Corbacho Daudinot v. Puig Valdes et al

Filing 76

RESPONSE in Opposition re 74 Second MOTION for Sanctions under Rule 37 filed by Miguel Angel Corbacho Daudinot. Replies due by 5/18/2015. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G)(Bravo, Kenia)

From:
To:
Cc:
Subject:
Date:

Sean Santini
Kenia Bravo; [e-mail]
Averil Andrews
RE: Corbacho v. Puig
Tuesday, February 10, 2015 3:41:11 PM

Thanks for getting back to me, Kenia. Hope you’re feeling better. Do
you have any sense of whether you’ll be able to reach your client before
the weekend?

From: Kenia Bravo [mailto:[e-mail]]
Sent: Monday, February 09, 2015 6:34 PM
To: Sean Santini; [e-mail]
Cc: Averil Andrews
Subject: RE: Corbacho v. Puig
Sean,
I have been out of the office all day due to illness, and came in just to pick up a file that I need for
tomorrow morning.
I have not been able to speak to Avelino about this weekend, but it is my understanding that they
were not able to communicate due to some kind of technical difficulty. But I know that Avelino is still
working on getting in contact with him.
Sincerely,
Kenia Bravo, Esq.
From: Sean Santini [mailto:[e-mail]]
Sent: Monday, February 09, 2015 11:58 AM
To: Kenia Bravo; [e-mail]
Cc: Averil Andrews
Subject: RE: Corbacho v. Puig

Hello. Were you able to speak with your client this weekend about
settlement?
Sean

From: Sean Santini
Sent: Wednesday, February 04, 2015 5:36 PM
To: 'Kenia Bravo'; [e-mail]
Cc: Averil Andrews
Subject: RE: Corbacho v. Puig

No problem (It’s just that I really need to get this case ready if this isn’t
going to settle).

From: Kenia Bravo [mailto:[e-mail]]
Sent: Wednesday, February 04, 2015 5:25 PM
To: Sean Santini; [e-mail]
Cc: Averil Andrews
Subject: RE: Corbacho v. Puig
Sean,
Avelino was not here earlier. I thought we would be able to speak with our client by tomorrow, but
it turns out that we shall not be able to speak with him until Saturday, when he shall have access to
a telephone booth.
I’m sorry for the confusion, but let’s maintain the spirit of negotiation open until Saturday
afternoon.
Sincerely,
Kenia Bravo, Esq.

From: Sean Santini [mailto:[e-mail]]
Sent: Wednesday, February 04, 2015 11:23 AM
To: '[e-mail]'
Cc: 'Kenia Bravo'; Averil Andrews
Subject: Corbacho v. Puig

Hola, Avelino. Pudiste hablar con Miguel Ángel? Dado los comentarios
de la juez, no nos podemos dar el lujo de esperar mucho más para
comenzar con el desahogo de pruebas.
Saludos,

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]
CONFIDENTIALITY NOTE: The information contained in this transmission may be privileged and
confidential information, and is intended only for the use of the individual or entity named above. If the
reader of this message is not the intended recipient, you are hereby notified that any dissemination,
distribution or copying of this communication is strictly prohibited. If you have received this transmission
in error, please immediately reply to the sender that you have received this communication in error and
then delete it. Thank you.
CIRCULAR 230 NOTICE: To comply with U.S. Treasury Department and IRS regulations, we are
required to advise you that, unless expressly stated otherwise, any U.S. federal tax advice contained in
this transmittal, is not intended or written to be used, and cannot be used, by any person for the
purpose of (i) avoiding penalties under the U.S. Internal Revenue Code, or (ii) promoting, marketing or
recommending to another party any transaction or matter addressed in this e-mail or attachment.

From:
To:
Cc:
Subject:
Date:

Sean Santini
Kenia Bravo; [e-mail]
Averil Andrews
RE: Corbacho v. Puig
Thursday, February 26, 2015 5:31:33 PM

Hello, Kenia. Hope this finds you well. Two questions:
(1) Has Avelino been able to speak with plaintiff regarding settlement?
(2) Do you have any updates on plaintiff’s arrival in the United States?
Regards,
Sean

From: Kenia Bravo [mailto:[e-mail]]
Sent: Tuesday, February 10, 2015 6:39 PM
To: Sean Santini; [e-mail]
Cc: Averil Andrews
Subject: RE: Corbacho v. Puig
I’m doing better, Sean. Thanks for asking.
As for getting in contact with our client, for some reason he has not been able to attain access to
the phone booth. We are unclear if the phone booth was disabled or what may have happened, but
it is out intent to get in contact with him before the weekend.
Let me assure you that Avelino is working on this matter with an interest in reaching a mutually
beneficial agreement that is in our client and in your client’s best interest. Be aware that what we
stated in court is true—if our clients do not reach an agreement, we shall put no hindrance on
discovery when our client comes to the United States.
Sincerely,
Kenia Bravo, Esq.
From: Sean Santini [mailto:[e-mail]]
Sent: Tuesday, February 10, 2015 3:41 PM
To: Kenia Bravo; [e-mail]
Cc: Averil Andrews
Subject: RE: Corbacho v. Puig

Thanks for getting back to me, Kenia. Hope you’re feeling better. Do
you have any sense of whether you’ll be able to reach your client before
the weekend?

From: Kenia Bravo [mailto:[e-mail]]
Sent: Monday, February 09, 2015 6:34 PM
To: Sean Santini; [e-mail]
Cc: Averil Andrews
Subject: RE: Corbacho v. Puig
Sean,
I have been out of the office all day due to illness, and came in just to pick up a file that I need for
tomorrow morning.
I have not been able to speak to Avelino about this weekend, but it is my understanding that they
were not able to communicate due to some kind of technical difficulty. But I know that Avelino is still
working on getting in contact with him.
Sincerely,
Kenia Bravo, Esq.
From: Sean Santini [mailto:[e-mail]]
Sent: Monday, February 09, 2015 11:58 AM
To: Kenia Bravo; [e-mail]
Cc: Averil Andrews
Subject: RE: Corbacho v. Puig

Hello. Were you able to speak with your client this weekend about
settlement?
Sean

From: Sean Santini
Sent: Wednesday, February 04, 2015 5:36 PM
To: 'Kenia Bravo'; [e-mail]
Cc: Averil Andrews
Subject: RE: Corbacho v. Puig

No problem (It’s just that I really need to get this case ready if this isn’t
going to settle).

From: Kenia Bravo [mailto:[e-mail]]
Sent: Wednesday, February 04, 2015 5:25 PM
To: Sean Santini; [e-mail]
Cc: Averil Andrews
Subject: RE: Corbacho v. Puig
Sean,
Avelino was not here earlier. I thought we would be able to speak with our client by tomorrow, but
it turns out that we shall not be able to speak with him until Saturday, when he shall have access to
a telephone booth.
I’m sorry for the confusion, but let’s maintain the spirit of negotiation open until Saturday
afternoon.
Sincerely,
Kenia Bravo, Esq.

From: Sean Santini [mailto:[e-mail]]
Sent: Wednesday, February 04, 2015 11:23 AM
To: '[e-mail]'
Cc: 'Kenia Bravo'; Averil Andrews
Subject: Corbacho v. Puig

Hola, Avelino. Pudiste hablar con Miguel Ángel? Dado los comentarios
de la juez, no nos podemos dar el lujo de esperar mucho más para
comenzar con el desahogo de pruebas.
Saludos,
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]
CONFIDENTIALITY NOTE: The information contained in this transmission may be privileged and
confidential information, and is intended only for the use of the individual or entity named above. If the
reader of this message is not the intended recipient, you are hereby notified that any dissemination,
distribution or copying of this communication is strictly prohibited. If you have received this transmission
in error, please immediately reply to the sender that you have received this communication in error and
then delete it. Thank you.
CIRCULAR 230 NOTICE: To comply with U.S. Treasury Department and IRS regulations, we are
required to advise you that, unless expressly stated otherwise, any U.S. federal tax advice contained in
this transmittal, is not intended or written to be used, and cannot be used, by any person for the
purpose of (i) avoiding penalties under the U.S. Internal Revenue Code, or (ii) promoting, marketing or
recommending to another party any transaction or matter addressed in this e-mail or attachment.

From:
To:
Cc:
Subject:
Date:

Sean Santini
Kenia Bravo; [e-mail]
Averil Andrews
RE: Corbacho v. Puig
Monday, February 09, 2015 11:58:27 AM

Hello. Were you able to speak with your client this weekend about
settlement?
Sean

From: Sean Santini
Sent: Wednesday, February 04, 2015 5:36 PM
To: 'Kenia Bravo'; [e-mail]
Cc: Averil Andrews
Subject: RE: Corbacho v. Puig

No problem (It’s just that I really need to get this case ready if this isn’t
going to settle).

From: Kenia Bravo [mailto:[e-mail]]
Sent: Wednesday, February 04, 2015 5:25 PM
To: Sean Santini; [e-mail]
Cc: Averil Andrews
Subject: RE: Corbacho v. Puig
Sean,
Avelino was not here earlier. I thought we would be able to speak with our client by tomorrow, but
it turns out that we shall not be able to speak with him until Saturday, when he shall have access to
a telephone booth.
I’m sorry for the confusion, but let’s maintain the spirit of negotiation open until Saturday
afternoon.
Sincerely,
Kenia Bravo, Esq.

From: Sean Santini [mailto:[e-mail]]
Sent: Wednesday, February 04, 2015 11:23 AM
To: '[e-mail]'
Cc: 'Kenia Bravo'; Averil Andrews
Subject: Corbacho v. Puig

Hola, Avelino. Pudiste hablar con Miguel Ángel? Dado los comentarios
de la juez, no nos podemos dar el lujo de esperar mucho más para
comenzar con el desahogo de pruebas.
Saludos,
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]
CONFIDENTIALITY NOTE: The information contained in this transmission may be privileged and
confidential information, and is intended only for the use of the individual or entity named above. If the
reader of this message is not the intended recipient, you are hereby notified that any dissemination,
distribution or copying of this communication is strictly prohibited. If you have received this transmission
in error, please immediately reply to the sender that you have received this communication in error and
then delete it. Thank you.
CIRCULAR 230 NOTICE: To comply with U.S. Treasury Department and IRS regulations, we are
required to advise you that, unless expressly stated otherwise, any U.S. federal tax advice contained in
this transmittal, is not intended or written to be used, and cannot be used, by any person for the
purpose of (i) avoiding penalties under the U.S. Internal Revenue Code, or (ii) promoting, marketing or
recommending to another party any transaction or matter addressed in this e-mail or attachment.

From:
To:
Cc:
Subject:
Date:
Attachments:

Sean Santini
Kenia Bravo
[e-mail]; Averil Andrews
Corbacho v. Puig
Tuesday, March 03, 2015 1:29:32 PM
15-03-03-Third Notice of Taking Deposition of Plaintiff Corbacho 3-13-15.pdf
15-03-03 First RFP to Corbacho.pdf

Hello, Kenia. Not having heard back from you regarding settlement, I
have no choice but to proceed with discovery. To that end, attached
are Defendants’ Third Notice of Taking Plaintiff’s Deposition and First
Request for Production of Documents. So as to avoid incurring
unnecessary expenses, I’d appreciate it if you’d let me know whether
Mr. Corbacho will be attending his deposition as noticed and, if so,
whether he’ll require and 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]
CONFIDENTIALITY NOTE: The information contained in this transmission may be privileged and
confidential information, and is intended only for the use of the individual or entity named above. If the
reader of this message is not the intended recipient, you are hereby notified that any dissemination,
distribution or copying of this communication is strictly prohibited. If you have received this transmission
in error, please immediately reply to the sender that you have received this communication in error and
then delete it. Thank you.
CIRCULAR 230 NOTICE: To comply with U.S. Treasury Department and IRS regulations, we are
required to advise you that, unless expressly stated otherwise, any U.S. federal tax advice contained in
this transmittal, is not intended or written to be used, and cannot be used, by any person for the
purpose of (i) avoiding penalties under the U.S. Internal Revenue Code, or (ii) promoting, marketing or
recommending to another party any transaction or matter addressed in this e-mail or attachment.