9/8/23, 9:47 AM PereGonza The Attorneys Mail - RE: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR ...

https://mail.google.com/mail/u/0/?ik=e9372dcc5a&view=pt&search=all&permthid=thread-f:1691882067190754631%7Cmsg-f:1705371358548414785&simpl=msg-... 1/9

Nathaly Saavedra <nathaly@peregonza.com>

RE: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR

Charge F-8515 - 30-Day Rebuttal Ltr.

1 message

Obando, Mercedes (HR) <Mercedes.Obando@miamidade.gov> Thu, Jul 15, 2021 at 1:07 PM

To: Nathaly Saavedra <nathaly@peregonza.com>

Cc: Gustavo Torres <gustavo@peregonza.com>

Good afternoon Ms. Saavedra,

This above-referenced case is still under investigation since the Respondent is no longer interested in mediating the case.

Regards,

Mercy Obando, HRFEP Specialist

Miami-Dade County Human Resources Department

Human Rights & Fair Employment Practices

111 NW 1 Street, 21st Floor, Miami, FL 33128

Office: 305-375-5762 Fax: 305-375-2114

www.miamidade.gov/humanrights

Miami-Dade County is a public entity subject to Chapter 119 of the Florida Statutes concerning public records. E-mail messages are covered under such

laws and thus subject to disclosure.

From: Nathaly Saavedra <nathaly@peregonza.com>

Sent: Thursday, July 15, 2021 11:21 AM

To: Obando, Mercedes (HR) <Mercedes.Obando@miamidade.gov>

Cc: Gustavo Torres <gustavo@peregonza.com>

Subject: Re: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR Charge F-8515 - 30-Day Rebuttal Ltr.

EMAIL RECEIVED FROM EXTERNAL SOURCE

Good Morning investigator Mercedes, 

Can you advise on the status of this claim? Is the respondent not interested in mediation?

Best Regards,

Notices: This email may contain information which is privileged, confidential, and protected by the attorney-client or attorney work product privileges. If you are not the

addressee, note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. If you have received this transmission in error, please destroy it

and notify us immediately.

Fair Debt Collection Practices Act: This law firm is a debt collector and this may be an attempt to collect a debt. Any information obtained may be used for that purpose.

On Thu, Mar 11, 2021 at 1:49 PM Obando, Mercedes (HR) <Mercedes.Obando@miamidade.gov> wrote:

Case 1:22-cv-22343-KMM Document 111-18 Entered on FLSD Docket 09/24/2023 Page 1 of 9
9/8/23, 9:47 AM PereGonza The Attorneys Mail - RE: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR ...

https://mail.google.com/mail/u/0/?ik=e9372dcc5a&view=pt&search=all&permthid=thread-f:1691882067190754631%7Cmsg-f:1705371358548414785&simpl=msg-... 2/9

Great, thank you. I’ll send you a calendar invitation in a few moements.

Mercy Obando, HRFEP Specialist

Miami-Dade County Human Resources Department

Human Rights & Fair Employment Practices

111 NW 1 Street, 21st Floor, Miami, FL 33128

Office: 305-375-5762 Fax: 305-375-2114

www.miamidade.gov/humanrights

Miami-Dade County is a public entity subject to Chapter 119 of the Florida Statutes concerning public records. E-mail messages are covered under such

laws and thus subject to disclosure.

Due to the unprecedented and changing situation involving COVID-19, the Human Rights & Fair Employment Practices

Division, which includes the Commission on Human Rights, is currently working remotely. We will have limited access to

regular mail, physical files, and other resources that we would otherwise have while working in the office. As a result, we ask

that you please correspond with us by e-mail or send an electronic copy of any physical document you send to our offices to

the e-mail address of the investigator assigned to your case or to our general inbox at ofep@miamidade.gov. We also will have

limited access to certain physical and other records in response public records requests and other similar requests and ask for

your patience and understanding in any delayed or untimely response. To the extent that we have stored data or information

online and readily accessible, we will continue to provide it in a timely manner. We appreciate your cooperation at this difficult

time. Thank you.

From: Cesar Roqueta <cesar@peregonza.com>

Sent: Thursday, March 11, 2021 1:48 PM

To: Obando, Mercedes (HR) <Mercedes.Obando@miamidade.gov>

Cc: Nathaly Saavedra <nathaly@peregonza.com>

Subject: Re: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR Charge F-8515 - 30-Day Rebuttal

Ltr.

EMAIL RECEIVED FROM EXTERNAL SOURCE

Yes. 10 AM is actually perfect for us.

Kind regards,

Cesar J. Roqueta

Paralegal

cesar@peregonza.com

1414 NW 107th Ave, Suite 302

Doral, FL 33172

Office: (786) 650-0202

Fax: (786) 650-0200

https://www.peregonza.com

Case 1:22-cv-22343-KMM Document 111-18 Entered on FLSD Docket 09/24/2023 Page 2 of 9
9/8/23, 9:47 AM PereGonza The Attorneys Mail - RE: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR ...

https://mail.google.com/mail/u/0/?ik=e9372dcc5a&view=pt&search=all&permthid=thread-f:1691882067190754631%7Cmsg-f:1705371358548414785&simpl=msg-... 3/9

Notices: This email may contain information which is privileged, confidential, and protected by the attorney-client or attorney work

product privileges. If you are not the addressee, note that any disclosure, copying, distribution, or use of the contents of this message is

prohibited. If you have received this transmission in error, please destroy it and notify us immediately.

Fair Debt Collection Practices Act: This law firm is a debt collector and this may be an attempt to collect a debt. Any information

obtained may be used for that purpose.

From: "Obando, Mercedes (HR)" <Mercedes.Obando@miamidade.gov>

Date: Thursday, March 11, 2021 at 1:47 PM

To: 'Cesar Roqueta' <cesar@peregonza.com>

Cc: Nathaly Saavedra <nathaly@peregonza.com>

Subject: RE: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR

Charge F-8515 - 30-Day Rebuttal Ltr.

Is 10:00 am a good time for you? We can begin at that time if it’s fine with you.

Thank you.

Mercy Obando, HRFEP Specialist

Miami-Dade County Human Resources Department

Human Rights & Fair Employment Practices

111 NW 1 Street, 21st Floor, Miami, FL 33128

Office: 305-375-5762 Fax: 305-375-2114

www.miamidade.gov/humanrights

Miami-Dade County is a public entity subject to Chapter 119 of the Florida Statutes concerning public records. E-mail messages are covered under such

laws and thus subject to disclosure.

Due to the unprecedented and changing situation involving COVID-19, the Human Rights & Fair Employment Practices

Division, which includes the Commission on Human Rights, is currently working remotely. We will have limited access to

regular mail, physical files, and other resources that we would otherwise have while working in the office. As a result, we ask

that you please correspond with us by e-mail or send an electronic copy of any physical document you send to our offices to

the e-mail address of the investigator assigned to your case or to our general inbox at ofep@miamidade.gov. We also will have

limited access to certain physical and other records in response public records requests and other similar requests and ask for

your patience and understanding in any delayed or untimely response. To the extent that we have stored data or information

online and readily accessible, we will continue to provide it in a timely manner. We appreciate your cooperation at this difficult

time. Thank you.

From: Cesar Roqueta <cesar@peregonza.com>

Sent: Thursday, March 11, 2021 1:00 PM

To: Obando, Mercedes (HR) <Mercedes.Obando@miamidade.gov>

Cc: Nathaly Saavedra <nathaly@peregonza.com>

Subject: Re: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR Charge F-8515 - 30-Day Rebuttal

Ltr.

Case 1:22-cv-22343-KMM Document 111-18 Entered on FLSD Docket 09/24/2023 Page 3 of 9
9/8/23, 9:47 AM PereGonza The Attorneys Mail - RE: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR ...

https://mail.google.com/mail/u/0/?ik=e9372dcc5a&view=pt&search=all&permthid=thread-f:1691882067190754631%7Cmsg-f:1705371358548414785&simpl=msg-... 4/9

EMAIL RECEIVED FROM EXTERNAL SOURCE

Ms. Obando:

April 8th in the AM would work for us and the client. Can you confirm this date is still available on your end and provide me with the best time to begin so I

can calendar? Thanks in advance.

Kind regards,

Cesar J. Roqueta

Paralegal

cesar@peregonza.com

1414 NW 107th Ave, Suite 302

Doral, FL 33172

Office: (786) 650-0202

Fax: (786) 650-0200

https://www.peregonza.com

Notices: This email may contain information which is privileged, confidential, and protected by the attorney-client or attorney work

product privileges. If you are not the addressee, note that any disclosure, copying, distribution, or use of the contents of this message is

prohibited. If you have received this transmission in error, please destroy it and notify us immediately.

Fair Debt Collection Practices Act: This law firm is a debt collector and this may be an attempt to collect a debt. Any information

obtained may be used for that purpose.

From: "Obando, Mercedes (HR)" <Mercedes.Obando@miamidade.gov>

Date: Wednesday, March 10, 2021 at 4:53 PM

To: 'Cesar Roqueta' <cesar@peregonza.com>

Cc: Nathaly Saavedra <nathaly@peregonza.com>

Subject: RE: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR

Charge F-8515 - 30-Day Rebuttal Ltr.

Good Afternoon Mr. Roqueta,

I’m available on the following days:

March 22, 23, 26, 29, 30

Case 1:22-cv-22343-KMM Document 111-18 Entered on FLSD Docket 09/24/2023 Page 4 of 9
9/8/23, 9:47 AM PereGonza The Attorneys Mail - RE: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR ...

https://mail.google.com/mail/u/0/?ik=e9372dcc5a&view=pt&search=all&permthid=thread-f:1691882067190754631%7Cmsg-f:1705371358548414785&simpl=msg-... 5/9

March 25 (available AM only)

April 2, 5, 6,

April 7 (available PM only)

April 8 (available AM only)

If none of these work, I can provide you with other dates .

Thank you.

Mercy Obando, HRFEP Specialist

Miami-Dade County Human Resources Department

Human Rights & Fair Employment Practices

111 NW 1 Street, 21st Floor, Miami, FL 33128

Office: 305-375-5762 Fax: 305-375-2114

www.miamidade.gov/humanrights

Miami-Dade County is a public entity subject to Chapter 119 of the Florida Statutes concerning public records. E-mail messages are covered under such

laws and thus subject to disclosure.

Due to the unprecedented and changing situation involving COVID-19, the Human Rights & Fair Employment Practices

Division, which includes the Commission on Human Rights, is currently working remotely. We will have limited access to

regular mail, physical files, and other resources that we would otherwise have while working in the office. As a result, we ask

that you please correspond with us by e-mail or send an electronic copy of any physical document you send to our offices to

the e-mail address of the investigator assigned to your case or to our general inbox at ofep@miamidade.gov. We also will have

limited access to certain physical and other records in response public records requests and other similar requests and ask for

your patience and understanding in any delayed or untimely response. To the extent that we have stored data or information

online and readily accessible, we will continue to provide it in a timely manner. We appreciate your cooperation at this difficult

time. Thank you.

From: Cesar Roqueta <cesar@peregonza.com>

Sent: Wednesday, March 10, 2021 10:13 AM

To: Obando, Mercedes (HR) <Mercedes.Obando@miamidade.gov>

Cc: Nathaly Saavedra <nathaly@peregonza.com>

Subject: Re: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR Charge F-8515 - 30-Day Rebuttal

Ltr.

EMAIL RECEIVED FROM EXTERNAL SOURCE

Ms. Obando:

As it relates to the Jorge Monteagudo matter, I see that the date you proposed for the interview, 3/17/21 is not going to work for us. Would you please

provide a few alternate dates so I can go ahead and coordinate with the client? Perhaps provide me with 3-4 days towards the end of March and early April.

Please advise.

On Tue, Mar 9, 2021 at 9:19 AM Obando, Mercedes (HR) <Mercedes.Obando@miamidade.gov> wrote:

Good Morning Nathaly,

Let’s do next Wednesday, March 17 at 10:30 a.m. or thereabouts. Would that work? 

Thank you.

Case 1:22-cv-22343-KMM Document 111-18 Entered on FLSD Docket 09/24/2023 Page 5 of 9
9/8/23, 9:47 AM PereGonza The Attorneys Mail - RE: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR ...

https://mail.google.com/mail/u/0/?ik=e9372dcc5a&view=pt&search=all&permthid=thread-f:1691882067190754631%7Cmsg-f:1705371358548414785&simpl=msg-... 6/9

Mercy Obando, HRFEP Specialist

Miami-Dade County Human Resources Department

Human Rights & Fair Employment Practices

111 NW 1 Street, 21st Floor, Miami, FL 33128

Office: 305-375-5762 Fax: 305-375-2114

www.miamidade.gov/humanrights

Miami-Dade County is a public entity subject to Chapter 119 of the Florida Statutes concerning public records. E-mail messages are covered under

such laws and thus subject to disclosure.

Due to the unprecedented and changing situation involving COVID-19, the Human Rights & Fair Employment Practices

Division, which includes the Commission on Human Rights, is currently working remotely. We will have limited access to

regular mail, physical files, and other resources that we would otherwise have while working in the office. As a result, we ask

that you please correspond with us by e-mail or send an electronic copy of any physical document you send to our offices to

the e-mail address of the investigator assigned to your case or to our general inbox at ofep@miamidade.gov. We also will

have limited access to certain physical and other records in response public records requests and other similar requests and

ask for your patience and understanding in any delayed or untimely response. To the extent that we have stored data or

information online and readily accessible, we will continue to provide it in a timely manner. We appreciate your cooperation

at this difficult time. Thank you.

From: Nathaly Saavedra <nathaly@peregonza.com>

Sent: Monday, March 8, 2021 12:13 PM

To: Obando, Mercedes (HR) <Mercedes.Obando@miamidade.gov>

Cc: Cesar Roqueta <cesar@peregonza.com>

Subject: Re: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR Charge F-8515 - 30-Day Rebuttal

Ltr.

EMAIL RECEIVED FROM EXTERNAL SOURCE

Good Morning Mercedes, 

This week is a bit hectic for me. Are you available next Monday or wednesday? 

Best Regards,

Nathaly Saavedra, Esq.

nathaly@peregonza.com

1414 NW 107th Ave, Suite 302

Doral, FL 33172

Office: (786) 650-0202

Fax: (786) 650-0200

https://www.peregonza.com

Notices: This email may contain information which is privileged, confidential, and protected by the attorney-client or attorney work product privileges. If you are

not the addressee, note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. If you have received this transmission in error,

please destroy it and notify us immediately.

Case 1:22-cv-22343-KMM Document 111-18 Entered on FLSD Docket 09/24/2023 Page 6 of 9
9/8/23, 9:47 AM PereGonza The Attorneys Mail - RE: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR ...

https://mail.google.com/mail/u/0/?ik=e9372dcc5a&view=pt&search=all&permthid=thread-f:1691882067190754631%7Cmsg-f:1705371358548414785&simpl=msg-... 7/9

Fair Debt Collection Practices Act: This law firm is a debt collector and this may be an attempt to collect a debt. Any information obtained may be used for that

purpose.

On Mon, Feb 22, 2021 at 9:52 AM Obando, Mercedes (HR) <Mercedes.Obando@miamidade.gov> wrote:

Good Morning,

Sorry for the delay in getting back to you. I’m free all next week and the following, with the exception of the hour between 12:30-1:30 pm and on

March 10, 2021, I am available only after 11:00 a.m.. Please let me know what works best with your client.

Thank you.

Mercy Obando, HRFEP Specialist

Miami-Dade County Human Resources Department

Human Rights & Fair Employment Practices

111 NW 1 Street, 21st Floor, Miami, FL 33128

Office: 305-375-5762 Fax: 305-375-2114

www.miamidade.gov/humanrights

Miami-Dade County is a public entity subject to Chapter 119 of the Florida Statutes concerning public records. E-mail messages are covered under

such laws and thus subject to disclosure.

Due to the unprecedented and changing situation involving COVID-19, the Human Rights & Fair Employment Practices

Division, which includes the Commission on Human Rights, is currently working remotely. We will have limited access to

regular mail, physical files, and other resources that we would otherwise have while working in the office. As a result, we

ask that you please correspond with us by e-mail or send an electronic copy of any physical document you send to our

offices to the e-mail address of the investigator assigned to your case or to our general inbox at ofep@miamidade.gov. We

also will have limited access to certain physical and other records in response public records requests and other similar

requests and ask for your patience and understanding in any delayed or untimely response. To the extent that we have

stored data or information online and readily accessible, we will continue to provide it in a timely manner. We appreciate

your cooperation at this difficult time. Thank you.

From: Nathaly Saavedra <nathaly@peregonza.com>

Sent: Thursday, February 18, 2021 5:58 PM

To: Obando, Mercedes (HR) <Mercedes.Obando@miamidade.gov>

Cc: Travis Hoopingarner <travis@peregonza.com>

Subject: Re: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR Charge F-8515 - 30-Day

Rebuttal Ltr.

EMAIL RECEIVED FROM EXTERNAL SOURCE

Good Evening Investigator Mercedes, 

At your convenience, please provide some proposed dates so I can check my client's availability. 

Thank you. 

On Tue, Feb 16, 2021 at 2:41 PM Obando, Mercedes (HR) <Mercedes.Obando@miamidade.gov> wrote:

Good Afternoon Ms. Saavedra,

Case 1:22-cv-22343-KMM Document 111-18 Entered on FLSD Docket 09/24/2023 Page 7 of 9
9/8/23, 9:47 AM PereGonza The Attorneys Mail - RE: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR ...

https://mail.google.com/mail/u/0/?ik=e9372dcc5a&view=pt&search=all&permthid=thread-f:1691882067190754631%7Cmsg-f:1705371358548414785&simpl=msg-... 8/9

This is to inform you that the respondent in the above indicated matter has submitted a response to the allegations raised in the above-cited charge

of discrimination. As part of the investigation of this claim, it is necessary to schedule a conference with you and your client to obtain your rebuttal to

the respondent’s articulated defense.

Please contact me at Mercedes.Obando@miamidade.gov or at 305-375-5762, to confirm receipt of this letter and to schedule a conference. If I am

not available, please leave a message with your name, the CHR charge number, and a telephone number where you can be contacted and I will

return your call as soon as possible.

If you fail to respond within thirty (30) days of your receipt of this letter, we will assume that you are no longer interested in pursuing the charge and

the file will be closed.

Sincerely,

Mercy Obando, HRFEP Specialist

Miami-Dade County Human Resources Department

Human Rights & Fair Employment Practices

111 NW 1 Street, 21st Floor, Miami, FL 33128

Office: 305-375-5762 Fax: 305-375-2114

www.miamidade.gov/humanrights

Miami-Dade County is a public entity subject to Chapter 119 of the Florida Statutes concerning public records. E-mail messages are covered

under such laws and thus subject to disclosure.

Due to the unprecedented and changing situation involving COVID-19, the Human Rights & Fair Employment Practices

Division, which includes the Commission on Human Rights, is currently working remotely. We will have limited access

to regular mail, physical files, and other resources that we would otherwise have while working in the office. As a result,

we ask that you please correspond with us by e-mail or send an electronic copy of any physical document you send to

our offices to the e-mail address of the investigator assigned to your case or to our general inbox at

ofep@miamidade.gov. We also will have limited access to certain physical and other records in response public records

requests and other similar requests and ask for your patience and understanding in any delayed or untimely response.

To the extent that we have stored data or information online and readily accessible, we will continue to provide it in a

timely manner. We appreciate your cooperation at this difficult time. Thank you.

--

Best Regards,

Nathaly Saavedra, Esq.

nathaly@peregonza.com

1414 NW 107th Ave, Suite 302

Doral, FL 33172

Office: (786) 650-0202

Fax: (786) 650-0200

https://www.peregonza.com

Case 1:22-cv-22343-KMM Document 111-18 Entered on FLSD Docket 09/24/2023 Page 8 of 9
9/8/23, 9:47 AM PereGonza The Attorneys Mail - RE: Jorge Monteagudo Alburquerque v. The De Moya Group, Inc. / EEOC Charge No. 15C-2021-00021/ CHR ...

https://mail.google.com/mail/u/0/?ik=e9372dcc5a&view=pt&search=all&permthid=thread-f:1691882067190754631%7Cmsg-f:1705371358548414785&simpl=msg-... 9/9

Notices: This email may contain information which is privileged, confidential, and protected by the attorney-client or attorney work product privileges. If you are

not the addressee, note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. If you have received this transmission in

error, please destroy it and notify us immediately.

Fair Debt Collection Practices Act: This law firm is a debt collector and this may be an attempt to collect a debt. Any information obtained may be used for that

purpose.

--

Cesar J. Roqueta

Paralegal

cesar@peregonza.com

1414 NW 107th Ave, Suite 302

Doral, FL 33172

Office: (786) 650-0202

Fax: (786) 650-0200

https://www.peregonza.com

Notices: This email may contain information which is privileged, confidential, and protected by the attorney-client or attorney work product privileges. If you are not

the addressee, note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. If you have received this transmission in error, please

destroy it and notify us immediately.

Fair Debt Collection Practices Act: This law firm is a debt collector and this may be an attempt to collect a debt. Any information obtained may be used for that purpose.

Case 1:22-cv-22343-KMM Document 111-18 Entered on FLSD Docket 09/24/2023 Page 9 of 9