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)

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Attachments:

Exhibit F

Sean Santini
Avelino Gonzalez
Averil Andrews; Betty Caballero; [e-mail]
14-08-12-Second Notice of Taking Deposition of Plaintiff Corbacho
Tuesday, August 12, 2014 4:55:43 PM
14-08-12-Second Notice of Taking Deposition of Plaintiff Corbacho.pdf

Hello, Kenia. With August 7 having come and gone, attached is a
second notice for the taking of your client’s deposition. I’ve noticed the
deposition for September 12, but, as with the previous notice, I’m happy
to work with you on dates that make sense for both of us. Let me know,
please. Also, please let me know whether I’ll need to arrange for an
interpreter.
Regards,
Sean
Sean R. Santini
Santini Law
1001 Brickell Bay Drive
Suite 2650
Miami, Florida 33131
305-372-7307 (direct)
305-372-7308 (fax)
305-790-7660 (mobile)
[e-mail]

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
CASE NO.: 1:13-cv-22589-KMW
MIGUEL ANGEL CORBACHO
DAUDINOT
Plaintiff,
v.
YASIEL PUIG VALDES a/k/a
YASIEL PUIG and MARITZA
VALDES GONZALEZ,
Defendants.
__________________________/
SECOND NOTICE OF TAKING DEPOSITION
To:

Avelino J. Gonzalez
Kenia Bravo
Avelino J. Gonzalez, P.A.
6780 Coral Way
Miami, FL 33155

Networking Reporting
44 W. Flagler St., Suite 1200
Miami, FL 33130

PLEASE TAKE NOTICE that, pursuant to Federal Rule of Civil Procedure 30,
defendants, by and through their undersigned attorneys, will take the deposition upon
oral examination of plaintiff, Miguel Angel Corbacho Daudinot.
The deposition will commence at 10:00 a.m. on September 12, 2014, take place
at the offices of Santini Law, 1001 Brickell Bay Drive, Suite 2650, Miami Florida 33131,
and will continue day to day until completed.

The deposition will be recorded

stenographically before a notary public or other officer authorized to administer oaths
and is being taken for the purpose of discovery, for use at hearing, for trial, or for such
other purposes as are permitted under the applicable and governing rules.

In accordance with the Americans with Disabilities Act, individuals who have a
disability which may need accommodation should contact Sean R. Santini seven days
prior to the deposition.
Dated this 12th day of August, 2014

Respectfully submitted,
SANTINI LAW
1001 Brickell Bay Drive
Suite 2650
Miami, Florida 33131
Tel: [phone]
Fax: [phone]
[e-mail]

By: /s/ Sean R. Santini
Sean R. Santini
Florida Bar No. 832898

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CERTIFICATE OF SERVICE
I hereby certify that on this 12th day of August, 2014 a true and correct copy of
the foregoing was served on all counsel of record identified on the attached Service List,
in the manner specified.

/s/ Sean R. Santini
Sean R. Santini

SERVICE LIST

Kenia Bravo
[e-mail]
Avelino J. Gonzalez, P.A.
6780 Coral Way
Miami, FL 33155
Avelino Jose Gonzalez
[e-mail]
Avelino J. Gonzalez, P.A.
6780 Coral Way
Miami, FL 33155
Via Email and U.S. Mail

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