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Chanelle Artiles

From: Reginald J. Clyne

Sent: Thursday, November 2, 2023 2:07 PM

To: Nathaly Saavedra; Chanelle Artiles

Cc: juan@peregonza.com; brian@fairlawattorney.com; Brooks Larou; Andres F. Vidales; 

Cecilia Quevedo; Sofia Morales Arcila

Subject: RE: CONFERRAL - 1:22-cv-22343-KMM Alburquerque v. The De Moya Group, Inc.

We have no objection to deferral. We would like to defer the Motion to Tax Costs and Motion for Fees. I think 

everything can wait till Motion for Rule 11 is ruled upon. 

Reginald J. Clyne | Partner

Quintairos, Prieto, Wood & Boyer, P.A.

9300 South Dadeland Blvd., 4th Floor, Miami, FL 33156

Ph: (305) 670-1101 x3426 Fax: (305) 670-1161

Email: reginald.clyne@qpwblaw.com Web: www.qpwblaw.com

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From: Nathaly Saavedra <nathaly@peregonza.com> 

Sent: Thursday, November 2, 2023 12:47 PM 

To: Chanelle Artiles <chanelle.artiles@qpwblaw.com>; Reginald J. Clyne <reginald.clyne@qpwblaw.com> 

Cc: juan@peregonza.com; brian@fairlawattorney.com; Brooks Larou <brooks@peregonza.com>; Andres F. Vidales 

<andres.vidales@qpwblaw.com>; Cecilia Quevedo <cecilia.quevedo@qpwblaw.com>; Sofia Morales Arcila 

<sofia.arcila@qpwblaw.com> 

Subject: CONFERRAL - 1:22-cv-22343-KMM Alburquerque v. The De Moya Group, Inc. 

Counsel, 

As previously communicated in response to your conferral email, Plaintiff's position is that Defendant's Motion for fees is 

premature until Defendant's Rule 11 Motion is disposed of by the Court. 

Since no ruling has been made as of today, Plaintiff's intends to file a Motion to Defer Adjudication of Defendant's Motion 

for Entitlement to Attorney's Fees until Defendant's Rule 11 Motion is disposed of by the Court. In accordance with Local 

Rule 7.3, this email serves as Plaintiff's conferral on the relief he intends to seek therein. To that end, please advise on your 

position by no later than close of business, Friday November 3, 2023. 

If you wish to discuss further feel free to contact me. 

Best Regards,

NATHALY SAAVEDRA, ESQ. | M A N A G I N G P A R T N E R

 O U R O F F I C E H A S M O V E D

 5201 Blue Lagoon Drive, Suite 290, Miami, FL 33126

 786.650.0202 PereGonza.com

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Case 1:22-cv-22343-KMM Document 128-1 Entered on FLSD Docket 11/08/2023 Page 1 of 2
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Case 1:22-cv-22343-KMM Document 128-1 Entered on FLSD Docket 11/08/2023 Page 2 of 2