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)

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From: To: Cc: Subject: Date: Averil Andrews Rene Murai "Kenia Bravo"; "Avelino Gonzalez"; Sean Santini Re: Agreed Motion for Corbacho Daudinot v. Puig et al Tuesday, April 14, 2015 8:30:23 AM Mr. Murai,  Good morning.  The defendants do not object to the motion.   Regards,    Averil Andrews Associate Attorney SantiniLaw 1001 Brickell Bay Drive Suite 2650 Miami, FL  33131 305.372.7307 (direct) 305.372.7308 (fax) aandrews@santinilawfirm.com     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: Rene Murai <rmurai@mwbm.com> Date: Monday, April 13, 2015 at 2:45 PM To: Averil Andrews <aandrews@santinilawfirm.com> Cc: 'Kenia Bravo' <avelinogonzalez2@bellsouth.net>, 'Avelino Gonzalez' <avelinogonzalez@bellsouth.net> Subject: FW: Agreed Motion for Corbacho Daudinot v. Puig et al Please let me know if Avelino can represent to the court that this is an agreed motion.   Rene V. Murai Murai Wald Biondo & Moreno P.A. Business Lawyers, Mediators and Arbitrators 1200 Ponce de Leon Boulevard Miami, FL 33134 Direct Line: 305-529-3290 Office Telephone: 305-444-0101 ext 202 Cell: 305-542-0131 Fax: 305-444-0174 Email: rmurai@mwbm.com web site: www.mwbm.com   ************************************************************************************** ********** IRS Circular 230 Disclosure To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. The information contained in this electronic mail is personal and confidential and is intended only for the person or persons named above. This message and the information contained in this electronic mail may be an attorney-client communication and therefore may be subject to the attorney-client privilege. If the reader of this message is not the recipient named above or an authorized agent of such recipient responsible for delivering it to the intended recipient, you are hereby notified that you have received this electronic mail in error, and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone or electronic mail and delete the original message or any copy thereof, whether electronic or hard copy. Thank you.   From: Kenia Bravo [mailto:avelinogonzalez2@bellsouth.net] Sent: Friday, April 10, 2015 4:43 PM To: Rene Murai Cc: avelinogonzalez@bellsouth.net Subject: Agreed Motion for Corbacho Daudinot v. Puig et al   Rene,   Please see the agreed motion. We need to file it today so I’ll be waiting for your response.   Sincerely,   Kenia Bravo, Esq. Law Offices of Avelino J. Gonzalez, P.A. 6780 Coral Way, Miami, Florida 33155 Ph: 305-668-3535; Fax: 305-668-3545 WARNING: THIS COMMUNICATION IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHOM IT IS ADDRESSED AND MAY CONTAIN INFORMTION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW.  If the reader of this message is not the intended recipient or the employee or agent responsible for delivering this communication to the intended recipient you are hereby notified that any distribution, us or copying of this communication is strictly prohibited. If you have received this communition in error, please notify our staff immediately at the above-listed number and return the original message to our office at the above address via U.S. Postal Service.  

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