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 K

Sean Santini
Kenia Bravo
Averil Andrews; [e-mail]; Betty Caballero
Re: Corbacho v. Puig
Wednesday, September 17, 2014 5:50:43 PM

Kenia, if your work schedule precludes you from having the deposition before
December, then, yes, let's do it in December. Please let me know by September 25,
when in December I'll be able to take your client's deposition so that I can notice it
accordingly (and please keep in mind that I will be out for the holidays from
December 22 through January 2). Thank you,
Sean
Sent from my iPad
On Sep 16, 2014, at 7:06 PM, "Kenia Bravo" <[e-mail]>
wrote:
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