JORGE DIAZ-CUETO, ESQ.

5827 SHIR1[)AN STREET, HOLLYWOOD, FL 33021

Lc)RGF.D1\ZC)1OjRFLLSO1TH NET
TEL: 305-417-3530

May 31, 2016

SENT VIA E-MAIL

Gianfranco Napolitano
groma7uno(2igmail.com
RE: RONDON V NAPOLITANO et all CASE NO.: 1:1 5-CV-21811-UU
Dear Mr. Gianfranco Napolitano,
I am writing this letter in response to a tweet by Gianfranco Rondon where he falsely
states that he obtained a judgment against Patricia Poleo and you in the United States. He writes
"Justicia no tiene tintas ... Estados Unidos sentencio a Patricia Poleo por difamacion contra mi
persona", the translation in English is: Justice has no ink.. .USA sentence or adjudicated Patricia
Poleo guilty of defamation against my person. The exact opposite of this is what happened. Th
statement made by Rondon via his twitter account is entirely false.
I am attaching a copy of the docket sheet printed out today May 31st, 2016 for the case
that Rondon claims to have obtained a judgment against my clients Poleo and Napolitano (see
exhibit A). The docket sheet reflects that on September 9, 2015 the Court granted Napolitano
and Poleo's Motion to Dismiss (see exhibit B).
The self-serving statements made by Rondon quoted in paragraph one above are entirely
false and made with ill intent. However, such statements are refuted not by my words, but by th
Order of United States District Court Judge Ursula-Ungaro.

EXHIBIT A

CM/ECF

31/2016

- Live Database- flsd-History/Documents Query

1:15-cv-21811 -UU Rondon v. Napolitano et a!

Ursula Ungaro, presiding
Alicia M. Otazo-Reyes, referral
Date filed: 05/13/2015
Date terminated: 09/09/2015
Date of last filing: 10/06/2015

History
Doc.
No.

Description

Dates

1.

Filed & Entered. 05/13/2015 '3 Complaint

Judge Assignment
05/13/2015
Filed.'
05/14/2015
Entered.
Clerk's Notice of Consent to Proceed Before Magistrate Jud
05/13/2015
Filed:
05/14/2015
Entered:
Filed & Entered.' 05/14/2015 '3Summons Issued

Filed & Entered.'

Filed & Entered.'

05/14/2015
05/15/2015

Filed & Entered.' 05/15/2015

Filed & Entered:
9

Filed & Entered:

fl

Filed & Entered.'

05/15/2015
05/15/2015
05/15/2015

'3Clerks Notice to Filer re: Electronic Case

Summons Returned Executed
Summons Returned Executed
'3Summons Returned Executed
'3Summons Returned Executed
'3Summons Returned Executed

U Filed & Entered: 05/15/2015 '3Summons Returned Executed

12 Filed & Entered.' 05/28/2015 '3 Amended Complaint

Filed & Entered.'
14 Filed & Entered.'
15 Filed & Entered.'
16 Filed &

05/29/2015
06/09/2015
06/17/2015

J Notice (Other)
Order
Order to Show Cause

Entered.' 06/18/2015 1 4 Mot]

oil for Clerks Entry of Default

ttps://ecf.flsd.uscourts.gov/cgi-bir*1istDocQry.p?49567O4498OO918-L_1_O-1

1/

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FLU 10

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06/19/2015
Terminated.
G Notice of Compliance
17 Filed & Entered:
06/18/2015
.j.. Filed & Entered: 06/18/2015

Motion to Dismiss

09/02/2015
Terminated:
19 Filed &
Entered: 06/19/2015

Order on Motion for Clerks Entry of Default

20 Filed & Entered: 07/02/2015

Initial Disclosure(s)

21 Filed & Entered. 07/06/2015

Response in Opposition to Motion

22 Filed &

SCHEDULING REPORT - Rule 26(0/16.1

Entered. 07/10/2015

07/15/2015 J Order
23 Filed:
07/16/2015
Entered.
24 Filed & Entered. 07/16/2015 Response/Reply (Other)
25 Filed &

Clerks Notice of Docket Correction and Instruction to Filer

Entered: 07/17/2015 Attorney

26 Filed & Entered: 07/17/2015 J Initial Disclosure(s)

07/20/2015
22 Filed:
07/21/2015
Entered:
28 Filed &
Entered. 07/23/2015

Order
Notice of Unavailability

22 Filed & Entered: 07/31/2015 J Statement

30 Filed & Entered. 07/31/2015

Motion to Compel

Terminated.
08/06/2015
3.1 Filed & Entered: 08/04/2015

Order

Filed & Entered: 08/04/2015

33 Filed & Entered:

08/04/2015

Order Referring Motion

Order Setting Hearing on Motion

3.4 Filed & Entered: 08/06/2015

Notice of Attorney Appearance

35 Filed &

Motion Hearing

36 Filed &

Entered: 08/06/2015
Entered: 08/06/2015

Order on Motion to Compel

hs://ecf.flsd.uscourts.gov/cgi-bin/HistDocQry.pl?49567044980091&-L_1_O-1

2J

CMIECF - Live Database - flsd-History/Documents Query

5/31/2016

Motion for Sanctions

3.2 Filed & Entered: 08/18/2015

09/09/2015

Terminated:

3.8 Filed & Entered: 08/25/2015 J Notice (Other)

3.2 Filed & Entered. 08/28/2015 111 Response in Opposition to Motion
40 Filed & Entered: 09/02/2015

Order on Motion to Dismiss

41

Filed & Entered. 09/09/2015

Order Dismissing Case

Filed & Entered:

Reply to Response to Motion

09/10/2015

4.3. Filed & Entered. 10/06/2015 ( Order

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1:1 5-cv-2 1811UU

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EXIIIBIT B

Case 1:15-cv-21811-UU Document 41 Entered on FLSD Docket 09/09/2015 Page 1 of

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
CASE NO. 1:15-cv-21811-UU
GIANFRANCO RONDON,
Plaintiff,
I,,
GIANFRANCO NAPOLITANO et al.,
Defendants.
/

ORDER OF DISMISSAL
THIS CAUSE is before the Court upon a sua sponte examination of the record.
THE COURT has considered the pertinent portions of the record and is otherwise
fully advised in the premises.
On September 2, 2105, the Court granted the Defendants Motion to Dismiss the
Amended Complaint and ordered the Plaintiff to file a Second Amended Complaint on or
before September 8, 2015. D.E. 40. The Court cautioned Plaintiff that failure to file a
Second Amended Complaint by September 8, 2015 would result in dismissal of the action
without further notice. Id. As of September 9, 2015, a Second Amended Complaint has not
been filed and therefore, Plaintiff has failed to comply with this Court's Order or take the
necessary steps to prosecute this action. Accordingly, it is
ORDERED AND ADJUDGED that for administrative purposes this case is hereby
CLOSED and all pending motions are DENIED AS MOOT.

Case 1:15-cv-21811-UU Document 41 Entered on FLSD Docket 09/09/2015

Page 2 of

DONE AND ORDERED in Chambers at Miami, Florida, this 9th day of September,
201 5September, 2015.

URSULA
UNITED STATES DISTRICT JUDGE
copies provided:
counsel of record