In Libertad Act Lawsuit Filings, Including 163-Page Motion To Compel, Plaintiff Makes Case To Pierce Attorney-Client Privilege Of Four Cruise Lines
/Excerpt From One Plaintiff Filing:
"Through its twenty-nine affirmative defenses, Defendant Royal Caribbean Cruises, Ltd. injects a host of issues into this case, including its knowledge of the LIBERTAD Act and regulations issued by the Office of Foreign Assets Control (OFAC). (D.E. 59.) And through its two privilege logs, each exceeding 1,000 entries, Royal withholds substantial documents bearing on that issue.1 Eleventh Circuit precedent, however, is clear that where a party injects its knowledge of the law, as Royal does, it waives privilege over the attorney advice informing that knowledge. The Court should order Royal to produce withheld evidence reflecting its knowledge of the LIBERTAD Act and OFAC regulations. Royal also withholds over 700 exchanges with COMAR S.A., an agency of the Cuban Government, pertaining to Royal’s contract negotiations with the Cuban Government, a circumstance where no reasonable expectation of confidentiality exists. Among the withheld records are reports and minutes of meetings with Cuban Government agencies that were drafted by COMAR as Royal’s liaison to the Cuban Government. These documents do not qualify as legal advice and are not privileged. The Court should order Royal to produce its exchanges with COMAR."
HAVANA DOCKS CORPORATION V. NORWEGIAN CRUISE LINE HOLDINGS, LTD. [1:19-cv-23591; Southern Florida District]
Colson Hicks Eidson, P.A. (plaintiff)
Margol & Margol, P.A. (plaintiff)
Hogan Lovells US LLP (defendant)
Joint Notice Of Mootness As To Noticed Issue In Docket Entry 152 (3/24/21)
Norwegian Cruise Line Holdings Ltd.’s Notice Of Compliance (3/23/21)
Norwegian Cruise Line Holdings Ltd.’s Notice Of Compliance (3/19/21)
HAVANA DOCKS CORPORATION VS. ROYAL CARIBBEAN CRUISES, LTD. [1:19-cv-23590; Southern Florida District]
Colson Hicks Eidson, P.A. (plaintiff)
Margol & Margol, P.A. (plaintiff)
Holland & Knight (defendant)
Havana Docks’ Unopposed Motion For Leave To File Exhibits To Motion To Compel Under Seal (3/24/21)
Havana Docks’ Motion To Compel Production Of Evidence Under The Attorney-Client Privilege (3/22/21)
HAVANA DOCKS CORPORATION V. MSC CRUISES SA CO, AND MSC CRUISES (USA) INC. [1:19-cv-23588; Southern Florida District]
Colson Hicks Eidson, P.A. (plaintiff)
Margol & Margol, P.A. (plaintiff)
Venable (defendant)
Havana Docks’ Unopposed Motion For Leave To File Exhibits To Motion To Compel Under Seal (3/16/21)
Havana Docks’ Motion To Compel Production Of Evidence Withheld Under The Attorney-Client Privilege (3/15/21)
HAVANA DOCKS CORPORATION VS. CARNIVAL CORPORATION D/B/A/ CARNIVAL CRUISE LINES [1:19-cv-21724; Southern Florida District]
Colson Hicks Eidson, P.A. (plaintiff)
Margol & Margol, P.A. (plaintiff)
Jones Walker (defendant)
Boies Schiller Flexner LLP (defendant)
Akerman (defendant)
Order On Defendant’s Unopposed Motion To Seal Docket Entry 231 (3/24/21)
Havana Docks’ Unopposed Motion For Leave To File Unredacted Motion To Compel (D.E. 234) And Exhibits Under Seal (3/24/21)
Carnival’s Unopposed Motion To Seal Docket Entry 231 (3/23/21)
