Carnival's Motion To Dismiss One Libertad Act Lawsuit: Costa Rica Law & When-Is-What-Owned
/UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
CASE NO.: 19-cv-21725-KING
JAVIER GARCIA-BENGOCHEA,
Plaintiff,
v.
CARNIVAL CORPORATION d/b/a/ CARNIVAL CRUISE LINE, a foreign corporation,
Defendant.
CARNIVAL CORPORATION’S RULE 44.1 NOTICE OF INTENT TO RAISE AN ISSUE OF FOREIGN LAW
Pursuant to Fed. R. Civ. P. 44.1, Defendant Carnival Corporation (“Carnival”) hereby gives notice of its intent to raise an issue of Costa Rican law, including the issues raised in the affidavits of Esteban Aguero and Keith Rosenn. See Fed. R. Civ. P. 44.1.
EVEN IF THE BEQUEST WERE EFFECTIVE, BENGOCHEA’S CLAIM FAILS BECAUSE HE “ACQUIRE[D]” HIS “OWNERSHIP OF THE CLAIM” AFTER MARCH 12, 1996
A. Helms-Burton Requires a Plaintiff Suing Over Property Confiscated Before March 12, 1996 to Have Acquired Ownership of the Claim Before March 12, 1996
