Excerpts:

"Incredibly, Plaintiff makes this claim despite Defendants’ travel to Cuba having been expressly authorized and, indeed, encouraged by President Obama as part of his administration’s foreign policy goals. In other words, Plaintiff challenges the core of these foreign-policy decisions of the Executive Branch, and essentially asks this Court to hold “unlawful” and subject to crushing liability the very activities that the President of the United States had blessed."

"Plaintiff’s bid should proceed no further, because Defendants are entitled to summary judgment for at least four reasons: First, Plaintiff did not own the Terminal; rather, at most, Plaintiff had a limited right to operate a cargo business in which Defendants did not and could not have trafficked. Second, the travel in which Defendants engaged from 2016 to June 2019 was entirely lawful, and thus expressly exempt from the Act’s definition of “trafficking,” because that travel was pursuant to and in compliance with a series of licenses and authorizations issued by the United States Government, and Defendants’ alleged use of Pier 1 was “necessary” to the conduct of “such” lawful travel. Third, Plaintiff does not have statutory standing to bring a Title III claim as its principal place of business is not in the United States as required under the Act. Fourth, Title III as Plaintiff would have this Court apply it violates the United States Constitution in numerous ways. Because the material facts concerning these issues are not in dispute, and on those facts Defendants are entitled to judgment as a matter of law, this Motion should be granted."

LINK: Defendants’ Omnibus Motion For Summary Judgment (9/20/21)

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)

LINK: Norwegian Cruise Line Holdings Ltd.’s Individual Motion For Summary Judgment (9/20/21)

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)

LINK: Defendant’s Individual Motion For Summary Judgment (9/20/21)
LINK: Defendant’s Response In Opposition To Plaintiff’s Motion For Extension Of Time To Respond To Defendant’s Motion To Strike Jury Demand (9/3/21)

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)

LINK: MSC Cruises’ Individual Motion For Summary Judgment And Incorporated Memorandum Of Law (9/20/21)

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)

LINK: 870-Page Carnival Corporation’s Individual Motion For Summary Judgment (9/20/21)
LINK: Carnival Corporation’s Statement Of Material Facts Of Which There Is No Genuine Issue Of Dispute (9/20/21)
LINK: Carnival Corporation’s Motion To Preclude Plaintiff From Using Aphra Behn As A Witness (9/13/21)