Corbacho Daudinot v. Puig Valdes et al

Filing 80

REPLY to Response to Motion re 74 Second MOTION for Sanctions under Rule 37 filed by Yasiel Puig Valdes, Maritza Valdes Gonzalez. (Attachments: # 1 Exhibit Exhibit A, # 2 Exhibit Exhibit B, # 3 Exhibit Exhibit C)(Andrews, Averil)

EXHIBIT C
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION

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CASE NUMBER 13-22589-KMW

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MIGUEL ANGEL CORBACHO DAUDINOT,
Plaintiff

vs.
YASIEL PUIG VALDES and
MARITZA VALDES GONZALEZ
Defendant

_______________________________________________________________

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HEARING HELD 11-5-14
BEFORE THE HONORABLE KATHLEEN M. WILLIAMS
UNITED STATES DISTRICT COURT JUDGE
_______________________________________________________________

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APPEARANCES:

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FOR THE PLAINTIFF:

KENIA BRAVO, ESQ.
AVELINO GONZALEZ, ESQ.
6780 Coral Way
Miami, FL 33155

FOR THE DEFENDANT:

SEAN SANTINI, ESQ.
AVERIL ANDREWS, ESQ.
1001 Brickell Bay Drive
Miami, FL 33131

REPORTED BY:

PATRICIA SANDERS, RPR
United States Court Reporter
400 North Miami Avenue, Suite 11-3
Miami, FL 33128
T: 305.523.5528
[e-mail].

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THE COURTROOM DEPUTY:

This Court calls Case No.

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13-CV-22589, Miguel Angel Corbacho Daudinot versus Yasiel Puig

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Vales.

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Counsel, please state your appearances.

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MS. BRAVO: Good afternoon, Your Honor, Kenia Bravo and

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Avelino Gonzalez for the plaintiff.
MR. SANTINTI:

Good afternoon, Your Honor, Sean

Santini and Averil Andrews on behalf of the defendants.
THE COURT:

Good afternoon, everyone. All right.

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Where are we in this case? I know there is a pending motion for

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Rule 37 sanctions because Mr. Daudinot's deposition has not

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been scheduled.

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I know you have exchanged e-mails and responses.

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I know, Ms. Bravo, your December is now free; and your

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November, relative to the case as posing a scheduling conflict.

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So, how are we going to proceed?

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MS. BRAVO: Your Honor, what isn't free, unfortunately,

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is our client. He was re-arrested in Cuba, no charges.
This is something the authorities do with people in

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Mr. Daudinot's position. So, he has been re-arrested. He is

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scheduled to be released with no charges.

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He should have been released on Friday, and he wasn't.

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So we're hoping this week he is going to be released and we can

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go ahead and get the Visa for him to come to the United States

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in order to proceed with the deposition.

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THE COURT:

Okay. So the plan is Mr. Daudinot receives

a Visa, comes to the U.S. for his deposition.

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How long is that going to take?

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MS. BRAVO: Before mediation -- the date scheduled for

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mediation is January 14th. We are hoping to have him for

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deposition before that time.

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THE COURT:

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All right. Mr. Santini, you don't have to

reiterate what is in your motion.

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Any thoughts about the plan as it now stands that Mr.

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Daudinot comes to the U.S. and has his deposition taken before

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mediation?

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MR. SANTINI: Yes, Your Honor. The Court has asked I

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not rehash the motion, but I think there are a few things worth

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pointing out.

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THE COURT:

All right.

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MR. SANTINI:

It would have been nice to have been --

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my client has expended money in this briefing -- it would have

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been nice to have gotten word of any of this at some point in

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the process.

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I think that is only fair that at a minimum we walk

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out of this courthouse with an order that requires a date

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certain for his deposition.

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Plaintiff's counsel has made some representations

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regarding general timeframes.

I think it's fair I be told

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exactly when I will be able to depose her client.