Corbacho Daudinot v. Puig Valdes et al

Filing 4

Notice of Pendency of Other Action by MIGUEL ANGEL CORBACHO DAUDINOT (Gonzalez, Avelino)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIGUEL ANGEL CORBACHO DAUDINOT
Plaintiff,

CASE NO. 13-CV-22589-KMW

v.
YASIEL PUIG VALDES a/k/a YASIEL PUIG
and MARITZA VALDES GONZALEZ.
Defendants.
______________________________________/
PLAINTIFF’S NOTICE OF PENDING, REFILED, RELATED OR SIMILAR ACTIONS
Plaintiff, pursuant to Local Rule 3.8, hereby files the follow Notice of Pending, Refiled,
Related or Similar Actions:
Plaintiff notifies the Court that there are two (2) case raising similar issues that are
pending in the United States District Court for the Southern District of Florida before the
Honorable Cecilia Altonaga. The first case, captioned, Curbelo Garcia et al v. Chapman et al,
Case No. 12-cv-21891, was filed on May 18, 2012; and the second case, captioned, Curbelo
Garcia et al v. Chapman Bennett et al, Case No. 13-cv-22210, was filed on June 20, 2013.
The cases that are already before judge Altonaga concern the same issues of law and
similar issues of fact, and are brought under the jurisdiction of the court pursuant to the Torture
Victim Protection Act of 1991, 28 U.S.C. § 1350 (“TVPA”).
In all of the cases the Plaintiffs were victims of arbitrary and prolonged detention and
torture committed in Cuba as a result of the false accusations of the Defendants, who acted as
informants for the government as part of a conspiracy to imprison and torture the Plaintiffs, and

Plaintiffs in all cases are seeking claims against Defendants for torture under the TVPA based on
conspiracy and aiding and abetting.
The Defendants are Cuban baseball players (Chapman and Puig) and their families
(Chapman Bennett, De La Cruz, and Valdes), who acted as informants for the government and
accused Plaintiffs of Human Trafficking. The Defendants’ motivation was their own and their
sons’ career advancement and a chance to flee Cuba in to play professionally.
Both Chapman and Puig, who had been under sanctions in Cuba at the time they made
their accusations against Plaintiffs, profited from their actions. They were rewarded for accusing
the Plaintiffs of Human Trafficking by being reinstated in their respective baseball teams and
being included in the national team, which travels abroad. Shortly after testifying against
Plaintiffs, Defendants did the very thing for which they accused the Plaintiffs: they escaped
Cuba.
There is a shocking similarity and a startling pattern to both Chapman’s and Puig’s
accusations:
PUIG was under sanctions when he made his
accusations against the accused on the Cuban
case.

Chapman was under sanctions when he made
his accusations against the accused in the
Cuban case.

PUIG accused two men, who he saw driving
a tourism car, of offering to take him out of
Cuba illegally.

Chapman accused two men, who he saw
driving a tourism car, of offering to take him
out of Cuba illegally. (each time, he accused
2 men)

One of the two men PUIG accused lived
abroad, while the other was a Cuban citizen
living in Cuba.

One of the two men Chapman accused lived
abroad, while the other was a Cuban citizen
living in Cuba (both times).

PUIG claimed that the men offered him
millions of dollars to play baseball abroad

Chapman claimed that they men offered him
millions of dollars to play baseball abroad.

PUIG claimed that the men told him that they Chapman claimed that the men told him that
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were also planning to take other players
PUIG knew with them.
PUIG claimed that they would take him to a
safe house, then to a beach, from where they
would leave the island by speedboat.

they were also planning to take other players
Chapman knew with them.
Chapman claimed that they would take him
to a safe house, then to a beach from where
they would leave the island by speedboat.

PUIG’s mother made the initial accusations
against the Plaintiff.

Chapman’s father made the initial accusation
against Mena Perdomo.

PUIG called the DCSE after being contacted
by OROZCO and they arrested OROZCO
while he was leaving Cienfuegos.

Chapman called the DCSE after meeting
with Curbelo Garcia and Medina and the
DCSE attempted to arrest them while leaving
Frank Pais.

PUIG’s was immediately reinstated into the
team at Cienfuegos after he made his
accusations

Chapman was immediately reinstated into
the team at Holguin after he made his
accusation.

PUIG’s mother testified that Plaintiff offered
to take PUIG out of Cuba illegally despite
acknowledging that she was never privy to
any conversation between PUIG and
Plaintiff.

Chapman’s parents testified that the
Plaintiffs in the Chapman case offered to take
Chapman out of Cuba illegally despite
acknowledging that they were never privy to
any conversation between Chapman and the
Plaintiffs.

PUIG attempted to defect during the 2011
World Port Tournament in Rotterdam,
Netherlands

Chapman defected during the 2009 World
Port Tournament in Rotterdam, Netherlands.

Respectfully Submitted by: s/Kenia Bravo
_
Kenia Bravo, Esq., FBN 68296
Avelino J. Gonzalez, Esq., FBN 75530
Law Offices of Avelino J. Gonzalez, P.A.
6780 Coral Way, Miami, Florida 33155
Ph: 305-668-3535; Fax: [phone]
E-mail: [e-mail]

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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on July 22, 2013, I electronically filed the foregoing with the
Clerk of the Court by using the CM/ECF system, and that I emailed a true and correct copy of
same

to

Manuel

Garcia

Linares,

[e-mail],

Ethan

Wall,

[e-mail], attorneys for the Defendants in Curbelo Garcia et al v. Chapman,
Case No.12-cv-21891-Altonaga, and Curbelo Garcia et al v. Chapman Bennett, Case No. 13-cv22210-Altonaga.
By: s/Kenia Bravo
__
Kenia Bravo, Esq., FBN 68296
Avelino J. Gonzalez, Esq., FBN 75530
Law Offices of Avelino J. Gonzalez, P.A.
6780 Coral Way, Miami, Florida 33155
Ph: 305-668-3535; Fax: [phone]
E-mail: [e-mail]

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