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:
Attachments:

Exhibit H

Kenia Bravo
"Sean Santini"
"Averil Andrews"; "[e-mail]"; "Betty Caballero"
RE: Corbacho v. Puig
Monday, September 15, 2014 3:30:00 PM
Corbacho v. Puig.msg
RE Corbacho v. Puig.msg

Sean,
I will ask you to recall what occurred on or about August 7, 2014. On July 7, 2014, you asked us for a
three week extension of time to respond to Plaintiff’s Complaint (please see attached email). We
graciously did not object to that extension. On July 30, 2014 you asked for one additional extension,
until August 8, 2014, to answer the Complaint (please see attached email). We once again extended
you that professional courtesy. Since you did not even have the opportunity to file an Answer until
August 8, 2014, we could not reasonably assume that you would be holding a deposition in the
same case on August 7, 2014.
Secondly, neither one of your notices for deposition have been served in good faith because you
know very well that our client is in Cuba serving out what is left of a prison sentence that your
client’s actions forced on him. Due to your client’s behavior, Corbacho Daudinot cannot obtain a
passport to travel to the United States or anywhere else. Irrespective of that, we are doing our best
to comply with what we stated in court—to bring Corbacho Daudinot here to be deposed by the
Defendant and to testify in court.
Just as you have asked us to give you extensions of time, we are asking you for some leeway until
after December to schedule Corbacho Daudinot’s deposition due, not only to Corbacho Daudino’s
location, but to our office’s burdensome workload. We are inundated with excessive amounts of
work, and would appreciate your professional courtesy in this matter.
Sincerely,
Kenia Bravo
From: Sean Santini [mailto:[e-mail]]
Sent: Monday, September 15, 2014 1:37 PM
To: Avelino Gonzalez
Cc: Averil Andrews; [e-mail]; Betty Caballero
Subject: Corbacho v. Puig

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]