Corbacho Daudinot v. Puig Valdes et al

Filing 74

Second MOTION for Sanctions under Rule 37 by Yasiel Puig Valdes, Maritza Valdes Gonzalez. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D)(Andrews, Averil)

EXHIBIT A
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.
__________________________/
THIRD 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 March 17, 2015, 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 3rd day of March, 2015.

Respectfully submitted,
SANTINI LAW
1001 Brickell Bay Drive, Suite 2650
Miami, Florida 33131
Telephone: [phone]

By: /s/ Sean R. Santini
Sean R. Santini
Florida Bar Number: 832898
[e-mail]
Averil K. Andrews
Florida Bar Number: 105700
[e-mail]

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CERTIFICATE OF SERVICE
I hereby certify that on this 3rd day of March, 2015 a true and correct copy of the
foregoing was served via email and U.S. Mail on all counsel of record identified on the
attached Service List.

/s/ Averil K. Andrews
Averil K. Andrews

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

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