a blue checkmark indicating that
Levine personally operates the account4), and requested a copy of Levines official posts
for the last 30 days on Twitter. See Exhibit 5 Levine responded by deleting Sterns
public records request. Stern subsequently complained to Levine regarding the deletion of

Blocking is a feature that helps the account holder control how he or she interacts with other users on
social media such as Twitter. This feature allows the account holder to restrict specific users from
contacting the account holder, seeing the account holders messages, and following the account holder. See
https://support.twitter.com/articles/117063. On Facebook, blocking prevents an unwanted person or entity
from seeing things the account holder post on his or her profile, starting conversations with the account
holder or adding account holder as a friend. The person blocked will not be able to be tagged in a posts,
comments, or photos, invite the account holder to events or groups, start a conversation with the account
holder, and add the account holder as a friend. See https://www.facebook.com/help/131930530214371
4
See Verified Page or Profile https://www.facebook.com/help/196050490547892

the previous requests. See Exhibit 6. Levine then blocks Stern from Facebook and then
deleted any comments made by Stern.5
16.

On July 25, 2016, Stern called the City of Miami Beach and made a public

records request for Levines block list6 on his government official Facebook page. The
City emailed Stern acknowledging their receipt of Sterns request and assigning him a
public records request number 12089. See Exhibit 7.
17.

Stern followed up by providing instructions to the City on how to obtain

the block-list on Facebook. Specifically, Stern stated:

Id like a list or copy of all persons blocked by the Mayor of Miami
Beachs official Facebook account. In a personal account this list can be
found at https://www.facebook.com/settings?tab=blocking In a Facebook
page account its accessible from the below URL, there is a flip down box
that

says

Banned

People

and

Pages:

https://www.facebook.com/mayorphiliplevine/settings/?tab=people_and_o
ther_pages.
Id.
18.

On July 27, 2016, the City of Miami Beachs attorney, Aleksander

Boksner, informed Stern that the City will not be producing said documents because
these documents are not public records. Id. Specifically, Mr. Boksner stated: Please be

Interestingly enough, Levine did not delete Jeff Everharts comment containing an icon of a laughing
child and a kitten to the same comment.
6
A block list is the group of Facebook users the account holder has chosen to block. In the case of Levine
the block list is the group of individuals who are prohibited from commenting upon the official city
business.
5

advised that the request for a copy of all persons blocked or banned from Mayor Philip
Levines Facebook page, is not a public record that was made or received in the course of
the official business of the City of Miami Beach. Id.
19.

Undeterred by the City of Miami Beachs denial, Stern requested an in-

person inspection. Id. On behalf of the City of Miami Beach, Mr. Boksner stated: Please
be advised that the City of Miami Beach is disinclined to acquiesce to the below request,
and is hereby asserting its legal position that was clearly set forth in the letter remitted
directly to your attention. Id.
20.

Stern responded to the Citys denial, and again requested the public

records. Id. Days later, Stern sent one last message seeking a response. Defendants did
not respond to his final request. Id.
21.

On September 23, 2016, Stern made a public records request to the City of

Miami Beach seeking audio recordings from Mayor Levines SiriusXM show. Id.
Specifically, Stern requested:
[A]ll digital recordings related to The Mayor a radio program by
Mayor Philip Levine which broadcast on Sirius XM radio. Provide
copies of all episodes and all related audio material recorded by
Mayor Philip Levine in conjunction with his broadcast which have
been released or not, that is all recorded material whatsoever
including outtakes, to include all raw recorded episodes, all
segments and any material related to the Mayor's appearances on
Sirius XM for the entire calendar year of 2016.
6

Id. On September 26th, the City of Miami Beach acknowledged Sterns request.
22.

On September 28, 2016, Stern then requested: Cop[ies] of [c]ontracts or

[a]ll [w]ritten [a]greements between Mayor Levine and SiriusXM radio and/or all
independent producers or associated studios for the show entitled, The Mayor. Id. On
the same day, this request was acknowledged by the City of Miami Beach. Id. The City
of Miami Beachs attorney sent a reply letter to Stern, denying him access to the public
records requests related to Levines SiriusXM show.7 Id.
ENFORCEMENT OF THE PUBLIC RECORDS LAW
23.

Plaintiff re-alleges and incorporates by reference paragraphs 1 through 22

of this Complaint as if fully set forth herein.

24.

Section 119.011(12), Florida Statutes defines public records as all

documents, papers, letters, maps, books or other material, regardless of the physical
form, characteristics, or means of transmission, made or received pursuant to law or
ordinance or in connection with the transaction of official business by any agency.
25.

Section 119.011(2), Florida Statutes defines agency to mean any state,

county, district, authority, or municipal officer, department or other separate unit of

government created or established by lawand any public or private agency, person,
partnership, corporation, or business agency, acting on behalf of any public agency.
26.

The term received in section 119.011(12) refers not only to a situation in

which a public agent takes physical delivery of a document, but also to one in which a
public agent examines a document. If that were not the case, a party could easily
circumvent the public records laws. See National Collegiate Athletic Assn v. Associated
7

These requests were assigned the following public records request numbers:12364, 12352 and 12354.

Press, 18. So. 3d 1201 (Fla. 1st DCA 2009), pet. for rev. docketed, No. SC09-1909 (Fla.
Oct. 14, 2009); Times Publg Co. v. City of St. Petersburg, 558 So. 487 (Fla. 2d DCA
1990) (holding that records become public records once they have been viewed and used
by public officials). A document that is used in the course of public business is a public
record under the definition in section 119.011(12) if it was received by the public
official. NCAA, 18 So. 3d at 1208.
27.

Section 119.07(1)(a), Florida Statutes proves every person who has

custody of a public record shall permit the record to be inspected and copied by any
person desiring to do so. (Emphasis added).
28.

The documents Stern requested from Defendant requested from which are

public records subject to the disclosure requirements of section 119.07, Florida Statutes
were (1) 30 days of published posts on to Twitter, (2) a copy of Levines block list on
his government official Facebook page, and (3) audio recordings and agreements
related to the SiriusXM show.
29.

These documents are public records subject to the disclosure requirements

of Article I, section 24, Florida Constitution.

30.

These documents are not exempt from the disclosure requirements of

Section 119.07, Florida Statutes, nor did Levine or the City of Miami Beach declare any
exemptions from disclosure.
31.

Defendants failure to produce responsive documents to Plaintiffs

Chapter 119 requests constitutes a non-discretionary refusal to produce public records

and violates section 119.07, Florida Statutes, and Article I, section 24, Florida
Constitution.
32.

Plaintiff has retained the undersigned counsel to bring this suit, has

incurred costs and attorneys fees in bringing this action, and is entitled to recovery of
costs and reasonable attorneys fees pursuant to section 119.12, Florida Statutes.
WHEREFORE, Plaintiff demands entry of orders:
a. Setting an immediate hearing pursuant to section 119.11(1), Florida
Statutes in order to address Defendants ongoing refusal to comply with
Chapter 119 and Article I, section 24 of the Florida Constitution. Section
119.11(1), Florida Statutes, provides that [w]henever an action is filed to
enforce the provisions of this chapter, the court shall set an immediate
hearing, giving the case priority over other pending matters.
b. Directing the Defendants to appear at such hearing or hearings pursuant to
section 119.11(1), and to show cause why the records requested by
Plaintiff should not be ordered to be produced.
c. Directing the Defendants to produce the records requested by Plaintiff at
such hearing or hearings pursuant to section 119.11(1), Florida Statutes.
d. Directing the Defendants, by writ of mandamus or otherwise, to produce
to Plaintiff, all of the records requested.
e. Awarding Plaintiff the costs and attorneys fees that he reasonably has
incurred in prosecuting this action initially, and in seeking the Courts

intervention to obtain records requested subsequent to the initial

complaint, pursuant to section 119.12, Florida Statutes.
f. Awarding Plaintiff any other relief that is necessary or appropriate.
Certification
I certify that the following document has been served on the Defendants counsel
of record via Florida E-Portal. Respectfully submitted on January 13, 2017 by:
s/Faudlin Pierre
Faudlin Pierre
Attorney for Plaintiff
18900 NE 1st Court
Miami, FL 33179
(305) 336-9193
FLA. BAR #56770

10

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

9/19/2016

Gmail - Response to Public Records Request No. 12089

Exhibit 7

Grant Stern <grantstern@gmail.com>

Response to Public Records Request No. 12089

Caba, Sandra <SandraCaba@miamibeachfl.gov>
Wed, Jul 27, 2016 at 3:14 PM
To: "grantstern@gmail.com" <grantstern@gmail.com>
Cc: "Aguila, Raul" <RaulAguila@miamibeachfl.gov>, "Baez, Gloria" <GloriaBaez@miamibeachfl.gov>, "Granado, Rafael"
<RafaelGranado@miamibeachfl.gov>, "Boksner, Aleksandr" <AleksandrBoksner@miamibeachfl.gov>
Mr. Stern,

Please review the attached correspondence.

Thank you,
Sandra

Sandra Caba, Legal Assistant to

Aleksandr Boksner, Deputy City Attorney,
Gisela Nanson Torres, Senior Assistant City Attorney,and
Nicholas Kallergis, Assistant City Attorney I
OFFICE OF THE CITY ATTORNEY
1700 Convention Center Drive, 4th floor, Miami Beach, FL 33139
Tel: (305)673-7470 or (305)673-7000 ext. 6561 / Fax: (305)673-7002 /
SandraCaba@miamibeachfl.gov
We are committed to providing excellent public service and safety to all who live, work and play in our vibrant, tropical, historic community.

Please note that Florida has a broad public records law and that any communication with the City of Miami Beach could be considered a public
record. If you do not wish for your email address to become a public record, please do not send electronic communications to the City of Miami
Beach.

Ltr to Grant Stern Re Public Records Request No. 12089.pdf

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July 27, 2016

Mr. Grant Stern, President

Morningside Mortgage Corporation
9630 E. Bay Harbor Drive
Bay Harbor Islands, Fl. 33154

Via Electronic Mail

grantstern@gmail.com

Re: Request for Public Records

Dear Mr. Stern:
I am the Deputy City Attorney for the City of Miami Beach, who is handling the above matter on
behalf of the City of Miami Beach. Please direct all future inquiries regarding this matter directly
to my attention. This correspondence shall serve as the City of Miami Beachs response to the
July 25, 2016 request for public records pursuant to Chapter 119 of the Florida Statutes.
Please be advised that a public record that is held by the City of Miami Beach (the City) must
be made or received pursuant to law or ordinance or in connection with the transaction of official
business. The Florida Supreme Court has interpreted this definition to encompass, all materials
made or received by an agency in connection with official business which are used to
perpetuate, communicate or formulate knowledge. Shevin v. Byron, Harless, Schaffer, Reid
and Associates, Inc., 379 So.2d 633, 640 (Fla. 1980).
Accordingly, please be advised that the request for a copy of all persons blocked or banned
from Mayor Philip Levines Facebook page, is not a public record that was made or received in
the course of the official business of the City of Miami Beach. To that effect, such information
would not constitute a public record which was prepared in order to perpetuate, communicate
or formulize knowledge surrounding the official business of the City. In that regard, please be
advised that the City does not have any responsive records pursuant to the July 25, 2016
request.
Should you have any further questions or comments, please do not hesitate to contact me.
Respectfully submitted,

/s/ Aleksandr Boksner

Aleksandr Boksner
Deputy City Attorney
AB/sc
cc:

Raul Aguila, City Attorney

Gloria Baez, Mayors Chief of Staff
Rafael Granado, City Clerk

9/19/2016

Gmail - Response to Public Records Request No. 12089

Grant Stern <grantstern@gmail.com>

Response to Public Records Request No. 12089

Grant Stern <grantstern@gmail.com>
Wed, Jul 27, 2016 at 3:48 PM
To: "Caba, Sandra" <SandraCaba@miamibeachfl.gov>
Cc: "Aguila, Raul" <RaulAguila@miamibeachfl.gov>, "Baez, Gloria" <GloriaBaez@miamibeachfl.gov>, "Granado, Rafael"
<RafaelGranado@miamibeachfl.gov>, "Boksner, Aleksandr" <AleksandrBoksner@miamibeachfl.gov>, John McKnight
<publicrecordslaw.mcknight@gmail.com>, Ben Meiselas <meiselas@geragos.com>
Bcc: Billy Corben <billy@rakontur.com>, Eric McDonough <phd2b05@gmail.com>
The page MayorPhilipLevine is labeled Government Official. It is used for communication.
https://www.facebook.com/mayorphiliplevine
Since you acknowledge that it is in fact your account, I would like to make an in person inspection of this account and
photograph its administrative settings to verify who is the actual custodian.
Please advise of a reasonable time this week for me to visit City Hall and photograph all of the records related to
administration of this account with its custodian.
Thank you
Grant
[Quoted text hidden]

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9/19/2016

Gmail - Response to Public Records Request No. 12089

Grant Stern <grantstern@gmail.com>

Response to Public Records Request No. 12089

Boksner, Aleksandr <AleksandrBoksner@miamibeachfl.gov>
Wed, Jul 27, 2016 at 4:33 PM
To: Grant Stern <grantstern@gmail.com>, "Caba, Sandra" <SandraCaba@miamibeachfl.gov>
Cc: "Aguila, Raul" <RaulAguila@miamibeachfl.gov>, "Baez, Gloria" <GloriaBaez@miamibeachfl.gov>, "Granado, Rafael"
<RafaelGranado@miamibeachfl.gov>, John McKnight <publicrecordslaw.mcknight@gmail.com>, Ben Meiselas
<meiselas@geragos.com>
Mr. Stern:
Please be advised that the City of Miami Beach is disinclined to acquiesce to the below request, and is hereby asserting
its legal position that was clearly set forth in the letter remitted directly to your attention.
Thank you.
MIAMIBEACH
Aleksandr Boksner, Deputy City Attorney
OFFICE OF THE CITY ATTORNEY
1700 Convention Center Drive 4th Floor, Miami Beach, Florida 33139
Tel: 305-673-7470 or 305-673-7000 ext. 6212 / Fax: 305-673-7002
aleksandrboksner@miamibeachfl.gov<mailto:aleksandrboksner@miamibeachfl.gov>

________________________________
From: Grant Stern [grantstern@gmail.com]
Sent: Wednesday, July 27, 2016 3:48 PM
To: Caba, Sandra
Cc: Aguila, Raul; Baez, Gloria; Granado, Rafael; Boksner, Aleksandr; John McKnight; Ben Meiselas
Subject: Re: Response to Public Records Request No. 12089
The page Mayor Philip Levine is labeled Government Official. It is used for communication.
https://www.facebook.com/mayorphiliplevine
Since you acknowledge that it is in fact your account, I would like to make an in person inspection of this account and
photograph its administrative settings to verify who is the actual custodian.
Please advise of a reasonable time this week for me to visit City Hall and photograph all of the records related to
administration of this account with its custodian.
Thank you
Grant

On Wed, Jul 27, 2016 at 3:14 PM, Caba, Sandra <SandraCaba@miamibeachfl.gov<mailto:SandraCaba@

miamibeachfl.gov>> wrote:
Mr. Stern,

Please review the attached correspondence.

Thank you,
Sandra
https://mail.google.com/mail/u/0/?ui=2&ik=8a6c778845&view=pt&q=boks&search=query&msg=1562e100fc32fdde&siml=1562e100fc32fdde

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Gmail - Response to Public Records Request No. 12089

[Cropped-for-E-signature-MiamiBeachLogo_Green250px]
Sandra Caba, Legal Assistant to
Aleksandr Boksner, Deputy City Attorney,
Gisela Nanson Torres, Senior Assistant City Attorney,and
Nicholas Kallergis, Assistant City Attorney I
OFFICE OF THE CITY ATTORNEY
1700 Convention Center Drive, 4th floor, Miami Beach, FL 33139
Tel: (305)673-7470<tel:%28305%29673-7470> or (305)673-7000 ext. 6561<tel:%28305%29673-7000%20ext.%206561> /
Fax: (305)673-7002<tel:%28305%29673-7002> /
SandraCaba@miamibeachfl.gov<http://www.SandraCaba@miamibeachfl.gov>
[Quoted text hidden]

image001.jpg
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9/19/2016

Gmail - Response to Public Records Request No. 12089

Grant Stern <grantstern@gmail.com>

Response to Public Records Request No. 12089

Grant Stern <grantstern@gmail.com>
Tue, Aug 2, 2016 at 5:05 PM
To: "Boksner, Aleksandr" <AleksandrBoksner@miamibeachfl.gov>
Cc: "Caba, Sandra" <SandraCaba@miamibeachfl.gov>, "Aguila, Raul" <RaulAguila@miamibeachfl.gov>, "Baez, Gloria"
<GloriaBaez@miamibeachfl.gov>, "Granado, Rafael" <RafaelGranado@miamibeachfl.gov>, John McKnight
<publicrecordslaw.mcknight@gmail.com>, Ben Meiselas <meiselas@geragos.com>
Bcc: Eric McDonough <phd2b05@gmail.com>, thehemmingfirm@gmail.com, Felipe Hemming <felipe.hemming@gmail.com>
Dear Mr. Boksner,
You have not claimed any exemption under Floridas Public Records Act, and there is an existing opinion of the Florida
Attorney General which is considered presidential in this matter unless overturned in court, which to my knowledge you
have provided no evidence of any countervailing decision:
http://www.myfloridalegal.com/ago.nsf/Opinions/25F14F90483F3901852575A2004E46CB
Therefore, I am disinclined to acquiesce to your stubborn refusal to provide me with an in camera inspection of Mayor
Phillip Levines official Facebook page during which I may photograph (also a right under our Sunshine Law) the
contents of the page, and within the pages content is provided to all Facebook page users a list of persons blocked from
interacting with the page.
I have retained counsel and will name all parties who violate the Sunshine Law in both their official and personal
capacities as is my right, and that includes elected officials who may be subject to removal from office for willful and
knowing violation of Floridas Constitution.
It is bad enough that your citys leader (I stretch the bounds of credulity by using that word, but apply it in its most narrow
technical sense) decided to violate my constitutional right to free speech by destroying my public record comments from
his page, but upon further investigation, it has been determined that he actually is a frequent censor of all residents and
visitors to Miami Beach.
In this case, it is of vital public interest that I learn the full extent and list of all blocked persons, as their civil rights are
being violated.
Additionally, the Dade County Charter imposes an obligation of Truth in Government (Bill of Rights, A.2) and a cause of
action if a citizens right to truthful responses and lack of material omissions by our public officials.
I will pursue my rights under the Dade County Charter, the Florida Constitution, and the United States Constitution
vigorously and with assistance of counsel until these controversies are resolved.
I am available to make an in camera inspection on Friday anytime. Please advise what hours are available and I shall visit
City Hall, or provide electronically screen shots which reveal the entire list of names kept by the city in Mayor Phillip
Levines account as blocked.
Govern yourself accordingly.
Yours,
Grant

[Quoted text hidden]

-Grant Stern
President
Morningside Mortgage Corporation
9630 E. Bay Harbor Drive
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Gmail - Response to Public Records Request No. 12089

Bay Harbor Islands, Fl. 33154

786-220-0117 office
305-219-0326 mobile
305-675-3392 efax

https://mail.google.com/mail/u/0/?ui=2&ik=8a6c778845&view=pt&q=boks&search=query&msg=1564d1321a8fad68&siml=1564d1321a8fad68

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9/19/2016

Gmail - Response to Public Records Request No. 12089

Grant Stern <grantstern@gmail.com>

Response to Public Records Request No. 12089

Grant Stern <grantstern@gmail.com>
Thu, Aug 4, 2016 at 12:40 PM
To: "Boksner, Aleksandr" <AleksandrBoksner@miamibeachfl.gov>
Cc: "Caba, Sandra" <SandraCaba@miamibeachfl.gov>, "Aguila, Raul" <RaulAguila@miamibeachfl.gov>, "Baez, Gloria"
<GloriaBaez@miamibeachfl.gov>, "Granado, Rafael" <RafaelGranado@miamibeachfl.gov>, John McKnight
<publicrecordslaw.mcknight@gmail.com>, Ben Meiselas <meiselas@geragos.com>
Well?
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Gmail - City of Miami Beach - City Clerk Public Records Request System

Grant Stern <grantstern@gmail.com>

City of Miami Beach - City Clerk Public Records Request System

DoNotReply <DoNotReply@miamibeachfl.gov>
To: "grantstern@gmail.com" <grantstern@gmail.com>
Cc: "Salvatore, Jason" <JasonSalvatore@miamibeachfl.gov>

Mon, Jul 25, 2016 at 11:54 AM

We are in receipt of your Public Records Request, and it has been forwarded to the following department(s) for handling:
Communications, Mayors
Information requested: Please provide a copy of all persons blocked or banned from Mayor Philip Levine's Facebook
page.
Please be advised that if the nature and/or volume of the public records requested to be inspected, examined or copied
requires extensive use of information technology resources and/or extensive clerical or supervisory assistance by City
personnel, you will be required to pay a service charge for the costs incurred for such extensive use of resources and/or
assistance. The City will charge 15 cents for each copy provided, as well as for extensive labor costs (labor exceeding 30
minutes) involved in the responding to the records request.
Note that your Public Records Request has been assigned PRR #12089 and IT PRR# (not applicable) .
Please reference said PRR # when communicating with the City regarding your request. If you have any questions,
please contact the Office of the City Clerk at (305) 673-7411 or researchrequest@miamibeachfl.gov .

https://mail.google.com/mail/u/0/?ui=2&ik=8a6c778845&view=pt&q=12089&qs=true&search=query&msg=15622c3b02d41be5&siml=15622c3b02d41be5

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9/19/2016

Gmail - City of Miami Beach - City Clerk Public Records Request System

Grant Stern <grantstern@gmail.com>

City of Miami Beach - City Clerk Public Records Request System

Grant Stern <grantstern@gmail.com>
To: "Salvatore, Jason" <JasonSalvatore@miamibeachfl.gov>
Cc: researchrequest@miamibeachfl.gov, F Pierre <fplaw08@yahoo.com>

Mon, Jul 25, 2016 at 11:55 AM

PRR #12089
I'd like a list or copy of all persons blocked by the Mayor of Miami's official Facebook account.
In a personal account this list can be found at https://www.facebook.com/settings?tab=blocking
In a Facebook Page account it's accessible from the below URL, there is a flip down box that says "Banned People and
Pages":
https://www.facebook.com/mayorphiliplevine/settings/?tab=people_and_other_pages

cc: F. Pierre, Esq.

[Quoted text hidden]

-Grant Stern
President
Morningside Mortgage Corporation
9630 E. Bay Harbor Drive
Bay Harbor Islands, Fl. 33154
786-220-0117 office
305-219-0326 mobile
305-675-3392 efax

https://mail.google.com/mail/u/0/?ui=2&ik=8a6c778845&view=pt&q=12089&qs=true&search=query&msg=15622c50309e6377&siml=15622c50309e6377

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