About Emails: According To Plaintiff, Carnival Using "Myopic Application" To Contend Havana Docks Located United Kingdom, Not Kentucky. Carnival Registered Office In UK & Agent In Kentucky.

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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)

Excerpts: "With respect to Plaintiff’s nationality under § 6023(15)(B), Carnival acknowledges that Havana Docks was incorporated in Delaware in 1917 and has remained in good standing ever since. (See Def.’s Opposing Stmt. of Facts (ECF No. 367) at ¶¶ 1, 44-46.) But when it comes to Havana Docks’ principal place of business, Carnival argues it is not Lexington, Kentucky—the location from which Jerry Johnson (a corporate officer) manages its assets, receives and pays bills, sends and receives mail, holds annual meetings, and engages professionals to prepare its annual reports and tax returns. Instead, urging a myopic application of the diversity statute’s “nerve center” test, Carnival contends that Havana Docks’ principal place of business is in the United Kingdom, where its president—Mickael Behn—lives... To make this argument, Carnival relies on Ackert’s analysis of the geographic metadata embedded in 801 emails."

Ironically, the registered office for Carnival Corporation & plc is located in the United Kingdom and the Registrars for Carnival Corporation & plc are located in Kentucky...

From Carnival Corporation & plc 2020 Annual Report

Corporate Headquarters
Carnival Corporation Carnival Place 3655 N.W. 87th Avenue Miami, Florida 33178-2428 U.S.A. 305-599-2600

Registered Office
Carnival plc Carnival House 100 Harbour Parade Southampton S015 1ST UK 44 (0) 23 8065 5000

Registrars, Stock Transfer Agents and Dividend Reinvestment Plan Administrators
Carnival Corporation Computershare Investor Services
P.O. Box 505000 Louisville, Kentucky 40233-5000 U.S.A.

LINK: Plaintiff’s Partial Objection To Report And Recommendation On Plaintiff’s Motion To Exclude Opinion Of Julian Ackert (12/24/21)

LINK: Libertad Act Title II Lawsuit Filing Statistics