Corbacho Daudinot v. Puig Valdes et al

Filing 54

RESPONSE in Opposition re 52 Defendant's MOTION for Sanctions under Rule 37 filed by MIGUEL ANGEL CORBACHO DAUDINOT. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L)(Bravo, Kenia)

From:
To:
Cc:
Subject:
Date:

Exhibit J

Kenia Bravo
"Sean Santini"
"Averil Andrews"; "[e-mail]"; "Betty Caballero"
RE: Corbacho v. Puig
Tuesday, September 16, 2014 7:04:00 PM

Sean,
The Chapman case goes to trial in mid-November. I will be unable to do the depo at that time. Let’s
agree to something in December then?
Sincerely,
Kenia Bravo
From: Sean Santini [mailto:[e-mail]]
Sent: Tuesday, September 16, 2014 2:28 PM
To: Kenia Bravo
Cc: Averil Andrews; [e-mail]; Betty Caballero
Subject: RE: Corbacho v. Puig

Kenia,
I’m grateful for the professional courtesies you’ve extended to me. I will
note that I’ve extended the same courtesies to you and remain willing,
within reason, to continue accommodating your work schedule.
All I asked below was for a date certain in October for the taking of your
client’s deposition. If, due to your work schedule, there isn’t a single
day in the month of October when you’re available for your client’s
deposition, then please provide me some options in early November (I,
too, have scheduling constraints I need to work around).
Telling me that I’m going to have to wait “until after December” to get a
date from you for your client’s deposition simply is not reasonable.
Again, I’d appreciate it if you’d please provide me by September 25 with
a date certain (if it can’t be October, then early November) when I can
depose your client. Thanks,
Sean