Pernod Ricard Libertad Lawsuit Update: Plaintiff Wants Discovery

MARLENE CUETO IGLESIAS AND MARIAM IGLESIAS ALVAREZ V. PERNOD RICARD [1:20-cv-20157; Southern Florida District]

IPS Legal Group, P.A. (plaintiff)
Law Offices of Andre G. Raikhelson LLC (plaintiff)
Ainsworth & Clancy PLLC (plaintiff)
Carlton Fields P.A. (defendant)
Carlton Fields Jorden Burt, P.A. (defendant)

Plaintiff's Response In Opposition To Defendant's Motion To Dismiss The Second Amended Complaint (10/9/20)

Declaration Of Miriam Iglesias Alvarez (10/9/20)

Declaration Of Marlene Cueto Iglesias (10/9/20)

Declaration Of Justin Boyd In Support Of Plaintiff Response To Defendant's Motion To Dismiss Second Amended Complaint (10/9/20)

LINK: Plaintiffs’ Reply To Defendant’ss Memorandum Of Law In Opppsition To Plaintiffs’ Renewed Motion For Leave To Conduct Limited Jurisdictional Discovery (10/5/20)

Excerpts:

Defendant Pernod Ricard (“Defendant”) contends that the length of Plaintiffs Renewed Motion for Limited Jurisdictional Discovery is somehow indicative of the validity of Plaintiffs request to conduct discovery. While the substantive issues in this case are complex, Plaintiffs request before the Court is straightforward and does not require a twenty-page brief to reach the conclusion that jurisdictional discovery is warranted. The Eleventh Circuit has held that the court’s power to allow jurisdictional discovery “is not entirely discretionary.”

Defendant’s arguments in opposition to Plaintiffs’ request for jurisdictional discovery are premature. Notwithstanding Plaintiffs’ contention that limited jurisdictional discovery would reveal that Defendant would be subject to personal jurisdiction in this Court, Plaintiffs have not propounded discovery to Defendant. Defendant cannot make specific objections to discovery requests that is has not received. Accordingly, the Court should disregard Defendant’s arguments as untimely.