Plaintiff And Defendant In Carnival Corporation Libertad Act Lawsuit- Neither Party Wants To Disclose Certain Communications

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)

LINK: Order Granting Defendant’s Motion For Leave To File Its Response To
Plaintiff’s Motion To Compel Under Seal (4/5/21)

LINK: Havana Docks’ Corrected Opposition To Carnival’s Motion To Compel Evidence Withheld Under The Work Product Doctrine (4/3/21)

Excerpt:

The undersigned approached these conferrals in the frank and open manner that the Court expected. Havana Docks listened to Carnival’s questions, provided the substance of the withheld evidence, and considered (and re- considered) privilege and work product determinations on the narrowest possible grounds. The parties engaged each other with their respective legal arguments, and some challenges were resolved. This process also resulted in Havana Docks producing certain documents to Carnival in full. Where privileged or work product information appeared in only a small portion of the document, Havana Docks produced the record with redactions and explained to Carnival, often verbatim, the substance of the communication being withheld. Through this process, Carnival was read most of the redactions now challenged in the Motion.

After undertaking this process, it is surprising that Carnival would characterize the work product now challenged as “instructions to, and summaries from, public relations government lobbyists concerning efforts to influence” federal government agencies. (Mot. at 2.) Havana Docks’ lobbying records were not withheld and Carnival was informed of this.