Royal Caribbean Cruises Libertad Act Lawsuit: Tens Of Thousands Of Documents Unsealed
/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)
Order Unsealing The Summary Judgement Record
Joint Motion For Enlargement Of Time To File Objections And Responses To Omnibus Report And Recommendation Regarding Daubert Motions (4/7/22)
Order On Motions For Reconsideration (4/6/22)
Reply In Support Of Defendants’ Expedited Motion To Remove Cases From Trial Calendar And Continue Remaining Pretrial Deadlines (4/5/22)
Libertad Act Lawsuit Filing Statistics
04/04/2022 262
ORDER Unsealing the Summary Judgment Record as to Royal Caribbean Cruises, LTD. Signed by Judge Beth Bloom on 4/1/2022. (pes) (Entered: 04/04/2022)
11/08/2021 206
Plaintiff Havana Docks Corporation's Reply in Support of its Individual Motion for Summary Judgment Against Royal Caribbean Cruises LTD. by Havana Docks Corporation. (Martinez, Roberto) Modified by unsealing documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 11/08/2021)
11/08/2021 205
Plaintiff's Reply to Defendant's Statement of Additional Facts in Support of Plaintiff's Individual Motion for Summary Judgment by Havana Docks Corporation. (Casey, Stephanie) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 11/08/2021)
11/08/2021 203
REPLY In Support Of Its Individual Motion For Summary Judgment by Royal Caribbean Cruises, LTD.. (Ponce, Scott) Modified by unsealing documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 11/08/2021)
11/08/2021 202
Reply To Plaintiff's Statement Of Additional Facts Relating To Defendant's Individual Motion For Summary Judgment by Royal Caribbean Cruises, LTD.. (Ponce, Scott) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 11/08/2021)
11/08/2021 201
Plaintiff's Reply to Defendants' Additional Facts by Havana Docks Corporation. (Casey, Stephanie) Modified by unsealing documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 11/08/2021)
11/08/2021 200
Reply Statement Of Material Facts To Plaintiff's Corrected Statement Of Material Facts In Support Of Its Response In Opposition To Defendants' Omnibus Motion For Summary Judgment by Royal Caribbean Cruises, LTD.. (Ponce, Scott) Modified by unsealing documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 11/08/2021)
11/08/2021 199
PLAINTIFF HAVANA DOCKS CORPORATION'S REPLY IN SUPPORT OF ITS OMNIBUS MOTION FOR PARTIAL SUMMARY JUDGMENT by Havana Docks Corporation. (Martinez, Roberto) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 11/08/2021)
11/08/2021 198
NOTICE by Havana Docks Corporation of Filing Exhibit in Support of its Reply to Defendants' Additional Facts (Attachments: # 1 Declaration of Jerry Johnson) (Casey, Stephanie) (Entered: 11/08/2021)
11/08/2021 197
Defendants' Reply ISO their Omnibus Motion for Summary Judgment by Royal Caribbean Cruises, LTD.. (Ponce, Scott) Modified by unsealing documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 11/08/2021)
11/03/2021 194
PLAINTIFF'S CORRECTED STATEMENT OF MATERIAL FACTS IN SUPPORT OF PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT'S INDIVIDUAL MOTION FOR SUMMARY JUDGMENT by Havana Docks Corporation. (Martinez, Roberto) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 11/03/2021)
10/22/2021 190
PLAINTIFF HAVANA DOCKS CORPORATION'S CORRECTED RESPONSE IN OPPOSITION TO DEFENDANTS' OMNIBUS MOTION FOR SUMMARY JUDGMENT by Havana Docks Corporation. (Martinez, Roberto) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 10/22/2021)
10/22/2021 189
PLAINTIFF'S CORRECTED STATEMENT OF MATERIAL FACTS IN SUPPORT OF PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT'S OMNIBUS MOTION FOR SUMMARY JUDGMENT by Havana Docks Corporation. (Martinez, Roberto) Modified by unsealing documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 10/22/2021)
10/18/2021 183
Plaintiff's Statement of Material Facts in Support of Plaintiff's Response in Opposition to Defendant's Individual Motion for Summary Judgment by Havana Docks Corporation. (Casey, Stephanie) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 10/18/2021)
10/18/2021 182
Plaintiff's Response in Opposition to Royal's Individual Motion for Summary Judgment by Havana Docks Corporation. (Casey, Stephanie) Modified docket text/terminated motion on 10/20/2021 (nc). Modified by unsealing documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 10/18/2021)
10/18/2021 180
Notice of Filing Exhibits Cited in Plaintiff's Opposition to Royal Caribbean Cruises, Ltd.'s Statement of Material Facts by Havana Docks Corporation. (Attachments: # 1 Havana Docks Corporations Third Amended Answer and Objections to Royal Caribbeans Fourth Set of Interrogatories, dated August 20, 2021, # 2 Transcript of the Deposition of Mickael Behn, taken in Havana Docks Corporation v. Royal Caribbean Cruises, Ltd., dated January 20, 2021 (CONFIDENTIAL), # 3 Havana Docks Corporations Answers and Objections to Royal Caribbeans Corrected Second Set of Request for Admissions, dated June 30, 2021, # 4 Silversea Production (RCL-Havana0231580-231640), # 5 Form 10-K Royal Caribbean Cruises Ltd., for the period ending December 31, 2018, # 6 Transcript of and Exhibits to the Deposition of Mickael Behn, taken in Havana Docks Corporation v. MSC Cruises, S.A., et al, dated December 18, 2020 (CONFIDENTIAL), # 7 Royal Caribbeans Response to Plaintiffs Second Set of Interrogatories, dated August 30, 2021) (Casey, Stephanie) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 10/18/2021)
10/18/2021 179
Plaintiff's Statement of Material Facts in Support of Plaintiff's Response in Opposition to Defendant's Omnibus Motion for Summary Judgment by Havana Docks Corporation. (Martinez, Roberto) Modified by unsealing documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 10/18/2021)
10/18/2021 178
Plaintiff Havana Docks Corporation's Response in Opposition to Defendants' Omnibus Motion for Summary Judgment by Havana Docks Corporation. (Martinez, Roberto) Modified docket/terminated motion on 10/20/2021 (nc). Modified by unsealing documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 10/18/2021)
10/18/2021 177
Defendants' Response in Opposition to Plaintiff's Omnibus Motion for Partial Summary Judgment by Royal Caribbean Cruises, LTD.. (Ponce, Scott) Modified by unsealing documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 10/18/2021)
10/18/2021 176
Defendants' Opposing Statement of Facts and Additional Undisputed Material Facts as to Which There is No Genuine Issue To Be Tried by Royal Caribbean Cruises, LTD.. (Attachments: # 1 Exhibit 125- Decrees & Translations, # 2 Exhibit 126 - Cuba Civil Code 1889, # 3 Exhibit 127 - Cuban mortgage law of 1893, # 4 Exhibit 128 - Regulations to Cuba Mortgage Law, # 5 Exhibit 129 - Cuba Notorial Code of 1929, # 6 Exhibit 130 - December 9, 2020 Jerry Johnson Deposition & Exs., # 7 Exhibit 131 - HDC023141, # 8 Exhibit 132 - Ju;ly 30, 2021 Tandy Bondi Deposition & Exs., # 9 Exhibit 133 - April 1, 2021 Jerry Johnson Deposition & Exs.) (Ponce, Scott) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 10/18/2021)
10/18/2021 173
Defendant's Response to Plaintiff's Individual Motion for Summary Judgment by Royal Caribbean Cruises, LTD.. (Ponce, Scott) Modified by unsealing documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 10/18/2021)
10/18/2021 172
Defendant's Response to Plaintiff's Statement of Facts Relating to its Individual Motion for Summary Judgment by Royal Caribbean Cruises, LTD.. (Attachments: # 1 Exhibit) (Ponce, Scott) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 10/18/2021)
10/18/2021 171
PLAINTIFF'S NOTICE OF FILING EXHIBITS IN SUPPORT OF IT'S STATEMENT OF MATERIAL FACTS IN RESPONSE IN OPPOSITION TO DEFENDANT'S OMNIBUS MOTION FOR SUMMARY JUDGMENT by Havana Docks Corporation. (Attachments: # 1 Exhibit Havana Docks Corporation Minutes of Special Directors Meeting, dated January 8, 1921 (HDC 004328-4332), # 2 Exhibit State of Delaware 1956 Annual Report for Havana Docks Corporation (HDC 008518-8519), # 3 Exhibit Carnival Corporations Response to Havana Docks Corporations First Request for Admissions, dated August 30, 2021, # 4 Exhibit Transcript of and Exhibits to the Deposition of Arnaldo Perez, taken in Havana Docks Corporation v. Carnival Corporation, dated October 23, 2020 (CONFIDENTIAL), # 5 Exhibit Consent in lieu of Stockholders Meeting of Havana Docks Corporation, dated August 1, 2018 (HDC 13044-13046), # 6 Exhibit State of Delaware 1957 Annual Report for Havana Docks Corporation (HDC 008516-8517), # 7 Exhibit Transcript of and Exhibits to the Deposition of Mickael Behn, taken in Havana Docks Corporation v. Carnival Corporation, dated November 30, 2020 (CONFIDENTIAL), # 8 Exhibit By-Laws of Havana Docks Corporation, adopted April 15, 1969 (HDC 005779-5802), # 9 Exhibit Consent in Lieu of Directors Meeting of Havana Docks Corporation, dated March 30, 2007 (HDC 013081), # 10 Exhibit Transcript of and Exhibits to the Deposition of Robert MacArthur, taken in Havana Docks Corporation v. Norwegian Cruise Line Holdings Ltd., dated April 8, 2021 (CONFIDENTIAL), # 11 Exhibit Cuban Assets Control Regulations (CACR) as of July 1, 1996, # 12 Exhibit Havana Docks Corporation Minutes of Annual Meeting of Annual Meeting of Stockholders, Dated April 29, 2008 (HDC 01390-1392 CONFIDENTIAL), # 13 Exhibit Consent in Lieu of Stockholders Meeting of Havana Docks Corporation, dated August 1, 2018 (HDC 014689-14691)) (Martinez, Roberto) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 10/18/2021)
09/21/2021 146
Defendant's Notice of Filing Certain Exhibits Under Seal in Support of Statement of Undisputed Material Facts as to Defendants' Omnibus Motion for Summary Judgment (PART 2 OF 2) by Royal Caribbean Cruises, LTD.. (Attachments: # 1 Exhibit 48, # 2 Exhibit 49-1, # 3 Exhibit 49-2, # 4 Exhibit 50, # 5 Exhibit 51, # 6 Exhibit 52, # 7 Exhibit 53, # 8 Exhibit 54, # 9 Exhibit 55, # 10 Exhibit 56, # 11 Exhibit 57, # 12 Exhibit 58, # 13 Exhibit 59, # 14 Exhibit 61, # 15 Exhibit 62, # 16 Exhibit 63, # 17 Exhibit 65, # 18 Exhibit 67, # 19 Exhibit 72, # 20 Exhibit 73, # 21 Exhibit 74, # 22 Exhibit 75, # 23 Exhibit 76, # 24 Exhibit 78, # 25 Exhibit 80, # 26 Exhibit 82-1, # 27 Exhibit 85, # 28 Exhibit 90, # 29 Exhibit 92, # 30 Exhibit 93-1, # 31 Exhibit 93-2, # 32 Exhibit 93-3, # 33 Exhibit 97, # 34 Exhibit 99, # 35 Exhibit 100, # 36 Exhibit 102, # 37 Exhibit 104, # 38 Exhibit 105, # 39 Exhibit 109, # 40 Exhibit 110, # 41 Exhibit 111, # 42 Exhibit 112, # 43 Exhibit 114, # 44 Exhibit 115, # 45 Exhibit 117, # 46 Exhibit 120, # 47 Exhibit 121, # 48 Exhibit 122, # 49 Exhibit 123, # 50 Exhibit 124, # 51 Exhibit 82-2) (Ponce, Scott) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 09/21/2021)
09/21/2021 145
Defendant's Notice of Filing Certain Exhibits Under Seal in Support of Statement of Undisputed Material Facts as to Defendants' Omnibus Motion for Summary Judgment (PART 1 OF 2) by Royal Caribbean Cruises, LTD.. (Attachments: # 1 Exhibit Statement of Undisputed Material Facts, # 2 Exhibit 1, # 3 Exhibit 1-1, # 4 Exhibit 1-2, # 5 Exhibit 1-3, # 6 Exhibit 1-4, # 7 Exhibit 1-5, # 8 Exhibit 1-6, # 9 Exhibit 1-7, # 10 Exhibit 1-8, # 11 Exhibit 1-9, # 12 Exhibit 1-10, # 13 Exhibit 14, # 14 Exhibit 15, # 15 Exhibit 16-1, # 16 Exhibit 16-2, # 17 Exhibit 16-3, # 18 Exhibit 16-4, # 19 Exhibit 16-5, # 20 Exhibit 17, # 21 Exhibit 18, # 22 Exhibit 20, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26-1, # 27 Exhibit 26-2, # 28 Exhibit 26-3, # 29 Exhibit 28-1, # 30 Exhibit 28-2, # 31 Exhibit 28-3, # 32 Exhibit 29, # 33 Exhibit 30-1, # 34 Exhibit 30-2, # 35 Exhibit 30-3, # 36 Exhibit 32, # 37 Exhibit 32, # 38 Exhibit 33, # 39 Exhibit 34, # 40 Exhibit 35, # 41 Exhibit 36, # 42 Exhibit 37, # 43 Exhibit 38, # 44 Exhibit 39, # 45 Exhibit 40, # 46 Exhibit 41, # 47 Exhibit 42, # 48 Exhibit 43, # 49 Exhibit 44, # 50 Exhibit 46, # 51 Exhibit 47) (Ponce, Scott) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 09/21/2021)
09/20/2021 144
Havana Docks Corporation's Omnibus Statement of Material Facts in Support of its Omnibus Motion for Summary Judgment by Havana Docks Corporation. (Casey, Stephanie) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 09/20/2021)
09/20/2021 143
Plaintiff Havana Docks Corporation's Omnibus Motion for Partial Summary Judgment by Havana Docks Corporation. (Casey, Stephanie) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 09/20/2021)
09/20/2021 142
Plaintiff Havana Docks Corporation's Individual Motion for Summary Judgment Against Royal Caribbean Cruises LTD by Havana Docks Corporation. (Casey, Stephanie) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 09/20/2021)
09/20/2021 141
Plaintiff Havana Docks Corporation's Statement of Material Facts in Support of its Individual Motion for Summary Judgment Against Royal Caribbean Cruises LTD by Havana Docks Corporation. (Casey, Stephanie) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 09/20/2021)
09/20/2021 140
Statement of: Statement of Undisputed Material Facts by Royal Caribbean Cruises, LTD. re 137 Defendant's MOTION for Summary Judgment (Omnibus) (Attachments: # 1 Exhibit 2, # 2 Exhibit 3, # 3 Exhibit 4, # 4 Exhibit 5, # 5 Exhibit 6, # 6 Exhibit 7, # 7 Exhibit 8, # 8 Exhibit 9, # 9 Exhibit 10, # 10 Exhibit 11, # 11 Exhibit 12, # 12 Exhibit 13, # 13 Exhibit 19, # 14 Exhibit 21, # 15 Exhibit 22, # 16 Exhibit 27, # 17 Exhibit 45, # 18 Exhibit 60, # 19 Exhibit 64, # 20 Exhibit 66, # 21 Exhibit 68, # 22 Exhibit 69, # 23 Exhibit 70, # 24 Exhibit 71, # 25 Exhibit 77, # 26 Exhibit 79, # 27 Exhibit 81, # 28 Exhibit 83, # 29 Exhibit 84, # 30 Exhibit 86, # 31 Exhibit 87, # 32 Exhibit 88, # 33 Exhibit 89, # 34 Exhibit 91, # 35 Exhibit 94, # 36 Exhibit 95, # 37 Exhibit 96, # 38 Exhibit 98, # 39 Exhibit 101, # 40 Exhibit 103, # 41 Exhibit 106, # 42 Exhibit 107, # 43 Exhibit 108, # 44 Exhibit 113, # 45 Exhibit 116, # 46 Exhibit 118, # 47 Exhibit 119, # 48 Exhibit 123, # 49 Exhibit 124)(Ponce, Scott) (Entered: 09/20/2021)
09/20/2021 139
Notice of Filing 62-63 Cited in Plaintiff's Statement of Material Facts in Support of Omnibus Motion for Summary Judgment Against Defendants by Havana Docks Corporation. (Attachments: # 1 Havana Docks Corporations Second Amended and Supplemental Answer and Objections to Defendants Third Set of Interrogatories dated July 30, 2021, # 2 Havana Docks Corporations Answers and Objections to the First Request for Admissions Served by Defendant dated March 19, 2021) (Casey, Stephanie) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 09/20/2021)
09/20/2021 135
Notice of Filing Certain Exhibits Under Seal in Support of its Individual Statement of Undisputed Material Facts by Royal Caribbean Cruises, LTD.. (Attachments: # 1 Exhibit 1 - (Part 1 of 2) Deposition of Jerry Johnson, # 2 Exhibit 1 - (Part 2 of 2) Deposition of Jerry Johnson, # 3 Exhibit 3 - (Part 1 of 2) Deposition of Jorge Delgado, # 4 Exhibit 3 - (Part 2 of 2) Deposition of Jorge Delgado, # 5 Exhibit 11 - Deposition of Chris Allen, # 6 Exhibit 12 - (Part 1 of 2) Deposition of Bradley Stein, # 7 Exhibit 12 - (Part 2 of 2) Deposition of Bradley Stein, # 8 Exhibit 13 - Deposition of Adam Goldstein, # 9 Exhibit 15 - Expert Report of Ambar Diaz, # 10 Exhibit 16 - Composite Aries Contracts, # 11 Exhibit 29 - Deposition of Deanna Kim, # 12 Exhibit 40 - (Part 1 of 2) Deposition of Maria Shaw, # 13 Exhibit 40 - (Part 2 of 2) Deposition of Maria Shaw) (Ponce, Scott) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 09/20/2021)
09/20/2021 134
Notice of Filing Exhibits 60-61 Cited in Plaintiff's Statement of Material Facts in Support of Omnibus Motion for Summary Judgment Against Defendants by Havana Docks Corporation. (Attachments: # 1 January 23, 2019 Email re Update on Cuba Title III (NCL_23591-00110447-110448), # 2 January 24, 2019 Email re Confidential & Privileged Title III Suspension (NCLH_23591-0578134-578136 CONFIDENTIAL)) (Casey, Stephanie) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 09/20/2021)
09/20/2021 133
Statement of: Individual Statement of Undisputed Material Facts as to Which There is No Genuine Issue to be Tried by Royal Caribbean Cruises, LTD. re 132 Defendant's MOTION for Summary Judgment (Individual) (Attachments: # 1 Exhibit 1 - To Be Filed Under Seal, # 2 Exhibit 2 - HDC 001855-1858, # 3 Exhibit 3 - To Be Filed Under Seal, # 4 Exhibit 4 - RCL-Havana0000417-18, # 5 Exhibit 5 (Part 1 of 2) RCL-Havana0000419-634, # 6 Exhibit 5 (Part 2 of 2) RCL-Havana0000419-634, # 7 Exhibit 6 - RCL-Havana0000635-768, # 8 Exhibit 7 - RCL-Havana0000803-804, # 9 Exhibit 8 - RCL-Havana0000769, # 10 Exhibit 9 - 2020-05-29 RCL_s Responses to HDC_s 1st Interrogatories, # 11 Exhibit 10 - RCL-0001021, # 12 Exhibit 11 - To Be Filed Under Seal, # 13 Exhibit 12 - To Be Filed Under Seal, # 14 Exhibit 13 - To Be Filed Under Seal, # 15 Exhibit 14 - RCL-Havana0078270-78273, # 16 Exhibit 15 - To Be Filed Under Seal, # 17 Exhibit 16 - To Be Filed Under Seal, # 18 Exhibit 17 - RCL-Havana0011532-565, # 19 Exhibit 18 - RCL-Havana0080835-80868, # 20 Exhibit 19 - RCL-Havana0080798-830, # 21 Exhibit 20 - RCL-Havana00202129-62, # 22 Exhibit 21 - RCL-Havana0033335-37, # 23 Exhibit 22 - HDC014348-14350, # 24 Exhibit 23 - RCL-Havana0186076-084, # 25 Exhibit 24 - RCL-Havana0186094-102, # 26 Exhibit 25 - RCL-Havana0186103-111, # 27 Exhibit 26 - RCL-Havana0186085-093, # 28 Exhibit 27 - HDC001498-1503, # 29 Exhibit 28 - HDC 016084-16095, # 30 Exhibit 29 - To Be Filed Under Seal, # 31 Exhibit 30 - HDC 001013-1014, # 32 Exhibit 31 - HDC000083-85, # 33 Exhibit 32 - HDC 001328-30, # 34 Exhibit 33 - RCL-Havana0000062-68, # 35 Exhibit 34 - Maggie Levay Declaration, # 36 Exhibit 35 - Declaration of Maria Mattson, # 37 Exhibit 36 - RCL-Havana0000259-264, # 38 Exhibit 37 - RCL-Havana0000772-802, # 39 Exhibit 38 - (Part 1 of 2) Jessica Topow Declaration, # 40 Exhibit 38 - (Part 2 of 2) Jessica Topow Declaration, # 41 Exhibit 39 - RCL-Havana0000071-75, # 42 Exhibit 40 - To Be Filed Under Seal, # 43 Exhibit 41 - Declaration of Maria Shaw, # 44 Exhibit 42 - RCL-Havana0000256-258, # 45 Exhibit 43 - RCL-Havana0000770-71, # 46 Exhibit 44 - 2021-08-30 RCCL's Responses to HDC's 2nd Set of Interrogatories, # 47 Exhibit 45 - Declaration of Christopher Allen, # 48 Exhibit 46 - HDC 018289, # 49 Exhibit 47 - HDC015207, # 50 Exhibit 48 - Declaration of Meaghan Gies)(Ponce, Scott) (Entered: 09/20/2021)
09/20/2021 131
NOTICE OF FILING EXHIBITS NOS. 136-180 CITED IN Plaintiff's Statement of Material Facts in Support of Individual Motion fo Summary Judgment Against Royal Caribbean Cruises Ltd by Havana Docks Corporation. (Attachments: # 1 Exhibit Royal Caribbean Cruises Ltd. Answers to Plaintiffs First Set of Interrogatories dated May 29, 2020, # 2 Exhibit Royal Caribbean Cruises Ltd. Supplemental Answer to #6 of Plaintiffs First Set of Interrogatories dated August 18, 2020, # 3 Exhibit Royal Caribbean Cruises Ltd. Response to Plaintiffs First Request for Admissions dated August 2, 2021 (ATTORNEYS EYES ONLY), # 4 Exhibit Royal Caribbean Cruises Ltd. Response to Plaintiffs First Request for Admissions dated August 30, 2021 (ATTORNEYS EYES ONLY), # 5 Exhibit Royal Caribbean Cruises Ltd. Responses to Plaintiffs Corrected Request for Admissions dated September 7, 2021 (ATTORNEYS EYES ONLY), # 6 Exhibit Transcript of and Exhibits to the Deposition of Rosa Maria Caballero Stafford taken in Havana Docks Corporation v Carnival Corporation, 19-cv-21724 (S.D. Fla.), dated March 3, 2021 (CONFIDENTIAL), # 7 Exhibit Transcript of and Exhibits to the Deposition of Christopher Martin taken in Havana Docks Corporation v Carnival Corporation, 19-cv-21724 (S.D. Fla.), dated July 22, 2021 (CONFIDENTIAL), # 8 Exhibit Transcript of and Exhibits to the Deposition of Arnaldo Perez taken in Havana Docks Corporation v Carnival Corporation, 19-cv-21724, (S.D. Fla.), dated April 27, 2021 (CONFIDENTIAL, # 9 Exhibit February 13, 2019 Email re Havana Meetings First Draft (HavanaDocks_0484030-484034 CONFIDENTIAL), # 10 Exhibit Excel spreadsheet containing itineraries and passenger numbers (Pablo Spiller Report Exhibit PS-123) (CONFIDENTIAL/ATTORNEYS EYES ONLY), # 11 Exhibit October 16, 2016 Email re Cuban Agents Conflict sheet and Spreadsheet Temporada 2016-2017 (certified translation and original) (HavanaDocks_0397709-397711), # 12 Exhibit July 16, 2018 Article: Miami billboards accuse cruise ships that sail to Cuba of dealing in confiscated property (HDC 001416-1421), # 13 Exhibit Photograph of Billboard (HDC 001481), # 14 Exhibit Photographs of Protesters at the entry to the Port of Miami (HDC 001491-1492), # 15 Exhibit June 24, 2018 Email re Cruise ship CEOs (HDC 016334-16336), # 16 Exhibit August 10, 2021 Declaration of Duncan Hall (Internet Archive re Wayback Machine) (HDC 022628-022647), # 17 Exhibit MSC Cruises Responses to Plaintiffs First Request for Admissions to Defendants dated August 30, 2021, # 18 Exhibit June 15, 2015 Email re Meeting Cuba (certified translation and original) (MSCCUSA0000077313-77350 CONFIDENTIAL), # 19 Exhibit June 9, 2015 Email re Letter from Mr. Pierfrancesco Vago (certified translation and original) (MSCCUSA0000077298-77301 CONFIDENTIAL), # 20 Exhibit Spreadsheet Temporada 2016-2017 (in Spanish), # 21 Exhibit Transcript of and Exhibits to the Deposition of Massimiliano Mio in his capacity as Defendants Rule 30(b)(6) Corporate Representative, taken in Havana Docks Corporation v MSC Cruise, SA, et al, dated April 29, 2021, # 22 Exhibit Transcript of and Exhibits to the Deposition of Giovanni Onorato taken in Havana Docks Corporation v MSC Cruise, SA, et al, dated, # 23 Exhibit Transcript of and Exhibits to the Deposition of Gianluca Suprani taken in Havana Docks Corporation v MSC Cruises, SA et al, dated April 20, 2021., # 24 Exhibit March 4, 2019 03-04-19 Email re Seven Seas Voyager upcoming call to Havana on 06th March 2019; 48 hrs. NOA (certified translation and original) (NCLH_23591-00049220-49222, # 25 Exhibit January 17, 2019 Email re US considering allowing lawsuits over Cuba-confiscated properties (NCLH_23591-00111731-111739), # 26 Exhibit January 6, 2019 Email re Suspension Under Title III, # 27 Exhibit Transcript of and Exhibits to the Deposition of Hugo Cancio in his capacity as Norwegian Cruise Line Holdings Rule 30(b)(6) designee, taken in Havana Docks Corporation v. Norwegian Cruise Line Holdings, dated November 12, 2020 CONFIDENTIAL, # 28 Exhibit Transcript of and Exhibits to the Deposition of Mario Parodi in his capacity as Norwegian Cruise Line Holdings Rule 30(b)(6) designee, taken in Havana Docks Corporation v. Norwegian Cruise Line Holdings, dated November 5, 2020 CONFIDENTIAL V1, # 29 Exhibit Transcript of and Exhibits to the Deposition of Mario Parodi in his capacity as Norwegian Cruise Line Holdings Rule 30(b)(6) designee, taken in Havana Docks Corporation v. Norwegian Cruise Line Holdings, dated November 5, 2020 CONFIDENTIAL V2, # 30 Exhibit August 21, 2018 Email re Berth Request for Riviera (NCLH_23591-00005908-11), # 31 Exhibit Transcript of and Exhibits to the Deposition of Nicolai Skogland in his capacity as Vikings Rule 30(b)(6) designee taken in Havana Docks Corporation v. Norwegian Cruise Line Holdings, dated February 2, 2021, # 32 Exhibit Royal Caribbean Cruises Ltd Form 8-K, dated June 7, 2019, # 33 Exhibit Royal Caribbean Cruises Ltd Form 10-K for the fiscal year ended December 31, 2019, # 34 Exhibit June 1, 2021 Declaration of Yamilet Hurtado, # 35 Exhibit February 11, 2019 Margol Notice letter to Royal Caribbean Cruise Lines (RCL-Havana0000062-68), # 36 Exhibit June 4, 2019 Cautionary Letter to Royal Caribbean Cruises Ltd from Department of Treasury (RCL-Havana0000071-75), # 37 Exhibit Empress of the Seas Table of Contents and documents (RCL-Havana0000076-255), # 38 Exhibit Azamara Quest Table of Contents and documents (RCL-Havana0000265-411), # 39 Exhibit October 26, 2018 Letter to OFAC from Wilmer Hale re Administrative Subpoena (RCL-Havana0000772-802), # 40 Exhibit Payments to Aries, SA (RCL-Havana0001026-1032 CONFIDENTIAL), # 41 Exhibit January 31, 2018 Service Contract between Havanatur and Royal Caribbean Cruises (certified translation and original) RCL-Havana0011629-11670 CONFIDENTIAL), # 42 Exhibit January 12, 2015 Email re SCM Draft (RCL-Havana0011860-11892 CONFIDENTIAL), # 43 Exhibit Document titled Annex 4- Excursion Catalog, annex to Service Contract between Havanatur and Royal Caribbean Cruises (certified translation and original) (RCL-Havana0030487-30517 CONFIDENTIAL), # 44 Exhibit September 7, 2017 Email re Meeting in Havana (RCL-Havana0034267-34268 CONFIDENTIAL), # 45 Exhibit November 25, 2016 Email re Cuba Update (RCL-Havana0041038-0041040 CONFIDENTIAL), # 46 Exhibit November 3, 2017 Email re Empress Habana Sur May 208 Mar 2019 (in Spanish) (RCL-Havana0044939 CONFIDENTIAL)) (Casey, Stephanie) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 09/20/2021)
09/20/2021 128
Notice of Filing Exhibits 181-209 Cited in Plaintiff's Statement of Material Facts in Support of Individual Motion for Summary Judgment Against Royal Caribbean Cruises LTD. by Havana Docks Corporation. (Attachments: # 1 Exhibit November 3, 2017 Email re Empress. Urgente, pleaseee (in Spanish) (RCL-Havana0044942 CONFIDENTIAL), # 2 Exhibit February 3, 2017 Email re Another reason to believe Cuba high-prices, and a strong demand, is in for at least the next decade; unless there is a twit (RCL-Havana0048443-48444 CONFIDENTIAL), # 3 Exhibit April 17, 2019 Email re Title III Update (RCL-Havana0058131-58133 CONFIDENTIAL), # 4 Exhibit February 8, 2019 Draft Memo to Jason Liberty re Cuba Update RCL-(Havana0058212-58221 CONFIDENTIAL), # 5 Exhibit February 8, 2019 Draft Memo to Jason Liberty re Cuba Update (RCL-Havana0058787-58796 CONFIDENTIAL), # 6 Exhibit January 3, 2015 Email re Name the 11 Cuban ports (RCL-Havana0065349-65354 CONFIDENTIAL), # 7 Exhibit Update on Potential Cruise Opportunities with Cuba (RCL-Havana0066790-66792 CONFIDENTIAL), # 8 Exhibit January 5, 2015 Email re Cuba Update CSA edit 1-5-15.doc (RCL-Havana0066771-66774 CONFIDENTIAL), # 9 Exhibit July 16, 2018 Email re Google Alert cuba cruises (RCL-Havana0108271 CONFIDENTIAL), # 10 Exhibit June 25, 2018 Email re Google Alert cuba cruises (RCL-Havana0108872 CONFIDENTIAL), # 11 Exhibit July 7, 2015 Email re Carnival to Cuba (RCL-Havana0145495-145497 CONFIDENTIAL), # 12 Exhibit Azamara Guest Ticket Booklet (RCL-Havana0146809-146824 CONFIDENTIAL), # 13 Exhibit November 9, 2018 Email re Cuba: Trump administration tightens sanctions, may allow US lawsuits (RCL-Havana0153675-153677 CONFIDENTIAL), # 14 Exhibit February 3, 2019 Email re Havana Berth Schedule (RCL-Havana0157545157546 CONFIDENTIAL), # 15 Exhibit June 1, 2018 Email re Empress calls June (RCL-Havana0170124-170129 CONFIDENTIAL), # 16 Exhibit May 16, 2016 Email re Cuba Update (RCL-Havana0189306-189308 CONFIDENTIAL), # 17 Exhibit Service Contract No. 8/2017 between Aries S.A. and Royal Caribbean Cruises Ltd (certified translation and original) (RCL-Havana0219032-219058 CONFIDENTIAL), # 18 Exhibit November 2, 2017 Email re meeting in Aries (certified translation and original) (RCL-Havana0223077-22307 CONFIDENTIAL), # 19 Exhibit November 2, 2017 Email re meeting in Aries (certified translation and original) (RCL-Havana0223080-23081 CONFIDENTIAL), # 20 Exhibit Agency Agreement No. 13/16 between Empresa Consignataria Mambisa and Royal Caribbean Cruises Ltd (certified translation and original) (RCL-Havana0224083-224099 CONFIDENTIAL), # 21 Exhibit December 7, 2016 Service Agreement (Cruise Ships) between Havanatur and Royal Caribbean Cruises (certified translation and original) (RCL-Havana0229550-229576 CONFIDENTIAL), # 22 Exhibit August 4, 2021 Declaration of Bradley M. Rose, # 23 Exhibit August 30, 2021 Declaration of Bradley M. Rose in Response to Subpoena and Production of Documents, # 24 Exhibit Web article: CLIA Appoints Goldstein as Global Chair, # 25 Exhibit Web article: Thinking Big, # 26 Exhibit Web article: SeaTrade Caribbean stronger, Europe weaker than forecast, # 27 Exhibit Carnival Corporations Response to Plaintiffs Second Request for Admissions, dated September 7, 2021, # 28 Exhibit PLF Deposition Exhibit 86 (Havana Docks Corporation v MSC) May 13, 2015 Email re MSC Opera Report on the Havana Harbor (certified translation with original) (MSCCUSA0000077416-77421 CONFIDENTIAL), # 29 Exhibit Spreadsheet: MSC Cruises Cover Itinerary released on Thu, May 12, 2016, 12:53 (MSC0000049805 CONFIDENTIAL)) (Casey, Stephanie) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 09/20/2021)
09/19/2021 126
Notice of Filing Exhibits Cited in Plaintiff's Statement of Material Facts in Support of Omnibus Motion for Summary Judgment Against Defendants by Havana Docks Corporation. (Attachments: # 1 Exhibit Transcript of and Exhibits to the Deposition of Jerry Johnson in his capacity as Plaintiffs Rule 30(b)(6) designee in Havana Docks Corporation v. Carnival Corporation, dated November 24, 2020, # 2 Exhibit Transcript of and Exhibits to the Deposition of Jerry Johnson in his capacity as Plaintiffs Rule 30(b)(6) designee in Havana Docks Corporation v. MSC, dated December 15, 2020, # 3 Exhibit January 15, 2021 Declaration of Jerry Johnson in Havana Docks Corporation v Norwegian Cruise Line Holdings, # 4 Exhibit Transcript of and Exhibits to the Deposition of Michael Micky Meir Arison in Havana Docks Corporation v Carnival Corporation, dated May 4, 2021, # 5 Exhibit July 9, 2018 Document titled Evaluation of the possibilities of Nipe Bay for developing a Cruise Port for Modern Cruise Ships (HavanaDocks 396222-227 CONFIDENTIAL), # 6 Exhibit April 17, 2019 Email re Cuba announcement with new restrictions and sanctions (HavanaDocks 475791 CONFIDENTIAL), # 7 Exhibit April 17, 2019 Email re Cuba (HavanaDocks 388212 CONFIDENTIAL), # 8 Exhibit February 22, 2019 Letter to the Honorable Michael R. Pompeo (NCLH_23591 00111666-667), # 9 Exhibit March 19, 1911 Decree No. 184 (certified translation and original), # 10 Exhibit Form 666 submitted to Foreign Claims Settlement Commission (FCSC 00272-275) (HDC 001861-1864), # 11 Exhibit November 1 to November 13, 1060 Havana Docks Corporation Summary of Operations (HDC 002455), # 12 Exhibit June 29, 1921 Lease between Port of Havana Docks Company and United Fruit Company (HDC 004343-4357 CONFIDENTIAL), # 13 Exhibit July 1, 1921 Four Party Agreement between Havana Docks Company, Porto f Havana Docks Company, United Fruit Company and Old Colony Trust Company (HDC 004358- 4361 CONFIDENTIAL), # 14 Exhibit July 1, 1921 Old Colony Trust Company Principal Indenture (HDC 004362-4377 CONFIDENTIAL), # 15 Exhibit February 16, 1922 Havana Docks Corporation Directors Meeting Minutes (HDC 004398-4402 CONFIDENTIAL), # 16 Exhibit November 22, 1960 Havana Docks Corporation Directors Meeting Minutes (HDC 005303-5306), # 17 Exhibit July 1, 1921 Old Colony Trust Indenture (HDC 008953-8981 CONFIDENTIAL), # 18 Exhibit June 1, 1946 The National City Bank of New York Indenture (HDC 008982-9050 CONFIDENTIAL), # 19 Exhibit February 20, 1922 Turner Construction Contract (HDC 009186-9208 CONFIDENTIAL), # 20 Exhibit 1960 Budget (HDC 009210-9211 CONFIDENTIAL), # 21 Exhibit May 14, 1918 The Port of Havana Docks Company Meeting Minutes (HDC 010032-10041 CONFIDENTIAL), # 22 Exhibit November 11, 1910 Decree No. 1022 (HDC 011123-11135), # 23 Exhibit August 14, 1925 Old Colony Supplement Indenture (HDC 012563-12570), # 24 Exhibit March 9, 1928 Port of Havana Docks Special Directors Meeting Minutes (HDC 012636 CONFIDENTIAL), # 25 Exhibit Terms of Farmers Loan & Trust Company Indenture (HDC 01266612667 CONFIDENTIAL), # 26 Exhibit 2010 Havana Docks Corporation Annual Report (HDC 013175-13177 CONFIDENTIAL), # 27 Exhibit August 14, 1917 Articles of Incorporation of Havana Docks Corporation with certificate from Delaware Secretary of State (HDC 018013-018026), # 28 Exhibit 2019 Corporate Income Tax Return of Havana Docks Corporation (HDC 018874-18893), # 29 Exhibit 2021 Certificate of Good Standing from Delaware Secretary of State (HDC 021747-21749), # 30 Exhibit September 13, 1918 Havana Docks Directors Meeting Minutes (HDC 022587-022596), # 31 Exhibit May 14, 1919 Havana Docks Directors Meeting Minutes (HDC 022597-022627 CONFIDENTIAL), # 32 Exhibit August 10, 2021 Declaration of Duncan Hall (Custodian of Records for the Internet Archives Wayback Machine) (HDC 022628-22647), # 33 Exhibit August 24, 2021 Havana Docks Directors Meeting Minutes (HDC 023107-23108), # 34 Exhibit August 24, 2021 Havana Docks Stockholder Meeting Minutes (HDC 023109-23110), # 35 Exhibit Composite Exhibit: Analyses of Pier Operations and Auxiliary Operations Revenue, # 36 Exhibit Composite Exhibit: Havana Docks Pre-Confiscation Financial Reports, # 37 Exhibit Composite Exhibit: Havana Docks Post-Certified Claim Financial Reports, # 38 Exhibit Composite Exhibit: Havana Docks Corporation Tax Returns, # 39 Exhibit Map of Proposed Piers (MSC0000000172), # 40 Exhibit August 4, 2021 Declaration of Bradley M. Rose, # 41 Exhibit August 30, 2021 Declaration of Bradley M. Rose in Response to Subpoena and Production of Documents, with exhibits, # 42 Exhibit July 16, 1996 William J. Clinton, Statement of Action on Title III of the Cuban Liberty and Democratic Solidarity (LIBERTAD) Act of 1995, # 43 Exhibit June 20, 2018 Hearing of the Subcommittee of National Security of the House of Representatives Committee on Oversight and Government Reform, Holding Cuban Leaders Accountable, Report No. 115-87, # 44 Exhibit November 1, 2018 Miami Herald Article re National Security Advisor Ambassador John R. Bolton delivered Remarks on the Trump Administrations Policies in Latin America at Miami-Dade College, # 45 Exhibit January 16, 2019 State Department Announcement re: Suspension of Title III right-of-action for 45 days, # 46 Exhibit February 5, 2019 Email re Confidential and Legally Privileged Title III Suspension Language (NCLH_23591-00577934-577936 CONFIDENTIAL), # 47 Exhibit February 11, 2019 Letter to Carnival Corporation (Arison) from Rodney S. Margol, Esq. (HDC 018654-18655), # 48 Exhibit February 11, 2019 Letter to Carnival Corporation (Perez) from Rodney S. Margol, Esq. (HDC 018650-18651), # 49 Exhibit February 11, 2019 Letter to MSC from Rodney S. Margol, Esq. (HDC 018658-18659), # 50 Exhibit February 11, 2019 Letter to Frank Del Rio, Norwegian Cruise Lines Holdings, Ltd. from Rodney S. Margol, Esq. (HDC 01554-1555), # 51 Exhibit February 11, 2019 Letter to Royal Caribbean International from Rodney S. Margol, Esq. (HDC 01550-1551), # 52 Exhibit February 11, 2019 Letter to Royal Caribbean Cruise Lines from Rodney S. Margol, Esq., # 53 Exhibit March 4, 2019 State Department Announcement re: Suspension of Title III right-of-action for an additional 30 days, # 54 Exhibit April 3, 2019 State Department Announcement re: Secretary Pompeo extends the Title III right-of-action suspension until May 1, 2019, # 55 Exhibit Embassy of Switzerland Certification, dated June 12, 1968 (HDC 001718-1720), # 56 Exhibit April 1, 2015 Video of Frank Del Rio Wharton Business School Interview (HDC-NCL000945), # 57 Exhibit Transcript of April 1, 2015 Video of Frank Del Rio Wharton Business School Interview, # 58 Exhibit Havana Docks Corporations Second Amended and Supplemental Answers and Objections to Carnival Corporations Third Set of Interrogatories, dated August 20, 2021, # 59 Exhibit Update on Potential Cruise Opportunities with Cuba (RCL-Havana0066790-66792 CONFIDENTIAL)) (Casey, Stephanie) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 09/19/2021)
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MOTION for Leave to File CRUISE LINES INTERNATIONAL ASSOCIATION'S MOTION FOR LEAVE TO FILE BRIEF AMICUS CURIAE IN SUPPORT OF DEFENDANTS MOTION FOR SUMMARY JUDGMENT by Cruise Lines International Association. (Attachments: # 1 Exhibit CLIA Amicus Brief, # 2 Text of Proposed Order)(Friedman, Darren) (Entered: 09/17/2021)
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Notice of Filing Exhibits 101-135 Cited in Plaintiff's Statement of Material Facts in Support of Individual Motion for Summary Judgment Against Royal Caribbean Cruises LTD. by Havana Docks Corporation. (Attachments: # 1 PLF Deposition Exhibit 92 (Rand): December 18, 2014 Email re U.S. seeks to normalize relations with Cuba (RCL-Havana0066678-690 CONFIDENTIAL), # 2 PLF Deposition Exhibit 93 (Rand): March 11, 2018 Email re Very Urgent Feedback needed - Majesty Cuba 2019 (RCL-Havana0025181-184 CONFIDENTIAL), # 3 PLF Deposition Exhibit 94 (Rand): October 11, 2017 Email re Royal Presentation (RCL-Havana0150859-885 CONFIDENTIAL), # 4 PLF Deposition Exhibit 95 (Rand): Spreadsheet of Royal sailings to Cuba (RCL-Havana0001021 CONFIDENTIAL), # 5 PLF Deposition Exhibit 96 (Rand): July 25, 2018 Email re NE redeployment comparison, with attachment (RCL-Havana0150150 CONFIDENTIAL), # 6 PLF Deposition Exhibit 97 (Rand): June 2, 2017 Email re Royal deployment strategy 6-2-17 PPT (RCL-Havana0152299-321 CONFIDENTIAL), # 7 PLF Deposition Exhibit 98 (Rand): June 22, 2018 Email re Cuba (RCL-Havana0150223-225 CONFIDENTIAL), # 8 PLF Deposition Exhibit 92 (Goldstein): October 2, 2003 Email re U.S.- Cuba Travel conference (RCL-Havana 0055406 CONFIDENTIAL), # 9 PLF Deposition Exhibit 93 (Goldstein): January 22, 2007 Email re Comments besides Cuba (RCL-Havana 0055089-092 CONFIDENTIAL), # 10 PLF Deposition Exhibit 94 (Goldstein): Photograph of Havana Port Terminal (HDC001981), # 11 PLF Deposition Exhibit 95 (Goldstein): February 9, 2007 Email re House Legislation to allow travel between the United States and Cuba (RCL-Havana 0055085-086 CONFIDENTIAL), # 12 PLF Deposition Exhibit 96 (Goldstein): December 19, 2014 Email re Competitive deployment in Cuba (RCL-Havana066438-473 CONFIDENTIAL, # 13 PLF Deposition Exhibit 97 (Goldstein): January 3, 2015 Email re Cuba Potential Ports of call (RCL-Havana065349-354 CONFIDENTIAL), # 14 PLF Deposition Exhibit 98 (Goldstein): January 9, 2015 Email re Pullmanturs former expert on Cuba (RCL-Havana0053870 CONFIDENTIAL), # 15 PLF Deposition Exhibit 99: January 8, 2015 Email re Cuba Preliminary Deployment Strategy (RCL-Havana0011795-834 CONFIDENTIAL), # 16 PLF Deposition Exhibit 100: February 13, 2016 Email re Cuba Berthing Memo 2-12-2016 (RCL-Havana0066186-188 CONFIDENTIAL), # 17 PLF Deposition Exhibit 101: December 7, 2016 Email re RCL News release (RCL-Havana0041388-90 CONFIDENTIAL), # 18 PLF Deposition Exhibit 102: December 7, 2016 Email re Cuba Q&A (RCL-Havana0040885-87 CONFIDENTIAL), # 19 PLF Deposition Exhibit 103: December 9, 2016 Letter to Aries S.A. re Request to open office in Cuba (RCL-Havana0001009-1011), # 20 PLF Deposition Exhibit 104: December 20, 2016 Email re Cuba Letter (RCL-Havana0041636-37 CONFIDENTIAL), # 21 PLF Deposition Exhibit 105: March 23, 2017 Email re Painful (RCL-Havana0047683 CONFIDENTIAL), # 22 PLF Deposition Exhibit 106: April 24, 2017 Email re Gracias / Summary of first Cuba call (RCL-Havana037622-624 CONFIDENTIAL), # 23 PLF Deposition Exhibit 107: July 7, 2017 Four Letters re Cuba Policy (RCL-Havana186075-111 CONFIDENTIAL), # 24 PLF Deposition Exhibit 108 July 7, 2017 Email re Update-Cuba Letter (RCL-Havana187043-046 CONFIDENTIAL), # 25 PLF Deposition Exhibit 109: July 12, 2017 Email re Empress Azamara Majesty 2018 Mar 2019 (RCL-Havana0035991-995 CONFIDENTIAL), # 26 PLF Deposition Exhibit 110: March 1, 2018 Email re Very Urgent Feedback needed Majesty Cuba 2019 (RCL-Havana0030065-68 CONFIDENTIAL), # 27 PLF Deposition Exhibit 111: May 22, 2018 Email re Global Ports, Cuba, Sierra Maestra Terminal management contract (RCL-Havana22970 CONFIDENTIAL), # 28 PLF Deposition Exhibit 112: May 23, 2018 Email re Havana port announcement (RCL-Havana0023309-10 CONFIDENTIAL), # 29 PLF Deposition Exhibit 113: June 27, 2018 Email re Cuba Revenue Averages & Deposit Requirements (RCL-Havana186449-452 CONFIDENTIAL), # 30 PLF Deposition Exhibit 114: October 19, 2018 Email re Pier issue in Santiago de Cuba (RCL-Havana0027346-47 CONFIDENTIAL), # 31 PLF Deposition Exhibit 115: January 11, 2019 Email re Updates (RCL-Havana013870-72 CONFIDENTIAL), # 32 PLF Deposition Exhibit 116: January 17, 2019 Email re Cuba Updates (RCL-Havana13676 CONFIDENTIAL), # 33 PLF Deposition Exhibit 117: February 19, 2019 Email re Summary of Cuba Efforts in DC (RCL-Havana143621-624 CONFIDENTIAL), # 34 PLF Deposition Exhibit 118: March 2, 2019 Email re Cuba standby language (RCL-Havana0043897 CONFIDENTIAL), # 35 PLF Deposition Exhibit 119: 02-22-19 February 22, 2019 Letter to the Honorable Michael R. Pompeo re Title III of the Helms-Burton Act (NCLH_23591-00111666-667)) (Casey, Stephanie) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 09/17/2021)
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Notice of Filing Exhibits 51-100 Cited in Plaintiff's Statement of Material Facts in Support of Individual Motion for Summary Judgment Against Royal Caribbean Cruises LTD by Havana Docks Corporation. (Attachments: # 1 PLF Deposition Exhibit 42, # 2 PLF Deposition Exhibit 43, # 3 PLF Deposition Exhibit 44, # 4 PLF Deposition Exhibit 45, # 5 PLF Deposition Exhibit 46, # 6 PLF Deposition Exhibit 47, # 7 PLF Deposition Exhibit 48, # 8 PLF Deposition Exhibit 49, # 9 PLF Deposition Exhibit 50, # 10 PLF Deposition Exhibit 51, # 11 PLF Deposition Exhibit 52, # 12 PLF Deposition Exhibit 53, # 13 PLF Deposition Exhibit 54, # 14 PLF Deposition Exhibit 55, # 15 PLF Deposition Exhibit 56, # 16 PLF Deposition Exhibit 57, # 17 PLF Deposition Exhibit 58, # 18 PLF Deposition Exhibit 59, # 19 PLF Deposition Exhibit 60, # 20 PLF Deposition Exhibit 61, # 21 PLF Deposition Exhibit 62, # 22 PLF Deposition Exhibit 63, # 23 PLF Deposition Exhibit 64, # 24 PLF Deposition Exhibit 65, # 25 PLF Deposition Exhibit 66, # 26 PLF Deposition Exhibit 67, # 27 PLF Deposition Exhibit 68, # 28 PLF Deposition Exhibit 69, # 29 PLF Deposition Exhibit 70, # 30 PLF Deposition Exhibit 71, # 31 PLF Deposition Exhibit 72, # 32 PLF Deposition Exhibit 73, # 33 PLF Deposition Exhibit 74, # 34 PLF Deposition Exhibit 75, # 35 PLF Deposition Exhibit 76, # 36 PLF Deposition Exhibit 77, # 37 PLF Deposition Exhibit 78, # 38 PLF Deposition Exhibit 79, # 39 PLF Deposition Exhibit 80, # 40 PLF Deposition Exhibit 81, # 41 PLF Deposition Exhibit 82, # 42 PLF Deposition Exhibit 83, # 43 PLF Deposition Exhibit 84, # 44 PLF Deposition Exhibit 85, # 45 PLF Deposition Exhibit 86, # 46 PLF Deposition Exhibit 87, # 47 PLF Deposition Exhibit 88, # 48 PLF Deposition Exhibit 89, # 49 PLF Deposition Exhibit 90, # 50 PLF Deposition Exhibit 91) (Casey, Stephanie) Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 09/17/2021)
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NOTICE of Filing Exhibits 1-50 Cited In Plaintiff's Statement of Material Facts In Support of Individual Motion for Summary Judgment Against Royal Caribbean Cruises Ltd by Havana Docks Corporation. (Attachments: # 1 Deposition Christopher Allen, # 2 Deposition Bradley Stein, # 3 Deposition Yesenia Ortiz, # 4 Deposition Maria "Megan" Shaw, # 5 Deposition Eleni Kalisch, # 6 Deposition Jorge Delgado, # 7 Deposition Tyler Rand, # 8 Deposition Adam Goldstein, # 9 Exhibit PLF Deposition Exhibit 1: Plaintiffs Notice of Rule 30(b)(6) Deposition, # 10 Exhibit PLF Deposition Exhibit 1A: Plaintiffs Supplement to the Notice of Rule 30(b)(6) Deposition, # 11 Exhibit PLF Deposition Exhibit 2: Document prepared by Royal to assist in the Rule 30(b)(6) deposition, # 12 Exhibit PLF Deposition Exhibit 3: February 11, 2019 Letter to Royal Caribbean International from Rodney S. Margol, Esq. (HDC001550-51), # 13 Exhibit PLF Deposition Exhibit 4: February 11, 2019 Letter to Royal Caribbean Cruise Lines from Rodney S. Margol, Esq., # 14 Exhibit PLF Deposition Exhibit 5: July 17, 2015 OFAC license application (RCL Havana0000417-634 CONFIDENTIAL), # 15 Exhibit PLF Deposition Exhibit 6: August 1, 2015 Export license application (RCL Havana0000635-768 CONFIDENTIAL), # 16 Exhibit PLF Deposition Exhibit 7: September 23, 2015 Export License RWA Notice (RCL Havana0000803-804), # 17 Exhibit PLF Deposition Exhibit 8: October 7, 2015 Letter from Department of the Treasury re Vessel Carrier Services Application (RCL Havana0000769), # 18 Exhibit PLF Deposition Exhibit 9: January 19, 2017 OFAC License Application (RCL Havana0000412-416), # 19 Exhibit PLF Deposition Exhibit 10: Administrative Subpoena directed to Royal Caribbean Cruises Ltd., dated July 3, 2018 (RCL Havana0000259-264), # 20 Exhibit PLF Deposition Exhibit 11: July 6, 2018 Letter to OFAC re License for Non-US Travel to Cuba (RCL Havana0000256-258), # 21 Exhibit PLF Deposition Exhibit 12: License No. CU-2018-354788-1, dated August 1, 2018 (RCL Havana0000770-771), # 22 Exhibit PLF Deposition Exhibit 13: October 26, 2018 Letter response to Administrative Subpoena (RCL Havana0000772-802), # 23 Exhibit PLF Deposition Exhibit 14: June 4, 2019 Letter from Department of the Treasury re Cautionary letter to Royal Caribbean Cruises Ltd. (RCL Havana0000071-75), # 24 Exhibit PLF Deposition Exhibit 15: Photograph of Havana Port Terminal, # 25 Exhibit PLF Deposition Exhibit 16: Photograph of Pullmantur cruise ship at Havana Port Terminal, # 26 Exhibit PLF Deposition Exhibit 17: Photograph of Pullmantur cruise ship at Havana Port Terminal, # 27 Exhibit PLF Deposition Exhibit 18: Havana Docks Corporation Brochure (HDC001855-58), # 28 Exhibit PLF Deposition Exhibit 19: Photographs of Havana Port Terminal (HDC001981), # 29 Exhibit PLF Deposition Exhibit 20: Photograph of cigar shop at Havana Port Terminal (RCL Havana0011484), # 30 Exhibit PLF Deposition Exhibit 21: Photograph of RCL ship at the Havana Port Terminal (RCL Havana0011373), # 31 Exhibit PLF Deposition Exhibit 22: Photograph inside the Havana Port Terminal (RCL Havana0011476), # 32 Exhibit PLF Deposition Exhibit 23: Photographs of Royal cruise ships at the Havana Port Terminal, # 33 Exhibit PLF Deposition Exhibit 24: Re-Notice of Rule 30(b)(6) Deposition, # 34 Exhibit PLF Deposition Exhibit 25: Revenue Spreadsheet (RCL-Havana0218137 CONFIDENTIAL), # 35 Exhibit PLF Deposition Exhibit 26: March 7, 2017 Email re Mambisa (RCL-Havana0126192 CONFIDENTIAL), # 36 Exhibit PLF Deposition Exhibit 27: June 5, 2019 Email re Cuba Financial Impact Scenarios for 2019 (RCL-Havana0050059-63 CONFIDENTIAL), # 37 Exhibit PLF Deposition Exhibit 28: July 23, 2019 Email re Havantur overpayment (RCL-Havana0019456 CONFIDENTIAL), # 38 Exhibit PLF Deposition Exhibit 29: May 16, 2017 Email re operational manual (RCL-Havana0187227-262 CONFIDENTIAL), # 39 Exhibit PLF Deposition Exhibit 30: February 1, 2017 Email re Royal and Azamaras next visit to Cuba (RCL-Havana0126508-511 CONFIDENTIAL, # 40 Exhibit PLF Deposition Exhibit 31: March 23, 2017 Email re Cuba info (RCL-Havana0126002-005 CONFIDENTIAL, # 41 Exhibit PLF Deposition Exhibit 32: March 23, 2017 Email re: Cuba presentation (RCL-Havana0126038-044 CONFIDENTIAL), # 42 Exhibit PLF Deposition Exhibit 33: October 7, 2018 Email re Pre-Season Cuba Call with the Journey (RCL-Havana0229752-769 CONFIDENTIAL), # 43 Exhibit PLF Deposition Exhibit 34: October 23, 2018 Email re competitor cruise-NCL (RCL-Havana0098272-273 CONFIDENTIAL), # 44 Exhibit PLF Deposition Exhibit 35: November 22, 2018 Email re: OFAC Compliance Officer (RCL-Havana0027077-080 CONFIDENTIAL), # 45 Exhibit PLF Deposition Exhibit 36: Cuba Shore Excursions Operation Manual, dated December 31, 2017 (RCL-Havana0000003-23), # 46 Exhibit PLF Deposition Exhibit 37: December 19, 2018 Email re Santiago de Cuba Universal Bid Template, with attachment (RCL-Havana0099423 CONFIDENTIAL), # 47 Exhibit PLF Deposition Exhibit 38: October 8, 2018 Email re Cienfuegos tours Universal Bid Template, with attachment (RCL-Havana0098545 CONFIDENTIAL), # 48 Exhibit PLF Deposition Exhibit 39: October 12, 2018 Email re Silversea- Cuba Excursions Program (RCL-Havana0228541-546 CONFIDENTIAL), # 49 Exhibit PLF Deposition Exhibit 40: October 8, 2018 Email re: Azamara - Havana Universal Bid Template, with attachment (RCL-Havana0098589 CONFIDENTIAL), # 50 Exhibit PLF Deposition Exhibit 41: November 13, 2017 Email re Cuba Nov 8th update (RCL-Havana0115429-433 CONFIDENTIAL)) (Casey, Stephanie) Modified docket text on 9/20/2021 (nc). Modified by unsealing specific documents pursuant DE 262 Order on 4/5/2022 (kpe). (Entered: 09/17/2021)
