`
`IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR
`MIAMI-DADE COUNTY, FLORIDA
`
`CASE NO: 2021-CA-009833-01
`
`ESTEBAN IVANOFF-TZVETCOFF,
`OLANSHILE SHITTA-BEY,
`FLORIDA ASSOCIATION OF INTERNATIONAL MEDICAL GRADUATES d/b/a
`UNITED STATES ASSOCIATION OF INTERNATIONAL MEDICAL GRADUATES
`
`v. Plaintiffs,
`
`BORINQUEN HEALTH CARE CENTER, INC. d/b/a BORINQUEN MEDICAL CENTER,
`JOSEPH DURANDIS,
`TATIANA POSSO
`
`Defendants
`__________________________________________
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`Plaintiff's Response to Defendant’s Motion to set aside Default for Tatiana Posso
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`It is disingenuous of the defendant’s counsel, Ms. Kornfield, to choose to further attack
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`plaintiffs Bey and Ivanoff for her own negligence since Ms. Kornfield was also e-serviced
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`Plaintiff’s second amended complaint on February 27, 2022, which clearly shows that Ms. Posso
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`is a defendant under the third count of Fraudulent misrepresentation / Negligent
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`misrepresentation and or in the alternative information negligently provided for the guidance of
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`others.
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`It is also particularly disturbing that Borinquen as a whole continues to conduct business
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`as usual in trivializing the issue that has now devastated the medical careers of Plaintiffs Bey and
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`Ivanoff in stating to this court that they “forgot” to hand over Plaintiff’s second amended
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`1
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`
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`complaint to their counsel. Instead of Borinquen conducting a proper review as to why
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`professional competency and sub-competency evaluations were falsified, fabricated, and
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`published to third parties for plaintiffs Bey and Ivanoff by Joseph Durandis during an ongoing
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`litigation, and conducting an in-depth review as to why usernames and passwords were created
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`using plaintiffs Bey and Ivanoff’s identity, and Durandis and Posso impersonating plaintiffs Bey
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`and Ivanoff to favorably evaluate themselves by pretending to have been Plaintiffs Bey and
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`Ivanoff who completed and published the falsified reciprocal evaluations, Borinquen continues
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`to protect the perpetrators of these reckless conducts that have now devastated the medical
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`careers of Plaintiffs Bey and Ivanoff.
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`In the ninth paragraph of the defendant’s affirmative defense, after multiple assertions of
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`qualified privilege by Durandis, Durandis has now changed his narrative to go down the path of
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`attempting to lie and deceive this court that the evaluations were doctored, altered, edited, or
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`otherwise transformed by a third party even though he failed to retract the falsified evaluations
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`within the time specified in the statutory notice that was since served upon Durandis on June 5,
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`2020, through his counsels. Plaintiffs Bey and Ivanoff continue to languish in vain because of the
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`reckless conduct of Joseph Durandis and Tatiana Posso.
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`Plaintiffs have no objection to setting aside Ms. Posso’s default, as such, Plaintiffs will
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`agree to a joint order with the defendants.
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`2
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`
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`Esteban Ivanoff-Tzvetcoff
`
`Esteban Ivanoff-Tzvetcoff
`Address: 1300 NE 109th St
`Apt 306, Miami FL 331161
`Phone: 305733186
`Email: estebanivanoff@gmail.com
`
`Olanshile Shitta-Bey
`
`Olanshile Shitta-Bey
`Address: 8000 West Dr
`North Bay Village,
`Miami, FL 33141
`Email: oshittabey@gmail.com
`Phone: 9543265516
`
`3
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