U.S. Supreme Court Denies Petition For A Writ Of Certiorari In Libertad Act Lawsuit Against American Airlines

ROBERT M. GLEN V. AMERICAN AIRLINES, INC., [1:19-cv-23994 Southern Florida District; 4:20-cv-00482-A Transferred To Northern Texas District; 5th Circuit Court of Appeals 20-10903; 15 December 2021- Seeking Review From United States Supreme Court; Denied 1/18/22]
Reid Collins & Tsai (plaintiff)
Ewusiak Law, P.A. (plaintiff)
Jones Day (defendant)
Kelly Hart & Hallman LLP (defendant)

United States Supreme Court Denial Of Writ Of Certiorari (1/18/22)
Libertad Act Lawsuit Filing Statistics

Writs Of Certiorari: “Parties who are not satisfied with the decision of a lower court must petition the U.S. Supreme Court to hear their case. The primary means to petition the court for review is to ask it to grant a writ of certiorari. This is a request that the Supreme Court order a lower court to send up the record of the case for review. The Court usually is not under any obligation to hear these cases, and it usually only does so if the case could have national significance, might harmonize conflicting decisions in the federal Circuit courts, and/or could have precedential value. In fact, the Court accepts 100-150 of the more than 7,000 cases that it is asked to review each year. Typically, the Court hears cases that have been decided in either an appropriate U.S. Court of Appeals or the highest Court in a given state (if the state court decided a Constitutional issue). The Supreme Court has its own set of rules. According to these rules, four of the nine Justices must vote to accept a case. Five of the nine Justices must vote in order to grant a stay, e.g., a stay of execution in a death penalty case. Under certain instances, one Justice may grant a stay pending review by the entire Court.”

Related Link

American Airlines Libertad Title III Lawsuit Becomes First To Seek Review By United States Supreme Court. Twenty-Nine Months From District Court To SCOTUS Is Fast.  December 20, 2021

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)

09/17/2021 125 

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)

09/17/2021 124 

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)

09/17/2021 123 

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)

09/17/2021 122 

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)

Carnival Corporation Libertad Act Lawsuit: Tens Of Thousands Of Documents Unsealed

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)

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)
Order Unsealing The Summary Judgement Record (4/4/22)
Libertad Act Lawsuit Filing Statistics

Example Of Unsealed- File 312

11/08/2021 401 

Sealed Document Defendants Reply Statement of Material Facts to Plaintiffs Corrected Statement of Material Facts in Support of Its Response In Opposition to Defendants Omnibus Motion for Summary Judgment by Carnival Corporation. (Singer, Stuart) Modified by unsealing document pursuant to DE 486 Order on 4/5/2022 (kpe). (Entered: 11/08/2021)

11/08/2021 395 

Sealed Document 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 document pursuant to DE 486 Order on 4/5/2022 (kpe). (Entered: 11/08/2021)

10/18/2021 375 

NOTICE OF FILING EXHIBITS CITED IN PLAINTIFF'S OPPOSITION TO CARNIVAL CORPORATION'S STATEMENT OF MATERIAL FACTS by Havana Docks Corporation. (Attachments: # 1 Exhibit Transcript of and Exhibits to the Deposition of Gianluca Suprani, taken in Havana Docks Corporation v. MSC Cruises, SA, et al, dated April, 2021 (CONFIDENTIAL), # 2 Exhibit Airtours Public Offering, dated November, 24, 1998, # 3 Exhibit Cuba Trade and Investment News, dated September, 2005, # 4 Exhibit Cuba News, dated September 2005, # 5 Exhibit Carnival Corporation 1997 Annual Report) (Martinez, Roberto) Modified by unsealing document pursuant to DE 486 Order on 4/5/2022 (kpe). (Entered: 10/18/2021)

10/18/2021 374 

Sealed Document Carnival Corporation's Opposing Statement of Undisputed Facts as to Which There is No Genuine Issue to Be Tried by Carnival Corporation. (Attachments: # 1 Exhibit 46, # 2 Exhibit 47, # 3 Exhibit 48, # 4 Exhibit 49, # 5 Exhibit 50, # 6 Exhibit 51, # 7 Exhibit 52) (Singer, Stuart) Modified by unsealing document pursuant to DE 486 Order on 4/5/2022 (kpe). (Entered: 10/18/2021)

10/18/2021 365 

Sealed Document 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 to DE 486 Order on 4/5/2022 (kpe). (Entered: 10/18/2021)

09/20/2021 331 

Sealed Document Statement of: DEFENDANTS' Omnibus STATEMENT OF UNDISPUTED MATERIAL FACTS re 330 by Carnival Corporation. (Attachments: # 1 Exhibit 1, # 2 Exhibit 1, Ex. 1, # 3 Exhibit 1, Ex. 2, # 4 Exhibit 1, Ex. 3, # 5 Exhibit 1, Ex. 4, # 6 Exhibit 1, Ex. 5, # 7 Exhibit 1, Ex. 6, # 8 Exhibit 1, Ex. 7, # 9 Exhibit 1, Ex. 8, # 10 Exhibit 1, Ex. 19, # 11 Exhibit 1, Ex. 10, # 12 Exhibit 2, # 13 Exhibit 3, # 14 Exhibit 4, # 15 Exhibit 5, # 16 Exhibit 6, # 17 Exhibit 7, # 18 Exhibit 8, # 19 Exhibit 9, # 20 Exhibit 10, # 21 Exhibit 11, # 22 Exhibit 12, # 23 Exhibit 13, # 24 Exhibit 14, # 25 Exhibit 15, # 26 Exhibit 16, Part 1, # 27 Exhibit 16, Part 2, # 28 Exhibit 16, Part 3, # 29 Exhibit 16, Part 4, # 30 Exhibit 16, Part 5, # 31 Exhibit 17, # 32 Exhibit 18, # 33 Exhibit 19, # 34 Exhibit 20, # 35 Exhibit 21, # 36 Exhibit 22, # 37 Exhibit 23, # 38 Exhibit 24, # 39 Exhibit 25, # 40 Exhibit 26, Part 1, # 41 Exhibit 26, Part 2, # 42 Exhibit 26, Part 3, # 43 Exhibit 27, # 44 Exhibit 28, Part 1, # 45 Exhibit 28, Part 2, # 46 Exhibit 28, Part 3, # 47 Exhibit 29, # 48 Exhibit 30, Part 1, # 49 Exhibit 30, Part 2, # 50 Exhibit 30, Part 13, # 51 Exhibit 31, # 52 Exhibit 32, # 53 Exhibit 33, # 54 Exhibit 34, # 55 Exhibit 35, # 56 Exhibit 36, # 57 Exhibit 37, # 58 Exhibit 38, # 59 Exhibit 39, # 60 Exhibit 40, # 61 Exhibit 41, # 62 Exhibit 42, # 63 Exhibit 43, # 64 Exhibit 44, # 65 Exhibit 45, # 66 Exhibit 46, # 67 Exhibit 47, # 68 Exhibit 48, # 69 Exhibit 49, # 70 Exhibit 50, # 71 Exhibit 51, # 72 Exhibit 52, # 73 Exhibit 53, # 74 Exhibit 54, # 75 Exhibit 55, # 76 Exhibit 56, # 77 Exhibit 57, # 78 Exhibit 58, # 79 Exhibit 59, # 80 Exhibit 60, # 81 Exhibit 61, # 82 Exhibit 62, # 83 Exhibit 63, # 84 Exhibit 64, # 85 Exhibit 65, # 86 Exhibit 66, # 87 Exhibit 67, # 88 Exhibit 68, # 89 Exhibit 69, # 90 Exhibit 70, # 91 Exhibit 71, # 92 Exhibit 72, # 93 Exhibit 73, # 94 Exhibit 74, # 95 Exhibit 75, # 96 Exhibit 76, # 97 Exhibit 77, # 98 Exhibit 78, # 99 Exhibit 79, # 100 Exhibit 80, # 101 Exhibit 81, # 102 Exhibit 82, # 103 Exhibit 83, # 104 Exhibit 84, # 105 Exhibit 85, # 106 Exhibit 86, # 107 Exhibit 87, # 108 Exhibit 88, # 109 Exhibit 89, # 110 Exhibit 90, # 111 Exhibit 91, # 112 Exhibit 92, # 113 Exhibit 93, # 114 Exhibit 94, # 115 Exhibit 95, # 116 Exhibit 96, # 117 Exhibit 97, # 118 Exhibit 98, # 119 Exhibit 99, # 120 Exhibit 100, # 121 Exhibit 101, # 122 Exhibit 102, # 123 Exhibit 103, # 124 Exhibit 104, # 125 Exhibit 105, # 126 Exhibit 106, # 127 Exhibit 107, # 128 Exhibit 108, # 129 Exhibit 109, # 130 Exhibit 110, # 131 Exhibit 111, # 132 Exhibit 112, # 133 Exhibit 113, # 134 Exhibit 114, # 135 Exhibit 115, # 136 Exhibit 116, # 137 Exhibit 117, # 138 Exhibit 118, # 139 Exhibit 119, # 140 Exhibit 120, # 141 Exhibit 121, # 142 Exhibit 122, # 143 Exhibit 123, # 144 Exhibit 124) (Singer, Stuart) Modified by unsealing specific documents pursuant to DE 486 on 4/5/2022 (kpe). (Entered: 09/20/2021)

09/20/2021 326 

Sealed Document Carnival Corporation's Individual Statement of Material Macts of Wwhich There is No Genuine Issue of Dispute re 324 by Carnival Corporation. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, Part 1, # 11 Exhibit 10, Part 2, # 12 Exhibit 10, Part 3, # 13 Exhibit 10, Part 4, # 14 Exhibit 11, Part 1, # 15 Exhibit 11, Part 2, # 16 Exhibit 11, Part 3, # 17 Exhibit 11, Part 4, # 18 Exhibit 11, Part 5, # 19 Exhibit 12, # 20 Exhibit 13, # 21 Exhibit 14, # 22 Exhibit 15, # 23 Exhibit 16, # 24 Exhibit 17, Part 1, # 25 Exhibit 17, Part 2, # 26 Exhibit 18, # 27 Exhibit 19, Part 1, # 28 Exhibit 19, Part 2, # 29 Exhibit 19, Part 3, # 30 Exhibit 19, Part 4, # 31 Exhibit 19, Part 5, # 32 Exhibit 20, # 33 Exhibit 21, # 34 Exhibit 22, # 35 Exhibit 23, # 36 Exhibit 24, # 37 Exhibit 25, Part 1, # 38 Exhibit 25, Part 2, # 39 Exhibit 26, # 40 Exhibit 27, # 41 Exhibit 28, Part 1, # 42 Exhibit 28, Part 2, # 43 Exhibit 28, Part 3, # 44 Exhibit 28, Part 4, # 45 Exhibit 29, # 46 Exhibit 30, # 47 Exhibit 31, # 48 Exhibit 32, # 49 Exhibit 33, # 50 Exhibit 34, # 51 Exhibit 35, # 52 Exhibit 36, # 53 Exhibit 37, # 54 Exhibit 38, # 55 Exhibit 39, # 56 Exhibit 40, # 57 Exhibit 41, # 58 Exhibit 42, # 59 Exhibit 43, # 60 Exhibit 44, # 61 Exhibit 45) (Singer, Stuart) Modified by unsealing specific documents pursuant to DE 486 Order on 4/5/2022 (kpe). (Entered: 09/20/2021)

09/20/2021 324 

SEALED MOTION Carnival Corporation's Individual Motion for Summary Judgment by Carnival Corporation. (Singer, Stuart) Modified by unsealing document pursuant to DE 486 Order on 4/5/2022 (kpe). (Entered: 09/20/2021)

09/20/2021 323 

Sealed Document 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 documents pursuant to DE 486 Order on 4/5/2022 (kpe). (Entered: 09/20/2021)

09/20/2021 322 

Sealed Document Notice of Filing Exhibits 213-238 Cited in Plaintiff's Statement of Material Facts in Support of Individual Motion for Summary Judgment Against Carnival Corporation by Havana Docks Corporation. (Attachments: # 1 Transcript of and Exhibits to the Deposition of Jerry Johnson in his capacity as Plaintiffs Rule 30(b)(6) designee, dated November 24, 2020, # 2 Carnival Corporations Response to Plaintiffs First Request for Admissions dated August 30, 2021, # 3 Carnival Corporations Response to Plaintiffs Second Request for Admissions dated September 7, 2021, # 4 2000 Carnival Corporation Form 10K, # 5 February 10, 2017 Email re Escalas Cienfuegos Veendam (certified translation and original) (HavanaDocks_0443108-310 CONFIDENTIAL), # 6 Agency Agreement No. 5/2017 between Empresa Consignataria Mambisa and Carnival Corporation (HavanaDocks_0358914-921), # 7 March 21, 2016 Contrato De Servicios (Cruceros) No 5/2016 between Havanatur and Carnival Corporation Veendam (in Spanish) (HavanaDocks_0397852-862), # 8 July 21, 2017 Contract between Aries SA and Carnival Corporation (certified translation and original) (HavanaDocks_0397970-397984 ATTORNEYS EYES ONLY), # 9 Composite Exhibit: Adonia End of Cruise Reports, # 10 Composite Exhibit: Adonia End of Cruise Reports, # 11 February 11, 2019 Letter to Arnaldo Perez from Rodney S. Margol, Esq. (HDC 018650-51), # 12 February 11, 2019 Letter to Micky Arison from Rodney S. Margol, Esq. (HDC 018654-55), # 13 May 13, 2015 Email re MSC Opera Report on the Havana Harbor (translation and original) (MSCUSA00000077416-420 CONFIDENTIAL), # 14 06-15-15 Email re Meeting (MSCCUSA00000077311-350 CONFIDENTIAL), # 15 Transcript of and Exhibits to the Deposition of Nicolai Skogland in his capacity as Viking Cruises (USA) Ltd. Co. and Viking Ocean Cruises II, Ltd (jointly, Viking) Rule 30(b)(6) designee, taken in Havana Docks Corporation v. Norwegian Cruise Line Holdings dated February 2, 2021, # 16 May 18, 2017 Email re Final Approval VEENDAM (certified translation and original) (HavanaDocks 397584-85 CONFIDENTIAL), # 17 April 19, 2019 Contract between Aries and Carnival Corporation (HavanaDcks_0360877-360882 CONFIDENTIAL), # 18 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), # 19 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), # 20 August 21, 2019 Email re Berth request for Riviera (NCLH_23591-00005908-5911), # 21 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), # 22 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, # 23 Carnival Corporations Responses and Objections to Plaintiffs First Set of Interrogatories dated October 28, 2019, # 24 Carnival Corporations Amended Responses and Objections to Plaintiffs First Set of Interrogatories dated November 27, 2021, # 25 Spreadsheet: CCL Master Calls (HavanaDocks_0479086), # 26 1998 Carnival Corporation Form 10-K, filed as of February 25, 1999, # 27 Memorandum of Understanding between Grupo de Turismo GAVIOTA SA and Carnival Corporation & plc (certified translation and original) (HavanaDocks_0438969-438973), # 28 December 18, 2014 Email re US seeks to normalize relations with Cuba (RCL-Havana0066678-0066690 CONFIDENTIAL)) (Martinez, Roberto) Modified by unsealing specific documents pursuant to DE 486 Order on 4/5/2022 (kpe). (Entered: 09/20/2021)  

09/19/2021 318 

Sealed Document NOTICE OF FILING EXHIBITS CITED IN PLAINTIFFS Statement of Materials Facts in Support of Omnibus Motion for Summary Judment 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 Errata 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, # 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, # 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 (HDC 006440, HDC 006423, HDC 006406, HDC 006390, HDC 006374, HDC 006359, HDC 006343, HDC 006327, HDC 006311, HDC 006295, HDC 006279, HDC 006263, HDC 006246, HDC 006229, HDC 006212, HDC 006195, HDC 006179, HDC 006162, HDC 006146, HDC 006130, HDC 006114, HDC 006098, HDC 006082, HDC 006066, HDC 006049, HDC 006033, HDC 006016, HDC 006000, HDC 005984, HDC 005968, HDC 005936, HDC 005920, HDC 005904, HDC 005888, HDC 005872, HDC 005855, HDC 005839, HDC 023122, HDC 023139-23140, HDC 023121, HDC 023137-23138, HDC 023120, HDC 023135-23136, HDC 023119, HDC 023119, HDC 023133-23134, HDC 023131-23132, HDC 023117, HDC 023129, HDC 023130, HDC 023116, HDC 023127, HDC 023128, HDC 023115, HDC 023125, HDC 023126, HDC 023114, HDC 023123-23124, HDC 005271-5276, HDC 005263, HDC 005255-5260, HDC 005247, HDC 005238-5244, HDC 005230, HDC 005222-5227, HDC 005214, HDC 005206-5211, HDC 005198, HDC 005190-5195, HDC 005182, HDC 005166, HDC 005157-5163, HDC 005149, HDC 005140-5146, HDC 005132, HDC 005115, HDC 005107-5112, HDC 005090-5096, HDC 009218-9234, HDC 004896-4901, HDC 008047-8060, HDC 011918-11923, HDC 002509-2511, HDC 002518-2519, HDC 011908-11911, HDC 009210-9211 CONFIDENTIAL), # 36 Exhibit Composite Exhibit: Havana Docks Pre-Confiscation Financial Reports (HDC 004482-4483, HDC 004516-4517, HDC 004530-4531, HDC 012182-2184, HDC 012214-12215, HDC 012246-12247, HDC 012304-12305, HDC 012364-12365, HDC 12465-12466, HDC 010160-10163, HDC 010255-10258, HDC 010366-10369, HDC 010451-10454, HDC 010560-10563, HDC 010658, HDC 003725-3726, HDC 010736, HDC 003727-3736, HDC 011569-11570, HDC 002968-2971, HDC 002964-2967, HDC 008047-8061 CONFIDENTIAL), # 37 Exhibit Composite Exhibit: Havana Docks Post-Certified Claim Financial Reports (HDC 005712-5715, HDC 003208-3214, HDC 008339-8342, HDC 003252-3259, HDC 006514-6515, HDC 008399-8401, HDC 006455-6456, HDC 008621-8624, HDC 011225-11226, HDC 11593-11594, HDC 011394-11397, HDC 011451-11452, HDC 011529-11531, HDC -11597-1599, HDC 021174-21179, HDC 021191-21193, HDC 021216-21226, HDC 021230, HDC 021247-21251, HDC 021265, HDC 21266-21269, HDC 021270, HDC 021271-21273, HDC 021274-21275, HDC 021276-21279, HDC 021288-21290, HDC 013063-13065, HDC 013095-13096, HDC 013137-13139, HDC 013140, HDC 013123-13127, HDC013175-13177 CONFIDENTIAL), # 38 Exhibit Composite Exhibit: Havana Docks Corporation Tax Returns (HDC 008184-8185, HDC 002744-2745, HDC 008192-8210, HDC 008233-8247, HDC 002666-2688, HDC 002405-2414, HDC 002625, HDC 002980-2981, HDC 002982-2986, HDC 003013-3018, HDC 003033-3037, HDC 003065-3070, HDC 003076-3081, HDC 003088, HDC 018734-18742, HDC 003083-3085, HDC 003110-3115, HDC 018743-18745, HDC 003142-3150, HDC 003193-3207, HDC 003226-3238, HDC 003292-3307, HDC 003309, HDC 008318-8327, HDC 008329-8330, HDC 008379-8388, HDC 008401-8402, HDC 008417-8427, HDC 008594-8604, HDC00 8668-8682, HDC 008645-8656, HDC 008748-8758, HDC 008764, HDC 008702-8715, HDC 011192-11199, HDC 011176-11180, HDC 011282-11294, HDC 011427-11438, HDC 011496-11509, HDC 011566, HDC 021168-021173, HDC 021184-021190, HDC 021208-021215, 021231-021238, HDC 021280-021287, HDC 000342-348, HDC 013082-13088, HDC 013099-13107, HDC 013113-13122, HDC 013213-13223, documents provided by David Bush in response to subpoena, HDC 013288-13314, HDC 013316-13350, HDC 013721-13745, HDC 013352-13377, HDC 018836-18864, HDC 018866-18893 CONFIDENTIAL), # 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)) (Martinez, Roberto) Modified by unsealing specific documents pursuant to DE 486 Order on 4/5/2022 (kpe). (Entered: 09/19/2021)

09/16/2021 312 

Sealed Document NOTICE OF FILING EXHIBITS 201-212 CITED IN Plaintiff's Statement of Material Facts in Support of Individual Motion for Summary Judgment Against Carnival Corporation by Havana Docks Corporation. (Attachments: # 1 Exhibit PLF Deposition Exhibit 188: April 16, 2018 Email re Bill language attached (NCLH_23591-0055158-169), # 2 Exhibit PLF Deposition Exhibit 189: April 16, 2018 Email re The Cuban Claims Trust Fund Act (HavanaDocks 0501091 CONFIDENTIAL), # 3 Exhibit PLF Deposition Exhibit 190: September 6, 2018 Email re House Foreign Affairs Subcommittee Hearing: US Policy toward Cuba (NCLH_23591-0054244-247), # 4 Exhibit PLF Deposition Exhibit 191: January 23, 2019 Email re Updated on Cuba Title III (NCLH_23591-00110447-448), # 5 Exhibit PLF Deposition Exhibit 192: January 19, 2019 Email re Discussion with Rubio (HavanaDocks 0500215-218 CONFIDENTIAL), # 6 Exhibit PLF Deposition Exhibit 193: January 25, 2019 Email re MA Cuba TPS (HavanaDocks 0500502-503 CONFIDENTIAL), # 7 Exhibit PLF Deposition Exhibit 194: February 6, 2019 Email re Diaz-Balart - Cuba Discussion (HavanaDocks 0482427 CONFIDENTIAL/VSI), # 8 Exhibit PLF Deposition Exhibit 195: March 18, 2019 Email re Revised TPs (HavanaDocks 0500194-200 CONFIDENTIAL), # 9 Exhibit PLF Deposition Exhibit 196: March 20, 2019 Email re Call with President Trump (HavanaDocks 0500202-203 CONFIDENTIAL), # 10 Exhibit PLF Deposition Exhibit 197: April 24, 2019 Email re Are you going? (NCLH_23591-00563916-919), # 11 Exhibit PLF Deposition Exhibit 198: June 20, 2019 Email re Cuba License (NCLH_23591-00562009), # 12 Exhibit PLF Deposition Exhibit 199: June 21, 2019 Email re TPS (NCLH_23591-00562138)) (Martinez, Roberto) Modified by unsealing documents pursuant to DE 486 Order on 4/5/2022 (kpe). (Entered: 09/16/2021)

09/16/2021 311 

Sealed Document NOTICE OF FILING EXHIBITS 151-200 CITED IN Plaintiff's Statement of Material Facts in Support of Individual Motion for Summary Judgment Against Carnival Corporation by Havana Docks Corporation. (Attachments: # 1 Exhibit PLF Deposition Exhibit 138: Document prepared by Carnival to aid Fred Stein in testifying, # 2 Exhibit PLF Deposition Exhibit 139: July 1, 2021 Carnival Corporation's Second Amended Responses and Objections to HDCs Fourth Set of Interrogatories, # 3 Exhibit PLF Deposition Exhibit 140: CCL revenue Excel spreadsheet (HavanaDocks 395249 CONFIDENTIAL), # 4 Exhibit PLF Deposition Exhibit 141: HAL revenue Excel spreadsheet, provided by counsel via email, # 5 Exhibit PLF Deposition Exhibit 142: May 10, 2016 Email re Document (Fathom End of Cruise Report #10 (HavanaDocks 0468523-29 CONFIDENTIAL), # 6 Exhibit PLF Deposition Exhibit 143: March 29, 2017 Email re Fathom End of Curse Report Cuba D727 March 19th (EOC report 28A) (HavanaDocks 0461419-424 CONFIDENTIAL/VSI), # 7 Exhibit PLF Deposition Exhibit 144: June 3, 2017 Email re EOC - Adonia - Fathom - D745 (EOC report 36) (HavanaDocks 0454115-135 CONFIDENTIAL), # 8 Exhibit PLF Deposition Exhibit 145: October 1, 2015 Document titled Executive Summary Cuba Ports. Pre-feasibility studies (May-October 2015) (HavanaDocks 0358643-45), # 9 Exhibit PLF Deposition Exhibit 146: October 7, 2015 Email re board draft, FYI -Fathom (HavanaDocks 0463445-446 CONFIDENTIAL), # 10 Exhibit PLF Deposition Exhibit 147: September 2, 2016 Email re for review fathom release re new Cuba Shore Excursions (HavanaDocks 0481806-811 CONFIDENTIAL), # 11 Exhibit PLF Deposition Exhibit 148: February 28, 2017 Email re Holland America Line - Cuba Presentation - V1 (HavanaDocks 0445428-429 CONFIDENTIAL), # 12 Exhibit PLF Deposition Exhibit 149: March 8, 2017 Email re Agenda Cultures of the Caribbean Call 3/8/17 (HavanaDocks 0419093-94 CONFIDENTIAL), # 13 Exhibit PLF Deposition Exhibit 150: May 23, 2016 Travel affidavits of Micky and Madeline Arison, # 14 Exhibit PLF Deposition Exhibit 151: Excel spreadsheet titled Sailing by Sailing NTR (HavanaDocks 0481625 CONFIDENTIAL), # 15 Exhibit PLF Deposition Exhibit 152: October 1, 2016 Document titled fathom Reporting pack Oct-16 (HavanaDocks 0445419 CONFIDENTIAL), # 16 Exhibit PLF Deposition Exhibit 153: November 28, 2016 Email re fathom Oct 16 results (HavanaDocks 445418 CONFIDENTIAL), # 17 Exhibit PLF Deposition Exhibit 154: Reference sheet re Airtours and Costa used by Arnaldo Perez to assist in testimony for Rule 30(b)(6) deposition, # 18 Exhibit PLF Deposition Exhibit155: March 8, 1996 Carnival Corporation Form DEF 14A (Proxy Statement), # 19 Exhibit PLF Deposition Exhibit 156: February 21, 1996 Shareholders Agreement between Carnival Corporation and David Crossland (HavanaDocks 0476415-434 CONFIDENTIAL), # 20 Exhibit PLF Deposition Exhibit 157: February 21, 1996 Letter to Carnival Corporation and CS First Boston Limited re Proposed partial offers for shares in Airtours plc (HavanaDocks 0476435-444 CONFIDENTIAL), # 21 Exhibit PLF Deposition Exhibit 158: January 4, 2001 Letter to Howard Frank from David Crossland re Agreement dated 21 February 1996 (HavanaDocks 0476445-453 CONFIDENTIAL), # 22 Exhibit PLF Deposition Exhibit 159: February 21, 1996 Agreement between Carnival Corporation and Airtours PLC (HavanaDocks 0476454-484, # 23 Exhibit PLF Deposition Exhibit 160: 2000 Airtours Annual Report and accounts, # 24 Exhibit PLF Deposition Exhibit 161: March 2, 2021 Letter from Department of Treasury to Corey Gray, Esq. re Havana Docks Corporation v. Carnival Corporation, 19-cv-21724-X (S.D. Fl.), # 25 Exhibit PLF Deposition Exhibit 162: June 11, 2021 Letter from Department of Treasury to Corey Gray, Esq. re Havana Docks Corporation v. Carnival Corporation, 19-cv-21724-X (S.D. Fl.), # 26 Exhibit PLF Deposition Exhibit 163: June 30, 2021 Notice of Rule 30(b0(6) Deposition, # 27 Exhibit PLF Deposition Exhibit 164: Pablo Spiller Report Exhibit PS-123 (Excel spreadsheet containing itineraries and passenger numbers), # 28 Exhibit PLF Deposition Exhibit 165: Contract No. 5/2017 between Aries S.A. and Carnival Corporation (in Spanish) (HavanaDocks 0397970-984), # 29 Exhibit PLF Deposition Exhibit 166: Supplement No. 2 to Service Agreement for Cruise Ship Operation (Agreement No. 5/17) between Aries S.A. and Carnival Corporation (English and Spanish) (HavanaDocks 0360871-876 CONFIDENTIAL, HavanaDocks 0397947-953), # 30 Exhibit PLF Deposition Exhibit 167: Excel spreadsheet showing Carnival Corporations payments to vendors (HavanaDocks 0479084 CONFIDENTIAL), # 31 Exhibit PLF Deposition Exhibit 168: January 14, 2021 Declaration of Christopher Martin, # 32 Exhibit PLF Deposition Exhibit 169: Supplement No. 3 to Service Agreement for Cruise Ship Operation (Agreement No. 5/2017) between Aries S.A. and Carnival Corporation (English and Spanish) (HavanaDocks 0360863-870 CONFIDENTIAL, HavanaDocks 0438732-738 CONFIDENTIAL/VSI), # 33 Exhibit PLF Deposition Exhibit 170: Contract No. 11/2017 between Havanatur S.A. and Carnival Corporation (in Spanish) (HavanaDocks 0439099-114 CONFIDENTIAL/VSI), # 34 Exhibit PLF Deposition Exhibit 171: December 21, 2016 Email re Carnival - Solicitud Para Veendam (HavanaDocks 0494051-056 CONFIDENTIAL), # 35 Exhibit PLF Deposition Exhibit 172: March 3, 2018 Email re Recap from HAG visit to Cuba (HavanaDocks 0477381-384 CONFIDENTIAL), # 36 Exhibit PLF Deposition Exhibit 173: October 16, 2016 Email re Cuban Agents Conflict sheet (HavanaDocks 0397709-710, # 37 Exhibit PLF Deposition Exhibit 174: October 16, 2016 Excel spreadsheet attachment to email Bates numbered HavanaDocks 0397709-710 (HavanaDocks 0397711), # 38 Exhibit PLF Deposition Exhibit 175: November 28, 2017 Email re Havana Tour Descriptions (HavanaDocks 0476674-703 CONFIDENTIAL), # 39 Exhibit PLF Deposition Exhibit 176: February 15, 2018 Email re HAL Blog on Cuba - by Orlando Ashford (HavanaDocks 0477385-386, # 40 Exhibit PLF Deposition Exhibit 177: April 30, 2015 Email re Further updates (HavanaDocks 0389062-063 CONFIDENTIAL), # 41 Exhibit PLF Deposition Exhibit 178: May 6, 2015 Email re Update (HavanaDocks 0500790), # 42 Exhibit PLF Deposition Exhibit 179: November 21, 2015 Email re Cuba (HavanaDocks 0481027), # 43 Exhibit PLF Deposition Exhibit 180: July 21, 2015 Email re Cuba (HavanaDocks 0481226-230 CONFIDENTIAL), # 44 Exhibit PLF Deposition Exhibit 181: July 2, 2018 Email re Possible simulation of Port of Havana in CSMART (HavanaDocks 0476062-63), # 45 Exhibit PLF Deposition Exhibit 182: February 11, 2019 Letter to Carnival Corporation, PLC from Rodney S. Margol, Esq., # 46 Exhibit PLF Deposition Exhibit 183: February 22, 2019 Letter to the Honorable Michael R. Pompeo (NCLH_23591 00111666-667), # 47 Exhibit PLF Deposition Exhibit 184: April 30, 2015 Email re further updates (HavanaDocks 0481178 CONFIDENTIAL), # 48 Exhibit PLF Deposition Exhibit 185: May 13, 2015 Email re House Approps Mark-up: THUD Bill (NCLH_23591-00187593-594), # 49 Exhibit PLF Deposition Exhibit 186: May 6, 2015 Email re Update (HavanaDocks 0500790 CONFIDENTIAL), # 50 Exhibit PLF Deposition Exhibit 187: June 5, 2017 Email re Know before you go: Cruise Caucus (NCLH_23591-00055759-763)) (Martinez, Roberto) Modified by unsealing specific documents pursuant to DE 486 Order on 4/5/2022 (kpe). (Entered: 09/16/2021)

09/16/2021 310 

Sealed Document NOTICE OF FILING EXHIBITS 101-150 CITED IN Plaintiff's Statement of Material Facts in Support of individual Motion for Summary Judgment Against Carnival Cruise Corporation by Havana Docks Corporation. (Attachments: # 1 Exhibit PLF Deposition Exhibit 90: April 30, 2015 Email re further updates (HavanaDocks 389060 CONFIDENTIAL), # 2 Exhibit PLF Deposition Exhibit 91: July 2, 2015 License from OFAC to Carnival for travel to Cuba (HavanaDocks 345553 CONFIDENTIAL), # 3 Exhibit PLF Deposition Exhibit 92: February 3, 2016 Email re Cuba website comments (HavanaDocks 445758-795), # 4 Exhibit PLF Deposition Exhibit 93: April 11, 2016 Email re FAQ update for website (HavanaDocks 377301-307), # 5 Exhibit PLF Deposition Exhibit 94: April 3, 2016 Email re Cuba Deployment Visit Report (HavanaDocks 480793-79 CONFIDENTIAL), # 6 Exhibit PLF Deposition Exhibit 95: April, 2016 Fathom Brochure (HavanaDocks 346898-912), # 7 Exhibit PLF Deposition Exhibit 96: February 22, 2017 Email re Confirmacion Adonia (HavanaDocks 461994-997 CONFIDENTIAL), # 8 Exhibit PLF Deposition Exhibit 97: August 11, 2017 Email re Talking Points (HavanaDocks 358469-473 CONFIDENTIAL), # 9 Exhibit PLF Deposition Exhibit 98: September 12, 2016 Email re EOC - Adonia -Fathom - D669 (HavanaDocks 482135-169 CONFIDENTIAL), # 10 Exhibit PLF Deposition Exhibit 99: September 15, 2016 Email re TIME SENSITIVE WIRE FROM CARNIVAL CORPORATION (HavanaDocks 471959-968 CONFIDENTIAL/VSI), # 11 Exhibit PLF Deposition Exhibit 100: September 19, 2016 Email re thinking about future Cuba sailings (HavanaDocks 372954), # 12 Exhibit PLF Deposition Exhibit 101: July 21, 2017 Email re questions regarding HAL visits to Cuba (HavanaDocks 358350-351 CONFIDENTIAL), # 13 Exhibit PLF Deposition Exhibit 102: March 28, 2018 Cuba Chamber of Commerce License #1597 for CCO (English Translation) (HavanaDocks 468290-294 CONFIDENTIAL), # 14 Exhibit PLF Deposition Exhibit 103: March 28, 2018 Cuba Chamber of Commerce License #1597 for CCO (Spanish original) (HavanaDocks 438942-946), # 15 Exhibit PLF Deposition Exhibit 104: September 6, 2018 Agreement to Provide Labor Force between ACOCREC, SA and Carnival Corporation (English version) (HavanaDocks 438790-796 CONFIDENTIAL/VSI), # 16 Exhibit PLF Deposition Exhibit 105: Agreement to Provide Labor Force between ACOCREC, SA and Carnival Corporation (Spanish version) (HavanaDocks 438804-812 CONFIDENTIAL/VSI), # 17 Exhibit PLF Deposition Exhibit 106: June 28, 2017 Email re Meeting Recap (6.27.17) (HavanaDocks 358448-449 CONFIDENTIAL), # 18 Exhibit PLF Deposition Exhibit 107: February 26, 2018 Email re recap from HAG visit to Cuba (HavanaDocks 483846-847 CONFIDENTIAL, # 19 Exhibit PLF Deposition Exhibit 108: August 28, 2018 Email re visita de representante de CSMART a La Habana (HavanaDocks 437770-771 CONFIDENTIAL), # 20 Exhibit PLF Deposition Exhibit 109: October 29, 2018 Email re Recap of Havana Meetings (Oct 24-26, 2018) (HavanaDocks 360335-337 CONFIDENTIAL), # 21 Exhibit PLF Deposition Exhibit 110: November 5, 2018 Email re New Havana Pier (HavanaDocks 437684-685 CONFIDENTIAL), # 22 Exhibit PLF Deposition Exhibit 111: November 6, 2018 Email re De Perdigon ARIES - CAD drawing Havana terminal (HavanaDocks 437682-683 CONFIDENTIAL), # 23 Exhibit PLF Deposition Exhibit 112: November 10, 2018 Email re HAVANA XL_RENDERING (HavanaDocks 396196-197 CONFIDENTIAL), # 24 Exhibit PLF Deposition Exhibit 113: November 20, 2018 Email re Notes from the meeting with Aries (HavanaDocks 437670-677 CONFIDENTIAL), # 25 Exhibit PLF Deposition Exhibit 114: December 17, 2018 Email re mooring plan (HavanaDocks 479061-062 CONFIDENTIAL), # 26 Exhibit PLF Deposition Exhibit 115: February 1, 2019 Conference call appointment for Cuba trip prep (HavanaDocks 0468216 CONFIDENTIAL), # 27 Exhibit PLF Deposition Exhibit 116: December 18, 2020 Contents of Dropbox (HavanaDocks 483804-845 CONFIDENTIAL), # 28 Exhibit PLF Deposition Exhibit 117: March 21, 2018 Email re Cuba update from Seabourn (HavanaDocks 442735-739 CONFIDENTIAL, # 29 Exhibit PLF Deposition Exhibit 118: July 10, 2018 Email re Princess Cruises in Cuba 2019 and Beyond (HavanaDocks 476041-050 CONFIDENTIAL, # 30 Exhibit PLF Deposition Exhibit 119: July 13, 2018 Email re Pacific Princess 2020-2021 (HavanaDocks 476016-017 CONFIDENTIAL), # 31 Exhibit PLF Deposition Exhibit 120: August 6, 2018 Email re De Maritza (HavanaDocks 424285-287 CONFIDENTIAL/VSI), # 32 Exhibit PLF Deposition Exhibit 121: September 18, 2018 Email re Cuba summary (HavanaDocks 437714 CONFIDENTIAL), # 33 Exhibit PLF Deposition Exhibit 122: January 14, 2018 Email re recap of conversation with Perdigon in Habana (HavanaDocks 481402-407 CONFIDENTIAL), # 34 Exhibit PLF Deposition Exhibit 123: 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), # 35 Exhibit PLF Deposition Exhibit 124: April 17, 2019 Email re Cuba announcement with new restrictions and sanctions CCL (HavanaDocks 475791 CONFIDENTIAL), # 36 Exhibit PLF Deposition Exhibit 125: May 24, 2016 Letter to Ruben Ramos Arrieta from Arnie Perez (HavanaDocks 415724-730 CONFIDENTIAL/VSI), # 37 Exhibit PLF Deposition Exhibit 125-A: Partial translation of May 24, 2016 Letter to Ruben Ramos Arrieta from Arnie Perez (HavanaDocks 415724-730 CONFIDENTIAL/VSI), # 38 Exhibit PLF Deposition Exhibit 126: February 13, 2019 Email re Havana meetings First Draft and attachment (HavanaDocks 0484030-034 CONFIDENTIAL), # 39 Exhibit PLF Deposition Exhibit 127: December 2, 2018 Email re CCO tendering in Havana? (HavanaDocks 480331-333 CONFIDENTIAL), # 40 Exhibit PLF Deposition Exhibit 128: November 12, 2016 Email re Cuba Meetings (HavanaDocks 483959-960 CONFIDENTIAL), # 41 Exhibit PLF Deposition Exhibit 129: October 24, 2015 Email re Final Cuba Report (HavanaDocks 477767 CONFIDENTIAL), # 42 Exhibit PLF Deposition Exhibit 130: September 18, 1997 Fax from Costa Crociere to Airtours and Carnival (HavanaDocks 0484046-049 CONFIDENTIAL), # 43 Exhibit PLF Deposition Exhibit 131: Instagram post of Micky Arison in Cuba, # 44 Exhibit PLF Deposition Exhibit 132: 1996 Airtours Annual Report and accounts, # 45 Exhibit PLF Deposition Exhibit 133: 1997 Airtours Annual Report and accounts, # 46 Exhibit PLF Deposition Exhibit 134: 1996 Costa Cruceros brochure (HDC 18232-35), # 47 Exhibit PLF Deposition Exhibit 134-A: Translation of portion of 1996 Costa Cruceros brochure (HDC 183233), # 48 Exhibit PLF Deposition Exhibit 135: September 15, 2017 Letter to Ministerio Del Transporte from Alfonso Lavarello and attachments (HavanaDocks 484050-062), # 49 Exhibit PLF Deposition Exhibit 136: April 17, 2019 Email re Cuba from Micky Arison to Donald Trump (via Madeleine Westerhout) (HavanaDocks 388212 CONFIDENTIAL), # 50 Exhibit PLF Deposition Exhibit 137: June 30, 2019 Notice of Deposition of Rule 30(b)(6) Representative) (Martinez, Roberto) Modified by Unsealing specific documents on 4/5/2022 pursuant to DE 486 Order (kpe). (Entered: 09/16/2021)

09/16/2021 309 

Sealed Document NOTICE OF FILING EXHIBITS 51-100 CITED IN Plaintiff's Statement of Material Facts in Support of Individual Motion for Summary Judgement Agaisnt Carnival Corporation by Havana Docks Corporation. (Attachments: # 1 Exhibit PLF Deposition Exhibit 40: April 9, 2015 Email re Cuba Forum transcript (HavanaDocks 389058-59), # 2 Exhibit PLF Deposition Exhibit 41: 04-21-15 April 21, 2015 Document entitled About Ownership Claims. Current Sierra Maestra Piers. (HavanaDocks 456819-821), # 3 Exhibit PLF Deposition Exhibit 42: July 13, 2015 Email re Antwort: Cuba Strategy (HavanaDocks 413280-82 CONFIDENTIAL), # 4 Exhibit PLF Deposition Exhibit 43: July 14, 2015 Email re Capitol Hill Cubans (HavanaDocks 0457689-693 CONFIDENTIAL), # 5 Exhibit PLF Deposition Exhibit 44: July 24, 2015 Email re Cuba (HavanaDocks 0457491-92 CONFIDENTIAL), # 6 Exhibit PLF Deposition Exhibit 45: August 17, 2015 Email re Cuban engagement team (HavanaDocks 0443737-739 CONFIDENTIAL), # 7 Exhibit PLF Deposition Exhibit 46: August 19, 2015 Email re Report from Harvard Business review (Havana Docks 0398077-089 CONFIDENTIAL), # 8 Exhibit PLF Deposition Exhibit 47: October 7, 2015 Email re Biografias/CV (HavanaDocks 0359617-628 CONFIDENTIAL), # 9 Exhibit PLF Deposition Exhibit 48: 10-19-15 October 19, 2015 Email re Fathom Agenda October 2015 (HavanaDocks 0457616-618 CONFIDENTIAL), # 10 Exhibit PLF Deposition Exhibit 49: November 9, 2015 Email re Aries Portfolio of foreign investments explained (HavanaDocks 443880-884), # 11 Exhibit PLF Deposition Exhibit 50: January 12, 2016 Email re Cuba (HavanaDocks 457489-490 CONFIDENTIAL), # 12 Exhibit PLF Deposition Exhibit 51: February 3, 2016 Email re Good with Norberto (HavanaDocks 0457819-20 CONFIDENTIAL), # 13 Exhibit PLF Deposition Exhibit 52: March 23, 2016 Email re Cuba (HavanaDocks 0007487 CONFIDENTIAL), # 14 Exhibit PLF Deposition Exhibit 53: April 1, 2016 Email re 2016 - Fathom Cuban additional weeks - PLACEHOLDER w/a question (HavanaDocks 457761-764 CONFIDENTIAL), # 15 Exhibit PLF Deposition Exhibit 54: April 5, 2016 Email re Cuba deployment (HavanaDocks 443397-99 CONFIDENTIAL/VSI), # 16 Exhibit PLF Deposition Exhibit 55: April 13, 2016 Habana Servimar Shipping Agency Spreadsheet for Santiago, Cienfuegos, Havana (HavanaDocks 0457090), # 17 Exhibit PLF Deposition Exhibit 56: May 19, 2016 Email re Costs at the port (HavanaDocks 0443459-60 CONFIDENTIAL), # 18 Exhibit PLF Deposition Exhibit 57: May 31, 2016 Email re Cuba (HavanaDocks 0443458 CONFIDENTIAL, # 19 Exhibit PLF Deposition Exhibit 58: September 5, 2106 Email re Estimating port costs if we dont guarantee the minimum 400 pax (HavanaDocks 457558 CONFIDENTIAL), # 20 Exhibit PLF Deposition Exhibit 59: Transcript of a call Giora Israel and Arnold Donald on 10-27-16 at 7:30 AM Subject Cuba/Adonia/Paradise (HavanaDocks 0475588-592 CONFIDENTIAL), # 21 Exhibit PLF Deposition Exhibit 60: November 11, 2016 Email re Cuba Report - disregard prior version (HavanaDocks 457137-38 CONFIDENTIAL, # 22 Exhibit PLF Deposition Exhibit 61: November 23, 2016 Email re Adonia (HavanaDocks 044914-916 CONFIDENTIAL), # 23 Exhibit PLF Deposition Exhibit 62: February 10, 2017 Email re Escalas Cienfuegos Veendam (HavanaDocks 0443108-110 CONFIDENTIAL), # 24 Exhibit PLF Deposition Exhibit 63: February 3, 2017 Email re Cuba merged TT and KT comments (HavanaDocks 0443111-112 CONFIDENTIAL), # 25 Exhibit PLF Deposition Exhibit 64: May 18, 2017 Email re Final Approval VEENDAM (HavanaDocks 397584-85 CONFIDENTIAL), # 26 Exhibit PLF Deposition Exhibit 65: June 3, 2017 Email re Arnold Donald Letter (HavanaDocks 0358461-464), # 27 Exhibit PLF Deposition Exhibit 66: August 22, 2017 Email re a question from Bisb (HavanaDocks 442924-25), # 28 Exhibit PLF Deposition Exhibit 67: November 1, 2017 Email re New Cubas portfolio of opportunities for foreign investment (HavanaDocks 442930-443082)V1, # 29 Exhibit PLF Deposition Exhibit 67: November 1, 2017 Email re New Cubas portfolio of opportunities for foreign investment (HavanaDocks 442930-443082)V2, # 30 Exhibit PLF Deposition Exhibit 68: December 11, 2017 Email re Invitacion a puertos del Caribe (HavanaDocks 0397568-70 CONFIDENTIAL), # 31 Exhibit PLF Deposition Exhibit 69: January 12, 2018 Email re Recap of conversation with Jose Luis Perdigon in Habana (HavanaDocks 0442711-715 CONFIDENTIAL), # 32 Exhibit PLF Deposition Exhibit 70: July 9, 2018 CCO Evaluation of the possibilities of Nipe Bay for developing a Cruise Port for Modern Cruise Ships (HavanaDocks 0396222-226 CONFIDENTIAL), # 33 Exhibit PLF Deposition Exhibit 71: September 24,2018 Email re Do you need something else for Pre--NY Info (HavanaDocks 360338-342), # 34 Exhibit PLF Deposition Exhibit 72: February 1, 2019 Appointment - Cuba trip Prep. (HavanaDocks 0468216 CONFIDENTIAL), # 35 Exhibit PLF Deposition Exhibit 73: March 15, 2019 Email re Havana (HavanaDocks 0444615-616 CONFIDENTIAL), # 36 Exhibit PLF Deposition Exhibit 74: 3rd Quarter, 2016, Travel & Cruise Magazine article, # 37 Exhibit PLF Deposition Exhibit 75: Compilation of photographs taken by Giora Israel when visiting Cuba (HavanaDocks 0438756-772 CONFIDENTIAL), # 38 Exhibit PLF Deposition Exhibit 76: Photograph of front of Havana Port Terminal, # 39 Exhibit PLF Deposition Exhibit 77: Older map of Havana, showing port with handwriting Havana Docks Property (HDC 1976 (FCSC 387)), # 40 Exhibit PLF Deposition Exhibit 78: Historical photograph of HDC terminal showing front and back of terminal (HDC 1980 (FCSC 391)), # 41 Exhibit PLF Deposition Exhibit 79: Aerial photograph of property (historical) showing front and back views (HDC 1981 (FCSC 392)), # 42 Exhibit PLF Deposition Exhibit 80: 1960 HDC Brochure (HDC 1855 (FCSC 266)), # 43 Exhibit PLF Deposition Exhibit 81: Photograph of Carnival Paradise docked at Havana Port Terminal (HDC 212), # 44 Exhibit PLF Deposition Exhibit 82: Photograph of Fathoms Adonia docked at Havana Port Terminal (HavanaDocks 0346712 CONFIDENTIAL), # 45 Exhibit PLF Deposition Exhibit 83: Photograph of Carnivals Paradise docked at Havana Port Terminal, # 46 Exhibit PLF Deposition Exhibit 84: Photograph of HALs Veendam docked at Havana Port Terminal (HDC 215), # 47 Exhibit PLF Deposition Exhibit 85: Carnival Corporation Form 10K, dated February 25, 1999, # 48 Exhibit PLF Deposition Exhibit 86: Carnival Corporation Form 10Q, dated April 16, 2001, # 49 Exhibit PLF Deposition Exhibit 87: Carnival Corporation Form 10Q, dated July 13, 2001, # 50 Exhibit PLF Deposition Exhibit 88: Photograph of Sundream docked, # 51 Exhibit PLF Deposition Exhibit 89: 1997 Closing Binder - Acquisition of Costa Crociere by Airtours and Carnival Corp. (HavanaDocks 0391478 CONFIDENTIAL)) (Martinez, Roberto) Modified by Unsealing specific documents on 4/5/2022 pursuant to DE 486 Order (kpe). (Entered: 09/16/2021)

09/16/2021 308 

Sealed Document NOTICE OF FILING EXHIBITS 1-50 CITED IN Plaintiff's Statement of Material Facts in Support of Individual Motion for Summary Judgment againt Carnival Corporation by Havana Docks Corporation. (Attachments: # 1 Deposition Enrique Miguez, # 2 Deposition Giora Israel 10/22/2020, # 3 Deposition Arnie Perez 10/23/2020, # 4 Deposition Giora Israel 12/3/2020, # 5 Deposition Arnaldo Perez 12/22/2020, # 6 Deposition Rosamaria Caballero, # 7 Deposition Carlos Estrada, # 8 Deposition Arnaldo Perez 4/27/2021, # 9 Deposition Micky Arison, # 10 Deposition Fred Stein, # 11 Deposition Tara Russell 7/13/2021, # 12 Deposition Tara Russel 7/14/2021, # 13 Deposition Arnaldo Perez 7/21/2021, # 14 Deposition Chris Martin, # 15 Deposition Arnald Donald, # 16 Deposition Tandi Bondi, # 17 Exhibit PLF Deposition Exhibit 1: HDC Notice of Deposition of Carnival Corporations Rule 30(b)(6) witness, dated August 13, 2020, # 18 Exhibit PLF Deposition Exhibit 2: Order following July 16, 2020 Discovery Conference, # 19 Exhibit PLF Deposition Exhibit 3A: Carnival Organizational Chart, # 20 Exhibit PLF Deposition Exhibit 3B: Carnival Organizational Chart, # 21 Exhibit PLF Deposition Exhibit 3C: Carnival Organizational Chart, # 22 Exhibit PLF Deposition Exhibit 4: Carnival's Corporate Disclosure Statement filed in Giglio Sub v Carnival Corp, et al, Case No. 12-cv-21680-UNGARO (S.D. Fla.), # 23 Exhibit PLF Deposition Exhibit 5: Notice of Deposition of Carnival Corporation 30(b)(6) Representative, # 24 Exhibit PLF Deposition Exhibit 6: CCL Due Diligence Chart, # 25 Exhibit PLF Deposition Exhibit 7: Rule 30(b)(6) Deposition Notice, # 26 Exhibit PLF Deposition Exhibit 8: List of deposition topics related to Giora Israel testimony as corporate representative prepared by counsel for Carnival Corporation, # 27 Exhibit PLF Deposition Exhibit 9: Ports of Havana, Matanzas, Mariel & Cienfuegos berth availability for the Adonia in 2016, # 28 Exhibit PLF Deposition Exhibit 10: Ports of Havana, Matanzas, Mariel & Cienfuegos berth availability for the Fantasy Class in 2016, # 29 Exhibit PLF Deposition Exhibit 11: January 1, 2013 PowerPoint re Destination Havana (HavanaDocks 00396172 CONFIDENTIAL), # 30 Exhibit PLF Deposition Exhibit 12: April 7, 2016 Email re Carnival Berthing Requests (HavanaDocks 00346101-157 CONFIDENTIAL), # 31 Exhibit PLF Deposition Exhibit 13: June 23, 2017 Email re Table and Calendar; HavanaDocks 00358282-307 CONFIDENTIAL), # 32 Exhibit PLF Deposition Exhibit 14: April 28, 2017 Carnival Corp & plc timeline of berth requests to Cuba as of 04-28-17 (HavanaDocks 00386187190 CONFIDENTIAL), # 33 Exhibit PLF Deposition Exhibit 15: January 10, 2018 Email re Recap of conversation with Jose Luis Perdigon in Havana (HavanaDocks 00358180-181 CONFIDENTIAL), # 34 Exhibit PLF Deposition Exhibit 16: March 28, 2016 Email re Cuba Berthing requests (HavanaDocks 00378108-122 CONFIDENTIAL), # 35 Exhibit PLF Deposition Exhibit 17: November 10, 2018 Email re Havana XL Rendering (HavanaDocks 00396196-97 CONFIDENTIAL), # 36 Exhibit PLF Deposition Exhibit 18: November 6, 2018 screenshot of schematic/plan of 3 docks in Havana (HavanaDocks 00396251 CONFIDENTIAL), # 37 Exhibit PLF Deposition Exhibit 19: November 6, 2018 Santa Clara doc schematic (HavanaDocks 00396249 CONFIDENTIAL), # 38 Exhibit PLF Deposition Exhibit 20: December 30, 2018 CCL PowerPoint Havana, Updated Dec 2018 (HavanaDocks 0353464 CONFIDENTIAL), # 39 Exhibit PLF Deposition Exhibit 21: September 28, 1971 Certified Claim of HDC, # 40 Exhibit PLF Deposition Exhibit 30: Carnival Corp Excel Workbook of payments to Cuban entities, # 41 Exhibit PLF Deposition Exhibit Perez A: Chart prepared by Carnival Counsel re topics for Arnaldo Perez as Rule 30(b(b)(6) representative, # 42 Exhibit PLF Deposition Exhibit 31: July 1, 1996 Special Report on the Port of Havana by Cuba Caribbean Development Co and Arthur Andersen (HavanaDocks 0438611 CONFIDENTIAL), # 43 Exhibit PLF Deposition Exhibit 32: Autumn, 2009 Cruise Insight Article, # 44 Exhibit PLF Deposition Exhibit 33: January 12, 2012 Carnival PLC PowerPoint Cuba (HavanaDocks 0386482 CONFIDENTIAL), # 45 Exhibit PLF Deposition Exhibit 34: January 22, 2016 Carnival Corp & PLC prep by Global Port and Destination Development Group (HavanaDocks 0457889 CONFIDENTIAL), # 46 Exhibit PLF Deposition Exhibit 35: January 9, 2015 Email re Cuba- webinar (HavanaDocks 0443740-798 CONFIDENTIAL), # 47 Exhibit PLF Deposition Exhibit 36: January 21, 2015 Email re Turkey - Draft agenda Thursday, Jan 22 (HavanaDocks 00457890 CONFIDENTIAL), # 48 Exhibit PLF Deposition Exhibit 37: March 13, 2015 Cuba Fathom Maritime operation detail/status & Action Plan (HavanaDocks 0457552-557 CONFIDENTIAL), # 49 Exhibit PLF Deposition Exhibit 38: March 19, 2015 Email re: reconfirming the itinerary you have asked about (HavanaDocks 359214-15), # 50 Exhibit PLF Deposition Exhibit 39: March 16, 2016 Document entitled The Cuba Strategy (HavanaDocks 0412660-678 CONFIDENTIAL)) (Martinez, Roberto) Modified to Unseal per DE 486 on 4/4/2022 (pes). (Entered: 09/16/2021)

Norwegian Cruise Line Libertad Act Lawsuit: Tens Of Thousands Of Documents Unsealed

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)

Order Unsealing The Summary Judgement Record (4/4/22)

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

04/06/2022 381 

CLERK'S NOTICE of Compliance of Unsealing Sealed Entries re 375 Order to Unseal (pes) (Entered: 04/06/2022)

11/08/2021 311 

Sealed Document Plaintiff Havana Docks Corporation's Reply in Support of Its Individual Motion for Summary Judgment Against Norwegian Cruise Line Holdings Ltd. by Havana Docks Corporation. (Martinez, Roberto) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 11/08/2021)

11/08/2021 309 

Sealed Document Norwegian Cruise Line Holdings Ltd.'s Reply Statement of Material Facts to Havana Docks Corporation's Statement of Material Facts in Support of Its Response in Opposition to Defendant's Individual Motion for Summary Judgment by Norwegian Cruise Line Holdings, Ltd.. (Pegg, Allen) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 11/08/2021)

11/08/2021 308 

Sealed Document Norwegian Cruise Line Holdings Ltd.'s Reply in Support of Its Individual Motion for Summary Judgment by Norwegian Cruise Line Holdings, Ltd.. (Pegg, Allen) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 11/08/2021)

11/08/2021 307 

Sealed Document Defendants' 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 Norwegian Cruise Line Holdings, Ltd.. (Pegg, Allen) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 11/08/2021)

11/08/2021 306 

Sealed Document Defendants' Reply in Support of Their Omnibus Motion for Summary Judgment by Norwegian Cruise Line Holdings, Ltd.. (Pegg, Allen) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 11/08/2021)

11/08/2021 304 

Sealed Document Plaintiff's Reply to Defendants' Additional Facts by Havana Docks Corporation. (Casey, Stephanie) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 11/08/2021)

11/08/2021 303 

Sealed Document PLAINTIFF HAVANA DOCKS CORPORATION'S REPLY IN SUPPORT OF ITS OMNIBUS MOTION FOR PARTIAL SUMMARY JUDGMENT by Havana Docks Corporation. (Martinez, Roberto) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 11/08/2021)

10/22/2021 295 

Sealed Document PLAINTIFF HAVANA DOCKS CORPORATION'S CORRECTED RESPONSE IN OPPOSITION TO DEFENDANTS' OMNIBUS MOTION FOR SUMMARY JUDGMENT by Havana Docks Corporation. (Martinez, Roberto) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 10/22/2021)

10/22/2021 294 

Sealed Document 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 to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 10/22/2021)

10/21/2021 293 

NOTICE OF CONVENTIONAL FILING OF EXHIBIT IN SUPPORT OF PLAINTIFF'S OPPOSITION TO NORWEGIAN CRUISE LINE HOLDING'S STATEMENT OF MATERIAL FACTS of 292 Order on Motion for Leave to File by Havana Docks Corporation (ail) (Entered: 10/21/2021)

10/18/2021 285 

PLAINTIFF'S RESPONSE IN OPPOSITION OF NORWEGIAN'S INDIVIDUAL MOTION FOR SUMMARY JUDGMENT by Havana Docks Corporation. (Martinez, Roberto) Modified docket text/terminated on 10/20/2021 (nc). Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 10/18/2021)

10/18/2021 282 

Sealed Document Norwegian Cruise Line Holdings Ltd.'s Opposing Statement of Facts and Additional Undisputed Material Facts as to Which There is No Genuine Issue to Be Tried by Norwegian Cruise Line Holdings, Ltd.. (Attachments: # 1 Exhibit 68 - NCLH_23591-00525213, # 2 Exhibit 69 - Aries Agreements, # 3 Exhibit 70 - Mambisa Agreements, # 4 Exhibit 71 - Havanatur Agreements, # 5 Exhibit 72 - Fuego Enterprises Fla. Corp. Info, # 6 Exhibit 73 - Fuego Enterprises Nev. Corp. Info, # 7 Exhibit 74 - OnCuba Travel Fla. Corp. Info, # 8 Exhibit 75 - Fuego Agreements, # 9 Exhibit 76 - FOIA Response, # 10 Exhibit 77 - List of Restricted Entities and Subentities, # 11 Exhibit 78 - H. Cancio Declaration, # 12 Exhibit 79 - Manjencic Declaration, # 13 Exhibit 80 - NCLH_23591-00563842, # 14 Exhibit 81 - May 7, 2015 Auth. Req. to OFAC, # 15 Exhibit 82 - OFAC License, # 16 Exhibit 83 - Deposition of Gianluca Suprami) (Pegg, Allen) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 10/18/2021)

10/18/2021 281 

Sealed Document Norwegian Cruise Line Holdings Ltd.'s Response in Opposition to Havana Docks Corporation's Individual Motion for Summary Judgment by Norwegian Cruise Line Holdings, Ltd.. (Pegg, Allen) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 10/18/2021)

10/18/2021 280 

Sealed Document Defendants' Opposing Statement of Facts and Additional Undisputed Material Facts as to Which There is No Genuine Issue to Be Tried by Norwegian Cruise Line Holdings, 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 Notarial Code of 1929, # 6 Exhibit 130 - December 9, 2020 Jerry Johnson Deposition, # 7 Exhibit 131 - HDC023141, # 8 Exhibit 132 - July 30, 2021 T. Bondi Deposition, # 9 Exhibit 133 - April 1, 2021 Jerry Johnson Deposition) (Pegg, Allen) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 10/18/2021)

10/18/2021 279 

Sealed Document NOTICE OF FILING EXHIBITS CITED IN PLAINTIFF'S OPPOSITION TO NORWEGIAN CRUISE LINE HOLDING'S STATEMENT MATERIAL FACTS by Havana Docks Corporation. (Attachments: # 1 Exhibit 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), # 2 Exhibit March 7, 2019 Email re Question about Havana (NCLH_23591-00008021-8022), # 3 Exhibit Spreadsheet re Embarkation Day Miami Terminal J USA SIR180504 (NCLH_23591-00063657), # 4 Exhibit Video: Opportunities in Tourism, Payments and Retail Banking) (Martinez, Roberto) Modified to Unseal per DE 375 Order on 4/6/2022 (pes). (Entered: 10/18/2021)

10/18/2021 278 

Sealed Document Defendants' Response in Opposition to Plaintiff's Omnibus Motion for Partial Summary Judgment by Norwegian Cruise Line Holdings, Ltd.. (Pegg, Allen) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 10/18/2021)

10/18/2021 277 

Sealed Document 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 to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 10/18/2021)

10/18/2021 276 

SEALED MOTION Plaintiff Havana Docks Corporation's Response in Opposition to Defendants' Omnibus Motion for Summary Judgment by Havana Docks Corporation. (Martinez, Roberto) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 10/18/2021)

09/21/2021 240 

Statement of: UNDISPUTED MATERIAL FACTS (REDACTED) by Norwegian Cruise Line Holdings, Ltd. re 239 MOTION for Summary Judgment (OMNIBUS) (Attachments: # 1 Exhibit Ex. 2 - HDC 015213, # 2 Exhibit Ex. 3 - HDC-CCL000596, # 3 Exhibit Ex. 4 - HDC-CCL000552, # 4 Exhibit Ex. 5 - HDC-CCL000353, # 5 Exhibit Ex. 6 - RCL-Havana0000417-18, # 6 Exhibit Ex. 7 - RCL-Havana0000419-634, # 7 Exhibit Ex. 8 - RCL-Havana0000635-768, # 8 Exhibit Ex. 9 - RCL-Havana0000769, # 9 Exhibit Ex. 10 - NCLH_23591-00556558, # 10 Exhibit Ex. 11 - NCLH_23591-00027586, # 11 Exhibit Ex. 12 - 2020-05-29 RCL_s Responses to HDC_s 1st Interrogatories, # 12 Exhibit Ex. 13 - RCL-0001021, # 13 Exhibit Ex. 19 - 09-08-2020 - MSC First Supp. ROG Responses, # 14 Exhibit Ex. 21 - NCLH_23591-00019453, # 15 Exhibit Ex. 22 - RCL-0001021, # 16 Exhibit Ex. 27 - 2021_08_30 MSC Objs and Responses to 3rd Set of ROGs, # 17 Exhibit Ex. 45 - RCL-Havana0078270_RCL-Havana0012999, # 18 Exhibit Ex. 60 - NCLH_23591-00017356, # 19 Exhibit Ex. 64 - NCLH_23591-00014456, # 20 Exhibit Ex. 66 - NCLH_23591-00006355, # 21 Exhibit Ex. 68 - RCL-Havana0011532-565, # 22 Exhibit Ex. 69 - RCL-Havana0080835-68, # 23 Exhibit Ex. 70 - RCL-Havana0080798-830, # 24 Exhibit Ex. 71 - RCL-Havana00202129-62, # 25 Exhibit Ex. 77 - NCLH_23591-00021644, # 26 Exhibit Ex. 79 - Declaration of L. Pastena - Sept. 18, 2021, # 27 Exhibit Ex. 81 - HDC 001498, # 28 Exhibit Ex. 83 - HDC014348, # 29 Exhibit Ex. 84 - HDC016084, # 30 Exhibit Ex. 86 - HDC001013_image, # 31 Exhibit Ex. 87 - HDC013553_image, # 32 Exhibit Ex. 88 - HDC001328_image, # 33 Exhibit Ex. 89 - HDC001498_image, # 34 Exhibit Ex. 91 - HDC 2nd Amended Ans to NCL 3-Rogs (Signed), # 35 Exhibit Ex. 94 - HDC 001493, # 36 Exhibit Ex. 95 - HDC 023141, # 37 Exhibit Ex. 96 - 2021-07-07 - [19-23591] - Plaintiff_s Answers to NCL_s Amended First Set of RFAs, # 38 Exhibit Ex. 98 - HDC 18866, # 39 Exhibit Ex. 101 - HDC 001357, # 40 Exhibit Ex. 103 - HDC 014943, # 41 Exhibit Ex. 106 - HDC 017612, # 42 Exhibit Ex. 107 - HDC 000940, # 43 Exhibit Ex. 108 - HDC 001137, # 44 Exhibit Ex. 113 - HDC 016486, # 45 Exhibit Ex. 116 - AJohnson 0525, # 46 Exhibit Ex. 118 - AJohnson 0088, # 47 Exhibit Ex. 119 - AJohnson 0087, # 48 Exhibit Ex. 123 - HDC 015350, # 49 Exhibit Ex. 124 - HDC 014705, # 50 Exhibit Exhibits unavailable in public record - filed under seal)(Lorenzo, Richard) (Entered: 09/21/2021)

09/21/2021238 

Statement of: Undisputed Material Facts as to Which There is No Genuine Issue to Be Tried by Norwegian Cruise Line Holdings, Ltd. re 236 MOTION for Summary Judgment (Attachments: # 1 Exhibit Ex. 1 - NCLH_23591-00556558, # 2 Exhibit Ex. 2 - NCLH_23591-00570521, # 3 Exhibit Ex. 3 - NCLH_2359-00559898, # 4 Exhibit Ex. 4 - NCLH_2391-00027586, # 5 Exhibit Ex. 6 - NCLH_23591-0001453, # 6 Exhibit Ex. 9 - NCLH_s Amened Responses and Objections to HDC_s First Set of RFAs, # 7 Exhibit Ex. 10 - Decree 1944, # 8 Exhibit Ex. 14 - NCLH_23591-00564216, # 9 Exhibit Ex. 19 - NCLH_23591-00016266, # 10 Exhibit Ex. 20 - NCLH23591-00566910, # 11 Exhibit Ex. 24 - NCLH_23591-00036520, # 12 Exhibit Ex. 25 - NCLH_23591-00581276, # 13 Exhibit Ex. 26 - NCLH_23591-00581277, # 14 Exhibit Ex. 27 - NCLH_23591-00000076, # 15 Exhibit Ex. 28 - NCLH_23591-00012652, # 16 Exhibit Ex. 29 - NCLH_23591-00007971, # 17 Exhibit Ex. 30 - NCLH_23591-00016297, # 18 Exhibit Ex. 31 - NCLH_23591-00016491, # 19 Exhibit Ex. 33 - NCLH_23591-00056382, # 20 Exhibit Ex. 34 - NCLH_23591-00056400, # 21 Exhibit Ex. 35 - NCLH_23591-00056393, # 22 Exhibit Ex. 36 - NCLH_23591-00055356, # 23 Exhibit Ex. 40 - HDC 014326, # 24 Exhibit Ex. 42 - HDC 014348, # 25 Exhibit Ex. 45 - Plaintiff_s Answers to NCL_s Amended First Set of RFAs, # 26 Exhibit Ex. 46 - HDC 014666, # 27 Exhibit Ex. 47 - HDC 016084, # 28 Exhibit Ex. 49 - HDC 001013, # 29 Exhibit Ex. 50 - HDC 013553, # 30 Exhibit Ex. 51 - HDC 001328, # 31 Exhibit Ex. 52 - HDC 001498, # 32 Exhibit Ex. 56 - NCLH_23591-00017870, # 33 Exhibit Ex. 57 - NCLH_23591-00021644, # 34 Exhibit Ex. 58 - NCLH_23591-00067200, # 35 Exhibit Ex. 59 - NCLH_23591-00017356, # 36 Exhibit Ex. 63 - NCLH_23591-00014456, # 37 Exhibit Ex. 65 - NCLH_23591-00006355, # 38 Exhibit Ex. 67 - HavanaDocks_0438773, # 39 Exhibit Cover Sheet for Exhibits Filed Under Seal)(Pegg, Allen) (Entered: 09/21/2021)

09/21/2021237 

Sealed Document OMNIBUS STATEMENT OF UNDISPUTED MATERIAL FACTS (WITH EXHIBITS 61-124) by Norwegian Cruise Line Holdings, Ltd.. (Attachments: # 1 Exhibit Ex. 61 - NCLH_23591-00017179 (FILED UNDER SEAL), # 2 Exhibit Ex. 62 - NCLH_23591-00017357 (FILED UNDER SEAL), # 3 Exhibit Ex. 63 - NCLH_23591-00017359 (FILED UNDER SEAL), # 4 Exhibit Ex. 64 - NCLH_23591-000144564 - NCLH_23591-00014456, # 5 Exhibit Ex. 65 - NCLH_23591-00015571 (FILED UNDER SEAL), # 6 Exhibit Ex. 66 - NCLH_23591-00006355, # 7 Exhibit Ex. 67 - Deposition of N. Skogland - Feb. 2, 2021, # 8 Exhibit Ex. 68 - RCL-Havana0011532-565, # 9 Exhibit Ex. 69 - RCL-Havana0080835-68, # 10 Exhibit Ex. 70 - RCL-Havana0080798-830, # 11 Exhibit Ex. 71 - RCL-Havana00202129-62, # 12 Exhibit Ex. 72 - HavanaDocks_0353423, # 13 Exhibit Ex. 73 - HavanaDocks_0353427, # 14 Exhibit Ex. 73 - HavanaDocks_0353427, # 15 Exhibit Ex. 75 - HavanaDocks_0363301, # 16 Exhibit Ex. 76 - HavanaDocks_0444392, # 17 Exhibit Ex. 77 - NCLH_23591-00021644, # 18 Exhibit Ex. 78 - April 27, 2021, Arnaldo Perez Deposition Transcript & Exhibits, # 19 Exhibit Ex. 79 - Declaration of L. Pastena - Sept. 18, 2021, # 20 Exhibit Ex. 80 - Deposition of H. Cancio - Nov. 12, 2020, # 21 Exhibit Ex. 81 - HDC 001498, # 22 Exhibit Ex. 82 - SEAL Deposition of Jerry Johnson - Jan. 19, 2021, # 23 Exhibit Ex. 83 - HDC014348, # 24 Exhibit Ex. 84 - HDC016084, # 25 Exhibit Ex. 85 - Deposition of D. Kim - Apr. 14, 2021, # 26 Exhibit Ex. 86 - HDC001013_image, # 27 Exhibit Ex. 87 - HDC013553_image, # 28 Exhibit Ex. 88 - HDC001328_image, # 29 Exhibit Ex. 89 - HDC001498_image, # 30 Exhibit Ex. 90 - HDC Second Amended Answers to Rog No. 4 of NCL Second Set of Interrogatories (FILED UNDER SEAL), # 31 Exhibit Ex. 91 - HDC 2nd Amended Ans to NCL 3-Rogs (Signed), # 32 Exhibit Ex. 92 - Deposition of J. Johnson - Dec. 8, 2020, # 33 Exhibit Ex. 93 - Deposition of M. Behn - Dec. 14, 2020, # 34 Exhibit Ex. 94 - HDC 001493, # 35 Exhibit Ex. 95 - HDC 023141, # 36 Exhibit Ex. 96 - 2021-07-07 - [19-23591] - Plaintiff_s Answers to NCL_s Amended First Set of RFAs, # 37 Exhibit Ex. 97 - HDC 013255 (FILED UNDER SEAL), # 38 Exhibit Ex. 98 - HDC 18866, # 39 Exhibit Ex. 99 - Amended Declaration of J. Ackert - June 8, 2021, # 40 Exhibit Ex. 100 - Deposition of J. Ackert - June 22, 2021, # 41 Exhibit Ex. 101 - HDC 001357, # 42 Exhibit Ex. 102 - HDC 017586 (FILED UNDER SEAL), # 43 Exhibit Ex. 103 - HDC 014943, # 44 Exhibit Ex. 104 - HDC 017556 (FILED UNDER SEAL), # 45 Exhibit Ex. 105 - HDC 017564 (FILED UNDER SEAL), # 46 Exhibit Ex. 106 - HDC 017612, # 47 Exhibit Ex. 107 - HDC 000940, # 48 Exhibit Ex. 108 - HDC 001137, # 49 Exhibit Ex. 109 - HDC 016251 (FILED UNDER SEAL), # 50 Exhibit Ex. 110 - HDC 016254 (FILED UNDER SEAL), # 51 Exhibit Ex. 111 - HDC 016329 (FILED UNDER SEAL), # 52 Exhibit Ex. 112 - HDC 016398 (FILED UNDER SEAL), # 53 Exhibit Ex. 113 - HDC 016486, # 54 Exhibit Ex. 114 - HDC 017556 (FILED UNDER SEAL), # 55 Exhibit Ex. 115 - HDC 021750 (FILED UNDER SEAL), # 56 Exhibit Ex. 116 - AJohnson 0525, # 57 Exhibit Ex. 117 - Deposition of A. Johnson - Apr. 9, 2021, # 58 Exhibit Ex. 118 - AJohnson 0088, # 59 Exhibit Ex. 119 - AJohnson 0087, # 60 Exhibit Ex. 120 - HDC 021512ddp (FILED UNDER SEAL), # 61 Exhibit Ex. 121 - HDC 021720ddp (FILED UNDER SEAL), # 62 Exhibit Ex. 122 - MAC001313 (FILED UNDER SEAL), # 63 Exhibit Ex. 123 - HDC 015350, # 64 Exhibit Ex. 124 - HDC 014705) (Lorenzo, Richard) Modified to Unseal per DE 375 Order on 4/6/2022 (pes). (Entered: 09/21/2021)

09/20/2021235 

Sealed Document OMNIBUS STATEMENT OF UNDISPUTED MATERIAL FACTS (WITH EXHIBITS 1-60) by Norwegian Cruise Line Holdings, Ltd.. (Attachments: # 1 Exhibit Ex. 1 - Expert Report of Ambar Diaz, Esq. 3-19-21, # 2 Exhibit Ex. 1, Ex. 1 Map of Piers- Google, # 3 Exhibit Ex. 1, Ex. 3 Decrees that form Concession, # 4 Exhibit Ex. 1, Ex. 4 Law of Public Works, # 5 Exhibit Ex. 1, Ex. 5 Case Law, # 6 Exhibit Ex. 1, Ex. 6 Scovel, # 7 Exhibit Ex. 1, Ex. 7 (law), # 8 Exhibit Ex. 1, Ex. 8 Aries License, # 9 Exhibit Ex. 1, Ex. 9 Aries, # 10 Exhibit Ex. 1, Ex. 10 Servimar Bulletin, # 11 Exhibit Ex. 2 - HDC 015213, # 12 Exhibit Ex. 3 - HDC-CCL000596, # 13 Exhibit Ex. 4 - HDC-CCL000552, # 14 Exhibit Ex. 5 - HDC-CCL000353, # 15 Exhibit Ex. 6 - RCL-Havana0000417-18, # 16 Exhibit Ex. 7 - RCL-Havana0000419-634, # 17 Exhibit Ex. 8 - RCL-Havana0000635-768, # 18 Exhibit Ex. 9 - RCL-Havana0000769, # 19 Exhibit Ex. 10 - NCLH_23591-00556558, # 20 Exhibit Ex. 11 - NCLH_23591-00027586, # 21 Exhibit Ex. 12 - 2020-05-29 RCL_s Responses to HDC_s 1st Interrogatories, # 22 Exhibit Ex. 13 - RCL-0001021, # 23 Exhibit Ex. 14 - [2015 BIS License]_HavanaDocks_0359965, # 24 Exhibit Ex. 15 - 2015 BIS Authorization Email_HavanaDocks_0359958, # 25 Exhibit Ex. 16 - December 22, 2020, Arnaldo Perez Deposition Transcript & Exhibits - Part 1, # 26 Exhibit Ex. 16 - December 22, 2020, Arnaldo Perez Deposition Transcript & Exhibits - Part 2, # 27 Exhibit Ex. 16 - December 22, 2020, Arnaldo Perez Deposition Transcript & Exhibits - Part 3, # 28 Exhibit Ex. 16 - December 22, 2020, Arnaldo Perez Deposition Transcript & Exhibits - Part 4, # 29 Exhibit Ex. 16 - December 22, 2020, Arnaldo Perez Deposition Transcript & Exhibits - Part 5, # 30 Exhibit Ex. 17 - [2015 OFAC License Letter]_HavanaDocks_0345551, # 31 Exhibit Ex. 18 - [2015 OFAC license]_HavanaDocks_0345553, # 32 Exhibit Ex. 19 - 09-08-2020 - MSC First Supp. ROG Responses, # 33 Exhibit Ex. 20 - Norwegian_s Second Amended Responses and Objections to First Set of Rogs, # 34 Exhibit Ex. 21 - NCLH_23591-00019453, # 35 Exhibit Ex. 22 - RCL-0001021, # 36 Exhibit Ex. 23 - July 29, 2021, Arnold Donald Deposition Transcript & Exhibits, # 37 Exhibit Ex. 24 - SEAL Deposition of Jorge Delgado - Mar. 30, 2021, # 38 Exhibit Ex. 25 - SEAL Deposition of Chris Allen - Oct. 9, 2020, # 39 Exhibit Ex. 26 - SEAL Deposition of Bradley Stein - Nov. 20, 2020 - Part 1 of 3, # 40 Exhibit Ex. 26 - SEAL Deposition of Bradley Stein - Nov. 20, 2020 - Part 2 of 3, # 41 Exhibit Ex. 26 - SEAL Deposition of Bradley Stein - Nov. 20, 2020 - Part 3 of 3, # 42 Exhibit Ex. 27 - 2021_08_30 MSC Objs and Responses to 3rd Set of ROGs, # 43 Exhibit Ex. 28 - Deposition of M. Parodi - Nov. 5, 2020 - Part 1 of 3, # 44 Exhibit Ex. 28 - Deposition of M. Parodi - Nov. 5, 2020 - Part 2 of 3, # 45 Exhibit Ex. 28 - Deposition of M. Parodi - Nov. 5, 2020 - Part 3 of 3, # 46 Exhibit Ex. 29 - NCLH Responses and Objections to Second Set of Interrogatories, # 47 Exhibit Ex. 30 - December 3, 2020, Giora. Israel Deposition Transcript & Exhibits - Part 1 (1-450), # 48 Exhibit Ex. 30 - December 3, 2020, Giora. Israel Deposition Transcript & Exhibits - Part 2 (451-625), # 49 Exhibit Ex. 30 - December 3, 2020, Giora. Israel Deposition Transcript & Exhibits - Part 3 (626-744), # 50 Exhibit Ex. 31 - HavanaDocks_0378115, # 51 Exhibit Ex. 32 - HavanaDocks_0378131, # 52 Exhibit Ex. 33 - HavanaDocks_0385087, # 53 Exhibit Ex. 34 - HavanaDocks_0386061, # 54 Exhibit Ex. 35 - HavanaDocks_0386325, # 55 Exhibit Ex. 36 - HavanaDocks_0412496, # 56 Exhibit Ex. 37 - HavanaDocks_0412509, # 57 Exhibit Ex. 38 - HavanaDocks_0413044, # 58 Exhibit Ex. 39 - HavanaDocks_0413052, # 59 Exhibit Ex. 40 - HavanaDocks_0413138, # 60 Exhibit Ex. 41 - HavanaDocks_0413834, # 61 Exhibit Ex. 42 - HavanaDocks_0413842, # 62 Exhibit Ex. 43 - HavanaDocks_0438942, # 63 Exhibit Ex. 44 - SEAL Deposition of Adam Goldstein - Apr. 21, 2021, # 64 Exhibit Ex. 45 - RCL-Havana0078270_RCL-Havana0012999, # 65 Exhibit Ex. 46 - SEAL composite ex aries contracts, # 66 Exhibit Ex. 47 - SEAL_MSCCUSA0000079403, # 67 Exhibit Ex. 48 - NCLH_23591-00524981 (FILED UNDER SEAL), # 68 Exhibit Ex. 49, # 69 Exhibit Ex. 50 - HavanaDocks_0358180, # 70 Exhibit Ex. 51 - HavanaDocks_0353427, # 71 Exhibit Ex. 52 - HavanaDocks_0438773, # 72 Exhibit Ex. 53 - October 22, 2020, Giora Israel Deposition Transcript & Exhibits, # 73 Exhibit Ex. 54 - SEAL Deposition of M. Mio - Apr. 29, 2021, # 74 Exhibit Ex. 55 - SEAL Deposition of L. Pastena - June 17, 2021, # 75 Exhibit Ex. 56 - SEAL Deposition of G. Onorato - Jan. 14, 2021., # 76 Exhibit Ex. 57 - Deposition of F. Del Rio - Dec. 7, 2020, # 77 Exhibit Ex. 58 - Deposition of D. Farkas - Aug. 4, 2021, # 78 Exhibit Ex. 59 - Deposition of E. Cruz - Apr. 27, 2021, # 79 Exhibit Ex. 60 - NCLH_23591-00017356) (Lorenzo, Richard) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 09/21/2021)

09/20/2021234 

Sealed Document Statement of Undisputed Material Facts as to Which There is No Genuine Issue to Be Tried by Norwegian Cruise Line Holdings, Ltd.. (Attachments: # 1 Exhibit Ex. 1 - NCLH_23591-00556558, # 2 Exhibit Ex. 2 - NCLH_23591-0570521, # 3 Exhibit Ex. 3 - NCLH_23591-0559898, # 4 Exhibit Ex. 4 - NCLH_23591-00027586, # 5 Exhibit Ex. 5 - Norwegian_s Second Amended Responses and Objections to First Set of Interrogatories, # 6 Exhibit Ex. 6 - NCLH_23591-00019453, # 7 Exhibit Ex.7 - Deposition of M. Parodi - Nov. 5, 2020 - Part 1 of 3, # 8 Exhibit Ex. 7 - Deposition of M. Parodi - Nov. 5, 2020 - Part 2 of 3, # 9 Exhibit Ex. 7 - Deposition of M. Parodi - Nov. 5, 2020 - Part 3 of 3, # 10 Exhibit Ex. 8 -NCLH Responses and Objections to Second Set of Interrogatories, # 11 Exhibit Ex. 9 - NCLH_s Amended Responses and Objections to HDC_s First Set of RFAs, # 12 Exhibit Ex. 10 - Decree 1944, # 13 Exhibit Ex. 10 - Decree 1944, # 14 Exhibit Ex. 12 - HDC 018289 (FILED UNDER SEAL), # 15 Exhibit Ex. 13 - HDC 015207 (FILD UNDER SEAL), # 16 Exhibit Ex. 14 - NCLH_23591-00564216, # 17 Exhibit Ex. 15 - Deposition of D. Farkas - Aug. 4, 2021, # 18 Exhibit Ex. 16 - Deposition of L. Vidal - Dec. 4, 2020 - Part 1 of 2, # 19 Exhibit Ex. 16 - Deposition of L. Vidal - Dec. 4, 2020 - Part 2 of 2, # 20 Exhibit Ex. 17 - Deposition of C. Manjencic - Feb. 11, 2021, # 21 Exhibit Ex. 18 - Deposition of D. Farkas - Aug. 4, 2021, # 22 Exhibit Ex. 19 - NCLH_23591-00016266, # 23 Exhibit Ex. 20 - NCLH_23591-00566910, # 24 Exhibit Ex. 21 - NCLH_23591-00126373 (FILED UNDER SEAL), # 25 Exhibit Ex. 22 - NCLH_23591-00423255 (FILED UNDER SEAL), # 26 Exhibit Ex. 23 - NCLH_23591-00127627 (FILED UNDER SEAL), # 27 Exhibit Ex. 24 - NCLH_23591-00036520, # 28 Exhibit Ex. 25 - NCLH_23591-00581276, # 29 Exhibit Ex. 26 - NCLH_23591-00581277, # 30 Exhibit Ex. 27 - NCLH_23591-00000076, # 31 Exhibit Ex. 28 - NCLH_23591-00012652, # 32 Exhibit Ex. 29 - NCLH_23591-00007971, # 33 Exhibit Ex. 30 - NCLH_23591-00016297, # 34 Exhibit Ex. 31 - NCLH_23591-00016491, # 35 Exhibit Ex. 32 - Deposition of F. Del Rio - Dec. 7, 2020, # 36 Exhibit Ex. 33 - NCLH_23591-00056382, # 37 Exhibit Ex. 34 - NCLH_23591-00056400, # 38 Exhibit Ex. 35 - NCLH_23591-00056393, # 39 Exhibit Ex. 36 - NCLH_23591-00055356, # 40 Exhibit Ex. 37 - NCLH_23591-00091283 (FILED UNDER SEAL), # 41 Exhibit Ex. 38 - NCLH_23591-00091308 (FILED UNDER SEAL), # 42 Exhibit Ex. 39 - HDC 017218 (FILED UNDER SEAL), # 43 Exhibit Ex. 40 - HDC 014326, # 44 Exhibit Ex. 41 - Deposition of J. Johnson - Dec. 8, 2020, # 45 Exhibit Ex. 42 - HDC 014348, # 46 Exhibit Ex. 43 - Deposition of J. Johnson - Dec. 9, 2020, # 47 Exhibit Ex. 44 - Deposition of M. Behn - Dec. 14, 2020, # 48 Exhibit Ex. 45 - Plaintiff_s Answers to NCL_s Amended First Set of RFAs, # 49 Exhibit Ex. 46 - HDC 014666, # 50 Exhibit Ex. 47 - HDC 016084, # 51 Exhibit Ex. 48 - Deposition of D. Kim - Apr. 14, 2021, # 52 Exhibit Ex. 49 - HDC 001013, # 53 Exhibit Ex. 50 - HDC 013553, # 54 Exhibit Ex. 51 - HDC 001328, # 55 Exhibit Ex. 52 - HDC 001498, # 56 Exhibit Ex. 53 - Expert Report of Ambar Diaz, Esq. 3-19-21, # 57 Exhibit Ex. 53, Ex. 1, # 58 Exhibit Ex. 53, Ex. 2, # 59 Exhibit Ex. 53, Ex. 3, # 60 Exhibit Ex. 53, Ex. 4, # 61 Exhibit Ex. 53, Ex. 5, # 62 Exhibit Ex. 53, Ex. 6, # 63 Exhibit Ex. 53, Ex. 7, # 64 Exhibit Ex. 53, Ex. 8, # 65 Exhibit Ex. 53, Ex. 9, # 66 Exhibit Ex. 53, Ex. 10, # 67 Exhibit Ex. 54 - Deposition of E. Cruz - Apr. 27, 2021, # 68 Exhibit Ex. 55 - NCLH_23591-00524981 (FILED UNDER SEAL), # 69 Exhibit Ex. 56 - NCLH_23591-00017870, # 70 Exhibit Ex. 57 - NCLH_23591-00021644, # 71 Exhibit Ex. 58 - NCLH_23591-00067200, # 72 Exhibit Ex. 59 - NCLH_23591-00017356, # 73 Exhibit Ex. 60 - NCLH_23591-00017179 (FILED UNDER SEAL), # 74 Exhibit Ex. 61 - NCLH_23591-00017357 (FILED UNDER SEAL), # 75 Exhibit Ex. 62 - NCLH_23591-00017359 (FILED UNDER SEAL), # 76 Exhibit Ex. 63 - NCLH_23591-00014456, # 77 Exhibit Ex. 64 - NCLH_23591-00015571 (FILED UNDER SEAL), # 78 Exhibit Ex. 65 - NCLH_23591-00006355, # 79 Exhibit Ex. 66 - Deposition of H. Cancio - Nov. 12, 2020, # 80 Exhibit Ex. 67 - HavanaDocks_0438773) (Pegg, Allen) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 09/21/2021)

09/20/2021233 

Plaintiff's SEALED MOTION HAVANA DOCKS CORPORATIONS OMNIBUS STATEMENT OF MATERIAL FACTS IN SUPPORT OF ITS OMNIBUS MOTION FOR SUMMARY JUDGMENT by Havana Docks Corporation. (Martinez, Roberto) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 09/20/2021)

09/20/2021232 

Plaintiff's SEALED MOTION PLAINTIFF HAVANA DOCKS CORPORATIONS OMNIBUS MOTION FOR PARTIAL SUMMARY JUDGMENT by Havana Docks Corporation. (Martinez, Roberto) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 09/20/2021)

09/20/2021231 

Sealed Document NOTICE OF FILING EXHIBITS 62-63 CITED IN PLAINTIFFS STATEMENT OF MATERIAL FACTS IN SUPPORT OF OMNIBUS MOTION FOR SUMMARY JUDGMENT AGAINST DEFENDANTS by Havana Docks Corporation. (Attachments: # 1 Exhibit Havana Docks Corporations Second Amended and Supplemental Answer and Objections to Defendants Third Set of Interrogatories dated July 30, 2021, # 2 Exhibit Havana Docks Corporations Answers and Objections to the First Request for Admissions Served by Defendant dated March 19, 2021) (Martinez, Roberto) Modified to Unseal per DE 375 Order on 4/6/2022 (pes). (Entered: 09/20/2021)

09/20/2021230 

SEALED MOTION for Summary Judgment by Norwegian Cruise Line Holdings, Ltd.. (Pegg, Allen) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 09/20/2021)

09/20/2021 229 

Plaintiff's SEALED MOTION Plaintiff Havana Docks Corp's Individual Motion for Summary Judgment Against Norwegian Cruise Line Holdings, Ltd. by Havana Docks Corporation. (Martinez, Roberto) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 09/20/2021)

09/20/2021 228 

Plaintiff Havana Docks Corporation's Statement of Material Facts in Support of Its Individual Motion for Summary Judgment Against Norwegian Cruise Line Holdings Ltd. by Havana Docks Corporation. (Martinez, Roberto) Modified docket text/terminated date entered on 9/22/2021 (nc). Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 09/20/2021)

09/20/2021 227 

SEALED MOTION OMNIBUS MOTION FOR SUMMARY JUDGMENT by Norwegian Cruise Line Holdings, Ltd.. (Pegg, Allen) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 09/20/2021)

09/20/2021 224 

Sealed Document 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 to Unseal per DE 375 Order on 4/6/2022 (pes). (Entered: 09/20/2021)

09/20/2021 223 

Sealed Document Notice of Filing Exhibits 188-189 Cited in Plaintiff's Statement of Material Facts in Support of Individual Motion for Summary Judgment Against Norwegian Cruise Line Holdings LTD by Havana Docks Corporation. (Attachments: # 1 June 9, 2015 Email re Letter from Mr. Pierfrancesco Vago (certified translation and original) MSCCUSA0000077298-773010, # 2 Spreadsheet: MSC Cruises Cover Itinerary released on Thu, May 12, 2016, 12:53 (MSC0000049805 CONFIDENTIAL)) (Martinez, Roberto) Modified to Unseal per DE 375 Order on 4/6/2022 (pes). (Entered: 09/20/2021)

09/19/2021 221 

Sealed Document Notice of Filing Exhibits 149-186 Cited in Plaintiff's Statement of Material Facts in Support of Individual Motion for Summary Judgment Against Norwegian Cruise Line Holdings LTD by Havana Docks Corporation. (Attachments: # 1 Exhibit Norwegian Cruise Line Holdings, Ltd.s Amended Responses and Objections to Plaintiffs First Set of Interrogatories, dated September 8, 2020, # 2 Exhibit Norwegian Cruise Line Holdings, Ltd.s Supplemental Answers to Plaintiffs First Set of Interrogatories, dated January 18, 2021, # 3 Exhibit Norwegian Cruise Line Holdings, Ltd.s Response and Objections to Plaintiffs First Request for Admissions, dated August 30, 2021, # 4 Exhibit Norwegian Cruise Line Holdings, Ltd.s Amended Answers and Objections to Plaintiffs First Request for Admissions, dated September 8, 2021, # 5 Exhibit Norwegian Cruise Line Holdings, Ltd.s Supplemental Answer to Havana Docks Corporations First Set of Interrogatories, dated September 8, 2021, # 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, # 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, # 8 Exhibit Carnival Itinerary information for the Veendam (Exhibit PS-123 to Expert Report of Pedro Spiller ATTORNEYS EYES ONLY), # 9 Exhibit Cuba Conflicts spreadsheet, 2016-2017 (certified translation and original) (HavanaDocks_0397711), # 10 Exhibit February 13, 2019 Email from Fernando Perez to Giora Israel re Havana meetings First Draft dated 02-13-2019 (HavanaDocks_0484025-48429 CONFIDENTIAL), # 11 Exhibit PLF Deposition Exhibit 86 in Havana Docks Corporation v MSC: May 13, 2015 Email re MSC Opera Report on the Havana Harbor (MSCUSA00000077416-420 CONFIDENTIAL), # 12 Exhibit June 15, 2015 Email re Meeting (MSCCUSA00000077311-77350 CONFIDENTIAL), # 13 Exhibit Spreadsheet titled Temporada 2016-2017 (in Spanish) (MSCCUSA00000080571) CONFIDENTIAL), # 14 Exhibit April 1, 2015 Video of Frank Del Rio Wharton Business School Interview (HDC-NCL000945), # 15 Exhibit Transcript of April 1, 2015 Video of Frank Del Rio Wharton Business School Interview, # 16 Exhibit Document titled Shore Excursion Overview, Miami, USA to Miami, USA, September 24, 2018 to October 3, 2018 (NCLH_23591-00008367-8374, # 17 Exhibit List of NCLH payments to Aries (NCLH_23591-0014316 CONFIDENTIAL), # 18 Exhibit List of NCLH payments to Empresa Consignataria Mambisa (NCLH_23591-0014318 CONFIDENTIAL), # 19 Exhibit List of NCLH payments to Havanatur (NCLH_23591-0014319 CONFIDENTIAL), # 20 Exhibit Habana-Servimar Shipping Agency information sheet re Havana Port (NCLH_23591-00021644-21655), # 21 Exhibit Document titled Shore Excursions Tour Descriptions (NCLH_23591-00036792-36797), # 22 Exhibit March 4, 2019 Email re Seven Seas Voyager upcoming call to Havana on 06th March 2019 (certified translation and original) (NCLH_23591-00049220-49222), # 23 Exhibit Spreadsheet: Embarkation Day Miami Terminal J USA SIR180504 (NCLH_23591-00063657), # 24 Exhibit March 30, 2017 Email re Harry Summer / Oncuba Travel / Havanatur (NCLH_23591-00102734-102736), # 25 Exhibit Contract No. 18/2016 between Aires Transportes, S.A. and Norwegian Cruise Line Holdings, Ltd. (in Spanish) (NCLH_23591-0052981-524993 CONFIDENTIAL), # 26 Exhibit Contract No. 18/2016 between Aires Transportes, S.A. and Norwegian Cruise Line Holdings, Ltd. (English translation) (NCLH_23591-00524994-525006 CONFIDENTIAL), # 27 Exhibit Supplement No. 5 to Contract No. 6/2017 between Aries S.A. and Norwegian Cruise Line Holdings, Ltd. (in Spanish) (NCLH_23591-00525141-252149 CONFIDENTIAL), # 28 Exhibit Spreadsheet: Shore Excursion Departures Cienfuegos, Cuba (NCLH_23591-00535533), # 29 Exhibit Norwegian Cruise Line Holdings Revenue Information (revised) produced on May 19, 2021 (NCLH_23591-00581051-581055 CONFIDENTIAL), # 30 Exhibit Updated list of payments by Defendant to Fuego Entertainment/OnCuba Travel produced on August 27, 2021 (NCLH_23591-00581289-581293 ATTORNEYS EYES ONLY), # 31 Exhibit Norwegian Cruise Lines Holdings Ltd Form 10-K, dated February 27, 2019, # 32 Exhibit January 23, 2018 Email re Royal employees voyage on Norwegian cruise to Cuba (RCL-Havana0098272-98273 CONFIDENTIAL), # 33 Exhibit February 3, 2019 Email re Havana Berth Schedule (RCL-Havana01575450157546 CONFIDENTIAL), # 34 Exhibit December 18, 2014 Email re US seeks to normalize relations with Cuba (RCL-Havana0066678-0066690 CONFIDENTIAL), # 35 Exhibit Transcript of and Exhibits to the Deposition of Megan Shaw taken in Havana Docks Corporation v Royal Caribbean Cruise, Ltd., 19-23590 (S.D. Fla.) dated February 25, 2021, # 36 Exhibit Web printout: https://sanctionssearch.ofac.treas.gov/Details.aspx?id=8129, # 37 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, # 38 Exhibit February 13, 2019 Email re Havana Meetings First Draft (HavanaDocks_0484030-484034 CONFIDENTIAL), # 39 Exhibit Carnival Corporations Response to Plaintiffs Second Request for Admissions, dated September 7, 2021) (Martinez, Roberto) Modified to Unseal per DE 375 Order on 4/6/2022 (pes). (Entered: 09/19/2021)

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Sealed Document NOTICE OF FILING EXHIBITS CITED IN PLAINTIFFS Statement of Material Facts iIn Suport 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 Errata 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, # 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, # 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 (HDC 006440, HDC 006423, HDC 006406, HDC 006390, HDC 006374, HDC 006359, HDC 006343, HDC 006327, HDC 006311, HDC 006295, HDC 006279, HDC 006263, HDC 006246, HDC 006229, HDC 006212, HDC 006195, HDC 006179, HDC 006162, HDC 006146, HDC 006130, HDC 006114, HDC 006098, HDC 006082, HDC 006066, HDC 006049, HDC 006033, HDC 006016, HDC 006000, HDC 005984, HDC 005968, HDC 005936, HDC 005920, HDC 005904, HDC 005888, HDC 005872, HDC 005855, HDC 005839, HDC 023122, HDC 023139-23140, HDC 023121, HDC 023137-23138, HDC 023120, HDC 023135-23136, HDC 023119, HDC 023119, HDC 023133-23134, HDC 023131-23132, HDC 023117, HDC 023129, HDC 023130, HDC 023116, HDC 023127, HDC 023128, HDC 023115, HDC 023125, HDC 023126, HDC 023114, HDC 023123-23124, HDC 005271-5276, HDC 005263, HDC 005255-5260, HDC 005247, HDC 005238-5244, HDC 005230, HDC 005222-5227, HDC 005214, HDC 005206-5211, HDC 005198, HDC 005190-5195, HDC 005182, HDC 005166, HDC 005157-5163, HDC 005149, HDC 005140-5146, HDC 005132, HDC 005115, HDC 005107-5112, HDC 005090-5096, HDC 009218-9234, HDC 004896-4901, HDC 008047-8060, HDC 011918-11923, HDC 002509-2511, HDC 002518-2519, HDC 011908-11911, HDC 009210-9211 CONFIDENTIAL), # 36 Exhibit Composite Exhibit: Havana Docks Pre-Confiscation Financial Reports (HDC 004482-4483, HDC 004516-4517, HDC 004530-4531, HDC 012182-2184, HDC 012214-12215, HDC 012246-12247, HDC 012304-12305, HDC 012364-12365, HDC 12465-12466, HDC 010160-10163, HDC 010255-10258, HDC 010366-10369, HDC 010451-10454, HDC 010560-10563, HDC 010658, HDC 003725-3726, HDC 010736, HDC 003727-3736, HDC 011569-11570, HDC 002968-2971, HDC 002964-2967, HDC 008047-8061 CONFIDENTIAL), # 37 Exhibit Composite Exhibit: Havana Docks Post-Certified Claim Financial Reports (HDC 005712-5715, HDC 003208-3214, HDC 008339-8342, HDC 003252-3259, HDC 006514-6515, HDC 008399-8401, HDC 006455-6456, HDC 008621-8624, HDC 011225-11226, HDC 11593-11594, HDC 011394-11397, HDC 011451-11452, HDC 011529-11531, HDC -11597-1599, HDC 021174-21179, HDC 021191-21193, HDC 021216-21226, HDC 021230, HDC 021247-21251, HDC 021265, HDC 21266-21269, HDC 021270, HDC 021271-21273, HDC 021274-21275, HDC 021276-21279, HDC 021288-21290, HDC 013063-13065, HDC 013095-13096, HDC 013137-13139, HDC 013140, HDC 013123-13127, HDC013175-13177 CONFIDENTIAL, # 38 Exhibit Composite Exhibit: Havana Docks Corporation Tax Returns (HDC 008184-8185, HDC 002744-2745, HDC 008192-8210, HDC 008233-8247, HDC 002666-2688, HDC 002405-2414, HDC 002625, HDC 002980-2981, HDC 002982-2986, HDC 003013-3018, HDC 003033-3037, HDC 003065-3070, HDC 003076-3081, HDC 003088, HDC 018734-18742, HDC 003083-3085, HDC 003110-3115, HDC 018743-18745, HDC 003142-3150, HDC 003193-3207, HDC 003226-3238, HDC 003292-3307, HDC 003309, HDC 008318-8327, HDC 008329-8330, HDC 008379-8388, HDC 008401-8402, HDC 008417-8427, HDC 008594-8604, HDC00 8668-8682, HDC 008645-8656, HDC 008748-8758, HDC 008764, HDC 008702-8715, HDC 011192-11199, HDC 011176-11180, HDC 011282-11294, HDC 011427-11438, HDC 011496-11509, HDC 011566, HDC 021168-021173, HDC 021184-021190, HDC 021208-021215, 021231-021238, HDC 021280-021287, HDC 000342-348, HDC 013082-13088, HDC 013099-13107, HDC 013113-13122, HDC 013213-13223, documents provided by David Bush in response to subpoena, HDC 013288-13314, HDC 013316-13350, HDC 013721-13745, HDC 013352-13377, HDC 018836-18864, HDC 018866-18893 CONFIDENTIAL), # 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)) (Martinez, Roberto) Modified to Unseal per DE 375 Order on 4/6/2022 (pes). (Entered: 09/19/2021)

09/17/2021 217 

Sealed Document NOTICE OF FILING EXHIBITS 101-148 CITED IN Plaintiff's Statement of Material Facts in Support of Individual Motion fo Summary Judgment Against Norwegian Cruise Line Holdings Ltd by Havana Docks Corporation. (Attachments: # 1 Exhibit PLF Deposition Exhibit 90: August 14, 2018 Email re Cuba Ports (NCLH_23591-005259-263), # 2 Exhibit PLF Deposition Exhibit 91: February 9, 2017 Email re Report on Havana, Cuba - Destination Services (NCLH_23591-0125976-6409), # 3 Exhibit PLF Deposition Exhibit 92: November 10, 2017 Email re updated deck for meeting (NCLH_23591-0165581-598), # 4 Exhibit PLF Deposition Exhibit 93: December 4, 2018 Email re Voyager - OFAC officer for Sailing VOY181206 (NCLH_23591-0149360-364 CONFIDENTIAL), # 5 Exhibit PLF Deposition Exhibit 94: November 8, 2018 Email re OFAC Refresher/Training (NCLH_23591-074598-605), # 6 Exhibit PLF Deposition Exhibit 95: Document titled Shore Excursion Overview dated April 10, 2017 (NCLH_23591-0564714-721), # 7 Exhibit PLF Deposition Exhibit 96: Official Tour Summary Form for The Legendary Tropicana Cabaret (NCLH_23591-000535789), # 8 Exhibit PLF Deposition Exhibit 97: September 13, 2018 Email re Cienfuegos and Santiago Shorex for OCI/RSSC (NCLH_23591-0086473-483 CONFIDENTIAL), # 9 Exhibit PLF Deposition Exhibit 98: April 26, 2017 Email re sky tour numbers - Cuba (NCLH_23591-00161121-122 CONFIDENTIAL), # 10 Exhibit PLF Deposition Exhibit 99 (part 1): September 29, 2017 Email re Cuba costs and retail (NCLH_23591-00543337), # 11 Exhibit PLF Deposition Exhibit 99 (part 2): Attachment (Excel Spreadsheet) to September 29, 2017 Email (NCLH_23591-00543338), # 12 Exhibit PLF Deposition Exhibit 100 (Part 1): June 4, 2019 Email re Cuba Tours (NCLH_23591-00546781, # 13 Exhibit PLF Deposition Exhibit 100 (Part 2): Attachment (Excel Spreadsheet) to June 4, 2019 Email (NCLH_23591-00546782 CONFIDENTIAL), # 14 Exhibit PLF Deposition Exhibit 101: June 21, 2018 Email re shore ex - the life of Hemingway in Havana (NCHL_23591-0054765-768), # 15 Exhibit PLF Deposition Exhibit 102: October 6, 2018 Email re HAV-010 The Old Colonial Havana - Not OFAC Compliant (NCLH_23591-0086162-163), # 16 Exhibit PLF Deposition Exhibit 103: June 7, 2019 Email re Cuba Impact Statement (NCLH_23591-00030408-412), # 17 Exhibit PLF Deposition Exhibit 104: Compilation of NCL Flash Reports CONFIDENTI v1AL, # 18 Exhibit PLF Deposition Exhibit 104: Compilation of NCL Flash Reports CONFIDENTIAL V2, # 19 Exhibit PLF Deposition Exhibit 105: NCL Consolidated Financial Statement for year ended December 31, 2020, # 20 Exhibit PLF Deposition Exhibit 106: Defendants Supplemental Rule 26 Initial Disclosures, # 21 Exhibit PLF Deposition Exhibit 107: Excerpts of the transcript of the deposition of Mario Parodi as Defendant's corporate representative dated November 5, 2020, # 22 Exhibit PLF Deposition Exhibit 108: July 28, 2015 Email re Combined 2-5 July 28, (NCLH_23591-00021909-924), # 23 Exhibit PLF Deposition Exhibit 109: September 3, 2015 Email re Follow up questions (NCLH_23591-00544041-043), # 24 Exhibit PLF Deposition Exhibit 110: August 31, 2015 Email re Engage Cuba Agreement (NCLH_23591-00555154-158 CONFIDENTIAL), # 25 Exhibit PLF Deposition Exhibit 111: March 2, 2016 Email re NCLH - CCL Cuba Product Comparison (NCLH_23591-0119591-597), # 26 Exhibit PLF Deposition Exhibit 112: March 22, 2016 Email re Department of Commerce Fact sheet (NCLH_23591-00119542-546), # 27 Exhibit PLF Deposition Exhibit 113: February 11, 2017 Email re its flipping Facebook! (NCLH_23591-00005286-91), # 28 Exhibit PLF Deposition Exhibit 114: November 8, 2017 Email re New Cuba Regulations To Be Announced Tomorrow (NCLH_23591-00012420-421), # 29 Warrant PLF Deposition Exhibit 115: May 26, 2016 Email re Cuba pricing (NCLH_23591-00122899-907 CONFIDENTIAL), # 30 Exhibit PLF Deposition Exhibit 116: February 17, 2017 Email re Cuba Tour Operators Expense - $15 per person (NCLH_23591-00545658-660), # 31 Exhibit PLF Deposition Exhibit 117: January 19, 2017 Email re Cuba verbiage for board (NCLH_23591-00170378-381), # 32 Exhibit PLF Deposition Exhibit 118: April 18, 2017 Email re Oceania Board Slides (NCLH_23591-00543274-278 CONFIDENTIAL), # 33 Exhibit PLF Deposition Exhibit 119: November 14, 2017 Email re investment opportunity (NCLH_23591-00522538-550 CONFIDENTIAL), # 34 Exhibit PLF Deposition Exhibit 120: May 13, 2015 Email re House Approps Markup THUD Bill (NCLH_23591-00187593-94), # 35 Exhibit PLF Deposition Exhibit 121: December 2, 2015 Email re US Legislative Update (NCLH_23591-00570728), # 36 Exhibit PLF Deposition Exhibit 122: January 23, 2019 Email re GEC update on Title III Suspension (NCLH_23591-00577901-903 CONFIDENTIAL), # 37 Exhibit PLF Deposition Exhibit 123: April 19, 2019 Email re Cuba Sanctions (NCLH_23591-00578322-326 CONFIDENTIAL), # 38 Exhibit PLF Deposition Exhibit 124: April 28, 2019 Email re Comments re Your Draft Talking Points (NCLH_23591-00577862-863 CONFIDENTIAL), # 39 Exhibit PLF Deposition Exhibit 125: June 13, 2019 Email re Cuba export license (NCLH_23591-00578268-274 CONFIDENTIAL), # 40 Exhibit PLF Deposition Exhibit 126: July 28, 2017 Email re On the FAQ question (NCLH_23591-00564310), # 41 Exhibit PLF Deposition Exhibit 127: March 4, 2019 Email re Call with Ballard (NCL_23591-00557853-854), # 42 Exhibit PLF Deposition Exhibit 128: June 28, 2017 Email re Cuba Regulations (NCLH_23591-00578112-114 CONFIDENTIAL), # 43 Exhibit PLF Deposition Exhibit 129: June 5, 2017 Email re Know before you go: cruise caucus info, with attachment (NCLH_23591-00055759-763), # 44 Exhibit PLF Deposition Exhibit 130: September 2, 2015 Email re Engage Cuba Agreement (NCLH_23591-00580889-893 CONFIDENTIAL), # 45 Exhibit Skogland (Viking Corporate Representative) Deposition Exhibit 1: Notice of Taking Rule 30(b)(6) Deposition of Viking Cruises (USA) Ltd. Co. and Viking Ocean Cruises II, Ltd., # 46 Exhibit Skogland (Viking Corporate Representative) Deposition Exhibit 2: Subpoena directed to Viking Cruises (USA) Ltd. Co. and Viking Ocean Cruises II, Ltd., # 47 Exhibit Skogland (Viking Corporate Representative) Deposition Exhibit 3: Video titled Viking Ocean Cultural Cuba Itinerary, # 48 Exhibit Skogland (Viking Corporate Representative) Deposition Exhibit 4: Passenger brochure titled Cultural Cuba, November 1, 2018, Viking Star, # 49 Exhibit Skogland (Viking Corporate Representative) Deposition Exhibit 5: Passenger brochure titled Cultural Cuba, November 17, 2017, Viking Sun) (Martinez, Roberto) Modified to Unseal per DE 375 Order on 4/6/2022 (pes). (Entered: 09/17/2021)

09/17/2021 215 

Sealed Document NOTICE OF FILING EXHIBITS 51-100 CITED IN Plaintiff's Statement of Material Facts in Support of Individual Motion for Summary Judgment Agasint Norweigian Cruie Line Holdlings Ltd. by Havana Docks Corporation. (Attachments: # 1 Exhibit PLF Deposition Exhibit 40: First Amendment to Master Letter Agreement between Fuego Enterprises, Inc. and Norwegian Cruise Line Holdings Ltd. dated July 1, 2018 (Fuego\Hugo 000569-573), # 2 Exhibit PLF Deposition Exhibit 41: Contract No. 6/2017 between Aries S.A. and Norwegian Cruise Line Holdings Ltd. (in Spanish) (NCLH_23591-00004580-94 CONFIDENTIAL), # 3 Exhibit PLF Deposition Exhibit 42: September 22, 2015 Email re Norwegian Expenses to be billed in October (Fuego\Hugo 000661), # 4 Exhibit PLF Deposition Exhibit 43: Final business plan for submission to Cuban Government, dated September 29, 2015 (in Spanish) (NCLH_23591-00021271-382), # 5 Exhibit PLF Deposition Exhibit 44: November 3, 2016 Email re Cuba desespera a Royal Caribbean mientras autoriza a Carnival / Intermediacin (NCLH_23591-00005349-51 CONFIDENTIAL), # 6 Exhibit PLF Deposition Exhibit 45: November 24, 2016 Email re CUBA approval (NCLH_23591-00005342-43), # 7 Exhibit PLF Deposition Exhibit 46: March 3, 2017 Letter to Ambassador Jos Ramn Cabaas Rodrguez re issues related to Norwegians operations in Cuba (NCLH_23591-00525312 CONFIDENTIAL), # 8 Exhibit PLF Deposition Exhibit 47: May 10, 2018 Email re Carnival Cruise Line to Expand in Cuba (Fuego\Hugo 001060), # 9 Exhibit PLF Deposition Exhibit 48: February 10, 2017 Email re Important, of life or death (NCLH_23591-00004276-4284), # 10 Exhibit PLF Deposition Exhibit 49: March 2, 2017 Email re Final list of guests for lunch on march 9th (NCLH_23591-000028684-686 CONFIDENTIAL, # 11 Exhibit PLF Deposition Exhibit 50: March 16, 2017 Email re Norwegian Cruise Line Holdings / Introduction (NCLH_23591-00008169-75), # 12 Exhibit PLF Deposition Exhibit 51: March 16, 2018 Email re guest list (NCLH_23591-00029661-665 CONFIDENTIAL), # 13 Exhibit PLF Deposition Exhibit 52: Defendants Amended Initial Rule 26 Disclosures, # 14 Exhibit PLF Deposition Exhibit 53: Defendants Answer and Affirmative Defenses to Amended Complaint (D.E. 107, # 15 Exhibit Omitted, # 16 Exhibit PLF Deposition Exhibit 55: Vessel Operations Manual, dated September 30, 2020 (NCLH_23591-00524314-339), # 17 Exhibit PLF Deposition Exhibit 56: Draft Document titled Norwegian Cruise Line Destination Brief, dated August 9 2018 (NCLH_23591-00047949-971), # 18 Exhibit PLF Deposition Exhibit 57: Defendants Second Amended Responses and Objections to Havana Docks Corporations First Set of Interrogatories, # 19 Exhibit PLF Deposition Exhibit 58: OFAC License Application, dated April 6, 2015 (NCLH_23591-000545451), # 20 Exhibit PLF Deposition Exhibit 59: OFAC License Application, dated July 14, 2015 (NCLH_23591-00556558-569), # 21 Exhibit PLF Deposition Exhibit 60: Compilation of NCL Contracts with Havanatur CONFIDENTIAL, # 22 Exhibit PLF Deposition Exhibit 61: February 24, 2017 Email re reporte de las excursiones (NCLH_23591-00005324-26), # 23 Exhibit PLF Deposition Exhibit 62: Compilation of NCL Contracts with Comar CONFIDENTIAL, # 24 Exhibit PLF Deposition Exhibit 63: Compilation of NCL Contracts with Empresa Consignataria Mambisa CONFIDENTIAL, # 25 Exhibit PLF Deposition Exhibit 64: Compilation of NCL Contracts with Aries CONFIDENTIAL, # 26 Exhibit PLF Deposition Exhibit 65: June 9, 2017 Email re Aries Letter (NCLH_23591-00005797-798 CONFIDENTIAL), # 27 Exhibit PLF Deposition Exhibit 66: April 16, 2019 Email re Herald Article (NCLH_23591-000051587-88), # 28 Exhibit PLF Deposition Exhibit 67: Engagement letter between Norwegian Cruise Line Holding Ltd. and Fuego Enterprises Inc. dated August 11, 2015 (NCLH_23591-00559755-759 CONFIDENTIAL), # 29 Exhibit PLF Deposition Exhibit 68: Amendment to August 11, 2015 Engagement Letter between Norwegian Cruise Line Holding Ltd. and Fuego Enterprises Inc. dated May 25, 2016 (NCLH_23591-00559754 CONFIDENTIAL), # 30 Exhibit PLF Deposition Exhibit 69: Redacted Email (w/h for privilege) with Certified Claims attached (NCLH_23591-00056291-311), # 31 Exhibit PLF Deposition Exhibit 70: June 14, 2017 Email re Cuba policy (NCLH_23591-00104870-874), # 32 Exhibit PLF Deposition Exhibit 71: July 7, 2017 Email re NCLH Comments on forthcoming changes to Cuba sanctions (NCLH_23591- 0006392-98), # 33 Exhibit PLF Deposition Exhibit 72: July 8, 2107 Email re URGENT Cuba comments letter update (NCLH_23591- 00109276-278, # 34 Exhibit PLF Deposition Exhibit 73: November 22, 2017 Email re Anthony Scaramucci (NCLH_23591-00540073, # 35 Exhibit PLF Deposition Exhibit 74: December 8, 2018 Email re HD Talking Points Draft (NCLH_23591-00012252), # 36 Exhibit PLF Deposition Exhibit 75: December 29, 2018 Email re Cuba (NCLH_23591-00098023-025), # 37 Exhibit PLF Deposition Exhibit 76: December 29, 2018 Email re Cuba (NCLH_23591-0098060-061), # 38 Exhibit PLF Deposition Exhibit 77: February 22, 2019 Letter to the Honorable Michael R. Pompeo re Title III of the Helms-Burton Act (NCLH_23591-00111666-667), # 39 Exhibit PLF Deposition Exhibit 78: April 16, 2019 Email re Helms Burton Title III (NCLH_23591-00011592-593), # 40 Exhibit PLF Deposition Exhibit 79: April 17, 2019 Email re Cuba (HavanaDocks 388212 CONFIDENTIAL), # 41 Exhibit PLF Deposition Exhibit 80: April 28, 2019 Email re US Chamber Invitation U.S.-Cuba Business Summit May 21 (NCLH_23591-00111761-762), # 42 Exhibit PLF Deposition Exhibit 81: May 8, 2019 Email re Hola (NCLH_23591-00114111-15), # 43 Exhibit PLF Deposition Exhibit 82: May 28, 2019 Email re OCI RM notes, 28 May 2019 (NCLH_23591-0012181-182), # 44 Exhibit PLF Deposition Exhibit 83: June 4, 2019 Email re Public Inspection Documents from Industry and Security Bureau (NCLH_23591-00553699-700), # 45 Exhibit PLF Deposition Exhibit 84: May 7, 2019 Email re CCL/NCLH/RCL: Cuba how much does it matter for cruising? (NCLH_23591-00109974-984), # 46 Exhibit PLF Deposition Exhibit 85: May 9, 2019 Email re RAW TRANSCRIPT - earning call (NCLH_23591-00110044-064 CONFIDENTIAL), # 47 Exhibit PLF Deposition Exhibit 86: June 11, 2019 Email re Cuba (NCLH_23591-00098464-465), # 48 Exhibit PLF Deposition Exhibit 87: January 9, 2017 Email re NCLH-ADUANA (NCLH_23591-0021694-703), # 49 Exhibit PLF Deposition Exhibit 88: December 15, 2017 Email re inaugural sailing of RSSC new build (NCLH_23591-0034549-553), # 50 Exhibit PLF Deposition Exhibit 89: July 2, 2018 Email re Berth Request - Riviera (NCLH_23591-0004215-4218)) (Martinez, Roberto) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 09/17/2021)

09/17/2021 214 

Sealed Document NOTICE OF FILING EXHIBITS 1-50 CITED IN Plaintiff's Statement of Material Facts in Support of Individual Motion for Summary Judgment Againt Norwegian Cruise Line Holdings Ltd. by Havana Docks Corporation. (Attachments: # 1 Deposition Mario Parodi, # 2 Deposition Hugo Cancio 30b6, # 3 Deposition Hugo Cancio (Individual), # 4 Deposition Omitted, # 5 Deposition Lincoln Vidal, # 6 Deposition Frank Del Rio, # 7 Deposition Nicola Skogland, # 8 Deposition Christine Manjencic, # 9 Deposition Lavanya Sareen, # 10 Deposition Edel Cruz, # 11 Deposition Daniel Farkas, # 12 Exhibit PLF Deposition Exhibit 1: Deposition Notice for Defendants Rule 30(b)(6) designee, # 13 Exhibit PLF Deposition Exhibit 2: Certified Claim No. CU-2492 (D.E. 56-1, # 14 Exhibit PLF Deposition Exhibit 3: Photographs of Norwegian Sky docked at Havana Port Terminal, # 15 Exhibit PLF Deposition Exhibit 4: Photograph of Havana Port Terminal, street view, # 16 Exhibit PLF Deposition Exhibit 5: Photographs of Havana Port Terminal (HDC1980), # 17 Exhibit PLF Deposition Exhibit 6: Aerial photographs of Havana Port Terminal (HDC 1981), # 18 Exhibit PLF Deposition Exhibit 7: Map of Havana, port area (HDC 1976), # 19 Exhibit PLF Deposition Exhibit 8: NCLH presentation titled Cuba Cruising Update, dated February 25, 2018 (NCLH_23591-00015477-15505), # 20 Exhibit PLF Deposition Exhibit 9: Havana Docks Corporation Brochure (HDC 1955-1858, # 21 Exhibit PLF Deposition Exhibit 10: February 11, 2019 Letter to Oceana from Rodney S. Margol, Esq., # 22 Exhibit PLF Deposition Exhibit 11: February 11, 2019 Letter to Regent Seven Seas Cruises from Rodney S. Margol, Esq., # 23 Exhibit PLF Deposition Exhibit 12: February 11, 2019 Letter to Frank Del Rio, Norwegian Cruise Line Holdings, Ltd. from Rodney S. Margol, Esq., # 24 Exhibit PLF Deposition Exhibit 13: Presentation titled Cuba Potential Cruise Destination, dated June 1, 2009 (NCLH_23591-00021193-236), # 25 Exhibit PLF Deposition Exhibit 14: Spreadsheet titled Cuba Itinerary Summary (NCLH_23591-00019453), # 26 Exhibit PLF Deposition Exhibit 15: Document titled Cubas port cities & their potential for US Cruise tourism, dated July 16, 2015 (NCLH_23591-00021132-138, # 27 Exhibit PLF Deposition Exhibit 16: Draft Document titled Operating Considerations for a Successful Cruise Product in Cuba, dated July 20, 2015 (NCLH_23591-00021139-149 CONFIDENTIAL), # 28 Exhibit PLF Deposition Exhibit 17: July 31, 2015 Email re Final English Draft (NCLH_23591-00021881-892), # 29 Exhibit PLF Deposition Exhibit 18: August 21, 2018 Email re Berth Request for Riviera (NCLH_23591-00005908-11), # 30 Exhibit PLF Deposition Exhibit 19: Document titled Cuba Report for April 24, 2019 (NCLH_23591-00013619-20), # 31 Exhibit PLF Deposition Exhibit 20: Contract No. 6/2017 between Aries S.A. and Norwegian Cruise Line Holdings Ltd. (in Spanish) (NCLH_23591-00004580-94 CONFIDENTIAL), # 32 Exhibit PLF Deposition Exhibit 21: Agency Contract No. 14/16 between Empresa Consignataria Mambisa and Norwegian Cruise Line Holdings Ltd. (NCLH_23591-00525152-163 CONFIDENTIAL), # 33 Exhibit PLF Deposition Exhibit 22: Spreadsheet of payments to Aries (NCLH_23591-0014316 CONFIDENTIAL), # 34 Exhibit PLF Deposition Exhibit 23: Spreadsheet of payments to Comar S.A. (NCLH_23591-0014317 CONFIDENTIAL), # 35 Exhibit PLF Deposition Exhibit 24: Spreadsheet of payments to Empresa Consignataria Mambisa (NCLH_23591-0014318 CONFIDENTIAL), # 36 Exhibit PLF Deposition Exhibit 25: Spreadsheet of payments to Havanatur S.A. (NCLH_23591-0014319 CONFIDENTIAL), # 37 Exhibit PLF Deposition Exhibit 26: Presentation titled Cuba Deployment Proposal, dated September 24, 2018 (NCLH_23591-00015571-589 CONFIDENTIAL), # 38 Exhibit PLF Deposition Exhibit 27: Norwegian Havana Cruise Revenue Calculation (NCLH_23591-00014315 CONFIDENTIAL), # 39 Exhibit PLF Deposition Exhibit 28: Presentation titled NCLH Experience in Cuba, dated March 26, 2018 (NCLH_23591-00015508-519 CONFIDENTIAL), # 40 Exhibit PLF Deposition Exhibit 29: April 25, 2019 Email re Full BOD Deck (NLCH_23591-00110649-710, # 41 Exhibit PLF Deposition Exhibit 30: Presentation titled Cuba Options, dated July 14, 2015 (NCLH_23591-00021111-131), # 42 Exhibit PLF Deposition Exhibit 31: December 9, 2016 Email re Cuba (NCLH_23591-00101133-136), # 43 Exhibit PLF Deposition Exhibit 32: December 12, 2016 Email re Cruising to Cuba (NCLH_23591-00005195 CONFIDENTIAL, # 44 Exhibit PLF Deposition Exhibit 33: December 13, 2016 Email re Cuba Proposal (NCLH_23591-00021673-675), # 45 Exhibit PLF Deposition Exhibit 34: December 13, 2016 Email re Cuba Proposal (NCLH_23591-00017408-413), # 46 Exhibit PLF Deposition Exhibit 35: December 14, 2016 Email re Cuba Proposal (NCLH_23591- 00525729), # 47 Exhibit PLF Deposition Exhibit 36: December 15, 2016 Email re Yesterday (NCLH_23591-0096340-343), # 48 Exhibit PLF Deposition Exhibit 37: February 22, 2017 Letter to Office of Foreign Assets Control re License Application Pursuant to 31 C.F.R. Part 515 (NCLH_23591-00190366-371 CONFIDENTIAL), # 49 Exhibit PLF Deposition Exhibit 38: Re-notice of Deposition of Defendants Rule 30(b)(6) designee, # 50 Exhibit PLF Deposition Exhibit 39: Master Letter Agreement between Fuego Enterprises, Inc. and Norwegian Cruise Line Holdings Ltd. dated January 27, 2017 (Fuego\Hugo 000574-592)) (Martinez, Roberto) Modified to Unseal per DE 375 Order on 4/5/2022 (pes). (Entered: 09/17/2021)

MSC Cruises Libertad Act Lawsuit: Tens Of Thousands Of Documents Unsealed

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)

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)
Order Unsealing The Summary Judgement Record (4/4/22)
Libertad Act Lawsuit Filing Statistics

04/08/2022 348 

CLERK'S NOTICE of Compliance by Unsealing documents reference in 344 Order. (kpe) (Entered: 04/08/2022)

04/07/2022 346 

Joint MOTION for Extension of Time to File Objections and Responses re 341 REPORT AND RECOMMENDATIONS on BIVENS case re 214 Plaintiff's SEALED MOTION Plaintiff Havana Docks Corporation's Motion to Exclude Opinions of Julian Ackert and Pablo Spiller filed by Havana Docks Corporation, 207 SEALED MOTI by Havana Docks Corporation. Responses due by 4/21/2022 (Kroeger, Thomas) (Entered: 04/07/2022)

04/05/2022 344 

ORDER Unsealing The Summary Judgment Record. Signed by Judge Beth Bloom on 4/1/2022. See attached document for full details. (kpe) (Entered: 04/06/2022)

03/17/2022 329 

OMNIBUS ORDER ON MOTIONS TO UNSEAL SUMMARY JUDGMENT RECORD granting in part and denying in part 317 Plaintiff Havana Docks Corporation's Motion to Unseal the Summary Judgment Record. Within 10 days of this Order, the parties shall meet and confer, and file and submit to the Court, a proposed order indicating a listing of the specific documents in each case that are to be unsealed and which documents will be refiled in the public record in redacted form. Signed by Judge Beth Bloom on 3/17/2022. See attached document for full details. (wc) (Entered: 03/17/2022)

03/17/2022 328 

SUPPLEMENT Brief on Daubert Motions by Havana Docks Corporation (Martinez, Roberto) (Entered: 03/17/2022)

03/16/2022 327 

SUPPLEMENT Memorandum In Connection with Daubert Motions by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO (Baldridge, James) (Entered: 03/16/2022)

03/14/2022 326 

NOTICE by Havana Docks Corporation re 324 Notice of Supplemental Authority, Havana Docks' Response to Defendants' Notice of Supplemental Authority (D.E. 324) (Martinez, Roberto) (Entered: 03/14/2022)

03/11/2022 325 

ORDER GRANTING IN PART DEFENDANTS MOTION FOR BRIEF ENLARGEMENT OF TIME TO FILE MOTIONS IN LIMINE. ORDER granting in part and denying in part 322 Motion for Extension of Time. In Limine Motions due by 4/8/2022. Signed by Judge Beth Bloom on 3/8/2022. See attached document for full details. (amb) (Entered: 03/11/2022)

03/10/2022 324 

Notice of Supplemental Authority re 209 MOTION for Summary Judgment MSC CRUISES' INDIVIDUAL MOTION FOR SUMMARY JUDGMENT AND INCORPORATED MEMORANDUM OF LAW by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO (Attachments: # 1 Exhibit 1 - United States ex rel. Sheldon v. Allergan Sales, LLC) (Baldridge, James) (Entered: 03/10/2022)

03/08/2022 323 

RESPONSE to Motion re 322 MOTION for Extension of Time to File Motions in Limine filed by Havana Docks Corporation. Replies due by 3/15/2022. (Martinez, Roberto) (Entered: 03/08/2022)

03/07/2022 322 

MOTION for Extension of Time to File Motions in Limine by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO. Responses due by 3/21/2022 (Attachments: # 1 Text of Proposed Order)(Baldridge, James) (Entered: 03/07/2022)

02/23/2022 321 

REPLY to Response to Motion re 317 MOTION to Unseal the Summary Judgment Record filed by Havana Docks Corporation. (Martinez, Roberto) (Entered: 02/23/2022)

02/22/2022 320 

OMNIBUS ORDER ON MOTIONS TO STRIKE PLAINTIFF'S JURY TRIAL DEMAND. Defendants Carnival Corporation, MSC Cruises S.A. et al., and Royal Caribbean Cruises, LTD.'s Motions to Strike Plaintiff's Jury Trial Demand (ECF Nos. 297 in case 19-cv-21724, 190 in case 19-cv-23588, 112 in case 19-cv-23590) are DENIED. Signed by Judge Beth Bloom on 2/18/2022. See attached document for full details. (mc) (Entered: 02/22/2022)

02/16/2022 319 

RESPONSE in Opposition re 317 MOTION to Unseal the Summary Judgment Record filed by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO. Replies due by 2/23/2022. (Attachments: # 1 Exhibit MSC Cruises' Proposed Documents to Remain Sealed or Be Refiled with Redactions, # 2 Affidavit of Joel Dovico)(Baldridge, James) (Entered: 02/16/2022)

02/10/2022 318 

PAPERLESS ORDER expediting response to 317 Motion to Unseal. Response due by 2/16/2022. Signed by Judge Beth Bloom on 2/10/2022. (jd01) (Entered: 02/10/2022)

02/09/2022 317 

MOTION to Unseal the Summary Judgment Record by Havana Docks Corporation. (Attachments: # 1 Text of Proposed Order)(Martinez, Roberto) (Entered: 02/09/2022)

02/08/2022 316 

Plaintiff's RESPONSE to 313 Notice of Adoption Plaintiff Havana Docks Corporation's Response to Defendants' Objections to Judge Louis's Report & Recommendation on Plaintiff's Jury Demand by Havana Docks Corporation. (Martinez, Roberto) (Entered: 02/08/2022)

02/02/2022 315 

TRANSCRIPT of Motion Hearings held on 01/12/2022 before Judge Beth Bloom, 1 - 265, plus index pages, Court Reporter: Yvette Hernandez, 305-523-5698 / Yvette_Hernandez@flsd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 2/23/2022. Redacted Transcript Deadline set for 3/7/2022. Release of Transcript Restriction set for 5/3/2022. (yhz) (Entered: 02/02/2022)

01/31/2022 314 

NOTICE by Havana Docks Corporation of Filing Daubert Hearing Presentations (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 12a Part 1, # 14 Exhibit 12a Part 2, # 15 Exhibit 12b Part 1, # 16 Exhibit 12b Part 2, # 17 Exhibit 12c, # 18 Exhibit 12d Part 1, # 19 Exhibit 12d Part 2) (Martinez, Roberto) (Entered: 01/31/2022)

11/08/2021 277 

Plaintiff's Reply to Defendants' Additional Facts by Havana Docks Corporation. (Casey, Stephanie) Modified by unsealing documents pursuant to DE 344 Orderon 4/8/2022 (kpe). (Entered: 11/08/2021)

11/08/2021 276 

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 documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 11/08/2021)

11/08/2021 275 

DEFENDANTS' REPLY IN SUPPORT OF THEIR OMNIBUS MOTION FOR SUMMRY JUDGMENT (ECFS 216 & 254) by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO. (Baldridge, James) Modified by unsealing specific documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 11/08/2021)

11/08/2021 274 

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 273 

MSC CRUISES' REPLY STATEMENT OF MATERIAL FACTS (ECF 210 & ECF 259) by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO. (Baldridge, James) Modified by unsealing documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 11/08/2021)

11/08/2021 272 

MSC CRUISES' REPLY IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT (ECF 209 & ECF 258) by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO. (Baldridge, James) Modified by unsealing documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 11/08/2021)

10/29/2021 270 

ORDER ON JOINT MOTION FOR BRIEF ENLARGEMENT OF TIME granting 269 Motion for Extension of Time. Signed by Judge Beth Bloom on 10/28/2021. See attached document for full details. (pcs) (Entered: 10/29/2021)

10/28/2021 269 

Joint MOTION for Extension of Time to File Replies & Responses to Dispositive and Daubert Motions, Response and Reply to Plaintiff's Motion Relating to Ambar Diaz's Testimony and for Leave to File Those Replies and Response and Accompanying Exhibits Under Seal by Havana Docks Corporation. Responses due by 11/12/2021 (Attachments: # 1 Text of Proposed Order)(Martinez, Roberto) (Entered: 10/28/2021)

10/25/2021 268 

ORDER SETTING HEARING ON MOTIONS FOR SUMMARY JUDGMENT granting 260 Joint MOTION for Hearing on Motions for Summary Judgment re 209 MOTION for Summary Judgment. Motion Hearing set for 12/14/2021 09:30 AM in Miami Division before Judge Beth Bloom. Signed by Judge Beth Bloom on 10/25/2021. See attached document for full details. (pcs) Modified text on 10/26/2021 (pcs). (Entered: 10/26/2021)

10/22/2021 267 

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 documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 10/22/2021)

10/22/2021 266 

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 document pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 10/22/2021)

10/20/2021 265 

Clerks Notice to Filer re 258 SEALED MOTION, 250 Plaintiff's SEALED MOTION 254 SEALED MOTION. Wrong Event Selected; ERROR - The Filer selected the wrong event. Theses documents are not Motions. The corrections has been made by the Clerk. It is not necessary to refile this document. (nc) (Entered: 10/20/2021)

10/19/2021 264 

NOTICE by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO NOTICE OF FILING INDEX OF EXHIBITS TO DEFENDANTS' OPPOSITION TO PLAINTIFF'S OMNIBUS MOTION FOR SUMMARY JUDGMENT AND DEFENDANTS' OPPOSING STATEMENT OF FACTS AND ADDITIONAL UNDISPUTED MATERIAL FACTS (ECF 252) (Attachments: # 1 Exhibit 1 Index of Exhibits) (Baldridge, James) (Entered: 10/19/2021)

10/19/2021 263 

NOTICE by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO NOTICE OF FILING INDEX OF EXHIBITS TO MSC CRUISES' OPPOSITION TO PLAINTIFF'S INDIVIDUAL MOTION FOR SUMMARY JUDGMENT AND MSC CRUISES' OPPOSING STATEMENT OF UNDISPUTED MATERIAL FACTS (ECF 253) (Attachments: # 1 Exhibit 1 Index of Exhibits) (Baldridge, James) (Entered: 10/19/2021)

10/19/2021 262 

NOTICE by Havana Docks Corporation NOTICE OF FILING INDEX OF EXHIBITS CITED IN PLAINTIFF'S OPPOSITION TO MSC DEFENDANTS' STATEMENT OF MATERIAL FACTS (Martinez, Roberto) (Entered: 10/19/2021)

10/19/2021 261 

NOTICE by Havana Docks Corporation NOTICE OF FILING INDEX OF EXHIBITS CITED IN PLAINTIFF'S STATEMENT OF MATERIAL FACTS IN RESPONSE IN OPPOSITION TO DEFENDANT'S OMNIBUS MOTION FOR SUMMARY JUDGMENT (Martinez, Roberto) (Entered: 10/19/2021)

10/18/2021 260 

Joint MOTION for Hearing on Motions for Summary Judgment by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO. (Baldridge, James) (Entered: 10/18/2021)

10/18/2021 259 

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 documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 10/18/2021)

10/18/2021 258 

Plaintiff's Response in Opposition to MSC'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 specific documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 10/18/2021)

10/18/2021 257 

Notice of Filing Exhibits Cited in Plaintiff's Opposition to MSC Defendants' Statement of Material Facts by Havana Docks Corporation. (Attachments: # 1 Havana Docks Corporations Amended Answers and Objections to the First Request for Admissions Served by MSC Cruises (USA) Inc., MSC Cruise SA Co. and MSC Cruise S.A. (collectively, MSC Cruises), dated August 3, 2021, # 2 Brochure: MSC Armonia Miami Caribbean & Cuba (MSCCUSA0000047703-47722), # 3 Brochure: Cuba (MSCCUSA0000047777-47786), # 4 Brochure: MSC Opera and MSC Armonia to Cuba (MSCCUSA0000048938-48952)) (Casey, Stephanie) Modified by unsealing documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 10/18/2021)

10/18/2021 256 

MSC CRUISES' OPPOSITION TO PLAINTIFF'S INDIVIDUAL MOTION FOR SUMMARY JUDGMENT (ECF 225) by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO. (Baldridge, James) Modified by unsealing documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 10/18/2021)

10/18/2021 255 

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 to DE 344 Order on 4/8/2022 (kpe). (Entered: 10/18/2021)

10/18/2021 254 

Plaintiff Havana Docks Corporation's Response in Opposition to Defendants' Omnibus Motion for Summary Judgment by Havana Docks Corporation. (Martinez, Roberto) Modified docket text/terminated motion on 10/20/2021 (nc). Modified by unsealing documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 10/18/2021)

10/18/2021 253 

MSC CRUISES' OPPOSING STATEMENT OF UNDISPUTED FACTS (ECF 224) by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO. (Attachments: # 1 Exhibit Ex. 145 MSC Cruises Expert Report of Benoit Merkt, # 2 Exhibit Ex. 146 MSCCUSA0000058302, # 3 Exhibit Ex. 147 MSCCUSA0000046952 (MSCC0000039350)) (Baldridge, James) Modified by unsealing documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 10/18/2021)

10/18/2021 252 

DEFENDANTS' OPPOSING STATEMENT OF FACTS AND ADDITIONAL UNDISPUTED MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE TRIED (ECF 223) by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO. (Attachments: # 1 Exhibit Ex. 125 Decrees & Translations-Final, # 2 Exhibit Ex. 126 Cuba Civil Code 1889, # 3 Exhibit Ex. 127 Cuban Mortgage Law of 1893, # 4 Exhibit Ex. 128 Regulations to Cuba Mortgage Law, # 5 Exhibit Ex. 129 Cuba Notorial Code of 1929, # 6 Exhibit Ex. 130 Dec. 9, 2020 Jerry Johnson Deposition & Exhibits, # 7 Exhibit Ex. 131 HDC023141, # 8 Exhibit Ex. 132 July 30, 2021 Tandy Bondi Deposition & Exhibits, # 9 Exhibit Ex. 133 Apr. 1, 2021 Jerry Johnson Deposition & Exhibits) (Baldridge, James) Modified by unsealing specific documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 10/18/2021)

10/18/2021 251 

DEFENDANTS' RESPONSE IN OPPOSITION TO PLAINTIFF'S OMNIBUS MOTION FOR PARTIAL SUMMARY JUDGMENT (ECF 222) by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO. (Baldridge, James) Modified by unsealing document pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 10/18/2021)

10/18/2021  

SYSTEM ENTRY - Docket Entry 250 [motion] restricted/sealed until further notice. (517538) (Entered: 10/18/2021)

10/18/2021  

SYSTEM ENTRY - Docket Entry 249 [motion] restricted/sealed until further notice. (517538) (Entered: 10/18/2021)

10/18/2021 248 

PLAINTIFF'S NOTICE OF FILING EXHIBITS IN WUPPORT 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 to DE 344 Order on 4/8/2022 (kpe). (Entered: 10/18/2021)

10/15/2021 244 

Unopposed MOTION for Leave to File Exhibits Under Seal by Havana Docks Corporation. (Attachments: # 1 Text of Proposed Order)(Martinez, Roberto) (Entered: 10/15/2021)

09/21/2021 225 

Plaintiff Havana Docks Corporation's Individual Motion for Summary Judgment Against MSC Cruises SA & MSC Cruises (USA), Inc. by Havana Docks Corporation. (Martinez, Roberto) Modified by unsealing documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 09/21/2021)

09/21/2021 224 

Plaintiff Havana Docks Corporation's Statement of Material Facts in Support of Its Individual Motion for Summary Judgment Against MSC Cruises S.A., MSC Cruises S.A., CO., MSC Cruises (USA), Inc. by Havana Docks Corporation. (Martinez, Roberto) Modified by unsealing specific pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 09/21/2021)

09/20/2021 223 

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 documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 09/20/2021)

09/20/2021 222 

Plaintiff Havana Docks Corporation's Omnibus Motion for Partial Summary Judgment by Havana Docks Corporation. (Casey, Stephanie) Modified by unsealing documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 09/20/2021)

09/20/2021 221 

NOTICE by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO re 216 Defendant's MOTION for Summary Judgment DEFENDANT'S OMNIBUS MOTION FOR SUMMARY JUDGMENT, 217 Statement,,,,, NOTICE OF FILING CERTAIN EXHIBITS UNDER SEAL IN SUPPORT OF DEFENDANTS' STATEMENT OF UNDISPUTED MATERIAL FACTS AS TO DEFENDANTS' OMNIBUS MOTION FOR SUMMARY JUDGMENT (Baldridge, James) (Entered: 09/20/2021)

09/20/2021 220 

Notice of Filing Exhibits 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 documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 09/20/2021)

09/20/2021 219 

DEFENDANTS' STATEMENT OF UNDISPUTED FACTS IN SUPPORT OF OMNIBUS MOTION FOR SUMMARY JUDGMENT (ECF 216) by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO. (Attachments: # 1 Exhibit 1, # 2 Exhibit 1-1, # 3 Exhibit 1-2, # 4 Exhibit 1-3, # 5 Exhibit 1-4, # 6 Exhibit 1-5, # 7 Exhibit 1-6, # 8 Exhibit 1-7, # 9 Exhibit 1-8, # 10 Exhibit 1-9, # 11 Exhibit 1-10, # 12 Exhibit 14, # 13 Exhibit 15, # 14 Exhibit 16-1, # 15 Exhibit 16-2, # 16 Exhibit 16-3, # 17 Exhibit 16-4, # 18 Exhibit 16-5, # 19 Exhibit 17, # 20 Exhibit 18, # 21 Exhibit 20, # 22 Exhibit 23, # 23 Exhibit 24, # 24 Exhibit 25, # 25 Exhibit 26-1, # 26 Exhibit 26-2, # 27 Exhibit 26-3, # 28 Exhibit 28-1, # 29 Exhibit 28-2, # 30 Exhibit 28-3, # 31 Exhibit 29, # 32 Exhibit 30, # 33 Exhibit 31, # 34 Exhibit 32, # 35 Exhibit 33, # 36 Exhibit 34, # 37 Exhibit 35, # 38 Exhibit 36, # 39 Exhibit 37, # 40 Exhibit 38, # 41 Exhibit 39, # 42 Exhibit 40, # 43 Exhibit 41, # 44 Exhibit 42, # 45 Exhibit 43, # 46 Exhibit 44, # 47 Exhibit 46, # 48 Exhibit 47, # 49 Exhibit 48, # 50 Exhibit 49, # 51 Exhibit 50, # 52 Exhibit 51, # 53 Exhibit 52, # 54 Exhibit 53, # 55 Exhibit 54, # 56 Exhibit 55, # 57 Exhibit 56, # 58 Exhibit 57, # 59 Exhibit 58, # 60 Exhibit 59, # 61 Exhibit 61, # 62 Exhibit 62, # 63 Exhibit 63, # 64 Exhibit 65, # 65 Exhibit 67, # 66 Exhibit 72, # 67 Exhibit 73, # 68 Exhibit 74, # 69 Exhibit 75, # 70 Exhibit 76, # 71 Exhibit 78, # 72 Exhibit 80, # 73 Exhibit 82, # 74 Exhibit 85, # 75 Exhibit 90, # 76 Exhibit 92, # 77 Exhibit 93, # 78 Exhibit 97, # 79 Exhibit 99, # 80 Exhibit 100, # 81 Exhibit 102, # 82 Exhibit 104, # 83 Exhibit 105, # 84 Exhibit 109, # 85 Exhibit 110, # 86 Exhibit 111, # 87 Exhibit 112, # 88 Exhibit 114, # 89 Exhibit 115, # 90 Exhibit 117, # 91 Exhibit 120, # 92 Exhibit 121, # 93 Exhibit 122) (Baldridge, James) Modified by unsealing specific documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 09/20/2021)

09/20/2021 218 

Notice of Filing Exhibits 102-144 Cited in Plaintiff's Statement of Material Facts in Support of Individual Motion for Summary Judgment Against MSC Cruises S.A., MSC Cruises S.A. Co., MSC Cruises (USA), Inc. by Havana Docks Corporation. (Attachments: # 1 MSC Cruises (USA) Incs and MSC Cruises SA Co.s Supplement Responses to Plaintiffs First Set of Interrogatories dated September 8, 2020, # 2 MSC Cruises (USA) Incs and MSC Cruises SA Co.s Third Supplemental Response to Plaintiffs First Set of Interrogatories dated October 6, 2020, # 3 MSC Cruises SAs Objections and Responses to Plaintiffs First Sec of Interrogatories to MSC Cruises SA dated February 8, 2021., # 4 MSC Defendants Amended Responses to Plaintiffs First Request for Admissions to Defendants dated September 8, 2021, # 5 MSC Cruises SAs Second Supplemental Responses to Plaintiffs Second Set of Interrogatories to MSC Cruises, SA dated September 10, 2021, # 6 February 11, 2019 Letter to MSC from Rodney S. Margol, Esq. (HDC 018658-18659), # 7 June 21, 2018 Email re Documents for Cuba (MSCCUSA0000050633 50638 CONFIDENTIAL), # 8 Shore Excursion list (MSCCUSA0000065588-65589 CONFIDENTIAL), # 9 Shore Excursion Agreement for MSC Cruises Passengers between MSC Cruises S.A. and Agencia Viajes Cubanacan S.A. (certified translation and original) (MSCCUSA000006631566388 CONFIDENTIAL), # 10 MSC Armonia Excursion Revenue Report per Excursion Date (MSCCUSA0000068715 CONFIDENTIAL), # 11 Shore Excursion Daily Report for MSC Opera (MSCCUSA0000068783- 68792 CONFIDENTIAL), # 12 July 31, 2018 Cruise Port Operations Service Contract between Aries S.A. and MSC Cruises S.A. re Armonia (certified translation and original) (MSCCUSA000007940379420 CONFIDENTIAL), # 13 July 31, 2018 Cruise Port Operations Service Contract between Aries S.A. and MSC Cruises S.A. re Opera (certified translation and original) (MSCUSA000007942179435 CONFIDENTIAL), # 14 December 17, 2015 Agency Agreement between MSC Cruises SA and Agencia Maritima Mapor SA. (MSCCUSA000007993779950 CONFIDENTIAL), # 15 Document titled Recap Spreadsheet MIA-HAV 2018 & 2019 (MSCSA0000000236 CONFIDENTIAL), # 16 Spreadsheet titled HAV-HAV: 2015-2019 (MSCSA0000000370 ATTORNEYS EYES ONLY), # 17 List of MSC Excursions in Havana (NCLH_23591-00027311-27333), # 18 May 9. 2016 Email re MSC tour info Cuba (RCL-Havana0127752-127757 CONFIDENTIAL), # 19 FL Division of Corporations (Sunbiz) Printout for MSC Cruises SA CO, # 20 Transcript of and Exhibits (PLF 125-130) 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), # 21 February 13, 2019 Email re Havana Meetings First Draft (HavanaDocks_0484030-484034 CONFIDENTIAL), # 22 Carnival Corporations Response to Plaintiffs Second Request for Admissions dated September 7, 2021, # 23 June 9, 2015 Email re Letter from Mr. Pierfrancesco Vago (certified translation and original) (MSCCUSA0000077298-77301 CONFIDENTIAL), # 24 February 3, 2019 Email re Havana Berth Schedule (RCL-Havana0157545157546 CONFIDENTIAL), # 25 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), # 26 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, # 27 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, # 28 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, # 29 August 21, 2018 Email re Berth Request for Riviera (NCLH_23591-00005908-11), # 30 Spreadsheet: MSC Cruises Cover Itinerary released on Thu, May 12, 2016, 12:53 (MSC0000049805 CONFIDENTIAL), # 31 December 18, 2014 Email re US seeks to normalize relations with Cuba (RCL-Havana0066678-0066690 CONFIDENTIAL), # 32 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, # 33 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, # 34 Carnival Itinerary information for the Veendam (Exhibit PS-123 to Expert Report of Pedro Spiller ATTORNEYS EYES ONLY), # 35 November 9, 2018 Email re Cuba: Trump administration tightens sanctions, may allow US lawsuits (RCL-Havana0153675-153677 CONFIDENTIAL), # 36 May 28, 2015 Email re letter from Mr. Pierfranceso Vago to Rodrigo (certified translation and original) MSCCUSA0000077429-77431, # 37 June 1, 2015 Email re letter from Mr. Pierfrancesco Vago to Senor Ministro del Transporte Cesar Arocha Macid (certified translation and original) MSCCUSA0000080695-80697), # 38 August 10, 2021 Declaration of Duncan Hall (Internet Archive re Wayback Machine) (HDC 022628-022647), # 39 Transcript of Deposition of Bradley Stein in his capacity as Defendants Rule 30(b)(6) designee, dated November 20, 2020, # 40 Transcript of Deposition of Bradley Stein in his capacity as Defendants Rule 30(b)(6) designee, dated November 20, 2020, # 41 Transcript of Deposition of Adam Goldstein, dated April 21, 2021, # 42 July 16, 2018 Article: Miami billboards accuse cruise ships that sail to Cuba of dealing in confiscated property (HDC 001416-1421), # 43 Photograph of Billboard (HDC 001481), # 44 June 24, 2018 Email re Cruise ship CEOs (HDC 016334-16336), # 45 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) (Martinez, Roberto) Modified by unsealing specific documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 09/20/2021)

09/20/2021 217 

Statement of: DEFENDANTS' STATEMENT OF UNDISPUTED MATERIAL FACTS by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO re 216 Defendant's MOTION for Summary Judgment DEFENDANT'S OMNIBUS MOTION FOR SUMMARY JUDGMENT (Attachments: # 1 Appendix Consolidated Exhibit Slipsheet for Under Seal Exhibits, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 19, # 15 Exhibit 21, # 16 Exhibit 22, # 17 Exhibit 27, # 18 Exhibit 45, # 19 Exhibit 60, # 20 Exhibit 64, # 21 Exhibit 66, # 22 Exhibit 68, # 23 Exhibit 69, # 24 Exhibit 70, # 25 Exhibit 71, # 26 Exhibit 77, # 27 Exhibit 79, # 28 Exhibit 81, # 29 Exhibit 83, # 30 Exhibit 84, # 31 Exhibit 86, # 32 Exhibit 87, # 33 Exhibit 88, # 34 Exhibit 89, # 35 Exhibit 91, # 36 Exhibit 94, # 37 Exhibit 95, # 38 Exhibit 96, # 39 Exhibit 98, # 40 Exhibit 101, # 41 Exhibit 103, # 42 Exhibit 106, # 43 Exhibit 107, # 44 Exhibit 108, # 45 Exhibit 113, # 46 Exhibit 116, # 47 Exhibit 118, # 48 Exhibit 119, # 49 Exhibit 123, # 50 Exhibit 124)(Baldridge, James) (Entered: 09/20/2021)

09/20/2021 212 

Notice of Filing EXHIBITS TO ECF 210 MSC CRUISES' STATEMENT OF UNDISPUTED FACTS by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 8, # 8 Exhibit 9, # 9 Exhibit 11, # 10 Exhibit 21, # 11 Exhibit 26, # 12 Exhibit 27, # 13 Exhibit 28, # 14 Exhibit 30, # 15 Exhibit 37, # 16 Exhibit 39, # 17 Exhibit 40, # 18 Exhibit 45, # 19 Exhibit 52, # 20 Exhibit 53, # 21 Exhibit 54, # 22 Exhibit 55, # 23 Exhibit 56, # 24 Exhibit 57, # 25 Exhibit 60, # 26 Exhibit 61a, # 27 Exhibit 61b, # 28 Exhibit 61c, # 29 Exhibit 63, # 30 Exhibit 64, # 31 Exhibit 65, # 32 Exhibit 66) (Baldridge, James) Modified by unsealing specific documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 09/20/2021)

09/20/2021 211 

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 to DE 344 Order on 4/8/2022 (kpe). (Entered: 09/20/2021)

09/20/2021 210 

Statement of: 209 MSC CRUISES' STATEMENT OF UNDISPUTED FACTS IN SUPPORT OF ITS INDIVIDUAL MOTION FOR SUMMARY JUDGMENT by MSC Cruises (USA) Inc., MSC Cruises SA, MSC Cruises SA CO (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26, # 27 Exhibit 27, # 28 Exhibit 28, # 29 Exhibit 29, # 30 Exhibit 30, # 31 Exhibit 31, # 32 Exhibit 32, # 33 Exhibit 33, # 34 Exhibit 34, # 35 Exhibit 35, # 36 Exhibit 36, # 37 Exhibit 37, # 38 Exhibit 38, # 39 Exhibit 39, # 40 Exhibit 40, # 41 Exhibit 41, # 42 Exhibit 42, # 43 Exhibit 43, # 44 Exhibit 44, # 45 Exhibit 45, # 46 Exhibit 46, # 47 Exhibit 47, # 48 Exhibit 48, # 49 Exhibit 49, # 50 Exhibit 50, # 51 Exhibit 51, # 52 Exhibit 52, # 53 Exhibit 53, # 54 Exhibit 54, # 55 Exhibit 55, # 56 Exhibit 56, # 57 Exhibit 57, # 58 Exhibit 58, # 59 Exhibit 59, # 60 Exhibit 60, # 61 Exhibit 61, # 62 Exhibit 62, # 63 Exhibit 63, # 64 Exhibit 64, # 65 Exhibit 65, # 66 Exhibit 66, # 67 Exhibit 67, # 68 Exhibit 68, # 69 Exhibit 69, # 70 Exhibit 70)(Baldridge, James) (Entered: 09/20/2021)

09/19/2021 205 

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 to DE 344 Order on 4/8/2022 (kpe). (Entered: 09/19/2021)

09/16/2021 202 

Notice of Filing Exhibits 51-101 Cited in Plaintiff's Statement of Material Facts in Support of Individual Motion for Summary Judgment Against MSC Cruises S.A., MSC Cruises S.A., CO. and MSC Cruises (USA), Inc. by Havana Docks Corporation. (Attachments: # 1 Exhibit PLF Deposition Exhibit 42: May 31, 2015 Email re Cuba (MSCCUSA0000077393 CONFIDENTIAL), # 2 Exhibit PLF Deposition Exhibit 43: June 17, 2015 Email re Letter to the Honourable Seor Ministro del Transporte, Csar Arocha Macid, with attached letter (MSCCUSA0000077230-71 CONFIDENTIAL), # 3 Exhibit PLF Deposition Exhibit 44: June 27, 2015 Email re Cuba Sierra Maestra, with attachment (MSCCUSA0000080644-64 CONFIDENTIAL), # 4 Exhibit PLF Deposition Exhibit 45: July 3, 2015 Email re MSC Cruises to Inaugurate Cuba as a Destination in December 2015 (MSCCUSA0000079193-96 CONFIDENTIAL), # 5 Exhibit PLF Deposition Exhibit 46: September 29, 2015 Email re Terminal Havana - Onsite Inspection September 2015 (MSCCUSA0000076747-61 CONFIDENTIAL), # 6 Exhibit PLF Deposition Exhibit 47: December 3, 2015 Email re MSC Cruises to Double Presence in Cuba, Sending Second Ship to Meet Rising Demand for the Islands Uniquely Rich Culture (MSCCUSA0000080402-405 CONFIDENTIAL), # 7 Exhibit PLF Deposition Exhibit 48: December 27, 2015 Email re Terminal Havana - 1st call MSC Opera 22/12/15 (MSCCUSA0000079238-59 CONFIDENTIAL), # 8 Exhibit PLF Deposition Exhibit 49: January 2, 2016 Email re Punta Frances (Isla de la Juventud) (MSCCUSA0000076769-785 CONFIDENTIAL), # 9 Exhibit PLF Deposition Exhibit 50: January 16, 2016 Letter from Maltzman Partners re Request for formal opinion letter regarding Cuba People to People Program onboard MSC Opera (MSCCUSA0000066473-481 CONFIDENTIAL), # 10 Exhibit PLF Deposition Exhibit 51: March 25, 2016 Email re Updated media strategy (MSCCUSA0000063164-67 CONFIDENTIAL), # 11 Exhibit PLF Deposition Exhibit 52: November 13, 2016 Email re Isla de la Juventud (MSCCUSA0000079321-23 CONFIDENTIAL), # 12 Exhibit PLF Deposition Exhibit 53: July 18, 2017 Email re Port charges - Havana (Cuba) 2017 (Capt. Pastena) (MSCCUSA0000080535-36 CONFIDENTIAL), # 13 Exhibit PLF Deposition Exhibit 54: November 22, 2017 Email re CLIA Cruise Industry Symposium Bilateral Meetings (MSCCUSA0000076820-21 CONFIDENTIAL), # 14 Exhibit PLF Deposition Exhibit 55: April 17, 2019 Email re Helms Burton FYI Trump will allow Cuban-Americans to sue for confiscated property in Cuba (MSCCUSA0000080132-35 CONFIDENTIAL), # 15 Exhibit PLF Deposition Exhibit 56: April 21, 2019 Email from Frank Del Rio to Pierfrancesco Vago (NCLH_23591-00113713-14), # 16 Exhibit PLF Deposition Exhibit 57: Photograph of Havana Port Terminal (HDC 001967), # 17 Exhibit PLF Deposition Exhibit 58: Photograph of Havana Port Terminal (water view), # 18 Exhibit PLF Deposition Exhibit 59: Photograph of Havana Port Terminal (water view), # 19 Exhibit PLF Deposition Exhibit 60: Google Earth photograph of Havana Port Terminal, # 20 Exhibit PLF Deposition Exhibit 61: June 16, 2016 Email re: RFP Dynamic Mooring Analysis-Sierra Maestra (MSCUSA0000077280-93 CONFIDENTIAL), # 21 Exhibit PLF Deposition Exhibit 62: 12-27-15 December 27, 2015 Email re Terminal Havana 1st Call MSC Opera 12/22/2015 (MSCUSA0000079238-58 CONFIDENTIAL), # 22 Exhibit PLF Deposition Exhibit 63: November 13, 2016 Email re Isla de la Juventud (MSCUSA0000079308-20 CONFIDENTIAL), # 23 Exhibit PLF Deposition Exhibit 64: December 8, 2016 Email re MSC Armonia NCA 2nd Cruise (MSCUSA0000049743-46 CONFIDENTIAL), # 24 Exhibit PLF Deposition Exhibit 65: May 22, 2018 Email Re: GPH bags long-term deal to manage Havana cruise port, 6 berths planned (MSCUSA0000079306-07 CONFIDENTIAL), # 25 Exhibit PLF Deposition Exhibit 66: April 2, 2019 Email re: Havana (MSCUSA0000078424 CONFIDENTIAL), # 26 Exhibit PLF Deposition Exhibit 67: Re-Notice of Deposition of Rule 30(b)(6) Deposition of MSC Cruises SA, # 27 Exhibit PLF Deposition Exhibit 67A: Amended Supplemental Notice of Rule 30(b)(6) Deposition of MSC Cruises SA, # 28 Exhibit PLF Deposition Exhibit 68: Certified Claim CU-2492, # 29 Exhibit PLF Deposition Exhibit 69: Photograph of MSC Opera at Havana Port Terminal, # 30 Exhibit PLF Deposition Exhibit 70: Service Contract for the Operation of Cruise Vessel (Contract No. 15/2015) between Aries Transportes, S.A. and MSC Cruises S.A. (MSCSA0000000048-56 CONFIDENTIAL), # 31 Exhibit PLF Deposition Exhibit 71: Contract dated July 31, 2018 between Aries S.A. and MSC Cruises S.A. (in Spanish) (MSCCUSA0000079403-20 CONFIDENTIAL), # 32 Exhibit PLF Deposition Exhibit 72: Revenue Excel Spreadsheet (MSCSA0000000236 CONFIDENTIAL), # 33 Exhibit PLF Deposition Exhibit 72A: Revenue Excel Spreadsheet (MSCSA0000000044 CONFIDENTIAL), # 34 Exhibit PLF Deposition Exhibit 72B: Document titled HDC v MSC April 28, 2021 Supplemental 30(b)(6) Topic used to assist in testimony, # 35 Exhibit PLF Deposition Exhibit 72C: Document titled, MIA-HAV: 2018 & 2019) containing summary information re Deposition Exhibit 72 CONFIDENTIAL, # 36 Exhibit PLF Deposition Exhibit 73: MSC Cruises 2019 Annual Report, # 37 Exhibit PLF Deposition Exhibit 74: William J. Clinton Administration Statement on Action on Title III of the Cuban Liberties and Democratic Solidarity (LIBERTAD) Act of 1995, dated July 16, 1996 (MSCCUSA0000079643-44), # 38 Exhibit PLF Deposition Exhibit 75: April 21, 2019 Email re Contact in relation to HB Act Title III/IV (MSCCUSA0000079202-203 CONFIDENTIAL), # 39 Exhibit PLF Deposition Exhibit 76: Defendants Supplemental Initial Disclosures, dated January 13, 2021, # 40 Exhibit PLF Deposition Exhibit 77: March 8, 2018 Email re Cuba cruises from USA confidential (MSCCUSA0000080078-82 CONFIDENTIAL), # 41 Exhibit PLF Deposition Exhibit 78: July 18, 2018 Email re: USA Havana Excursions (MSCCUSA0000080324-327 CONFIDENTIAL), # 42 Exhibit PLF Deposition Exhibit 79: August 16, 2016 Email re MSC Armonia - US Guests v EU - Prepaid Sales (MSCCUSA0000079694-713 CONFIDENTIAL), # 43 Exhibit PLF Deposition Exhibit 80: November 20, 2018 Email re 2018 & 2019 Caribbean and Cuba Campaign - Shorex program and prices 20.11.2018 (MSCCUSA0000054019-283 CONFIDENTIAL) Volume 1, # 44 Exhibit PLF Deposition Exhibit 80: November 20, 2018 Email re 2018 & 2019 Caribbean and Cuba Campaign - Shorex program and prices 20.11.2018 (MSCCUSA0000054019-283 CONFIDENTIAL) Volume 2, # 45 Exhibit PLF Deposition Exhibit 81: MSC Cruises brochure (MSCCUSA0000047393-488), # 46 Exhibit PLF Deposition Exhibit 82: April 11, 2018 Email re Urgent: people to people excursions (MSCCUSA0000080203-210 CONFIDENTIAL), # 47 Exhibit PLF Deposition Exhibit 83 (Iaccarino): December 11, 2018 Email re part#2 MSC Armonia 2018-2019 CAR Season - Havana calls - Additional info people-to-people program (MSCCUSA0000064794-96 CONFIDENTIAL), # 48 Exhibit PLF Deposition Exhibit 83 (Pastena): MSC Cruises (USA) Inc.s and MSC Cruises SA Co.s Second Supplemental Responses to Plaintiffs First Set of Interrogatories, dated September 23, 2020 CONFIDENTIAL, # 49 Exhibit PLF Deposition Exhibit 84: November 21, 2016 Email re Havana Berth Request from now to April 2019 (MSCCUSA0000077066-77 CONFIDENTIAL), # 50 Exhibit PLF Deposition Exhibit 85: November 27, 2015 Email re: Havana Meeting, Nov. 24 and 25 2015 (certified translation and original) (MSCCUSA 0000080384-392 CONFIDENTIAL), # 51 Exhibit PLF Deposition Exhibit 86: May 13, 2015 Email re MSC Opera Report on the Havana Harbor (certified translation and original) (MSCCUSA77416-21 CONFIDENTIAL), # 52 Exhibit PLF Deposition Exhibit 87: June 15, 2015 Email re Sierra Maestra No 1 draft Final Findings Report (MSCCUSA77311-50 CONFIDENTIAL)) (Martinez, Roberto) Modified by unsealing specific documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 09/16/2021)

09/16/2021 201 

Notice of Filing Exhibits 1-50 Cited in Plaintiff's Statement of Material Facts in Support of Individual Motion for Summary Judgment Against MSC Cruises S.A., MSC Cruises S.A., CO. and MSC Cruises (USA), Inc. by Havana Docks Corporation. (Attachments: # 1 Deposition Richard Sasso, # 2 Deposition Robert Fusaro, # 3 Deposition Giovanni Onorato, # 4 Deposition Pierfrancesco Vago, # 5 Deposition Gianluca Suprani, # 6 Deposition Massimiliano Mio, # 7 Deposition Marialuisa Iaccarino, # 8 Deposition Capt. Luigi Pastena, # 9 Exhibit PLF Deposition Exhibit 1: Notice of Deposition of Defendants Rule 30(b)(6) Representative, # 10 Exhibit PLF Deposition Exhibit 1A: Supplemental Notice of Deposition of Defendants Rule 30(b)(6) Representative, # 11 Exhibit PLF Deposition Exhibit 2: February 11, 2019 Letter to MSC from Rodney S. Margol, Esq., # 12 Exhibit PLF Deposition Exhibit 3: Screenshot of MSC Cruises Web page, titled Cuba, Not Only Havana, # 13 Exhibit PLF Deposition Exhibit 4: MSC Cruises (USA) Inc.s and MSC Cruises SA Co.s Third Supplemental Answers to Plaintiffs First set of Interrogatories (unverified), # 14 Exhibit PLF Deposition Exhibit 5: MSC Cruises (USA) Inc.s and MSC Cruises SA Co.s Third Supplemental Answers to Plaintiffs First set of Interrogatories (verified), # 15 Exhibit PLF Deposition Exhibit 6: Contract between Aries S.A. and MSC Cruises S.A. dated July 31, 2018 (in Spanish) (MSCCUSA0000066297-66314 CONFIDENTIAL), # 16 Exhibit PLF Deposition Exhibit 7: General Sales & Marketing Agreement between MSC SA and MSC USA (MSCCUSA0000066389-97 CONFIDENTIAL), # 17 Exhibit PLF Deposition Exhibit 8: Article from Travel & Cruise Magazine, First Quarter, 2018, # 18 Exhibit PLF Deposition Exhibit 9: Article from Travel & Cruise Magazine, First Quarter, 2016, # 19 Exhibit PLF Deposition Exhibit 10: Article titled Foreign cruise lines offer Americans way into Cuba, dated July 11, 2011, # 20 Exhibit PLF Deposition Exhibit 11: December 24, 2015 Email re People to People CUBA MSC Opera 2016 and MSC Opera and Armonia 2016/17 (MSCCUSA0000048726-727 CONFIDENTIAL), # 21 Exhibit PLF Deposition Exhibit 12: 02-01-14 Email re Cuba/Rick Sasso (MSCCUSA0000048717-20 CONFIDENTIAL), # 22 Exhibit PLF Deposition Exhibit 13: February 23, 2016 Email re SUMMER 2017 WINTER 2017/18 PREVIEW (MSCCUSA0000066448-49 CONFIDENTIAL), # 23 Exhibit PLF Deposition Exhibit 14: March 30, 2016 Email re Follow up to our call/Cuba (MSCCUSA0000049508-10 CONFIDENTIAL), # 24 Exhibit PLF Deposition Exhibit 15: March 23, 2016 Memorandum to Gianni Onorato from MSC Cruises USA re MSC Cruises Cuba Announcement (MSCCUSA0000063165-67 CONFIDENTIAL), # 25 Exhibit PLF Deposition Exhibit 16: Draft Press Release titled MSC Cruises to offer people to people Cuba cruises to US Citizens onboard two newly renovated and modern cruise ships (MSCCUSA0000062979-80 CONFIDENTIAL), # 26 Exhibit PLF Deposition Exhibit 17: November 7, 2017 Appointment re Cuba Cruise Symposium - Nov 28 & 29 (MSCCUSA0000066426-29 CONFIDENTIAL), # 27 Exhibit PLF Deposition Exhibit 18: Proposed Agenda for CLIA Cruise Industry Symposium, Havana, Cuba, November 28 & 29, 2017 (MSCCUSA0000066430-35 CONFIDENTIAL), # 28 Exhibit PLF Deposition Exhibit 19: July 11, 2018 Email re MSC Cruises announces agreement for new PortMiami terminal (MSCCUSA0000050507-09 CONFIDENTIAL), # 29 Exhibit PLF Deposition Exhibit 20: 12-28-16 December 28, 2016 Email re Canada Cuba brochure (MSCCUSA0000048811-27 CONFIDENTIAL), # 30 Exhibit PLF Deposition Exhibit 21: Notice of Deposition of Roberto Fusaro, # 31 Exhibit PLF Deposition Exhibit 22: Defendants Initial Disclosures, dated October 23, 2019, # 32 Exhibit PLF Deposition Exhibit 23: July 28, 2016 Email re CUBA (MSCCUSA0000049391 CONFIDENTIAL), # 33 Exhibit PLF Deposition Exhibit 24: August 8, 2016 Email re Cuba North American Announcement Edited Version (MSCCUSA0000049392-94 CONFIDENTIAL), # 34 Exhibit PLF Deposition Exhibit 25: August 8, 2016 Email re Cuba (MSCCUSA0000049642-44 CONFIDENTIAL), # 35 Exhibit PLF Deposition Exhibit 26: September 8, 2016 Email re Cuba USA product launch (MSCCUSA0000066437 CONFIDENTIAL), # 36 Exhibit PLF Deposition Exhibit 27: September 9, 2016 Email re Air Package Program to Cuba (MSCCUSA0000049647-49 CONFIDENTIAL), # 37 Exhibit PLF Deposition Exhibit 28: September 26, 2016 Email re CROL OX AX 17-18 (MSCCUSA0000049597-99 CONFIDENTIAL), # 38 Exhibit PLF Deposition Exhibit 29: October 4, 2018 Email re MSC Armonia/Cuba 60 day countdown release (MSCCUSA0000055378-87 CONFIDENTIAL), # 39 Exhibit PLF Deposition Exhibit 30: December 12, 2018 Email re Armonia Cuba Sailings (MSCCUSA0000055710-13 CONFIDENTIAL), # 40 Exhibit PLF Deposition Exhibit 31: June 21, 2018 Email re Documents for Cuba (MSCCUSA0000050633-38 CONFIDENTIAL), # 41 Exhibit PLF Deposition Exhibit 32: December 24, 2016 Email re Cuba/Central Holidays and MSC (MSCCUSA0000048803-04 CONFIDENTIAL), # 42 Exhibit PLF Deposition Exhibit 33: December 20, 2018 Email re issue with Cuba on Martha Stewart excursions (MSCCUSA0000055700 CONFIDENTIAL), # 43 Exhibit PLF Deposition Exhibit 34: January 30, 2017 Email re Cuba Group conditions policy update (MSCCUSA0000048712-13 CONFIDENTIAL), # 44 Exhibit PLF Deposition Exhibit 35: March 21, 2019 Email re Port Miami Event March 22 (MSCCUSA0000066402-03 CONFIDENTIAL), # 45 Exhibit PLF Deposition Exhibit 36: MSC Cruises (USA) Inc. and MSC Cruises SA Co.s Answer to Second Amended Complaint, dated October 22, 2020, # 46 Exhibit PLF Deposition Exhibit 37: February 22, 2019 Letter to the Honorable Michael R. Pompeo (NCLH_23591-00111666-67), # 47 Exhibit PLF Deposition Exhibit 38: December 18, 2014 Email re Cuba (MSCCUSA0000066450-51 CONFIDENTIAL), # 48 Exhibit PLF Deposition Exhibit 39: April 27, 2015 Email re Lettera Cuba; (MSCCUSA0000077553-60 CONFIDENTIAL), # 49 Exhibit PLF Deposition Exhibit 40: May 13, 2015 Email re Letter to MSC USA Cruises re Cuba with attached letter (MSCCUSA0000077534-35 CONFIDENTIAL), # 50 Exhibit PLF Deposition Exhibit 41: May 30, 2015 Email re Cuba (MSCCUSA0000077396-400 CONFIDENTIAL)) (Martinez, Roberto) Modified by unsealing specific documents pursuant to DE 344 Order on 4/8/2022 (kpe). (Entered: 09/16/2021)

U.S. Federal Court Rules Bacardi Must Use USPTO Rules For "Havana Club" Trademark Issue.

Bloomberg- (7 April 2022)- Court lacks judicial review under the Lanham Act.  Bacardi, Cubaexport in decadeslong battle over mark.  Bacardi U.S.A. Inc. lost a lawsuit against the U.S. Patent and Trademark Office after a Virginia federal court found it didn’t have the ability to review whether the agency should have renewed a Cuban rum maker’s “Havana Club” trademark registration. 

Bacardi and Cubaexport, the Cuban government agency that makes and sells the rum internationally, have been in a decadeslong fight over who owns the rights to the Havana Club trademark.  Bacardi, a Florida-based rum maker, argued that the USPTO violated the Administrative Procedure Act by allowing Cubaexport to renew its rights to Havana Club in 2016. Bacardi sells rum internationally using the Havana Club mark and has a trademark application that has been pending since 1994. The Havana Club mark was originally owned and registered in the U.S. by Cuban rum maker Jose Arechabala SA, but the Cuban government took control of the company’s assets in 1960 following the revolution there. Congress passed a law in 1998 that “prevented the registration of trademarks that were seized by the Cuban Government,” the court said.  

The U.S. Office of Foreign Assets Control denied Cubaexport a license to renew its registration in 2006, but reversed course a decade later. Bacardi argued the renewal will doom its pending application for the same trademark, and that the court should cancel Cubaexport’s trademark.  Judge Liam O’Grady of the U.S. District Court for the Eastern District of Virginia ruled that judicial review of the USPTO’s actions was improper in this case. Judicial review under the APA doesn’t apply when the statute in question, in this instance the Lanham Act, precludes it, O’Grady said. The court said the Lanham Act provides detailed procedures for how to contest trademark registrations, which means Bacardi already has a remedy through traditional trademark litigation. Bacardi is part of a pending 2004 lawsuit against Cubaexport over the Havana Club trademark in a Washington, D.C., federal court.  “Congress did not allow for challenges to another party’s registration by filing civil suit against the USPTO,” the court said.  The Lanham Act also explicitly precludes the USPTO director, a defendant in the case, from facing civil action, the court said.  

Kelley Drye & Warren LLP and Covington & Burling LLP represent Bacardi. The U.S. Attorney’s Office represents the USPTO. The case is Bacardi & Company Limited v. United States Patent and Trademark Office, E.D. Va., No. 1:21-cv-01441, 4/6/22. 

(Reuters- 7 April 2022)- The U.S. Patent and Trademark Office has defeated a lawsuit brought by rum maker Bacardi & Co in Virginia federal court over the PTO's revival of a Cuba-owned trademark that the liquor giant uses on American rum. The court said Wednesday that Bacardi could not sue the PTO directly in the liquor giant's long-running dispute with Cuba's state-run Cubaexport over the "Havana Club" trademark, and must challenge the trademark through the PTO itself. 

Bacardi attorney Michael Lynch of Kelley Drye & Warren said Thursday that the company is disappointed with the decision and was considering an appeal.  Bermuda-based Bacardi's founders were exiled from Cuba after the Cuban revolution. Bacardi says the Cuban government unlawfully seized the "Havana Club" mark along with other assets from Cuban company Jose Arechabala SA in 1960. Cubaexport and French spirits company Pernod Ricard sell "Havana Club" rum outside of the United States. Bacardi bought Jose Arechabala's brand and began selling Havana Club rum in the United States in 1995.

Bacardi's December lawsuit against the PTO said Cubaexport's trademark registration should have expired after it failed to get a license from the U.S. Treasury Department's Office of Foreign Assets Control in 2006. It challenged the agency's decision to renew Cubaexport's trademark in 2016 after OFAC changed course. Bacardi also said its pending application to register its own "Havana Club" mark will likely be refused because of Cubaexport's mark. U.S. District Judge Liam O'Grady said Wednesday that the court could not review the renewal under federal trademark law, and that Bacardi's only recourse was to ask the PTO to cancel Cubaexport's registration.  He rejected Bacardi's argument that the court should hear the case because the PTO does not have a process for challenging a trademark based on an improper renewal.  O'Grady also noted that Bacardi already went through PTO proceedings and has challenged the agency's decisions in Washington, D.C., federal court, in a case that is still pending.  The PTO declined to comment. 

The case is Bacardi & Co v. U.S. Patent and Trademark Office, U.S. District Court for the Eastern District of Virginia, No. 1:21-cv-01441.  For Bacardi: Michael Lynch, Damon Suden and Cameron Argetsinger of Kelley Drye & Warren; and David Zionts of Covington & Burling 

Read more:

Bacardi sues USPTO over renewal of Cuban 'Havana Club' trademark

Bacardi demands U.S. explain giving Havana Club brand to Cuba

Airbnb Successfully Lobbied Trump Administration. Airbnb Should Now Focus On Biden Administration To Advocate For Direct Correspondent Banking So Hosts In Cuba May Access Funds Directly, Efficiently.

At Peak Year, There Were 40,000 Airbnb Listings In Cuba Whose Hosts Were Paid Approximately US$60 Million.   

Airbnb Spent US$250,000.00 To Successfully Lobby Trump-Pence Administration (2017-2021) To Exempt Private Homes From Its Restrictions.  

Airbnb Should Now Direct Its Energies Towards The Biden-Harris Administration (2021- ) To Advocate For Direct Correspondent Banking So Hosts In Cuba May Access Funds Directly, Efficiently, And Transparently. 

The Less Airbnb Hosts In Cuba Pay To Receive Their Payments, The More Funds Will Be Available For Investments In Their Properties. 

San Francisco, California-based Airbnb, Inc. (2021 revenues US$6 billion.  The company reported that its Host community had six million active listings and earned US$34 billion in 2021). 

In 2015, the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury authorized Pompano Beach, Florida-based Stonegate Bank to have an account with Republic of Cuba government-operated Banco Internacional de Comercia SA (BICSA), a member of Republic of Cuba government-operated Grupo Nuevo Banca SA, created by Corporate Charter No. 49 on 29 October 1993 and commenced operation on 3 January 1994.    

Stonegate Bank provides commercial operating accounts for the Embassy of the Republic of Cuba in Washington, DC and the Permanent Mission of the Republic of Cuba to the United Nations in New York City; the financial institution also handles other types of OFAC-authorized transactions.  In September 2017, Stonegate Bank was purchased by Conway, Arkansas-based Home BancShares (2021 assets approximately US$17.7 billion) through its Centennial Bank subsidiary.      

Despite intense advocacy, the Obama-Biden Administration (2009-2017) National Security Council (NSC) inexplicably and stubbornly to permit BICSA a correspondent account with Stonegate Bank, so Stonegate Bank was required to use third country financial institutions.  Transactions for approximately eighty (80) customers were managed on a regular basis through Panama City, Panama-based Multibank, which had dealing with Republic of Cuba government-operated financial institutions in the Republic of Cuba.   

Absent bilateral direct correspondent banking accounts, the payment process for funds from the United States to the Republic of Cuba and from the Republic of Cuba to the United States remains triangular rather than a straight line- which would be more efficient, more secure, more transparent, more timely (same day versus two or more days), and less costly.  

NOTE: Since the first exports of agricultural commodities from the United States to the Republic of Cuba in December 2001, more than US$6,622,784,996.00 has been received as payment from the Republic of Cuba- every penny through a third country where a financial institution takes a fee.  

Grupo Aval Of Colombia Purchase Of Multibank 

On May 11, 2020 Grupo Aval informed that its subsidiary Banco de Bogotá (through its subsidiary Leasing Bogotá S.A. Panamá) has agreed to amend the purchase agreement for up to 100% of the outstanding common shares (the “SPA”) of Multi Financial Group, Inc. (“MFG”), parent company of Panamanian bank Multibank.  From Grupo Aval On 16 June 2020: “On May 25th, Banco de Bogotá, through its subsidiary Leasing Bogotá S.A. Panamá, acquired 96.6% of the ordinary shares of Multi Financial Group.  As part of the acquisition process, MFG’s operation in Cuba was closed and as part of the transaction.  Grupo Aval complies with OFAC regulations and doesn't have transactional relationships with Cuba.”     

“Grupo Aval Acciones y Valores S.A. (“Grupo Aval”) is an issuer of securities in Colombia and in the United States.  As such, it is subject to compliance with securities regulation in Colombia and applicable U.S. securities regulation.  Grupo Aval is also subject to the inspection and supervision of the Superintendency of Financeas holding company of the Aval financial conglomerate.  

The OFAC should rephrase existing regulations to make easier, more transparent, and less costly for entrepreneurs in the Republic of Cuba to engage with their counterparts in the United States and for entrepreneurs in the United States to engage with their counterparts in the Republic of Cuba.  Only an individual absent private sector commercial experience would believe strangling the movement of capital benefits the United States in its re-engagement with the re-emerging private sector (self-employed) the Republic of Cuba.  

If the Biden-Harris Administration wants to increase the demand from entrepreneurs in the United States to re-engage with entrepreneurs in the Republic of Cuba, and simultaneously frustrate the Miguel Diaz-Canel Administration (2018- ) in the city of Havana, then increase, overwhelm the supply of the means of production.  This begins with the efficient and transparent movement of capital.   

Does This Make Sense?  Initially, It Does- But Then Falls Apart   

Today, an individual subject to United States jurisdiction 1) may travel to the Republic of Cuba 2) use credit cards and debit cards in the Republic of Cuba 3) open a bank account in the Republic of Cuba 4) use a bank, credit union, or money services business to process remittances to or from the Republic of Cuba 5) utilize online payment platforms to facilitate or process authorized transactions involving the Republic of Cuba and 6) send remittances (gifts not loans or investments) to certain individuals and independent non-governmental organizations in Cuba that encourage the development and operation of private businesses by self-employed individuals.  

Today, a company subject to United States jurisdiction 1) may process credit and debit card transactions for individuals traveling to, from, or within the Republic of Cuba, and related settlements, for third-country financial institutions 2) financial institutions may have a correspondent account at a financial institution in the Republic of Cuba 3) financial institutions in the Republic of Cuba may not have a correspondent account with a United States financial institution 4) banking institutions are not permitted to process “U-turn” transactions, i.e., funds transfers originating and terminating outside the United States, where neither the originator nor the beneficiary is a person subject to United States jurisdiction 5) may export medical equipment, medical instruments, medical supplies, pharmaceuticals, informational materials, artwork, agricultural commodities and food products 6) may import agricultural commodities, artwork, informational materials, and products produced by registered self-employed and 7) may import medications for clinical trials and create joint ventures to market the medications.  

Here is the rub: Mr. Smith from Washington DC may have an account at a bank in Havana, but Mr. Smith may not directly transfer any money from his checking account in Washington DC to his account at the bank in Havana.  He may transfer the funds from Washington to Paris and then from Paris to Havana.  If Mr. Smith wants to have an investment in an independent business in Havana, wants to receive payment for a product or service sold to an independent business, wants to send additional funds, or receive a profit-sharing payment from an independent business, United States regulations do not permit him to do so.   

Today, when receiving payment from the Republic of Cuba or sending payment to the Republic of Cuba there is no straight-line transaction.  It is a triangle.  And often not an equilateral triangle or isosceles triangle.  Distance can create an acute triangle or obtuse triangle.  In banking, triangles are harmful, not helpful.    

A financial institution in a third country is always involved- and it receives a fee for that involvement.  Is the triangle necessary?  No.  Does the triangle provide the United States government with increased opportunities to monitor the transactions?  No.  Does the triangle increase the cost for an individual subject to United States jurisdiction and company subject to United States jurisdiction?  Yes.  Does the triangle increase the cost to a Republic of Cuba national and Republic of Cuba-based company?  Yes.  

Inflicting as much pain as possible upon those engaging in a transaction involving the United States was never logical as it served as a perpetual boomerang of pain for those involved in statutorily protected export transactions.  The message to agricultural interests in the United States- you may legally export your products to the Republic of Cuba, but by the time you are done, you wish you hadn’t done so.  That is an inspirational message from the taxpayer-funded United States Department of State, United States Department of the Treasury, United States Department of Agriculture, and United States Department of Commerce?  Reminds of… “We’re from the government and here to help…”    

United States policy is not solely focused upon increasing the financial costs associated with engagement with the Republic of Cuba.  The focus is also upon increasing inefficiencies for each transaction.  The goal is to assault individuals and companies with an upper cut (increased costs) and a body blow (inefficiencies) and a left jab (multiple compliance layers for each transaction).  Most companies do not wait for a TKO or KO, they throw in the towel.  

When a United States-based financial institution employee reads “Cuba” on any document (outgoing or incoming), there is a nearing 100% certainty the transaction will be subjected to additional compliance review and then returned to the customer- even if the transaction is specifically authorized.  If the transaction makes it past an employee, computer systems will most certainly flag it and terminate it.  Financial institutions in the United States are warry of all Republic of Cuba-related transactions.  For the farmer awaiting payment for a shipment of poultry, soybeans, corn, wood, and other products, the delay is unhelpful to their already challenging bottom-line.    

One-Way Correspondent Banking Does Not Work  

Sending investment funding and providing loans to someone who wants to have or wants to expand a small business can be transformative.  Is not the goal of the Biden Administration to extract as many Republic of nationals as possible from commercial and economic reliance upon the government of the Republic of Cuba?  

Would not be impactful for registered self-employed and Micro, Small and Medium-Size Enterprises (MSMEs) to open hundreds, thousands of accounts at financial institutions in the Republic of Cuba?  Where they could receive funds transparently and directly from their investor or customer within hours.  Where they could deliver profit-sharing funds and supplier payments transparently and directly within hours.  Each transaction transparent and compliant with United States financial institution regulations.  Yes, the transaction activity could overwhelm the financial sector within the Republic of Cuba- but, would that be such an undesired outcome?  The financial sector would be required to meet the demand or explain to customers the reasons for the failure to adapt to the marketplace.  

The Republic of Cuba may not embrace direct correspondent banking due to the requirements of the United States Department of the Treasury, United States Department of Justice, and United States Federal Reserve for all correspondent accounts regardless of country.  Again, there is a point here- let it be the Republic of Cuba who declines to re-establish a “normalized” financial landscape with the United States.  

Regarding the re-authorization of “U-turns” where financial institutions were permitted to process non-United States-related transactions involving the Republic of Cuba, the prism through which a decision to again permit “U-turns” should not be solely whether permitting “U-turns” benefits the Republic of Cuba.  It does.  More important is the transparency required for “U-turns” which remains an important goal of the United States.  Also, not permitting “U-turns” is an additional reason for financial institutions to avoid all Republic of Cuba-related authorized transactions.   

If the Biden-Harris Administration wants “prosperity in Cuba” then it should re-calibrate the means to that end.  Doing so will demonstrate removing impediments for re-engagement with the self-employed in the Republic of Cuba is the most efficient means of creating indigestion for the government of the Republic of Cuba.  

No one in the United States must engage commercially with the Republic of Cuba.  The Biden-Harris Administration must seed the garden.  Those seeds must be focused upon making easier and more transparent the movement of funds and the use of those funds.  And commercial engagement with the Republic of Cuba should not have a unique “carve-out” for individuals of Cuban descent who are subject to United States jurisdiction.  The Biden-Harris Administration should ensure that all individuals subject to United States jurisdiction are subject to the same regulations as those regulations relate to commercial engagement with the Republic of Cuba.   

Link To Related Post 

Remittances: Will Biden-Harris Administration Repeat Mistakes Of Obama-Biden Administration And Learn From Mistakes Of Trump-Pence Administration? No Triangles. Yes Loans. Yes Investments.  May 18, 2021 

Rest of World
New York, New York
4 April 2022

How Airbnb reshaped Cuba’s tourism economy in its own image
The booking platform was a game changer on the island, but the embargo still fosters some tension between Cubans and the U.S. company.

By Leo Schwartz and Lidia Hernández-Tapia  

Lorelis García de la Torre hails from the Cuban city of Camagüey but has always loved the stately old colonial homes of Havana, many crumbling and long past their glory days. She left Cuba in 2006, first for Spain and then Canada. Shortly after, the country’s tourism industry heated up, with aspiring entrepreneurs buying up properties to turn into casas particulares, private homes available for rent. In 2014, she made an offer on a two-story house in the neighborhood of Vedado. 

Three years later, she opened the newly renovated house for business, naming it Casa Brava. But instead of renting it out through word-of-mouth or booking agencies, as Cubans had done for years, she first listed it on Airbnb. “It was the only way I knew of where Cubans had access and could receive payments,” she said.  

But Airbnb didn’t just offer Cubans like García de la Torre a means of renting their properties to tourists in a simple and centralized way. According to interviews with hosts, guides, service workers, and hotel industry professionals, Airbnb fundamentally changed the way that tourism operates on the island, replacing the country’s decades-old casa particular system and transforming entire neighborhoods to serve the needs of new clients with different expectations. Airbnb declined to be interviewed for this article.

Lorelis García de la Torre bought a two-story house in Havana and turned it into a rental property on Airbnb. Lorelis García de la Torre  

The uniquely Cuban system of casas particulares grew out of the country’s so-called Special Period, after the fall of the Soviet Union in the early 1990s. The government began to open up the housing market, allowing for the sale of private homes for tourist accommodation. Ricardo Torres Pérez, an economist and research fellow at American University, in Washington D.C., said that, as a result, “the number of visitors grew exponentially.”  The casas particulares offered something that other accommodations couldn’t. “Before it was a business, it was somebody’s home,” said Alison Coelho, who has been leading tourism experiences in Cuba since 2000.  

The model felt, and looked, not so different from the one Airbnb pitched when it was founded in 2008. “Hotels leave you disconnected from the city and its culture,” the company’s original pitch deck read. “Book rooms with locals.” 

“Airbnb is definitely a continuation of the casa particular model,” said Tom Popper, an expert on Cuban tourism from 82° West Consultants, a firm focused on business entry to Cuba.  

Airbnb entered the Cuban market in 2015 to much fanfare, as President Obama eased travel restrictions. In its first year of operations, the platform brought 4,000 of Cuba’s estimated 20,000 casas particulares onto its platform. Current data provided to Rest of World from the short-term rental data provider AirDNA shows that by May 2017, the total number of Airbnb listings had topped 20,000, essentially subsuming the casa particular market. Listings peaked at almost 35,000, the summer before Covid-19.  According to tourism experts, Airbnb made the casa particular model easier for both guests and owners, providing a place to not only list properties but make payments, rather than rely on word-of-mouth and cash. Furthermore, people like García de la Torre were buying properties to list them on Airbnb — people from not only Cuba but other countries like Italy and Spain as well.  Airbnb’s entry into Cuba coincided with an increase in tourism to the island overall, with the number of travelers growing by over 50% between 2014 and 2018. Tourism from the United States nearly quadrupled between 2015 and 2018. 

Yusleidys Pérez Ugarte, a travel agent who worked with the government until the pandemic hit, said that the expansion of private home rentals under Airbnb quickly took precedence over the hotel industry. “It’s not a secret to anyone that the hotels in Cuba are expensive and don’t have the best service,” she said. “During Obama’s term, when relations improved and Americans began to come, the private houses expanded because hotels could not keep up.” 

According to residents, neighborhoods in Havana began to transform under the new influx of development and tourists. Adriana Ricardo Díaz is the director of Arte Corte, a nonprofit community project in Old Havana that trains hairdressers. “During the years before the pandemic, the private sector took off, especially in the rental housing market,” she said. “Improvement didn’t look like the gentrification that you usually see in other countries, with its devastating impact. … People sold their houses that were in bad conditions, and there was a recuperation of wealth.”  

Cubans began to take advantage of Airbnb’s experiences feature as well. Ricardo Díaz offered experiences centered around cocktail making and would show tourists around Arte Corte.  Manuel Fortún Manzano, a 29-year-old from Havana, was working in human resources for a government-run construction company when his friend told him about Airbnb in 2018. He began offering an experience called “The Havana Whisperer,” where he would teach tourists about everything from how to change money to what neighborhoods to visit (accompanied by cocktails and food, of course). It quickly became his main source of income. “More than anything, it provided me with economic autonomy,” he told Rest of World.   

David Ferrán had been working as a tour guide in Havana when Airbnb came to the country. Before, people struggled to promote their tours and find clients. “What Airbnb did was allow a lot of people working as tour guides for the state to start working independently,” he told Rest of World. Ferrán began to create different experiences for the platform, going so far as to open a family-run spa business, which he now operates outside of Airbnb.  Havana is still the main hub for tourists in Cuba, but parts of the country that had never seen tourism changed as well. According to several hosts and Pérez, the American University economist who spoke with Rest of World, Airbnb was able to open different regions to private home rentals in a way that casas particulares never could.

Manuel Fortún Manzano launched his Airbnb tourism experience in 2018 and it quickly became his main source of income. https://www.airbnb.es/experiences/156319  

Nadal Antelmo Vizcaíno is originally from Santa Marta, a small town bordering the popular tourist destination of Varadero Beach, about two hours east of Havana. He moved to Miami in 2016 but decided to list his house on Airbnb in 2017, after he saw its burgeoning footprint on the island.  At first, his town was slow to adapt to the platform. “There weren’t more than five or 10 houses [on Airbnb],” Antelmo told Rest of World. But as he went back each year, he began to see how much the town was changing. New restaurants and cafés opened. There was a construction boom to satisfy demand for more houses. “Airbnb completely revolutionized Santa Marta,” he said. 

Evelio Jesús Medero Vázquez was a taxi driver in the Varadero area between 2015 and 2018, driving the type of classic car that has become synonymous with Cuba — in his case, a 1956 Porsche. He began to do more trips back and forth from Havana, shuttling tourists, mostly staying at Airbnbs, to the beach town. “It created a constant flow of clients who wanted to learn more about Cuba,” he said.  Like Antelmo, he saw how quickly the towns around Varadero changed. Upscale new restaurants popped up, and people who owned classic cars like himself were servicing thousands of tourists a day. “Places that used to be dumps or abandoned were becoming … clean and beautiful places,” he told Rest of World. “Airbnb was an unprecedented driving force.” 

“There were definitely bumps in the road,” said Popper, the tourism consultant. Internet access was one. Some casa particular owners, long used to operating through word-of-mouth, were unable to adapt to the new technology. Rodolfo Rodríguez Trejo has been renting his property in the Vedado neighborhood in Havana for over 20 years. When Airbnb opened in Cuba, he tried to sign up for the platform, but his internet access was spotty, and he wasn’t able to create an account.  "Places that used to be dumps or abandoned were becoming…clean and beautiful places. Airbnb was an unprecedented driving force."   

Another pain point for Cuban hosts was payment. People with dual citizenship or operating from other countries, like Antelmo, could accept payments through non-Cuban bank accounts. However, Cubans still in the country and with no other nationalities were faced with payment issues on the platform. 

On a plane to Miami in 2018, Rodríguez Trejo met an Airbnb host who told him that he was going to the company’s headquarters to ask them for overdue payments. After hearing this testimony, Rodríguez Trejo felt good about his decision to not use the platform. “In Cuba, it’s a struggle to buy things like butter, cheese, and eggs,” he told Rest of World. “It takes a lot of time and effort to then have to also deal with delayed payments for months.”  As Airbnb took over the casa particular model, two years after its launch in Cuba, the platform was handed an advantage over its remaining main competitor: hotels.  

New rules under the Trump administration restricted where U.S. citizens could stay, forcing Marriott to cease operations on the island. Instead, after Airbnb reportedly spent a quarter million dollars in lobbying efforts, the U.S. government encouraged visitors to Cuba to stay at private homes.  Alessandro Benedetti, the executive assistant manager at Gran Hotel Manzana Kempinski in Havana, one of the premiere hotels in Cuba, said that, normally, Airbnb would not be a direct competitor with the luxury hotel market. That was not the case in Cuba, where Americans made up the biggest percentage of guests before the pandemic.  “For this particular market, I would say that for hotels, Airbnb is the competition,” he told Rest of World. “Many tourists want to come to Cuba but are concerned with the regulation, so they go the safer way.” 

While the Trump administration’s more restrictive policies began to diminish the flow of tourism to Cuba, the pandemic nearly shut it off. Except for a brief period in the summer of 2020, Cuba’s borders were closed to international travelers for nearly all of 2020 and 2021, finally reopening in 2021. Hotels were closed, and Airbnb occupancy dropped precipitously.  

Now, with tourism on the rebound, it’s unclear to tourism experts whether Airbnb is better positioned than hotels. Properties like the Kempinski resorts continue to open in Cuba, offering the types of luxury experiences that were unavailable on the island before the pandemic.  García is hopeful that Airbnb business will rebound with the easing of the pandemic. She’s even helping her nephew restore an antique house in the town of Trinidad in central Cuba, about four hours east of Havana. Her vision is that once it opens, they can bring guests on a tour between the two houses.  “Even though people don’t have hope in Cuba, I think there is a lot of future in this country,” she said. 

The Hill
Washington DC
11 November 2017

Airbnb’s Cuba lobbying blitz pays off
By Melanie Zanona

Airbnb launched an ambitious lobbying blitz this summer to claw back some of President Trump’s planned new restrictions on Cuban travel — and the effort appears to have paid off. 

The popular travel-booking site, which considers Cuba its fastest-growing market, successfully secured language in Trump’s regulations issued this week that will allow Americans to stay in private homes, which are often listed on Airbnb, if they visit the island to support the Cuban people.{mosads}The victory for Airbnb underscores the White House’s struggle to balance its promised crackdown on Cuba with the interests of U.S. businesses, which have overwhelmingly supported former President Obama’s historic opening with the island nation.  

“Airbnb was founded on the belief that travel helps to break down barriers between people and countries and contributes to a greater understanding of the world,” Airbnb said in a statement to The Hill.  “We appreciate that hosts will continue to have the chance to share their space and that guests can continue to visit the island. Hosts in Cuba have welcomed guests from around the world and these regulations will allow Airbnb to keep supporting individual Cuban people who share their homes.”  The White House unveiled the details of its new Cuba policy on Wednesday, nearly five months after the president directed agencies to craft new rules tightening travel and commercial ties to Cuba. The effort was aimed at fulfilling Trump’s campaign promise to reverse Obama’s thaw with the communist-run country. 

But internally, the Trump administration wrestled with how far to go in cracking down on the communist regime, according to two sources familiar with the discussions. Trump ended up leaving the core of Obama’s Cuba policies intact.  The new rules that did come down, and which took effect Thursday, restrict Americans’ ability to travel to Cuba and prevent business deals with certain entities controlled by the Cuban government and military.  

The government will no longer allow individual “people-to-people” trips for educational purposes, meaning visitors must travel to Cuba with a licensed tour group instead of going on their own.  But there is an exception that helps companies like Airbnb. 

Obama had allowed Americans to travel to Cuba for 12 different reasons, though tourism was still strictly prohibited. The individual “people-to-people” category became one of the more popular ways to see Cuba and has been credited with bringing a flood of American visitors to the island.  More than 346,000 American citizens visited the island during the first six months of 2017 — a 149 percent increase from the same time last year. Commercial flights between the U.S. and Cuba resumed last August, while Obama restored diplomatic ties with Cuba in 2015.  A wide range of Cuban and U.S. businesses have been racing to cash in on the travel surge, with Airbnb becoming one of the major beneficiaries of Obama’s relaxed travel rules.  

Private bed-and-breakfasts, or “casa particulares”, have long been a common way to stay in Cuba. Since Airbnb started operating on the island in the spring of 2015, at least 22,000 rooms have been listed on the travel-booking site and $40 million was paid to Cuban individuals who shared their home. About 35 percent of Cuba’s Airbnb guests are American, the San Francisco-based startup added. 

But Trump’s June announcement that he would be restricting travel to Cuba sent shivers through the travel and tourism industry.  Their top concern was about the shift from individual to group travel – a model that is far more difficult for bed-and-breakfasts and other small businesses to accommodate.  So Airbnb went to work, setting up a new in-house team to lobby on the issue and spending a quarter of a million dollars over six months. Previously, Airbnb had only hired outside firms to lobby on its behalf, but it began to expand its footprint in Washington around the same time it started lobbying on Cuba for the first time ever.  Meagan McCanna, who was brought on to lead Airbnb’s federal affairs last December, became a registered lobbyist for the company starting in May. 

Between April and June, when Trump first announced the Cuba changes, Airbnb spent $160,000 to lobby on issues including “general discussions regarding the Executive Order related to Cuba.”

And from July to September, when the National Security Council and other relevant agencies were in the process of actually drafting language to carry out Trump’s order, Airbnb spent $90,000 to lobby the council on Cuba, among other things.  The company’s strategy was to educate policymakers about how the platform works and highlight how the sharing economy has benefited the Cuban people. 

When the rules finally came out this week, they ended up including a provision that allows travelers to stay in private bed-and-breakfasts, like those listed on Airbnb, if they are visiting the island under the “Support for the Cuban People” travel category.  A summary sheet of the new regulations says that “renting a room in a private Cuban residence (casa particular), eating at privately owned Cuban restaurants (paladares), and shopping at privately owned stores run by self-employed Cubans (cuentapropistas)” can now count towards supporting the Cuban people.  However, a traveler must engage in additional Support for the Cuban People activities — such as humanitarian purposes and human rights assistance — in order to meet the requirements of a full-time schedule.  Still, the language was welcome news for Airbnb and the private bed-and-breakfasts that use the travel-booking site  and even Cuba hard-liners in Congress said it was something they could swallow.  “I don’t have a problem with that,” Rep. Mario Diaz-Balart (R-Fla.) told The Hill.

Libertad Lawsuits Against Four Cruise Lines: Court Questioning Certified Claimant Legitimacy- Constitutional Issues With 1960 Claims Valuation Process? Experts In; Experts Out.

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)

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)

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)

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)

Links

Reply In Support Of Defendants’ Expedited Motion To Remove Cases From Trial Calendar And Continue Remaining Pretrial Deadlines (4/5/22)
Order Amending Scheduling Order And Certain Pretrial Deadlines (4/5/22)
Order Unsealing The Summary Judgment Record (4/4/22)
Plaintiff Havana Docks Corporation’s Response To Defendants’ Expedited Motion To Remove Cases From Trial Calendar And Continue Remaining Pretrial Deadlines (4/4/22)
Joint Notice Of Filing Proposed Order On Unsealing The Summary Judgment Record (4/1/22)
45-Page Omnibus Report And Recommendation Regarding Daubert Motions (4/1/22)
Defendants’ Expedited Motion To Remove Cases From Trial Calendar And Continue Remaining Pretrial Deadlines (3/31/22)
Libertad Act Lawsuit Filing Statistics

Excerpts 

THIS CAUSE is set for trial during the Court’s two-week trial calendar beginning on August 1, 2022, at 9:00 a.m. Courtroom 10-2 at the Wilkie D. Ferguson, Jr. United States Courthouse, 400 North Miami Avenue, Miami, Florida 33128.  

On April 1, 2022, Magistrate Judge McAliley issued a report recommending that all of Havana Docks’ experts be excluded, including its damages experts. (the “Report,” Carnival Case, D.E. 485.) The Report also recommends excluding two (out of three) opinions rendered by the Defendants’ damages expert.2 The current deadline to object to the Report is April 15, 2022. Id. at 45. 3. Havana Docks intends to file an objection to the Report and, due to the complexity and importance of the issues involved, will be seeking a two-week enlargement of its deadline to do so. Further, in its objection, Havana Docks intends to request a Daubert hearing, which would permit the Court to explore Havana Docks’ experts’ methodology and approach to valuation. 

Havana Docks intends to file an objection to the Report and, due to the complexity and importance of the issues involved, will be seeking a two-week enlargement of its deadline to do so. Further, in its objection, Havana Docks intends to request a Daubert hearing, which would permit the Court to explore Havana Docks’ experts’ methodology and approach to valuation.  Considering that the fair market value of Havana Docks’ confiscated property is the only issue remaining for trial, and that the Report recommends that all but one valuation witness be precluded from testifying on that issue, Havana Docks agrees with the Defendants that trial preparation and presentation will be meaningfully informed by the Court’s resolution of the Daubert motions. (Mot. at 4.) Thus, Havana Docks joins the Defendants in requesting an enlargement of the remaining pretrial deadlines and the present trial setting.

Plaintiff has shown, however, that Spiller’s second opinion is not relevant. His $1.5 million value of the Confiscated Property in 1960 is less than the $9.2 million that the Commission certified; it is also less than his current fair market valuation of $46 million. The Act’s damages provision plainly states that the greater figure isthe amount of damages. It also provides that the Commission’s $9.2 million finding is presumed to be the amount of Defendants’ liability. 22 U.S.C. § 6082 (a)(1)(A), (a)(2). As the lesser and disfavored number, Spiller’s 1960 fair market value is irrelevant. Defendants may attempt to argue that Spiller’s $1.5 million 1960 value is the more “appropriate amount of liability” and if that is the case, the Court may wish to consider his opinion in that context. I otherwise recommend that the Court grant Plaintiff’s Daubert Motion and Exclude Spiller’s second opinion. 

For the reasons expressed above, I respectfully recommend that the Court GRANT Defendants’ Omnibus Motion to Exclude Testimony of Plaintiff’s Experts (ECF No. 320), and exclude from evidence the testimony of John Hentschel, Franc Pigna, Michael Deiters, James Patton, Michael Garlich and José Azel. I further recommend that the Court GRANT Plaintiff’s Motion to Exclude Opinion of Pablo Spiller (ECF No. 328).

Turkey's Karpowership Delivering Fifth Electric Generation Vessel; More Than 15% Of Cuba's Current Electricity Usage. Company Won't Comment. Contracts Profitable.

Along with the recently-announced increase in frequency of Turkish Airlines weekly flights from Turkey to the Republic of Cuba:

The most recent statement from Istanbul, Turkey-based Karadeniz Holding AS: “In October 2018, Karpowership signed a contract with Unión Eléctrica de Cuba (UNE), the state electricity company of Cuba, to deploy three Powerships of 110 MW in total for a period of 51 months. Karadeniz Powership Barış Bey and Karadeniz Powership Esra Sultan started operation in Port de Mariel in July 2019 and Karadeniz Powership Ela Sultan started operations in November 2019. In November 2019, the contract capacity was increased to 184 MW. Cuba is Karpowership’s first project in Western Hemisphere. Karpowership will supply 10% of Cuba’s total electricity needs.”   

NOTE: Karpowership has neither updated its Internet site to reflect a fourth vessel under contract to the Republic of Cuba nor to reflect a fifth vessel under contract to the Republic of Cuba.

NOTE: Karpowership vessels for use in the Republic of Cuba rely on high sulfur heavy crude oil (HSFO 3.5%S) or diesel fuel produced in or imported by the Republic of Cuba. 

Cuba to add new floating power plant to its electro-energy system 

Havana, Apr 3 (Prensa Latina) Cuba is moving forward today in the search for alternatives to reinforce electricity generation by adding a new floating power plant, which will arrive in the country in the coming weeks.  

By Ana Luisa Brown  

As reported on his Twitter account by the Minister of Energy and Mines, Livan Arronte Cruz, the Caribbean island finalized an agreement with the Turkish company Karen for the delivery of another floating power plant that will contribute with 15 megawatts (MW) to the national electro-energy system.  

This unit will complement the four existing ones, located in Havana Bay and near the Maximo Gomez Baez of Mariel Thermoelectric Power Plant, in Artemisa, as part of the Turkish company’s first project in Latin America.  The vessels with energy technology allow maintenance of other thermoelectric power plants, contribute to increase the national reserve and substitute the use of diesel, one of the most expensive fuels in generation.  

The news came on the same day that the Electric Union reported some service interruptions, due to the breakdowns of unit No. 1 at Felton and a unit at Nuevitas.  The interruptions will be programmed by the respective territories, in order to reduce the inconvenience to the population, according to a note published on the Ministry of Energy and Mines website.  In addition, work is being carried out on the maintenance of four thermoelectric power plants to guarantee the stability of this service during the summer, as well as on the reestablishment of two units in the Mariel CTE.  

Cuba sumará nueva central flotante a su sistema electroenergético 

La Habana, 3 abr (Prensa Latina) Cuba avanza hoy en la búsqueda de alternativas para reforzar capacidades de generación de electricidad con la suma de una nueva central flotante, que llegará al país en las próximas semanas.  

Según informó en su cuenta de Twitter el ministro de Energía y Minas, Liván Arronte Cruz, la Isla caribeña concretó un acuerdo con la compañía turca Karen para el envío de otra central flotante que aportará 15 megawatts (MW) al sistema electroenergético nacional.  Esa unidad complementará a las cuatro ya existentes, ubicadas en la Bahía de La Habana y en las proximidades de la Central Termoeléctrica Máximo Gómez Báez de Mariel, en Artemisa, como parte del primer proyecto de la compañía turca en América Latina.  Las embarcaciones con tecnología energética permiten dar mantenimiento a otras centrales termoeléctricas, contribuyen a incrementar la reserva nacional y sustituyen el uso de diésel, uno de los combustibles más caros en la generación. 

La noticia llegó el mismo día que la Unión Eléctrica informó algunas afectaciones al servicio, producto de la salida por averías de la unidad número No. 1 de Felton y una unidad de Nuevitas. Las interrupciones se programarán por los respectivos territorios, a los efectos de disminuir las molestias a la población, señaló una nota publicada en la web del Ministerio de Energía y Minas.  Además, se trabaja en el mantenimiento de cuatro centrales termoeléctricas para garantizar la estabilidad de este servicio en el verano, así como en el restablecimiento de dos unidades en la CTE del Mariel. 

LINKS To Related Analyses 

Turkey's Karpowership Adds Fourth Thermal Power Barge In Cuba. Company Generating More Than 10% Of Cuba's Electricity. Good For Turkish Companies. Reinforces Cuba's Energy Production Issues. November 25, 2021 

Karpowership From Turkey Extends And Expands Floating Electricity Generation In Cuba; Joining Turkey's Global Ports Holding Which Manages Cruise Ship Terminal In Havana. November 19, 2021 

Turkey's Karadeniz Holding May Add To “Karpowership” Fleet In Cuba. December 02, 2020 

Karadeniz Holding Of Turkey Update On "Karpowership" Operations In Cuba. March 09, 2020 

Karadeniz Of Turkey Delivering Floating Power Plant To Cuba For 51-Month Contract. April 23, 2019 

Turkey's Karadeniz Holding Reports Electricity Contract With Cuba In October 2018; But, No Contract Signed Five Months Later. April 01, 2019 

Karpowership Background 

“Karpowership is a member of Karadeniz Energy Group, Istanbul, Turkey. The group is a pioneer in innovative energy projects for the last 20 years, with investments in domestic and international markets. The group started its energy investments in 1996, and is the first private electricity exporter in Turkey. Today, the group owns and operates more than 4,350 MW installed capacity globally. 

Karpowership is the only owner, operator and builder of the first Powership (floating power plant) fleet in the world. Since 2010, 25 Powerships have been completed with total installed capacity exceeding 4,100 MW. Additional 4,400 MW of Powerships are either under construction or in the pipeline. 

Starting from the design, and ending with delivery of electricity, Karpowership fully executes all activities in-house including but not limited to construction, site preparation, commissioning, and fuel supply. Utilizing the highest technology, Karpowership provides fast-track delivery, high efficiency, and all integrated “plug&play” project execution. Via these capabilities, Karpowership is able to successfully undertake a variety of commercial structures such as short term IPPs (Independent Power Producer), long-term IPPs, PPAs (power purchase agreements), and rental contracts with its Powership fleet. 

Powerships supplied and have been supplying 60% of Gambia, 26% of Ghana, 100% of Guinea Bissau, 10% of Guinea, 25% of Lebanon, 10% of Mozambique, 15% of Senegal, 80% of Sierra Leone, 10% of Sudan, 10% of Cuba, 30% of North Sulawesi, Indonesia, 55% of East Nusa Teneggara, Indonesia, 80% of Ambon, Indonesia, 10% of Medan, Indonesia, and 16% of Zambia’s and 30% of Southern Iraq’s total electricity generation. 

As of today, Karpowership has more than 2,600 direct employees from 19 different nationalities, creates employment for additional 10,000 co-workers for the construction of the Powerships and is expanding through renewables, Powerships and other innovative energy supply solutions.”

UK Closes Trade Office In Havana, Citing Budget Cuts. First Major Challenge For New UK Ambassador To Cuba- Doing The Same Or More... With Less.

“Department for International Trade (DIT) Cuba provides trade and investment services and practical support. We help UK companies succeed in Cuba, and Cuban companies set up and invest in the UK.  We offer expertise and contacts through our extensive network of specialists in the UK, and staff in the British Embassy in Cuba.” 

English Text: “Dear colleagues, We are writing to inform you about that we are making here at the embassy; after much consideration (and with much regret), it has been decided to close the DIT office in Cuba.  The office will formally closed on 31st March 2022.  

This is not a decision that we came to lightly but, given budget challenges across the UK government, having a dedicated resource in Cuba could no longer be justified. This is a change that reflects decisions made in other similarly challenging posts in region such as Venezuela.  We will continue to support opportunities that arise in Cuba through two new support models, first through our Central American Team based in Panama: ariel.perez@fcdo.gov.uk and second through our Enquiry Hub based across the region which will handle enquiries from UK companies about the market dit.latac@mobile.trade.gov.uk and lucia.rojas@fcdo.gov.uk and pamela.esquivel@fco.gov.uk  

While it is important to bear in mind that the Embassy will not have the capacity of offering the same services as in the past, Lizzie Pinder  (lizzie.pinder@fcdo.gov.uk), 2nd Secretary Economics, will take calls on trade issues if the need arises.  We should also say that if circumstances change and significant opportunities for UK business in Cuba arise in the future, this decision will be reconsidered. We would like to reassure you that this does not change the UK Government’s commitment to Cuba and that our wider diplomatic presence in Havana remains unchanged.  Both the Embassy and our regional teams remain ready to continue to grow and develop the UK-Cuba relationship. British Embassy in Havana and DIT Latin America and The Caribbean (LATAC)”   

Spanish Text: “Estimados colegas, Les escribimos para informarles de algunos cambios que el Departamento de Comercio Internacional (DIT) del Gobierno del Reino Unido está realizando en Cuba.  Después de mucha consideración y análisis, hemos tomado la decisión de retirar nuestro pequeño equipo de DIT en Cuba. Esta no es una decisión a la que llegamos a la ligera, sin embargo, dada la necesidad de priorizar nuestros recursos, actualmente no vemos la necesidad de tener recursos dedicados en Cuba.  La oficina cerro formalmente el 31 de marzo de 2022. Seguiremos apoyando las oportunidades que surjan en Cuba a través de dos nuevos modelos de apoyo. En primer lugar, nuestro equipo de América Central, con sede en Panamá: ariel.perez@fcdo.gov.uk del que formaba parte nuestro equipo de Cuba, y en segundo lugar, nuestro Centro para consultas con sede en toda la región, que atenderá las consultas de las empresas británicas sobre el mercado dit.latac@mobile.trade.gov.uk y lucia.rojas@fcdo.gov.uk y pamela.esquivel@fco.gov.uk 

Dado que no podremos seguir operando como de costumbre para aquellos casos que requieran el apoyo de la Embajada, les rogamos que se pongan en contacto con Lizzie Pinder, la Segunda Secretaria de Economía, en la Embajada Británica en La Habana (lizzie.pinder@fcdo.gov.uk). Sin embargo, es importante tener en cuenta que la Embajada no tendrá la capacidad de ofrecer los mismos servicios que en el pasado. Ya que nuestro personal en La Habana nos dejará el 31 de marzo de 2022. Si en el futuro surgen oportunidades significativas para los negocios del Reino Unido, que requieran una presencia sobre el terreno, más allá de estas nuevas estructuras, entonces reconsideraríamos con gusto esta decisión.  

Me gustaría asegurarles que esto no cambia el compromiso más amplio del Gobierno del Reino Unido con Cuba, y nuestra presencia diplomática en La Habana permanece sin cambios.  Tanto la Embajada como nuestros equipos regionales siguen dispuestos a seguir creciendo y desarrollando la relación entre el Reino Unido y Cuba. Embajada Britanica en la Habana y Equipo de DIT de Latinoamerica y el Caribe,  (LATAC)” 

LINK To Related Analysis 

London Delivers High Wattage Political Appointee As UK Ambassador To Cuba. Since 1931, Only Third “Sir” To Serve. Issues: UK-Connected Libertad Act Lawsuit & China-Connected Bank Lawsuits.  January 31, 2022

Another Biden-Harris Administration Missed Opportunity: U.S. Investors & Financial Companies Should Have Been Permitted To Sponsor, Participate In Cuba's First Trade Show For Private Companies.

NOTE: The United States Department of State has not responded to a question- Did a representative of the United States Embassy in Havana visit the Havana Local Development Fair?

15 April 2022 From A State Department Spokesperson: “The Administration encourages the growth of a Cuban private sector independent of government control.  The U.S. Embassy in Havana regularly meets with members of the Cuban semi-private sector and hosts topical discussions related to business development and economic growth.  The Department also supports private sector development and entrepreneurship training through the Young Leaders of America’s Initiative, the Academy for Women Entrepreneurs, and other Embassy exchange programs.” While an informative statement, the statement did not answer the question. 

After three years of pursuing a license from the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury in Washington DC, in 2002, Westport, Connecticut-based PWN Exhibicon International LLC welcomed more than 900 representatives of United States-based companies to the U.S. Food & Agribusiness Exhibition held at the Palacio de Convenciones de la Habana (Pabexpo) in the city of Havana, Republic of Cuba, from 26 September 2002 through 30 September 2002. The primary sponsor of the event was Chicago, Illinois-based Archer Daniels Midland Company, known as ADM. LINK To Final Report

From 28 March 2022 to 3 April 2022 at the same location as the U.S. Food & Agribusiness Exhibition, seven hundred and twenty (720) privately-owned companies participated in the first-ever government of the Republic of Cuba officially-sanctioned event designed solely to promote privately-owned companies. There are approximately 2,523 privately-owned companies registered in the Republic of Cuba- 28% participated in the Havana Local Development Fair at the ExpoCuba fairground.

These participants included the self-employed, and micro, small and medium-size enterprises (MSME), the largest of which may have up to one hundred (100) employees.

Another missed opportunity for the Biden-Harris Administration (2021- ) for the OFAC to have authorized United States-based investors and United States-based finance providers not only attend, but to have sponsored the event and for investors and finance providers to engage directly with participants and execute investment agreements and finance agreements.

Despite numerous requests, the OFAC has yet to authorize individuals (and incorporated entities) subject to United States jurisdiction to directly invest in and directly provide financing to the self-employed and to MSMEs in the Republic of Cuba.

For reference, the 291 United States-based exhibitors participating in the 2002 U.S. Food & Agribusiness Exhibition signed contracts for US$91,970,990.00. To date, the Republic of Cuba has purchased more than US$6,622,784,996.00 in agricultural commodities and food products from United States-based producers. 

Associated Press
New York, New York
2 April 2022

Cuba’s new private companies show off products at trade fair

By ANDREA RODRÍGUEZ

A vintage Russian-made Lada car, right, and an American-made classic car drive past the Capitol in Havana, Cuba, Friday, April 1, 2022. Global restrictions on transport and trade with Russia after its invasion of Ukraine pose a serious problem for Cubans because much of the island's fleets of trucks, buses, cars and tractors came from distant Russia and are now aging and in need of parts. (AP Photo/Ramon Espinosa) 

HAVANA (AP) — The event at a convention center in Cuba’s capital looks like a lot of trade fairs: Music blares as visitors stroll between colorful booths displaying a wild variety of products: furniture or clothing, glassware or recycled paper, chocolates or cleaning products. 

But it’s a commercial milestone for Cuba: The companies showing off their wares are largely formal, private companies that were legalized only about six months ago — more than a half century after the Communist government banned nearly all private enterprise. 

“We’re experiencing something without precedent, at least for our generation,” said César Santos, a 36-year-old engineer who is a partner in Lucendi SRL, a company that offers electrical installations both for private and state clients. “We are seeing other businesses that we didn’t even know existed.”  Santos was born 18 years after the government closed or took over private businesses in 1968, consolidating a Soviet-style socialist system that had been forged following the 1959 revolution led by Fidel Castro. 

Cuba’s single-party political system has survived the 1991 collapse of the Soviet Union, but its socialist economy has continually struggled to find its footing in the decades following the loss of heavy Soviet subsidies. It has long tried to attract foreign investors and has expanded tourism, despite U.S. embargo measures that impede both. But productivity in the state-run sector has remained dismal. 

Fidel Castro’s government reluctantly began allowing small-scale individual private businesses in the early 1990s, then cracked down amid complaints they were creating a class of relatively rich people under a system that prizes equality over wealth. With the inefficient economy still struggling, the government led by his brother and heir Raul once again opened the door to individual businesses in 2010. On the eve of the pandemic, some 600,000 people were working in that sector on the island of 11.3 million people. 

They run little restaurants, rent out rooms, offer repair services, even at least one chic clothing boutique — though they supposedly can employ only family members or a handful of outsiders.  But the new policy that took effect in September — while the economy was slammed by shortages, pandemic restrictions and a tightened U.S. embargo — potentially goes far beyond: It allows actual companies that can employ up to 100 people, can get formal financing and do business with state enterprises. 

Within six months, 2,614 new “limited responsibility societies” — or SRLs in Spanish — have registered. And 2,523 of those are private companies, with the rest either state or cooperative enterprises. Most are in the Havana area.  So far, they employ about 42,000 people. 

Restrictions remain, however. The government says the state will remain the dominant force in the economy and the new companies can’t do journalism or offer key professional services such as architecture, medicine or law. And the business people at the fair said they still face bureaucratic hurdles that need to be smoothed if the system is to work better: For example, banking, import and export red tape is complicated, they said. 

The fair closing Sunday at the Expocuba center on the southern fringe of Havana features 720 companies and cooperatives showing off everything from yoghurt to construction materials. Officials hoped the gathering in part would help entrepreneurs make business contacts among themselves, said Suleidis Álvarez, an official with the capital’s Plaza of the Revolution municipality. For example, she said, a woodworking company had found a producer of nails it needed. 

The youth of the participants was notable on an island that has suffered the loss of many young people through emigration.  “The migratory crisis we’re experiencing currently is really sad,” Santos said. “Nevertheless, we are seeing opportunities arising through this private enterprise (policy). ... I prefer to bet on building my business in the country where I am.” 

LINKS To Self-Employed, Micro, Small & Medium-Size Enterprise (MSME) Analyses   

MSME's In Cuba Continue To Be Created, Continue To Expand While Biden-Harris Administration Ignores Opportunities For U.S.-Sourced Investment And Financing... 414 Days  March 19, 2022 

Surprise Decision: Biden-Harris Administration Renews Trump-Pence Administration License To Export EVs To Embassies In Cuba. Company Offers To Donate EV Chargers To U.S. Embassy/Ambassador Residence  January 25, 2022  

Cuba Updates Status Of Micro, Small & Medium-Sized Enterprises  January 19, 2022  

Why Is National Security Council (NSC) In The White House Refusing To Permit U.S.-Based Investors/Financiers To Directly Support Women-Owned (Or Men-Owned) Businesses In Cuba? State Dept. Complicit?  January 06, 2022  

Embassy Of Italy: V International Workshop of Women Entrepreneurs In Cuba: "The Talent Of Women. Art, Crafts & Design"  January 06, 2022  

President Biden Rejects BIS License Application To Export Electric Vehicles/Chargers To Cuba's Self-Employed, MSME's. Reversal Of "General Policy Of Approval." President Trump Authorized EV Exports.  December 20, 2021  

Cuba Again Expanding MSME Authorizations To Include Accessing Foreign Capital, Foreign Bank Accounts, Local Development Projects Qualify.  December 02, 2021  

Why Won't Biden Administration Permit U.S. Entities To Invest/Finance MSMEs? In December, Cuba’s FIMELSA Begins Convertible Currency-Equivalent Loans At 6.5% For 120 Days; Lower For CUP.  November 25, 2021  

Update: More Than 700 Micro, Small And Medium-Sized Enterprises Approved In Cuba  November 25, 2021  

OFAC & BIS To 107 Tech Companies? Cuba. Yes, You Can Go There, But We Dare You. "Encourage & Enable" Not The Same As "Access & Use." Memo: Donilon, Klain, Ricchetti, Richmond, Sullivan.  November 23, 2021  

Will President Biden's Statement That His Is "a small business presidency” Extend To Supporting Small Businesses In Cuba?  November 22, 2021  

Update On Registration Of Micro, Small & Medium-Size Enterprises In Cuba. Now More Than 600.  November 21, 2021  

Cuba Continues To Report On Activity Of MSME's- The Numbers Increase.  November 06, 2021 

Joint Venture Between Banco de Sabadell Of Spain And Banco International de Comercio In Cuba Will Provide Financing In Foreign Currency To MSMEs & Non-Agricultural Cooperatives  November 05, 2021  

Beginning Today Residents Of Cuba May Purchase And Install Residential Solar Systems. Cost 55,000.00 Pesos (US$2,300.00). Call 7833-3333.  November 04, 2021   

Bormey srl Among The First 35 Newly-Constituted Medium-Sized Enterprises In Cuba, Exported 5,000 Peanut Bars To Italy. Is United States Next? U.S. Department Of State Regulations Would Approve.  October 26, 2021  

Cuba Approves First 35 MIPYME Applications- Confirms No Application Thus Far Denied. Many More Applications Expected. Result Beneficial For Biden Administration Goal To Support SME's.  September 30, 2021  

Cuba Suspends Tariffs And Fees For Non-Commercial (SME's Next?) Solar Systems. Another Opportunity For Biden-Harris Administration To Support U.S. Exporters And Florida Companies Should Benefit.  July 30, 2021  

ProLimp Cleaning In Cuba Precisely Type Of Entrepreneurship Biden Administration Should Support. Will Cuba Permit U.S. Venture Capitalists?  March 08, 2021  

Cuba To Unify Currencies; Result Could Present Opportunities For Biden Administration And U.S. Companies  December 11, 2020  

Florida Company Receives License To Export Electric Vehicles To Cuba; Charging Stations From New Jersey-Based Company.  January 25, 2017  

Restriction On Sale Of Premium Gasoline May Benefit Electric Vehicles & Solar Panels; Embassies Concerned.  April 07, 2017

Law Firms Connected To Plaintiffs/Defendants In Libertad Act Lawsuits Facing Off In Lawsuit Against PAHO For Cuban Doctor Payments In Brazil

Ramona Matos Rodriguez, Tatiana Carballo Gomez, Fidel Cruz Rodrigue, and Russela Margarita Rivero Sarabia, plaintiffs, v. Pan American Health Organization, defendant. [1:20-cv-00928, Southern District Court- Miami Division].

Cooper & Kirk, PLLC (plaintiff)
Cuneo Gilbert & LaDuca, LLP (plaintiff)
Dubbin & Kravetz (plaintiff)
Wilmer Cutler Pickering Hale & Dorr LLP (defendant)

Judgement- 1 Page (3/29/22)
Opinion- 24 Pages (3/29/22)
Transcript Of Status Conference United States District Judge- 17 Pages (1/28/22)
Class Action Complaint- 85 Pages (11/30/2018)

Excerpt From Judgement
This cause came on to be heard on the record on appeal from the United States District Court for the District of Columbia and was argued by counsel. On consideration thereof, it is ORDERED and ADJUDGED that the District Court’s judgment denying PAHO’s motion to dismiss the 18 U.S.C. § 1589(b) claim be affirmed and the case be remanded for further proceedings, in accordance with the opinion of the court filed herein this date.

Excerpt From Opinion
Finally, we note that the United States has submitted an amicus brief affirming that, in its view, WHO Constitution Article 67(a) is not self-executing. “Respect is ordinarily due the reasonable views of the Executive Branch concerning the meaning of an international treaty.” El Al Israel Airlines, Ltd. v. Tsui Yuan Tseng, 525 U.S. 155, 168 (1999). The Executive Branch’s position reinforces our decision.

LINK: Libertad Act Lawsuit Filing Statistics

LUIS MANUEL RODRIGUEZ, MARIA TERESA RODRIGUEZ, a/k/a MARIA TERESA LANDA, ALFREDO RAMON FORNS, RAMON ALBERTO RODRIGUEZ, RAUL LORENZO RODRIGUEZ, CHRISTINA CONROY, and FRANCISCO RAMON RODRIGUEZ, Plaintiffs, v. IMPERIAL BRANDS PLC, CORPORACIÓN HABANOS, S.A., WPP PLC, YOUNG & RUBICAM LLC, and BCW LLC, a/k/a BURSON COHN & WOLFE LLC [1:20-cv-23287; Southern Florida District].

Berenthal & Associates (plaintiff)
Rodriguez Tramont & Nunez (plaintiff)
Nelson Mullins (defendant)
Allen & Overy (defendant)
Wilmer Cutler Pickering Hale and Dorr (defendant)
Broad & Cassel (defendant)
Akerman (defendant)
Trenam, Kemker, Scharf, Barkin, Frye, O’Neill & Mullis (defendant)
Rabinowitz, Boudin, Standard, Krinsky & Lieberman (defendant)
Strook & Strook & Lavan (defendant)

ROBERT M. GLEN VS. TRIPADVISOR LLC, TRIPADVISOR, INC., ORBITZ, LLC, TRIP NETWORK, INC. D/B/A CHEAPTICKETS, KAYAK SOFTWARE CORPORATION, BOOKING HOLDINGS, INC., EXPEDIA, INC., EXPEDIA GROUP, INC., HOTELS.COM, L.P., HOTELS.COM GP, LLC, and TRAVELSCAPE LLC D/B/A TRAVELOCITY [2:19-cv-01683; Nevada District] On 16 December 2019, plaintiff requested dismissal without prejudice, which was granted; action consolidated with 1:19-cv-01809 in Delaware District.

Rice Reuther Sullivan & Carroll, LLC (plaintiff)
Reid Collins & Tsai LLP (plaintiff)
Andrews & Springer LLC (plaintiff)
Walden Macht & Haran (defendant- Trip Advisor)
Potter Anderson & Corroon, LLP (defendant- Trip Advisor)
Scott Douglass McConnico (defendant- Expedia)
Morris, Nichols, Arsht & Tunnell LLP (defendant- Booking)
Dubbin & Kravetz (amicus)
Baker McKenzie (defendant- Booking)
Ballard Spahr LLP (defendant- Expedia)
Morris James LLP (defendant- Booking)
Duane Morris LLP (defendant- Booking)
Cooch and Taylor, P.A. (amicus)

Reuters Americas
London, United Kingdom
31 March 2022

(Reuters) - The Pan American Health Organization (PAHO), an international body that promotes health initiatives in the Americas, must face a lawsuit by Cuban doctors accusing it of helping arrange a program in which they were compelled to work in Brazil against their will, violating human trafficking laws.

A unanimous three-judge panel of the U.S. Circuit Court of Appeals for the D.C. Circuit ruled Tuesday that PAHO's status as an international organization did not make it immune from the lawsuit because the doctors had accused it of financial misconduct within the United States. Samuel Dubbin of Dubbin & Kravetz, a lawyer for the doctors, said in a statement that PAHO "will finally be held accountable for profiting more than $75 million off the backs of thousands of Cuban professionals."

PAHO could not immediately be reached for comment.

The case, brought by four doctors in 2018 in the Southern District of Florida and transferred in 2020 to Washington, D.C., district court, centers on the so-called Mais Medicos program, in which Cuba in 2012 agreed to send doctors to work in Brazil, which would pay for their services, using PAHO as an intermediary. The Cuban government received 85% of the money paid by Brazil, with just 10% going to the doctors and 5% retained by PAHO as a fee. The funds passed through PAHO's U.S.-based bank account.

The doctors in their lawsuit said that they had escaped from the program to the United States. They alleged they were forced to work under the threat of punishment by their government and paid far less than the value of their work. They are seeking to represent a class of similarly situated doctors in the program. The doctors said that PAHO violated the Trafficking Victims Protection Act by facilitating the program. PAHO moved to dismiss the lawsuit, citing a U.S. law that gives international organizations the same immunity from being sued as foreign governments under the Foreign Sovereign Immunities Act.

U.S. District Judge James Boasberg agreed that claims related to PAHO's activities outside the United States were barred, and dismissed them. However, he said claims could proceed based on PAHO's financial activity because the FSIA does not apply when an action "is based upon a commercial activity carried on in the United States."

On appeal, PAHO argued that the doctors' action was not "based upon" the financial transactions in the United States, but rather on foreign conduct. In Tuesday's opinion penned by U.S. Circuit Judge Karen Henderson, the D.C. Circuit said that the financial transactions, allegedly made in furtherance of trafficking, could stand on their own as a cause of action. Circuit Judges David Tatel and Cornelia Pillard joined in the opinion.

January 2022 Agricultural Commodities/Food Products Exports To Cuba Increase 14.5%.

ECONOMIC EYE ON CUBA©
March 2022

January 2022 Food/Ag Exports To Cuba Increase 14.5%- 1
57th Of 207 January 2022 U.S. Food/Ag Export Markets- 2
2022 Exports Increase 14.5%- 2
Cuba Ranked 75th Of U.S. Ag/Food Export Markets- 2
January 2022 Healthcare Product Exports US$0.00- 2
January 2022 Humanitarian Donations US$398,943.00- 3
Obama Administration Initiatives Exports Continue- 3
U.S. Port Export Data- 16

JANUARY 2022 FOOD/AG EXPORTS TO CUBA INCREASE %- Exports of food products and agricultural commodities from the United States to the Republic of Cuba in January 2022 were US$21,783,159.00 compared to US$19,018,549.00 in January 2021 and US$13,421,660.00 in January 2020.

January 2022 Exports Included: Chicken Leg Quarters (Frozen); Chicken Meat (Frozen); Chicken Legs (Frozen); While Chickens; Woodpulp; Coffee Beans; Bean Seeds for sowing.

This report contains information on exports from the United States to the Republic of Cuba- products within the Trade Sanctions Reform and Export Enhancement Act (TSREEA) of 2000, Cuban Democracy Act (CDA) of 1992, and regulations implemented (1992 to present) for other products by the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury and Bureau of Industry and Security (BIS) of the United States Department of Commerce.

The TSREEA re-authorized the direct commercial (on a cash basis) export of food products (including branded food products) and agricultural commodities from the United States to the Republic of Cuba, irrespective of purpose. The TSREEA does not include healthcare products, which remain authorized and regulated by the CDA.

Click here for a list of agricultural commodities eligible for export to Cuba under Section 902(1) of the Trade Sanctions Reform and Export Enhancement Act of 2000

Complete Report In PDF Format

44th Libertad Act Lawsuit Filed. Plaintiffs Suing Melia Hotels In Spain Now Suing Expedia In U.S. "Expedia Group does not list hotels on the Expedia Group websites for charitable purposes."

CENTRAL SANTA LUCIA, L.C., PLAINTIFF, V. EXPEDIA GROUP, INC., DEFENDANT. (1:22-CV-00367; Delaware District) 

Cross & Simon, LLC (plaintiff)
Berliner Corcoran & Rowe LLP (plaintiff)
Fields LLC (plaintiff)
Ballard Spahr LLP (defendant)

Complaint (3/22/22)
Link To Libertad Act Lawsuit Filing Statistics

Excerpts From Complaint 

Central Santa Lucia brings this action to recover damages and interest under the Cuban Liberty and Democratic Solidarity (LIBERTAD) Act of 1996, codified at 22 U.S.C. § 6021, et seq. (the “Helms-Burton Act” or “Act”) against Expedia for trafficking in property that was confiscated by the Cuban Government on or after January 1, 1959, and as to which Central Santa Lucia owns claims. 

The Confiscated Property includes real property located in or near Holguin province, Cuba that, until it was confiscated by the Cuban government in 1960, was owned by Santa Lucia Company, S.A., a Cuban corporation. The Confiscated Property consists of Santa Lucia Company, S.A. and approximately 102,300 acres of land, including thirty-five miles of oceanfront property that in some parts extended 8 miles inland. The following beaches (as they are currently known) are located on the Confiscated Property: Playa Blanca; Playa Pesquero; Playa Yuraguanal; Playa Esmeralda; and Playa Guardalavaca. 

A number of luxury hotels are currently located on the Confiscated Property including, but not limited to: Hotel Brisas Guardalavaca; Club Amigo Atlantico-Guardalavaca; Paradisus Rio de Oro; Sol Rio de Luna y Mares; Hotel Turquesa Holguin; Fiesta Americana Costa Verde; Hotel Playa Costa Verde; Playa Pesquero Resort Suite and Spa Hotel; Iberostar Selection Holquin; Villa Don Lino; Memories Holquin; and the Iberostar Selection Almirante. 

Under the agency model, Expedia Group facilitates travel bookings and acts as the agent in the transaction, passing reservations booked by the traveler to the relevant travel provider with Expedia Group receiving commissions or ticketing fees from the travel supplier and/or the traveler. Customers pay at the time of stay under this model, referred to as “Hotel Collect.” The agency model accounted for 24% of Expedia Group’s revenue in 2020. 

On May 23, 2017, Expedia Group announced that it had started offering online booking for hotels in Cuba. Veronica Vega, Expedia Area Manager for the Caribbean, stated that, “I see a lot of potential. We are talking about the largest country in the Caribbean with significant hotel expansion plans,” and that, “We are very excited about being able to facilitate travel and give people the independence to select their itinerary.” 1 57. Expedia Group entered into a settlement agreement with the Office of Foreign Assets Controls (“OFAC”) on May 17, 2019, regarding 2,221 potentially non-compliant Cubarelated travel transactions that occurred between 2011-2014. 

Expedia Group websites still facilitate online booking for hotels in Cuba and Expedia Group has never announced a withdrawal from the Cuban market. 62. Expedia Group websites advertise hotels on the Confiscated Property and enable the hotels, Grupo de Administración Empresarial S.A. (“GAESA”), and the Cuban government to normalize the appearance of the Cuban military’s involvement in the tourism and hotel industry in Cuba.2 63. Expedia Group websites facilitate the payment of hard currency to the Cuban government and military, including GAESA. 

Expedia Group is profiting from trafficking in the Confiscated Property by or through its retail brands that advertise, publicize, and/or facilitate the booking of rooms at hotel properties in Holguin province. 74. Expedia Group does not list hotels on the Expedia Group websites for charitable purposes. 

Links To Related Posts About Plaintiff’s Spain-Filed Lawsuit 

Lawsuit Against Spain's Melia Hotels International Takes Another Turn... Government Of Spain Never Served Cuba. Repeat. Start Again.  July 06, 2021 

In Lawsuit Filed In Spain Against Melia Hotels, Plaintiff Argues That Government Of Cuba Is Not Required To Be A Defendant; Melia Hotels Says Otherwise.  February 10, 2021 

Court In Spain Requires Government Of Cuba And Gaviota Tourism Company Be Included In "Unjust Enrichment" Lawsuit Against Melia Hotels International.  January 16, 2021 

Plaintiffs Appeal Dismissal Of Lawsuit In Spain Against Melia Hotels; Plaintiffs Sue In U.S.; Why Did Melia Hotels Offer US$5 Million Then US$3,197.75?  October 05, 2019

43rd Libertad Act Lawsuit Filed In Delaware. Previous Plaintiff Lawsuit Dismissed In Texas. New Plaintiff, Same Defendant.

SIERRA ET AL V. TRAFIGURA TRADING, LLC (1:22-cv-00366; Delaware District).

Cross Castle LLC (plaintiff)
McGuire Woods LLP (defendant)

Order (3/15/22)
Complaint (3/22/22)
Link To Libertad Act Lawsuit Filing Statistics

Excerpts From Complaint: 

Defendant is trafficking in the Confiscated Property in violation of the Act. Specifically, Defendant causes, participates in, and/or profits from the Trafigura Group’s and its Mining Group’s mining operations in Cuba, and those mining operations use the Confiscated Property. 73. According to their 2016 Annual Report, the Trafigura Group and its Mining Group entered into a joint venture with the Cuban Government to make a large investment in mining operations on the island: “The project is another illustration of Trafigura Mining Group’s ability to put its expertise and investment to work in challenging economic or political environments. Work is so far proceeding to plan, and the mine is expected to start production towards the end of 2017.” 74. The mining operation—referred to as the Castellanos lead and zinc mine—is conducted through EMINCAR, a joint venture between the Trafigura Group including its Mining Group (which owns a 49 percent interest) and Cuban state agency Geominera (which owns a 51 percent interest). With a capital outlay equivalent to $230 million, construction was completed in 18 months from start to finish. According to financial reports, the Trafigura Group and its Mining Group invested at least $230 million in the venture through a loan to EMINCAR. 

Links To Related Posts About Plaintiff 

HILDA M. CASTANEDO ESCALON, AS PERSONAL REPRESENTATIVE OF THE ESTATE OF HILDA CASTANEDO AND THE ESTATE OF EMMA DIAZ, Plaintiffs, v. TRAFIGURA TRADING, LLC, TRAFIGURA PTE LTD, TRAFIGURA GROUP PTE LTD, Defendants. (4:21-cv-00659; Texas Southern District).  Dismissed 3/15/22. 

34th Libertad Act Lawsuit Filed: Trafigura Of Singapore Sued For Using Two Ports (Including Mariel) And Other Mining Assets.  March 05, 2021

Despite Requesting Two Delays, DOJ Will File Brief To Court Of Appeals- Will DOJ Answer All Six Questions From Court? Answers Could Impact All Libertad Act Lawsuits.

MARIO DEL VALLE, ENRIQUE FALLA, MARIO ECHEVARRIA V. EXPEDIA, INC., HOTELS.COM L.P., HOTELS.COM GP, ORBITZ, LLC, BOOKING.COM B.V., BOOKING HOLDINGS INC.  Initial defendants were: TRIVAGO GMBH, BOOKING.COM B.V., GRUPO HOTELERO GRAN CARIBE, CORPORACION DE COMERCIO Y TURISMO INTERNACIONAL CUBANACAN S.A., GRUPO DE TURISMO GAVIOTA S.A., RAUL DOE I-5, AND MARIELA ROE 1-5, [1:19-cv-22619 Southern Florida District; 20-12407 11th Circuit Court of Appeals] 

Rivero Mestre LLP (plaintiff)
Manuel Vazquez, P.A. (plaintiff)
Baker & McKenzie, LLP (defendant)
Scott Douglass & McConnico (defendant)
Akerman (defendant)

Notice of Amicus Participation By The United States (3/22/22)
Link To Libertad Act Lawsuit Filing Statistics

On Appeal from the United States District Court for the Southern District of Florida .  BEFORE: JORDAN, NEWSOM, and BURKE,* District Judge.  ORDER: The Court invites the United States – through the Attorney General, the Solicitor General, and/or the Office of the Legal Adviser to the State Department –to file an amicus brief in Mario Del Valle, et al., v. Trivago GMBH, et al., No.20-12407 (argued Oct. 4, 2021), Javier Garcia-Bengochea v. Carnival Corporation, No. 20-12960 (argued Oct. 4, 2021), and Javier Garcia-Bengochea v. Royal Caribbean Cruises, LTD., No. 20-14251 (argued Oct. 4, 2021), pursuant to Fed.R.App.P. 29(a)....The Court invites the United States to address the following questions concerning the Helms-Burton Act, 22 U.S.C. § 6082:...The court asks that the U.S. file its amicus brief by 2/25/22... AJ, KCN and LCB (See attached order for complete text) [20-12407, 20-12960, 20-14251] [Entered: 12/20/2021 04:48 PM].  The Court invites the United States to address the following questions concerning the Helms-Burton Act, 22 U.S.C. § 6082:

1. Does the term “United States national” in 22 U.S.C. §§ 6082(a)(4)(B) and 6082(a)(4)(C) refer to the plaintiff bringing the action, or the original claimant to the confiscated property, or both?

2. What does the word “acquire[ ]” in 22 U.S.C. § 6082(a)(4)(B) mean? Is inheritance encompassed in the term “acquire[ ]?” And if “acquire[ ]” does include inheritance, at what point is a claim “acquire[d]” by an heir within the meaning of the statute?

3. How, if at all, does the phrase “assignment for value” in 22 U.S.C. §6082(a)(4)(C) affect the pool of eligible claimants compared to the pool of eligible claimants under 22 U.S.C. §6082(a)(4)(B)?

4. What effect, if any, does the President’s ability to suspend Title III pursuant to 22 U.S.C. § 6085(b) have on defining the class of eligible claimants who can bring an action under 22 U.S.C. § 6082(a)(4)? Does the President’s ability to suspend Title III imply that the statute was drafted to allow the heirs of American citizens – whose property was unlawfully confiscated and “trafficked” by third parties – to bring claims under 22 U.S.C. § 6082(a)(4)?

5. What effect, if any, does the lawful travel exception, 22 U.S.C. §6023(13)(B)(iii), have on the plaintiffs’ claims? What effect, if any, does the possibility that the Office of Foreign Assets Control (OFAC) can change the permissible reasons for travel to Cuba have on the lawful travel exception?

6. What does the phrase “incident to lawful travel” in 22 U.S.C. §6023(13)(B)(iii) mean? Who or what defines “lawful travel” (e.g. OFAC)? What guidance should persons and entities look to in determining whether their activities are “incident to lawful travel?”

The Court asks that the United States file its amicus brief by February 25, 2022, at which time the parties in the cases will be permitted to respond. Should the United States elect not to file an amicus brief, it should so notify the Court by January 25, 2022.

U.S. ATTORNEY GENERAL
UNITED STATES SOLICITOR GENERAL
OFFICE OF THE LEGAL ADVISER, U.S. DEPARTMENT OF STATE
UNITED STATES OF AMERICA (Southern District Attorneys)

“ORDER: The motion filed by the United States for an extension of time, up to and including April 11, 2022, to file the amicus brief is GRANTED. The motion for an extension to March 11, 2022, to notify the Court that the United States elects not to file an amicus brief is GRANTED.” 

Links To Related Posts 

U.S. Department Of Justice Requests And Is Granted Until 11 March 2022 To Decide Whether To Submit Answers To Six Questions To Court Of Appeals.  February 01, 2022 

Court Of Appeals "Invites" Biden-Harris Administration To Answer Six Questions In Libertad Act Lawsuits That May Impact More Than Cuba Lawsuits. Will They Answer? Due By 25 January 2022.  December 31, 2021  

American Airlines Libertad Title III Lawsuit Becomes First To Seek Review By United States Supreme Court. Twenty-Nine Months From District Court To SCOTUS Is Fast.  December 20, 2021 

11th Circuit Court Of Appeals Hearing Recording For Del Valle Vs. Expedia, Hotels, Orbitz, Trivago, Etc. Libertad Act Lawsuit.  December 16, 2021 

Did U.S. Department Of Justice “Intervene” And Tip The Scale In A Libertad Act Title III Cuba Lawsuit On Behalf Of United Kingdom-Based Company? Defendants Hope So.  September 01, 2021 

Plaintiff Files Appeal Against Expedia In Libertad Act Lawsuit.  September 05, 2020

Crowley Maritime Corporation Mostly Loses On Motion To Dismiss In Libertad Act Lawsuit. Judge Says Libertad Act Definition Of Trafficking Is Constitional.

ODETTE BLANCO DE FERNANDEZ née BLANCO ROSELL, Plaintiff, v. CROWLEY MARITIME CORPORATION, Defendant. [3:20-cv-01426 Middle District Florida; Transferred To Florida Southern District 1:21-cv-20443]. 

Murphy & Anderson, P.A. (plaintiff)
Berliner Corcoran & Rowe LLP (plaintiff)
Fields PLLC (plaintiff)
Law Offices of John S. Gaebe P.A. (plaintiff)
Horr, Novak & Skipp P.A. (plaintiff)
Venable LLP (defendant)

Order (3/23/22)

Libertad Act Lawsuit Filing Statistics

Excerpts From Order

“The Supreme Court has explained that ‘[c]entral to assessing concreteness is whether the asserted harm has a “close relationship” to a harm traditionally recognized as providing a basis for a lawsuit in American courts—such as physical harm, monetary harm, or various intangible harms.’” Glen v. American Airlines, Inc., No. 20-10903, 2021 WL 3285307, at *2 (5th Cir. Aug. 2, 2021). Here, Plaintiffs allege that they were harmed when Defendants used the Confiscated Property “without consent from or paying adequate compensation to Plaintiffs.” [ECF No. 50 ¶ 144]. This harm “bears a close relationship to unjust enrichment, which has indisputable commonlaw roots.” Glen, 2021 WL 3285307, at *2. Indeed, Congress passed the Act, in part, because it found the remedies for “unjust enrichment from the use of wrongfully confiscated property . . . by private entities at the expense of the rightful owners of the property” to be ineffective. 22 U.S.C. § 6081(8). See Havana Docks, 484 F. Supp. 3d at 1192 (finding a concrete injury where the plaintiff “allege[d] that [defendant] profited from its use of the Subject Property at [plaintiff’s] expense.”). Accordingly, the Court finds that Plaintiffs have alleged a concrete and particularized harm.  

B. Traceability To have standing, Plaintiffs must also show that their injuries are “fairly traceable” to Defendants’ use of the Confiscated Property. Spokeo, 136 S. Ct. at 1547. “To show traceability, a plaintiff must allege that his injury is ‘connect[ed] with the conduct about which he complains.’” Glen, 2021 WL 3285307 (quoting Trump v. Hawaii, 138 S. Ct. 2392, 2416 (2018)). The SAC alleges that Defendants profited from their use of the Confiscated Property without compensating Plaintiffs. See [ECF No. 1 ¶¶ 1, 7, 11]. Accordingly, like in the Glen and the Havana Docks cases, “there exists a causal link between a claimant’s injury from the Cuban Government’s expropriation of their property and a subsequent trafficker’s unjust enrichment from its use of that confiscated property.” Havana Docks, 484 F. Supp. 3d at 1230. Therefore, the Court finds Plaintiff has adequately alleged traceability.  

C. Redressability “The element of redressability requires that ‘it must be likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision.’” Hollywood Mobile Estates, Ltd. v. Seminole Tribe of Fla., 641 F.3d 1259, 1266 (11th Cir. 2011) (quoting Lujan, 504 U.S. at 561)). The parties do not dispute, and the Court agrees, that the element of redressability is properly alleged here. Accordingly, Plaintiffs have sufficiently established, at this stage of the litigation, that they have standing, and the Motion shall be denied on this ground. 

Defendants argue that the SAC must be dismissed because it fails to adequately allege that (1) Plaintiffs’ own a claim to the Container Terminal or the Concession; (2) Defendants’ alleged conduct constitutes “trafficking”; and (3) Defendants’ use of the Container Terminal is not “incident to lawful travel to Cuba.” [ECF No. 59]. The Court disagrees. 

Defendants focus much of their argument on the notion that Plaintiffs do not “own a claim” to the Container Terminal because ZEDM’s ports, docks, warehouses, and facilities did not exist until 2009, nearly fifty years after the Cuban government confiscated Plaintiffs’ property. Defendants’ argument is without merit. 

The Court finds that Plaintiffs sufficiently allege trafficking under the Act. First, Plaintiffs allege that Defendants use the Container Terminal, including storing their containers in the storage yard, and that using the Confiscated Property makes “[Defendants’] container business at the Port of Mariel possible and profitable.” [ECF No. 50 at ¶ 114]. This is enough to plausibly allege that Defendants “engage[d] in a commercial activity using or otherwise benefiting from confiscated property.” 22 U.S.C. § 6023(13)(A)(ii). In addition, Plaintiffs allege that ZEDM and AUSA all traffic in the Confiscated Property by developing and operating the Port of Mariel, and that Defendants profit from ZEDM and AUSA’s trafficking in the property. This is enough to plausibly allege that Defendants “profit[] from trafficking . . . by another person, or otherwise engage[] in trafficking . . . through another person.” 22 U.S.C. § 6023(13)(A)(iii). Accordingly, the Court finds that Plaintiffs have sufficiently alleged a violation of the Act. 

Defendants argue that Plaintiffs are required to plead around the lawful travel defense set forth in § 6023(13). The Court disagrees. “The lawful travel exception is an affirmative defense to trafficking that must be established by [Defendants], not negated by Plaintiff.” Garcia-Bengochea v. Carnival Corp, 407 F. Supp. 3d 1281, 1286 (S.D. Fla. 2019).11 Therefore, the burden is on Defendants to establish that their activity in the Port of Mariel and Container Terminals was incident to lawful travel to Cuba. Id. at 1287. As this defense is not apparent on the face of the SAC, it is inappropriate for consideration at this stage of the litigation. Id. 

Defendants argue that the Estates and Heirs do not have an actionable ownership interest in the Confiscated Property because they acquired their claims after March 12, 1996. On this point, the Court agrees. 

In addition, the Court does not find the term “trafficking” to be unconstitutionally vague. A civil statute “is not unconstitutionally vague if persons of reasonable intelligence can derive a core meaning from the statute.” Seniors Civil Lib. Ass’n, Inc. v. Kemp, 965 F.2d 1030, 1036 (11th Cir. 1992) (internal citations and quotations omitted). This Court, and the many other courts interpreting the Act, have not had difficulty in discerning the meaning of “trafficking.” Accordingly, the Motion on this ground is denied. 

Title III Does Not Violate the Due Process Clause.

In Belarus, Minsk Airport Duty Free Stores, Bacardi Outselling Havana Club

In Belarus, Minsk International Airport Duty Free retail stores have both Havana Club rum and Bacardi rum.  From the display sign, even though Belarus and the Republic of Cuba have a commercial, economic, and political relationship, travelers are preferring the Bermuda-based brand rather than the Havana-based brand. Republic of Cuba cigar brands are represented.

Related Post: At Vnukovo International Airport In Moscow, Havana Club Rum Has A Presence, But Bacardi Has More Real Estate In The Duty Free Shop. For Cigars, It's All About Cuba's Brands March 18, 2022

169-Page Ruling Against Four Largest Cruise Lines- They Engaged In Tourism In Cuba. Now A Binary Choice: Jury Trial In Miami, Florida, In May 2022 Or US$100+ Million Settlement? Is There Insurance?

With Judge Bloom’s ruling, the four cruise lines are nearing a binary choice- accept a jury trial or negotiate a settlement. As the plaintiffs seem to be seeking compensation (potentially US$100 million US$400 million) based upon what the Libertad Act permits, the four cruise lines will determine if a decision by a jury could be more costly than using the Libertad Act formulas to calculate what is owed to the plaintiffs. Key to remember- the jury will be residents of the Miami, Florida, area, and will certainly include individuals of Cuban descent.

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)

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)

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)

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 To 169-Page Omnibus Order (3/21/22)
LINK To Libertad Act Lawsuit Filing Statistics

LINK To Previous Post
Federal Judge Rules Libertad Act Lawsuit Against Carnival, MSC, Norwegian, And Royal Caribbean Will Be Heard By Jury In May 2022. "Cuban-Americans" On Jury May Be Problematic For Defendants. February 23, 2022