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:
Kenia Bravo
"Rene Murai"
"avelinogonzalez@bellsouth.net"
Corbacho Daudinot v. Puig et al.
Friday, April 10, 2015 1:46:00 PM
Dear Mr. Murai ,
Thank you for your continuing efforts to secure a settlement agreement between the parties in the
case of Corbacho Daudinot v. Yasiel Puig, et al.
This email shall serve to memorialize our conversation, wherein you advised me to propose an
agreed motion to extend the expert witness deadline (currently set for April 15) to permit the
parties to enter into an agreement without the expense of further litigation, and to send you the
motion in order for you to provide it to Sean Santini—who is vacationing at the moment—in order
to procure his agreement.
On a separate matter, which I did not mention during our conversation, Mr. Santini has sent the
Plaintiff Requests for Production, to which I have not yet sent a response. To avoid unnecessary
costs and time of litigation if our goal is to enter into a settlement, I would like to have a stay in the
discovery for the moment while we negotiate.
When Sean returns, I would like to set up a meeting next week with you and him—without the
presence of our clients--in order to further negotiate and iron out the numbers. Based on the time
constraints of the case, I believe face-to-face negotiation is preferable to telephone and email
communication. Additionally, we shall present Mr. Santini with new documentation from Cuba that
has just recently been brought to our attention—specifically, a Cuban court sentence from a
separate trial of two other individuals that Puig sent to prison. The sentence demonstrates that Puig
—along with several other baseball players—accussed two (2) other individuals of Human
Trafficking and testified against them, sending them to prison. We additionally have the affidavit of
another man, who Puig sent to prison by accusing him of Human Trafficking and then testifying
against him as well.
Sincerely,
Avelino J. Gonzalez, Esq.
AJG/kb
Law Offices of Avelino J. Gonzalez, P.A.
6780 Coral Way, Miami, Florida 33155
Ph: 305-668-3535; Fax: 305-668-3545
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