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.
______________________________________/
DECLARATION OF KENIA BRAVO
My name is Kenia Bravo. I am Plaintiff’s counsel of record in this matter. I submit this
declaration in support of Plaintiff’s Motion for Continuance of the Hearing on Defendants’
Motion for Sanctions [DE 74].
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.

I am scheduled to be out of town from May 31 - June 6, 2015 for a family

vacation with my two-year-old daughter. The vacation was planned and paid for in January 2015,
long before Defendants filed their Motion for Sanctions.
3.

This is the only opportunity that my family and I shall have to vacation together

this year.
I declare under penalty of perjury that the foregoing is true and correct.
Dated: 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]