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 G

Sean Santini
Avelino Gonzalez
Averil Andrews; [e-mail]; Betty Caballero
Corbacho v. Puig
Monday, September 15, 2014 1:36:55 PM

Kenia,
Hello. Twice now I’ve noticed your client for deposition. Both times
your client failed to show. On neither occasion did your client move for
a protective order, nor did you reach out to propose alternative dates for
your client’s deposition (as I invited you to do when I noticed the
depositions initially).
Please get back to me by no later than September 25, 2014 with a date
certain in October for your client’s deposition. If I do not hear from you
by the 25 th , I’ll have no choice but to file a Rule 37 motion. I trust it
won’t come to that.
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]