Corbacho Daudinot v. Puig Valdes et al

Filing 78

Unopposed MOTION to Continue the Hearing on Defendants' Motion for Rule 37 Sanctions by Miguel Angel Corbacho Daudinot. Responses due by 5/29/2015 (Attachments: # 1 Exhibit A)(Bravo, Kenia)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIGUEL ANGEL CORBACHO DAUDINOT,
Plaintiff,

CASE NO. 1:13-cv-22589-KMV

v.
YASIEL PUIG VALDES a/k/a YASIEL PUIG
and MARITZA VALDES GONZALEZ,
Defendants.
______________________________________/
UNOPPOSED MOTION FOR CONTINUANCE FOR HEARING ON
DEFENDANTS’ SECOND MOTION FOR RULE 37 SANCTIONS [DE 74]
Plaintiff, MIGUEL ANGEL CORBACHO DAUDINOT, through counsel, file this
Motion for Continuance of the Hearing on Defendants’ Motion for Rule 37 Sanctions [DE 74]
that was scheduled for June 1, 2014, and in support thereof, states:
1.

On May 11, 2015, the court entered a Paperless Notice of Hearing [DE 77] on

Defendants’ Second Motion for Sanctions under Rule 37, scheduling the hearing for June 1,
2015.
2.

Attached as Exhibit A is the declaration of the undersigned counsel explaining the

scheduling conflict that requires the filing of this Motion. See S.D. Fla. L.R. 7.6.
3.

The undersigned counsel spoke with Sean Santini, counsel for Defendants,

regarding this motion, and was advised that he had no objection to a motion for continuance so
long as it was scheduled prior to May 31, 2015, which is the date when the scheduling conflict
begins.

4.

The undersigned called Judge Williams’ chambers and spoke with a clerk, who

informed the undersigned that the court may have time available for hearing on the afternoon of
May 27, 2015.
WHEREFORE, for the reasons stated above, Plaintiff respectfully requests that this court
grant the instant motion and reset the hearing scheduled on June 1, 2015 for the afternoon of
May 27, 2015, or any practicable time that week.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of this document was filed in federal
court using CM/ECF on May 11, 2015.
s/Kenia Bravo
_
Kenia Bravo, Esq., FBN 68296
Avelino J. Gonzalez, Esz. FBN 75530
Law Offices of Avelino J. Gonzalez, P.A.
6780 Coral Way, Miami, Florida 33155
Ph: 305-668-3535; Fax: [phone]
E-mail: [e-mail]

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