LUIS MANUEL RODRIGUEZ, MARIA TERESA RODRIGUEZ, a/k/a MARIA TERESA LANDA, ALFREDO RAMON FORNS, RAMON ALBERTO RODRIGUEZ, RAUL LORENZO RODRIGUEZ, CHRISTINA CONROY, and FRANCISCO RAMON RODRIGUEZ, Plaintiffs, v. IMPERIAL BRANDS PLC, CORPORACIÓN HABANOS, S.A., WPP PLC, YOUNG & RUBICAM LLC, and BCW LLC, a/k/a BURSON COHN & WOLFE LLC [1:20-cv-23287; Southern Florida District].

Berenthal & Associates (plaintiff)
Rodriguez Tramont & Nunez (plaintiff)
Nelson Mullins (defendant)
Allen & Overy (defendant)
Wilmer Cutler Pickering Hale and Dorr (defendant)
Broad & Cassel (defendant)
Akerman (defendant)
Trenam, Kemker, Scharf, Barkin, Frye, O’Neill & Mullis (defendant)
Rabinowitz, Boudin, Standard, Krinsky & Lieberman (defendant)
Strook & Strook & Lavan (defendant)

Excerpt:

Plaintiffs have now completed jurisdictional discovery. All Defendants argue that this Court lacks personal jurisdiction. Plaintiffs seek to amend their complaint to clarify and supplement the allegations contained in the (First) Amended Complaint based on the information learned during jurisdictional discovery. The proposed Second Amended Complaint (“SAC”) alleges additional facts regarding this Court’s jurisdiction over Defendants WPP plc, Y&R and BCW. The new facts clarify and add allegations regarding the WPP Parties use of U.S. Services to further trafficking in Plaintiffs’ confiscated property. The new facts also include allegations of concerted action by the WPP Parties. Plaintiffs allege that the WPP Parties provided marketing and advertising services for Imperial and Habanos that served to further the alleged HBA trafficking at issue, for which all Defendants are liable. The newly alleged jurisdictional facts regarding use of U.S. Services, therefore, also affect the jurisdictional arguments made by Imperial and Habanos. The SAC will also address arguments presented in the Defendants’ motion to dismiss, some which were alleged for the first time after Habanos appeared in the action. Finally, the SAC will also address Habanos’ argument regarding propriety of service of process on Habanos as an agency or instrumentality of the Cuban government. The proposed Second Amended Complaint is annexed hereto as Exhibit A, and a redlined version of the same (without exhibits) is annexed hereto as Exhibit B.

208-Page Motion To Leave To Amend Complaint (20 December 2021)

Order Granting Agreed Motion To Set Briefing Schedule For Plaintiffs’ Motion For Leave To Amend The Complaint (20 December 2021)

LINK To Libertad Act Lawsuit Filing Statistics

LINKS To Related Analyses

Did U.S. Department Of Justice “Intervene” And Tip The Scale In A Libertad Act Title III Cuba Lawsuit On Behalf Of United Kingdom-Based Company? Defendants Hope So. (September 01, 2021)

Habanos Retains Two U.S. Law Firms For Libertad Act Lawsuit; One Represents Cuba In Exxon Mobil Libertad Act Lawsuit; Plaintiff Files Exhibits. (March 23, 2021)

UK's Imperial Brands Among Increasing Number Of EU-Based Defendants In Libertad Act Lawsuits Seeking Guidance From EC. (November 10, 2020)

London-Based Imperial Brands, WWP (And U.S.-Based Subsidiaries Y&R And Burson Cohn Wolfe), Havana-Based Habanos Sued Using Libertad Act: EU Asked To Respond. (October 08, 2020)