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3rd DCAAugust 31, 2022Affirmed⭐ Notable

Miami Dade College v. Nader + Museu I, LLLP

Case No. 21-1440

Miami Dade College sought over $200,000 as a 'special service charge' under section 119.07(4)(d) for costs (including outside counsel fees) incurred in responding to a public records request that ripened into mandamus litigation. The Third DCA affirmed the denial, holding that MDC never provided the requester with an estimate or invoice of anticipated production costs before producing the records, contrary to both its own Procedure 2107 and section 119.07(4)'s requirement that production be conditioned 'upon payment of the fee prescribed by law.'

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