04/18/2025- PAPERLESS Minute Entry for proceedings held before Judge Federico A. Moreno: Jury Trial held on 4/17/2025. Day 9. Attorney Appearance(s): Santosh Aravind, Stephen Burbank, Rebecca Jahnke, Cheryl J. LaFond, Ana C Malave, Genesis Martinez, Lorayne Perez, Andres Rivero, David D. Shank, Sylmarie Trujillo, Manuel Vazquez, Jane Webre, Jorge Alejandro Mestre. Court Reporters: Ilona Lupowitz, 305-523-5737 / Ilona_lupowitz@flsd.uscourts.gov ; Gilda Pastor-Hernandez, 305-523-5118 / Gilda_Pastor-Hernandez@flsd.uscourts.gov. (ms04)

04/18/2025- PAPERLESS Minute Entry for proceedings held before Judge Federico A. Moreno: Jury Trial held on 4/16/2025. Day 8. Witnesses Francis Nardozza, John Lancet testified. Attorney Appearance(s): Santosh Aravind, Stephen Burbank, Rebecca Jahnke, Cheryl J. LaFond, Ana C Malave, Genesis Martinez, Lorayne Perez, Andres Rivero, David D. Shank, Sylmarie Trujillo, Manuel Vazquez, Jane Webre, Jorge Alejandro Mestre. Court Reporter: Ilona Lupowitz, 305-523-5737 / Ilona_lupowitz@flsd.uscourts.gov. (ms04)

04/17/2025- Notice of Filing Denial of Defendants' Proposed Jury Instructions on Affirmative Defenses. Signed by Judge Federico A. Moreno on

4/17/2025- See attached document for full details. (ms04)

04/17/2025- PAPERLESS ORDER denying 472 Defendants' Unopposed Motion for Leave to File Confidential Settlement Agreement Under Seal. For the reasons stated in open court, this motion is denied. Signed by Judge Federico A. Moreno on 4/17/2025. (ms04)

04/17/2025- PAPERLESS ORDER denying 380 Defendants' Motion for Reconsideration. Signed by Judge Federico A. Moreno on 4/17/2025. (ms04)

04/16/2025- Defendant's MOTION for Judgment as a Matter of Law (Reurged) by Expedia Group, Inc., Hotels.com L.P., Hotels.com GP, Orbitz, LLC. (Perez, Lorayne)

04/16/2025- NOTICE OF FILING DEPOSITION TESTIMONY USED BY PLAINTIFF AT TRIAL by Mario Echevarria (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E) (Rivero, Andres)

04/16/2025- NOTICE of Filing Deposition Testimony Used by Defendants at Trial by Expedia Group, Inc., Hotels.com L.P., Hotels.com GP, Orbitz, LLC (Attachments: # 1 Exhibit A-1 CM1 - Christine McDonald Trial DX, # 2 Exhibit A-2 Christine McDonald Transcript Excerpts, # 3 Exhibit B-1 RT1-RaviTummala - Ravi Tummala Trial DX, # 4 Exhibit B-2 Ravi Tummala Transcript Excerpts, # 5 Exhibit C-1 MAB1 - MAB-Marc-Antonine-Blain-Trial DX, # 6 Exhibit C-2 Marc-Antoine Blain Transcript Excerpts, # 7 Exhibit D-1 PP5 - Paula Payne Trial DX, # 8 Exhibit D-2 Paula Payne Transcript Excerpts, # 9 Exhibit E-1 AH1 - Amanda Hulbert DX Trial, # 10 Exhibit E-2 Amanda Hulbert Transcript Excerpts) (Perez, Lorayne)

04/16/2025- Unopposed MOTION for Leave to File Confidential Settlement Agreement and Stipulated Disclosure of Settlement Agreement Terms Under Seal for Purposes of Making an Offer of Proof by Expedia Group, Inc., Hotels.com L.P., Hotels.com GP, Orbitz, LLC. (Perez, Lorayne)

4931-6641-0281
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
Case No. 1:19-cv-22620-FAM

Mario Echevarria, Esther Sanchez,Consuelo Cuevas, and Carmen Florido,Plaintiffs, v. Expedia Group, Inc., Hotels.com L.P.,Hotels.com GP, LLC, Orbitz, LLC,Defendants.

Consolidated withCase No. 1:19-cv-22621-FAM

Mario Echevarria,Plaintiff,v.Expedia Group, Inc., Hotels.com L.P.,Hotels.com GP, LLC, Orbitz, LLC,Defendants.

DEFENDANTS’ UNOPPOSED MOTION FOR LEAVE TO FILE CONFIDENTIAL SETTLEMENT AGREEMENT AND STIPULATED

DISCLOSURE OF SETTLEMENT AGREEMENT TERMS UNDER SEAL FOR PURPOSES OF MAKING AN OFFER OF PROOF

Defendants Expedia Group, Inc., Hotels.com L.P., Hotels.com GP, LLC, and Orbitz, LLC(collectively, the “Defendants”), pursuant to S.D. Fla. L.R. 5.4, respectfully request that the Court permit Defendants to file a Confidential Settlement Agreement and a Stipulated Disclosure of Settlement Agreement Terms under seal, and in support state as follows:The proposed sealed documents consist of (1) a Confidential Settlement Agreement that Plaintiff and certain of his family entered into with former defendants Booking Holdings, Inc., and Booking.com B.V. (collectively, “Booking Entities”), and (2) a Stipulated Disclosure of Settlement Agreement Terms related to that same settlement (collectively, the “Settlement Documents”). Defendants believe that the settlement between the Booking Entities and Plaintiff in this case is relevant to certain of its affirmative defenses. But the Court granted Plaintiff ’s motion in limine to preclude argument or evidence related to the settlement. Defendants are therefore precluded from offering the Settlement Documents unless and until they obtain the Court’s permission to do so outside the presence of the jury.

In order to preserve their request to offer the Settlement Documents, Defendants seek to make an offer of proof under Federal Rule of Evidence 103 by submitting the Settlement Documents to the Court. However, Plaintiff has designated the Settlement Documents as “Highly Confidential—Attorneys’ Eyes Only.” And Defendants agree that, under the Stipulated Confidentiality and Protective Orders entered in this case, the Settlement Documents meet the criteria for designation as “Confidential” because they are subject to a confidentiality obligation to a third party. (See ECF Nos. 22620-82 & 22621-49.) Therefore, Defendants respectfully request that the Court permit Defendants to file the Settlement Documents under seal for the purposes of making an offer of proof.

I hereby certify that counsel for the movants have conferred with counsel for Plaintiff and that counsel for Plaintiff has stated that Plaintiff is unopposed to the Settlement Documents being filed under seal.

By: _/s/ David Shank_________

David Shank
Dated: April 15, 2025
1 In accordance with Local Rule 5.4(b)(1), Defendants propose that the Settlement Documents re-
main sealed until further order from the Court.

Respectfully submitted,
SCOTT DOUGLASS & MCCONNICO LLP
303 Colorado Street, Suite 2400
Austin, Texas 78701
(512) 495-6300 Telephone
(512) 495-6399 Facsimile
By:
David D. Shank (pro hac vice)
Texas Bar No. 24075056
dshank@scottdoug.com
Cheryl Joseph LaFond (pro hac vice)
Texas Bar No. 24104015
clafond@scottdoug.com
Rebecca Jahnke (pro hac vice)
Texas Bar No. 24129982
bjahnke@scottdoug.com
Santosh Aravind (pro hac vice)
Texas Bar No. 24095052
saravind@scottdoug.com
Stephen Burbank (pro hac vice)
Texas Bar No. 24109672
sburbank@scottdoug.com
AKERMAN LLP
Three Brickell City Centre
98 Southeast Seventh Street, Suite 1100
Miami, FL 33131
(305) 374-5600 Telephone
(305) 349-4656 Facsimile
By:
Lorayne Perez
Florida Bar No. 085265
lorayne.perez@akerman.com
Attorneys for Defendants Expedia Group, Inc.,
Hotels.com, L.P., Hotels.com GP, LLC, and Orbitz, LLC