Explosives From Cuba To Suriname Mean OFAC Fines Totaling US$187,350.00 For Denver-Based Newmont Corporation And Miami-Based Chisu International Corporation.

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $141,442 settlement with Newmont Corporation (“Newmont”), a multinational mining firm headquartered in Denver, Colorado. Newmont has agreed to settle potential civil liability for four apparent violations of the Cuban Assets Control Regulations (CACR), 31 C.F.R. part 515. Specifically, between approximately June 2016 to November 2017, Newmont Suriname, a wholly owned subsidiary of Newmont that is a person subject to the jurisdiction of the United States under the CACR, purchased Cuban-origin explosives and explosive accessories from a third-party vendor involving four separate transactions. OFAC determined that Newmont voluntarily disclosed the apparent violations, and that the apparent violations constitute a non-egregious case.

Separately, OFAC today announced a $45,908 settlement with Chisu International Corporation (“Chisu”), a company located in Parkland, Florida that is affiliated with a distributor of explosives and accessories for mining operations. Chisu has agreed to settle potential civil liability for four apparent violations of the Cuban Assets Control Regulations (CACR), 31 C.F.R. part 515. Specifically, between June 2016 and November 2017, Chisu and its affiliates in Suriname and Panama on four occasions procured Cuban-origin explosives and related accessories originating from Cuban entity Unión Latinoamericana de Explosivos (ULAEX) on behalf of a U.S. company for the U.S. company’s mining project in Suriname. OFAC determined that Chisu did not voluntarily disclose the apparent violations and that the apparent violations constitute a non-egregious case.

LINK To Newmont Corporation OFAC Document

LINK To Chisu International Corporation OFAC Document

Defendant Cruise Lines And Plaintiff Havana Docks Corporation File Briefs About Juries And Damages: "unconstitutionally excessive and disproportionate under the Fifth Amendment."

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HAVANA DOCKS CORPORATION VS. CARNIVAL CORPORATION D/B/A/ CARNIVAL CRUISE LINES [1:19-cv-21724; Southern Florida District]

Colson Hicks Eidson, P.A. (plaintiff)
Margol & Margol, P.A. (plaintiff)
Jones Walker (defendant)
Boies Schiller Flexner LLP (defendant)
Akerman (defendant)

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)

Reply In Support Of Defendants’ Motion Seeking Clarification Of The Court’s March 21, 2022 Omnibus Order On Motions For Summary Judgment (4/19/22)

Plaintiff Havana Docks Corp.’S Response In Opposition To Motion For Certification For Interlocutory Appeal And Motion To Stay (4/15/22)

Order On Defendant’s Motion To Preclude Plaintiff From Using Aphra Behn As A Witness (4/12/22)

Plaintiff Havana Docks Corporation’s Response To Defendants’ Motion Seeking Clarification Of The Court’s March 21, 2022 Omnibus Order On Motions For Summary Judgment (4/12/22)

Link To Libertad Act Lawsuit Filing Statistics 

Excerpts: 

“Defendants’ Motion (Carnival Docket No. 480) seeks to clarify that any damages awarded in this case may be challenged as unconstitutionally excessive and disproportionate under the Fifth Amendment, after a trial or award of damages, notwithstanding the Court’s Order granting summary judgment on these affirmative defenses.1 In its Response (Carnival Docket No. 495), Plaintiff agrees with the substance of this request. As Plaintiff explains: “Following Eleventh Circuit precedent, the Court has twice held that a Fifth Amendment excessiveness argument is a post-trial issue to be addressed ‘after a jury has delivered a damages award.’” Response at 2.2 That is precisely the basis of Defendants’ Motion: under this Court’s holdings, any Fifth Amendment excessiveness and disproportionality issues should be resolved only after there is an award of damages. Accordingly, Defendants seek to clarify that the Court’s Summary Judgment Order does not preclude them from raising these challenges should damages be awarded.”

Expedia Asks Court Of Appeals To Ignore A Ruling By Judge In Libertad Act Lawsuit Filed Against Carnival Corporation.

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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)

Response To Appellants’ FRAP 28(J) Letter In Del Valle, Et Al. V. Expedia Group Inc., Et Al., No. 20-12407 (4/18/22)
Link To Libertad Act Lawsuit Filing Statistics

Excerpt: 

“On behalf of Appellees, we write in response to the April 4, 2022 FRAP 28(j) letter filed by Appellants, which cites a district court order in Havana Docks Corp. v. Carnival Corp., No. 19-CV-21724 (S.D. Fla. March 21, 2022) (the “Order”). This court should not consider the Order as pertinent to the instant case (Del Valle) for several reasons.  

First, the Order does not address personal jurisdiction, which is a determinative issue in Del Valle and was the basis for dismissal below. (See Booking Appellees’ Br. 17-44; Expedia Appellees’ Br. 12-27.)  

Second, the Order is not instructive with respect to constitutional standing because the court failed to conduct the historical-analogue analysis required by the Supreme Court in TransUnion and by this Court in Muransky and Trichell. (See Appellees’ July 12, 2021 Rule 28(j) Notice; Booking Appellees’ Br. 52; Expedia Appellees’ Br. 28-30.)  

Third, unlike Appellants, plaintiff Havana Docks holds a certified claim (compare App. 144, with Order 109), which entitles it to a presumption of the claim’s ownership and value. See 22 U.S.C. § 6082(a)(2). Because Appellants’ action is based on uncertified claims, Appellants retain the burden to plead and prove ownership and value. Accordingly, the absence of an uncertified claim in Havana Docks makes the Order inapposite in Del Valle.  

Fourth, the Order is not instructive on scienter, should the Court reach that issue. (See Booking Appellees’ Br. 37 n.8; Expedia Appellees’ Br. 37-39). The Order improperly limits the scope of the scienter requirement only to one element of a Title III claim: “trafficking.” (Order 96-97.) Yet the Act’s plain language requires a showing that defendant “knowingly and intentionally” engage in all elements of a Title III claim for liability to attach. (See 22 U.S.C. § 6023(13); App. 219-20, 247-48.)  

Finally, the Order is not instructive on the statute’s “lawful travel exception” because it limits the term necessary in contradiction to the legislative history. The Order also misconstrues the purpose of the exception, ignoring the OFAC regulations that provide the relevant context. (See Booking Appellees’ Br. 7, 10-11; see also U.S. Amicus Br. 30-36.)”

Biden Administration Believes Important To Discuss Immigration With Cuba. Should Also Discuss Engagement With Private Sector, Expanding Commerce, Settlement Of Certified Claims.

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If the Biden-Harris Administration (2021) believes important to discuss officially immigration, migration, and travel with Cuba, then there should also be discussions about supporting the equally important re-emerging private sector, commercial transactions, and settling the 5,913 certified claims.

The White House
Washington DC
19 April 2022

Daily Press Conference

Jen, can you tell us anything more about these Cuba-U.S. talks that the Cubans are saying that are happening, I think, tomorrow -- is that right?
MS. PSAKI: Let me get an update on that. I haven't had a chance to talk to the national security team about that.

Cuba to hold high-level migration talks in Washington

By Matt Spetalnick 

WASHINGTON, April 18 (Reuters) - American and Cuban officials are due to meet in Washington on Thursday to discuss migration concerns, people familiar with the matter said, in the highest-level formal U.S. talks with Havana since President Joe Biden took office last year. The meeting comes at a time when Biden's administration is grappling with rising numbers of migrants attempting to cross the U.S. border from Mexico, with Cubans making up a growing portion of them. Tensions between Washington and Havana over the Cuban government's crackdown on protests, continuing American sanctions on the Communist-ruled island and other issues have made it difficult for the countries to cooperate on challenges such as irregular migration.

Leading the Cuban delegation will be Deputy Foreign Minister Carlos Fernandez de Cossio, two sources said, speaking on condition of anonymity. The delegation is expected to meet with senior officials of the U.S. State Department and other agencies. The United States wants Cuba to take back more deportees from among the record numbers of Cubans arriving at the U.S.-Mexican border, according to a U.S. official and another source, speaking on condition of anonymity.

The Cuban government has not accepted deportation flights carrying Cubans from the United States for more than six months, a U.S. Department of Homeland Security (DHS) spokesperson said. As of March 26, there were about 40,000 Cubans in the United States with a final deportation order from an immigration judge, according to the spokesperson. Cuba has said it supports legal, orderly and safe migration. It blames the United States for the uptick in irregular migration, saying Cold War-era sanctions and a decision to close the American consular section in Havana encourage Cubans to seek riskier routes off the island.  The State Department last month said it would again begin processing some visas for Cubans in Havana to start reducing the backlog after a four-year hiatus, but progress has been slow.

'SIGNIFICANT INCREASE'

"We have seen a significant increase in irregular Cuban migrants to the United States, both via land and maritime routes," a State Department spokesperson said.  The spokesperson, who asked not to be named, declined to confirm the planned meeting but said "we regularly engage with Cuban officials on issues of importance to the U.S. government, such as human rights and migration."  Thursday's planned talks appear to be at a higher level than known formal contacts since Biden took office in January 2021.  The Cuban government did not immediately respond to questions seeking comment.  The talks are scheduled to be held just a day after U.S. Secretary of State Antony Blinken and regional counterparts are due to wrap up a conference on migration in Panama. Cuba is not due to attend that conference.

A record number of migrants attempted to cross the U.S.-Mexican border during Biden's first year in office. American officials are preparing for even higher numbers this year.  Amid Cuba's faltering economy, after Nicaragua lifted visa requirements for Cubans in November, many dropped everything, sold their homes and took a flight for Managua, with hopes of joining the mainland "migrant highway" north through Central America to the United States.  Nicaragua, a close regional ally of Cuba, said the move was intended to promote commercial exchange, tourism and humanitarian family relations.

Initial fervor has been followed by frustration as the United States has undertaken a regional effort to curb border crossings.  U.S. border authorities apprehended more than 32,000 Cubans at the U.S.-Mexico border in March, roughly double the 16,500 caught in February, then the highest single-month total on record, according to U.S. Customs and Border Protection data.

Even as the United States and Cuba prepare to re-engage on migration, Biden administration officials are mindful that any easing of restrictions on Cuba could lead to political fallout from conservative Cuban Americans, a key voting bloc in south Florida.  Former President Donald Trump rolled back a historic rapprochement that his predecessor Barack Obama oversaw between the United States and its old Cold War foe.  Biden, who served as Obama's vice president, promised during the 2020 U.S. election campaign against Trump to re-engage with Cuba, and many in both countries expected he would reverse some Trump-era restrictions. Biden instead imposed fresh sanctions on Cuban officials in response to Havana's crackdown on protesters following widespread marches on the island last July.  Thousands of people took to the streets of Cuban cities, voicing anger over shortages of basic goods, curbs on civil liberties and the handling of the COVID-19 pandemic by authorities. Some called for political change.

Cuba Wants Another At Bat With MLB To Resurrect 2018 Agreement. The Effort Will Struggle To Get To First Base At The White House.

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“The Cuban Baseball Federation (FCB) on Tuesday ratified its intention to recover the rapprochement with the Major League Baseball (MLB) in order to establish a stable and depoliticized relationship.”   

On 19 December 2018, New York, New York-based Major League Baseball (MLB; 2021 revenue approximately US$4 billion) reported an agreement with Republic of Cuba-based Federacion Cubana de Beisbol (FCB).  Terms of the agreement included payments to FCB.  LINK To Document  

Members of the United States Congress, the most notable being The Honorable Marco Rubio (R- Florida), a member of the United States Senate, and officials of the Trump Administration expressed displeasure with the agreement. The Trump Administration denied authorization for the agreement because of payments to the FCB which the Trump Administration believed would ultimately benefit the government of the Republic of Cuba. LINK OFAC Letter To MLB. There were then and remain now options to revise the agreement and resubmit as a license application to the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury in Washington DC. 

MLB should not as it did in 2018 retain a consultant, outside counsel or lobbyist to engage with the Biden Administration.  Doing so would be counterproductive as MLB can make its case in a license application to the OFAC.  Why create a triangle when a straight line is more efficient.  The direct approach is preferred.  The application will certainly be subject to an inter-agency review process including departments and agencies to determine if issuance of an OFAC license is “consistent with United States policy” so the decision will not be immediate. 

Options Include:  

First.  MLB believed the agreement was permitted under OFAC general license provisions implemented during the Obama Administration.  Those who opposed the agreement believed the agreement was not permissible within the OFAC general license guidelines; and, even if it was permitted during the Obama Administration, such an agreement should not be permitted during the Trump Administration as the agreement was “not consistent with United States policy.”  MLB should reformat the agreement and seek a two-year (which is normal) license from the OFAC.    

Second.  The MLB agreement was for two years (ending on 31 October 2021).  The annual release fee payments to FCB have been speculated to be from US$2 million to US$25 million to US$50 million to US$100 million.  The lower value estimates seem reasonable.  Instead of MLB making payment to FCB in currency, FCB would provide MLB with a shopping list of equipment equal to the value of the payments due.  This may satisfy those who opposed the agreement- because the government of the Republic of Cuba would not have access to currency.  By using the purchasing power of MLB, the FCB would be receiving the lowest pricing for equipment- thus maximizing the value of every payment.  Members of the United States Congress and Biden Administration could be supportive of an agreement that provides benefits to United States sporting “Made in the USA” equipment-focused companies.   

From The original MLB agreement: “The Release Fee owed to the FCB by the MLB Club that signs an FCB Player is calculated using the same formula embodied in MLB's agreements with the NPB, KBO, and CPBL (i.e., between 15% and 20% of the total guaranteed value for Major League contracts, and 25% of the signing bonus for Minor League contracts). In addition, Supplemental Release Fees may be owed if a contract with an FCB Player contains bonuses, escalators, or options that are later triggered. The Release Fee (and any Supplemental Release Fee) paid by the MLB Club is in addition to the compensation agreed to by the MLB Club to the FCB Player in the player's contract, which will be paid by the MLB Club directly to the FCB Player.”   

One important benefit of using product as payment rather than currency as payment is avoiding the use of a third-country financial institution for MLB to send payments to FCB; currently there are not operational direct correspondent banking agreements which would permit direct electronic transfers from the United States to the Republic of Cuba or from the Republic of Cuba to the United States.  Thus, third-country financial institutions receive fees for every transaction.  Members of the United States Congress and Biden Administration should oppose third-countries unnecessarily benefiting from bilateral commercial transactions involving the United States.    

Third.  MLB would agree to publish real-time data as to when a payment is made to FCB, the value of payment, and what products have been purchased with the payments.    

Prensa Latina
Havana, Republic of Cuba
12 April 2022

Cuba is willing to pave the way to resume deal with MLB 

Havana, Apr 12 (Prensa Latina) The Cuban Baseball Federation (FCB) on Tuesday ratified its intention to recover the rapprochement with the Major League Baseball (MLB) in order to establish a stable and depoliticized relationship.  We aspire to have a respectful, ethical and professional treatment, which had as maximum expression the signing of the FCB-MLB Agreement in December 2018, an agreement that was disqualified by the government of former President Donald Trump, FCB President Juan Reynaldo Perez noted. At a press conference at the Latin American stadium, in Havana, Perez acknowledged that resuming the pact will mean an effective tool against illegal emigration, human trafficking and other risks for baseball players and their families.  He recalled that the Trump administration frustrated the first steps of the FCB to give more life to the agreement, such as the definition of a list of eligible talents by the different franchises, in addition to closing the doors to its observers in an attempt to verify the quality of Cuban athletes. The official confirmed that the annulment demonstrated the politicization of sports from US territory, always under the influence of Cuban detractors.  Despite this situation, Cuba is willing to resume negotiations and defends the respectful relationship with the players born and trained in its land, but who play, without its representation, in the US and world circuits.  In that line, Perez, who is also the national baseball commissioner, said that those who comply with the provisions of the current immigration policy can rejoin the sports system and aspire to represent the nation at international tournaments. 

teleSUR
Havana, Republic of Cuba
12 April 2022

Such a relationship will allow "the natural flow of Cuban players to and from that circuit," Cuban Baseball Federation President Perez said.  On Tuesday, the Cuban Baseball Federation (FCB) President Reynaldo Perez indicated that his country aspires to develop a "stable and non-politicized" relationship with the U.S. Major League Baseball (MLB). Such a relationship will allow "the natural flow of Cuban players to and from that circuit," Perez said after taking office on Monday.  This official considered that the 2018 MLB-FCB agreement, which was annulled by former President Donald Trump, prompted a respectful, ethical, and professional exchange between both organizations.  "The agreement annulment demonstrated the U.S. government's politicization of sports and put our players in a vulnerable position by forcing them to risk their lives and incur debts to emigrate," Perez stated.   

They are at your front door now @MLB the ball is in your court, as they say. The Cuban Professional Baseball Association wants to play in the World Baseball Classic. How can the best in the world be unable to play. #mlb #wbc #cuba ⚾  pic.twitter.com/WQkYV3hJQu — Eddie Oropesa Jr. ⚾ (@OropesaBaseball) April 9, 2022  

Although baseball is considered a "cultural heritage" in Cuba, professional athletes experience a crisis due to the lack of infrastructure and implements. The outlet Trabajadores pointed out that 635 baseball players have left the country over the last six years, in many cases without official permits.  "Our Federation defends a respectful relationship with Cuban players working in other leagues. Those who comply with migration provisions have rejoined the National Series and the Cuba team in some cases," Perez explained.  He also mentioned that Cuban players in the MLB who meet the established requirements will be able to join national and foreign tournaments on behalf of Cuba without setbacks and that the FCB is ready to resume negotiations for the re-implementation of the 2018 agreement. 

Links To Related Analyses 

Baseball Diplomacy? An Opportunity For Re-Engagement With Cuba, Biden Administration May Be Open To Revised MLB Agreement January 27, 2021 

MLB Might Consider Three Options To Obtain Support For Agreement With Cuba January 11, 2019 

MLB Commissioner Plays Golf With President Trump; Renewed Life For Cuba Agreement? Second-Base For Lobbyist? November 02, 2019 

Cuba Lobbyist Works? President Trump To Participate In Oval Office Meeting With MLB To Discuss "Human Trafficking" June 10, 2019 

OFAC Responds To Major League Baseball Proposal For Players From Cuba April 09, 2019

Another Obama (Ben Rhodes) Administration Legacy Decision Harms Major League Baseball December 20, 2018 

New OFAC Regulation Benefits MLB Players; Performers & Teachers Too March 16, 2016

Some Parallels Between President Obama's Baseball and President Nixon's Ping Pong February 29, 2016

U.S. Department Of State Provides Statement, But Not Answer To Question: Did A U.S. Embassy Representative Attend The Havana Local Development Fair. Why Won't They Answer?

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From 28 March 2022 to 3 April 2022, 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. 

United States Department of State
Washington DC
15 April 2022

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.” 

Link To Related Analysis 

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.  April 03, 2022

U.S. Assistant Secretary Of State Telegraphs No Invitations For Cuba, Nicaragua, Venezuela To Summit Of The Americas Despite Importance Of Those Countries To Migration Issues Facing United States.

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The United States will host the Ninth Summit of the Americas in Los Angeles, California in June 2022 with a focus on “Building a Sustainable, Resilient, and Equitable Future” for our hemisphere. [6 June 2022 to 10 June 2022 with the Los Angeles Convention Center the primary venue.]

United States Department of State
Washington DC
15 April 2022

Assistant Secretary for Western Hemisphere Affairs Brian A. Nichols and Population, Refugees, and Migration Acting Principal Deputy Assistant Secretary Marta Youth On Secretary Blinken’s Upcoming Travel to Panama- Via Teleconference

Excerpts

ASSISTANT SECRETARY NICHOLS: Well, we’re working on addressing the root causes of migration as a collective effort, and one of the things that I think has been quite powerful in the near term has been Vice President Harris’ call to action, which has mobilized over $1.2 billion in private sector investment in Northern Central America and created thousands of jobs in that part of the hemisphere. And we know that those people are not migrating. We know that our efforts to provide COVID-19 vaccines to countries throughout the hemisphere – some 60 million vaccines in the Western Hemisphere – have helped countries recover more quickly from the COVID-19 pandemic which was a driver of migration to our southern border. We know that our efforts to provide assistance to communities that are hosting migrants in Colombia, Ecuador, Peru, Chile have all helped stabilize those populations to a greater degree. But this comes in the context of literally millions of migrants on the move in our hemisphere; some six million Venezuelans are migrants outside of Venezuela right now, over five million of them in the Western Hemisphere. There are half a million Nicaraguans who are displaced and living in Costa Rica right now, and I had the opportunity to meet with some of them when I was there a couple weeks ago. We’re talking about hundreds of thousands of Haitian migrants in Chile, in Brazil.

QUESTION: Great. Thank you. Two questions here. First, will any representatives of the Maduro government be present for the ministerial? And can any agreement – hemisphere-wide agreement solve the migration crisis without addressing Venezuela’s political, economic, and humanitarian crises?
And then second, the administration has announced plans to admit up to 100,000 Ukrainian refugees. What impact would that have on your plans to admit – or process asylum claims at the border or otherwise address migration issues? Thank you.

ASSISTANT SECRETARY NICHOLS: So the Maduro regime will not attend the ministerial. The – obviously the lack of access to opportunity, democracy, human rights, the rule of law inside the borders of Venezuela has led many Venezuelans to vote with their feet and depart that country. Our goal is to encourage the Maduro regime and the interim government to return to the negotiating table in Mexico City where Venezuela negotiated and led solution to that country’s problems. We continue to support that effort and believe it has the best prospects for a lasting solution to Venezuela’s problems.

QUESTION: Thanks. I just had a follow-up to my colleague Conor’s question on the Maduro regime, and you said that no representatives from that regime are attending the ministerial. Could you just advise as to whether or not any representatives from the regime were invited to attend? Thank you.

ASSISTANT SECRETARY NICHOLS: Not to my knowledge.

QUESTION: Thank you. You have mentioned a couple of times that this meeting in Panama is in preparation for the Summit of the Americas. So I was wondering if the United States has invited Cuba and Venezuela to the Summit of the Americas. Thank you.

ASSISTANT SECRETARY NICHOLS: So the White House will determine which leaders are invited to the Summit of the Americas, and the White House has not yet issued invitations. I will note that the Western Hemisphere is a part of the world that has a broad commitment to democracy, as enshrined in the Inter-American Democratic Charter. And I believe that as we move forward, we will see countries that share that commitment toward democracy as the key participants in the summit.

LINKS To Related Analyses

"Ninth Summit of the Americas" Scheduled For 6 June 2022 To 10 June 2022 In Los Angeles, California. Cuba And Venezuela Should Be Invited- And Both Countries Should Participate.  January 19, 2022

Might Cuba And Venezuela Participate In 2021 Summit Of The Americas? Might They Be Required To Participate?  October 31, 2020

U.S. Ag/Food Exports To Cuba Increase 40.3% In February; 28.1% Increase Year-To-Year. Products Included Poultry, Milk, Popcorn, Coffee Beans, Tuna, Shampoo.

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ECONOMIC EYE ON CUBA©
April 2022

February 2022 Food/Ag Exports To Cuba Increase 40.3%- 1
49th Of 216 February 2022 U.S. Food/Ag Export Markets- 2
2022 Exports Increase 28.1%- 2
Cuba Ranked 56th Of U.S. Ag/Food Export Markets- 2
February 2022 Healthcare Product Exports US$172,338.00- 2
February 2022 Humanitarian Donations US$364,841.00- 3
Obama Administration Initiatives Exports Continue- 3
U.S. Port Export Data- 16

FEBRUARY 2022 FOOD/AG EXPORTS TO CUBA INCREASE 40.3%- Exports of food products and agricultural commodities from the United States to the Republic of Cuba in February 2022 were US$29,812,459.00 compared to US$21,242,760.00 in February 2021 and US$14,809,161.00 in February 2020.

February 2022 Exports Included: Chicken Leg Quarters (Frozen); Chicken Meat (Frozen); Chicken Legs (Frozen); Whole Chickens; Soybeans; Preserved Chicken Meat; Beans; Green Coffee Beans; Roasted Coffee Beans; Lentils; Powdered Milk; Condensed Milk; Popcorn; Tuna; Communion Wafers; Shampoo; Soap; Dentifrices.

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

Iberostar Files 25th Notice To Court. Judge Waiting 730 Days For European Commission To Respond. Patience Waning For Judge? Deadline Notice Likely.

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Ag Delegations Traveling To Cuba Must Know What Is Possible, Advocate To Government Of Cuba To Permit All That Is Permissible- Direct Export Of Coffee, Cacao, Honey. Complaining Not Constructive.

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Ag Delegations Traveling To Cuba Need To Know What Is Possible And Advocate To Government Of Cuba To Permit All That Is Permissible- Waiting For Direct Export Of Coffee, Cacao, Honey.  Complaining Is Not Constructive.   

Important for individuals subject to United States jurisdiction to be knowledgeable in advance of traveling to the Republic of Cuba of statutes, regulations, and policies relating to exporting products and services to the Republic of Cuba, importing products and services from the Republic of Cuba, and providing direct investments within the Republic of Cuba.  Critically important is to have knowledge about what has been accomplished and what has not been accomplished.  These are the responsibilities of the visitor and the organizer of the visit, if there is one. 

Providing Republic of Cuba nationals who are officials, managers, owners, and workers with inaccurate information- and permitting officials, managers, owners, and workers to promote inaccurate information does nothing to advance the interests of United States-based companies and organizations. 

Critical for United States-based interests and Republic of Cuba-based interests to use what does exist with respect to export opportunities and import opportunities rather than misuse valuable time and unnecessarily high-priced face-to-face engagement for the purpose of complaining about what does not exist and what could be if what existed did not exist.  There are opportunities- important to use them.   

Republic of Cuba government-operated Cubaexport continues to prohibit the direct export of coffee, cacao, and honey to the United States.  The direct export of charcoal was authorized by Cubaexport which operates under the Ministry of Foreign Trade and Foreign Investment of the Republic of Cuba.  The indirect export of coffee (processed) was authorized by Cubaexport.  

According to the United States Department of Agriculture (USDA), no request was made immediately or soon after the Republic of Cuba provision in H.R. 2, the five-year Agriculture Improvement Act, known as the “Farm Bill” was signed into law on 20 December 2018 by The Honorable Donald J. Trump, President of the United States.   

In 2018, advocates maintained that the Farm Bill provision was critical to “laying the groundwork” for increasing exports of agricultural commodities and food products to the Republic of Cuba. Statements from members of Congress included: “… an important first step to regaining our presence in Cuba.” Most observers reasonably concluded that legislative advocates- within the United States Congress and organizations located in Washington DC and located outside of the beltway would have prominently teed-up at least one high-profile applicant to request funding on 21 December 2018- regardless of whether the USDA was expected to approve including the Republic of Cuba in Fiscal Year 2019 allocations.  

According to Denver, Colorado-based Potatoes USA, the organization applied to the USDA for the use of MAP (Market Access Program) funding in May 2019. The amount of the request was US$60,000.00. In November 2020, 33,118 pounds (15,022 kilos or 21.04 metric tons) of potato seeds valued at US$44,760.00 were shipped to the Republic of Cuba in a container by ocean freight. 

Constructing a foundation upon realities is far more effective than constructing a foundation upon a statutory, regulatory, and policy landscape that does not exist and likely will not exist for longer than many desire.  

There are neither limitations as to type, quantity, nor to quality, of agricultural commodities and food products which may be exported from the United States to the Republic of Cuba within provisions of the Trade Sanctions Reform and Export Enhancement Act (TSREEA) of 2000.  The TSREEA re-authorized the direct commercial (on a cash basis) export of food products (including branded food products found in a supermarket) and agricultural commodities (including fertilizers and telephone poles and paper) from the United States to the Republic of Cuba, irrespective of purpose.  Since the first deliveries using the TSREEA in December 2001, the total value of agricultural commodities and food products delivered from the United States to the Republic of Cuba exceeds US$6.6 billion. 

Useful to mention that those United States-based exporters of agricultural commodities and food products to the Republic of Cuba have not publicly advocated for a change in payment terms from cash-in-advance as required by the TSREEA to permitting payment terms and permitting financing.   

In 1999 and 2000, United States-based exporters of agricultural commodities and food products advocated against including payment terms and financing in the TSREEA for fear that the Republic of Cuba was likely to default, and any reported default would expectantly result in widespread reluctance for any commercial engagement with the Republic of Cuba.  The theory was better to have less volume and United States dollar value in overall exports when confined to cash-in-advance payments than insert considerable risk where none would exist.    

Instructive that no representative of a United States-based financial institution has confirmed in public, including at committee hearings and sub-committee hearings before members of the United States Congress (House of Representatives and Senate), that they would provide financing to a Republic of Cuba government-operated entity. 

The existing commercial, economic, and political relationship between the United States and the Republic of Cuba remains absent normality due to statutes, regulations, and policies initiated, implemented, and adhered to by the governments in both capitals.   

Each government has implemented harm upon the other government- and United States-based companies and Republic of Cuba-based companies, particularly the self-employed and newly-re-authorized micro, small, and medium-size enterprises (MSMEs) are unable to fully engage to levels where each are comfortable- and account for inspiration and aspiration, the fuel which propel entrepreneurs. 

The Republic of Cuba may purchase inputs including equipment.  In 2017, Deere & Company (2021 revenues approximately US$44 billion) established a distribution center in the Republic of Cuba, joining San Juan, Puerto Rico-based RIMCO, the Republic of Cuba distributor for Peoria, Illinois-based Caterpillar Inc. (2021 revenues approximately US$42 billion) established the same year.  At the time, neither Deere & Company nor Caterpillar issued media releases or posted information on their respective Internet sites.  

Since November 2017, Deere & Company delivered more than US$800,000.00 in agricultural equipment to the Republic of Cuba for use at its distribution center. Antioch, Tennessee-based Wirtgen America, Inc., a subsidiary of Windhagen, Germany-based Wirtgen Group (2021 revenues approximately US$3 billion), a construction equipment machinery subsidiary (acquired in 2017) of Deere & Company has also delivered products to the Republic of Cuba.  RIMCO continues to deliver equipment for use at its distribution center in the Republic of Cuba, including excavators, backhoes, graders, scrapers, bulldozers, railway fixtures, and signaling equipment, valued at more than US$4 million since December 2018.  John Deere Financial Services was to provide payment terms/financing for the exports, primarily Series 5000 (price range US$25,000.00 to US$80,000.00) with a limited quantity of Series 7000 (price range US$219,000.00 to US$280,000.00).  According to the company, several hundred tractors, parts and accessories may be exported from the United States to the Republic of Cuba during the next four years, with the first deliveries (for testing and evaluation) scheduled for mid-November 2017.  The potential value of the several hundred products exported from the United States to the Republic of Cuba that would be financed could range from US$9 million to US$30 million.  John Deere Financial Services has not commented as to whether the product sales goals have been achieved or if there have been issues relating to the receipt of payments.  Caterpillar has not disclosed if the company has provided payment terms for its products exported to the Republic of Cuba.  

United States Department of State
Washington DC
Section 515.582 List
Bureau of Economic and Business Affairs Goods and Services Eligible for Importation

“In accordance with the policy changes announced by the President on December 17, 2014, to further engage and empower the Cuban people, Section 515.582 of the Cuban Assets Control Regulations (31 CFR Part 515 – the CACR) authorizes the importation into the United States of certain goods and services produced by independent Cuban entrepreneurs as determined by the State Department as set forth on the Section 515.582. The goods whose import is authorized by Section 515.582 are goods produced by independent Cuban entrepreneurs, as demonstrated by documentary evidence, that are imported into the United States, except for goods specified in the following sections/chapters of the Harmonized Tariff Schedule of the United States (HTS).”  

Coffee from the Republic of Cuba is available throughout the United States through an agreement signed in 2016 between New York, New York-based Nespresso USA Inc., a subsidiary of Lausanne, Switzerland-based Nestle Nespresso S.A. (2021 revenue approximately US$95 billion); Arlington, Virginia-based TechnoServe; and Republic of Cuba government-operated Cubaexport, under the auspice of the Ministry of Foreign Trade of the Republic of Cuba.  

From Nespresso: “The green coffee sourced for Cafecito de Cuba is 100% pure Arabica, grown by smallholder farmers in the provinces of Granma and Santiago de Cuba in the eastern part of Cuba.  Nespresso coffee experts in Switzerland then used a split roasting technique to enhance the potential of the beans and highlight their authenticity. One part of the beans was roasted for a shorter time to a lighter colour to bring out the coffee’s unique flavours and aromas. The second part was roasted longer to a much darker colour to create a strong body with a dense, velvety texture and intense rich flavours.”  Link: https://nestle-nespresso.com/news/Nespresso-brings-Cuban-coffee-back-to-US  

United States-based companies have approached Cubaexport to seek authorization to import coffee directly from the Republic of Cuba to the United States.  Those entreaties were rejected. 

Charcoal from the Republic of Cuba has been imported directly to the United States.  The first company, Hialeah, Florida-based Fogo Premium Lump Charcoal purchased four (4) 20ft containers with the first delivered in January 2017 and the second in July 2018.  The second company Foley, Alabama-based GulfWise Commerce LLC, affiliated with Foley, Alabama-based Woerner Companies reported delivery in May 2019 to Port Everglades, Florida, of two (2) forty-foot containers.  Neither company reported no transactional issues with the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury, Bureau of Industry and Security (BIS) of the United States Department of Commerce, or Office of Legal Adviser (OLA) at the United States Department of State.  

Links To Related Analyses 

Coffee & Charcoal Have Been Imported From Cuba; U.S. Companies Want More.  Agricultural Commodities/Food Products/Healthcare Products Have Been Exported To Cuba; U.S. Companies Want More. October 02, 2021 

J.C. Newman Cigar Co. Wants To Add Tobacco Leaves To Coffee & Charcoal As Authorized Imports From Cuba. June 03, 2021 

Farm Bill- FMD/MAP Funding 

According the United States Department of Agriculture (USDA), no request was made in Fiscal Years 2019 or 2020 to use the Republic of Cuba provision in H.R. 2, the five-year Agriculture Improvement Act, known as the “Farm Bill” signed into law on 20 December 2018 by The Honorable Donald J. Trump, President of the United States.   

FMD: “The Foreign Market Development (FMD) Program, also known as the Cooperator Program, helps create, expand and maintain long-term export markets for U.S. agricultural products. Under the program, FAS partners with U.S. agricultural producers and processors, who are represented by non-profit commodity or trade associations called “cooperators,” to promote U.S. commodities overseas.” 

MAP: “Through the Market Access Program (MAP), FAS partners with U.S. agricultural trade associations, cooperatives, state regional trade groups and small businesses to share the costs of overseas marketing and promotional activities that help build commercial export markets for U.S. agricultural products and commodities.” 

A most significant impact of not having any immediate MAP/FMD requests for use the Republic of Cuba provision in the Farm Bill is what the lack of interest portended for other legislative efforts in the United States Congress to rescind prohibitions upon the provision of payment terms for agricultural commodity and food product exports from the United States to the Republic of Cuba.  

For the United States business community, the MAP/FMD amendment to the Farm Bill was significant, but more likely to provide greater financial value to the government of the Republic of Cuba than to United States food product and agricultural commodity exporters using provisions of the TSREEA.  The likelihood of a value to United States taxpayers, as members of the United States Senate have posited, of US$28.00 returned for every US$1.00 in expenditures of MAP/FMD throughout the world, and now including the Republic of Cuba, will be challenging to measure- but it will be important to measure and the USDA should focus upon the cost-benefit analysis. 

Link: USDA Updates Usage In Cuba Of MAP And FMD Funding Authorized By 2018 Farm Bill. In Four Funding Periods In Four Years, Two Uses Of MAP; No Uses Of FMD. Anemic Response By Export Advocates. November 11, 2021 

Prensa Latina News Agency
Havana, Republic of Cuba
7 April 2022

US farmers ask to end trade restrictions on Cuba (+Photos).  The USA-Cuba Agricultural Coalition seeks to change policies hindering bilateral trade relations, Doug Keesling, one of founders, said on Thursday.  It would bring benefits to both sides, Mr. Keesling added at a meeting with the press.  While the United States exports over 50% of food it produces, Cubans could sell organic products, vegetables and fruit to the West Coast and generate income to buy supplies, he explained.  American producers are willing to be the most reliable source to sell food in Cuba, but also to provide Cuban farmers with technology and knowledge, he added.  “We will go back to Washington and fight for this change to happen,” he said. Meanwhile, Tom Haag, vice president of the American Corn Grower Association, acknowledged the effects of the economic US blockade against Cuba.  Concerning the significance the Conference, Asiha Grigsby, director of International Promotion of the American Rice Association, stressed that talks “allow us to bring experiences home, speak in our associations and to create a base for better future.”  Discussions focused on barriers to doing business and chances of them being removed in the coming years, said Dalton Henry, vice president of the American Wheat Association.  Despite challenges, there is already a substantial trade between the two countries as a result of our associations´ work, especially in the poultry sector; we hope to increase as other US organizations urge for friendlier relations, Mr. Henry detailed.  For two days, Cuban and US farmers worked to strengthen joint production, bilateral trade and foreign investment.  The event, held at the Valentín Quinta Avenida Hotel, included technical round tables between Cuban and US businessmen, visits to Artemisa and Mayabeque provinces, as well as openings by the Chamber of Commerce and the Cuban Ministries of Foreign Trade and Agriculture. 

Granma
Havana, Republic of Cuba
7 April 2022

In the exchange between Díaz-Canel and US farmers, Paul Johnson, president of the US-Cuba Agricultural Coalition, which since 2015 has developed an intense agenda in favor of bilateral relations in the sector, emphasized that the links between the two countries are very strong.  We have historical ties in the cultural, logistical, family and agricultural. They are ties that unite us as countries and that has to be the basis for improving relations in the future, and not only to export our merchandise here, but also to work with Cuban producers and help them increase their production, and export merchandise. there. Things will not be easy in the future, but –he said– we share objectives that should allow us to move in that direction.  We want to contribute – Johnson added – to the development of the great talent that exists in Cuba, and we have come to help improve our relations and also to put an end to this embargo, so we have a lot of work to do. The blockade/embargo – he added – has been present for more than 60 years and has not worked, and it is time to find new strategies to solve the problems and our presence is to help with that. 

Ray D'Alessio, a reporter for the Georgia Farm Monitor, asked the Head of State about the concept they have, about what Cubans think of American farmers, to which Díaz-Canel replied that Cuban farmers, both state and private, have a very high rating from their North American colleagues, for their technological and productive development, for the quality of their products, for the good practices they apply.  In fact, he told them, there are many of our farmers who communicate with you online to talk and learn about everything related to agricultural production. Our farmers -he summarized- have a high appreciation of you, they aspire to have your development, they see you as a reference.  For us, the president pointed out, the natural market, the one that could favor us the most in the food sector, is the United States. We're only 90 miles away. Of you we favor the cost, the quality, the freight, the replenishment, the rapid response in an emergency. But that is an opportunity that neither of the two parties is taking full advantage of, due to the blockade.  Robert M. Tobiassen, President of the US National Association of Spirits Importers. UU., expressed that the sector he represents, by its nature, has a different vision than that of the farmers. This is my first visit to Cuba and "I have been impressed by the hospitality of the Cubans, and I thank you and your people," he told Díaz-Canel.  Tobiassen pointed out that the quality of its spirits is a heritage shared by Cuba and the United States, and in everything, culture counts, he stated.  Alcoholic beverages have their unique history, he added, pondering the importance that different sectors of both countries strengthen their branch relations and build coalitions, as the best way to advance bilateral relations. 

Among other interventions, James Summer, president of the United States Chicken and Egg Producers Export Council, explained that he has been coming to the island for 21 years, and recalled the strong ties they maintain here, to the point that Cuba is the third export market for chicken meat producers in his country, after Mexico and China.  Today -he added- we held a meeting with representatives of the poultry sector, and we extended our hand to help increase chicken and egg production in Cuba, a sector that is becoming very difficult to maintain, not only here, but also in my country. country, due to shortages, rising costs, problems with the workforce, new diseases, are concerns that we share, as well as the search for successful solutions for our productions, he pointed out, to which the President expressed his willingness of Cuba to cooperate in all that is possible to provide answers to these mutual challenges.  The meeting concluded with the words of the farmer from Kansas, Douglas Kessling, a wheat producer, who presented the President of the Republic with a symbolic box with the grain he harvests.  "Like Cubans," Kessling pointed out, "US farmers are also very proud and we want to work with Cuban farmers, and strive to have a trade in both directions.”

Verizon Adds Cuba To 17-Country Global Choice International Calling Plan.

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04.13.2022|Products & Plans|Mobile Plans & Devices LINK To Spanish Language Text

Verizon adds calling to more countries in Latin America, including Cuba, at no additional cost

Staying in touch with loved ones has never been easier or more affordable with Global Choice, the international calling plan now included in select plans

What you need to know:

Starting today, qualified new and existing wireless customers can stay in touch with their loved ones in more countries in Latin America at no additional cost with Global Choice¹

Qualified customers can now choose one of 17 countries in Latin America to add to their plan, including Cuba, Honduras, Costa Rica, Uruguay, Paraguay and Panama

Verizon is the only carrier that provides a block of monthly international calling minutes to Cuba at no cost

BASKING RIDGE, N.J. - Verizon knows how important it is to keep in touch with loved ones who may be outside of the U.S. That’s why, starting today, we have added more Latin American countries to be part of Global Choice, at no cost with select 5G Unlimited plans.

With Global Choice, the international calling plan that provides a select number of long distance calling minutes, new and existing qualified customers can access up to five hours per month to call their friends and loved ones in one of 17 countries in Latin America at no additional charge, with discounted rates for additional hours. Verizon is the only carrier to include a block of monthly international calling minutes to Cuba at no additional cost. And, as always, talk and text to Mexico and Canada is included on select 5G Unlimited plans.

“At Verizon we are committed to offering our Latinx customers the best value on the best network to help them stay connected to friends and family near and far,” said Nina Bibby, SVP Consumer Segment Marketing at Verizon. “We are proud to expand our Global Choice international calling plan to reach more countries in Latin America, including Cuba, so customers can receive a block of minutes every month to call their chosen country at no cost.”

More options for customers calling to and from the U.S., or coming to the the country for the first time

Global Choice gives customers access to international long distance calling with a monthly allowance of minutes to one of 17 select Latin American countries, now including Cuba, Honduras, Costa Rica, Uruguay, Paraguay and Panama in addition to Colombia, Peru, Argentina, Dominican Republic, Venezuela, Brazil, Guatemala, Chile, El Salvador, Ecuador and Bolivia.

Verizon also recently announced a partnership with Nova Credit that can help provide people that are new to the country access to the best 5G network and device promotions. Those relocating from certain countries to the U.S. can seamlessly opt-in to share their international credit history with Verizon as part of the application process to purchase the latest devices. That means no need to pay the full price up front with 0% interest on device financing.

Plus, for Verizon customers planning to visit loved ones abroad, 5G Do More and 5G Get More Unlimited plans include one day of International TravelPass per month at no additional cost. TravelPass lets you use your domestic talk, text and data in more than 210+ countries and destinations outside the U.S. for a set daily fee to call within the country you're visiting and calls back to the U.S.

To sign up or to learn more about Global Choice visit: verizon.com/globalchoice To learn more about Verizon international credit visit: verizon.com/internationalcredit or about our Get More Plans and included TravelPass days, visit verizon.com/plans/unlimited.

¹ Available for new and current wireless customers who add a line on postpaid 5G Unlimited plans only. For monthly access, must add Global Choice International plan and eligible country w/in 30 days of activating plan. $10/mo credit applied for select country; credit ends if eligibility req’s are no longer met. International calling available from the U.S. to mobile or landline to only select countries starting at 30 min/mo of usage; then up to $0.65 per minute after monthly time allotment depending on country. See vzw.com for list of eligible countries and add’l rates.

² Rates per minute apply once allowance has been used.

Verizon Communications Inc. (NYSE, Nasdaq: VZ) was formed on June 30, 2000 and is one of the world’s leading providers of technology and communications services. Headquartered in New York City and with a presence around the world, Verizon generated revenues of $133.6 billion in 2021. The company offers data, video and voice services and solutions on its award-winning networks and platforms, delivering on customers’ demand for mobility, reliable network connectivity, security and control.

For Biden-Harris Administration, Next Important Date Marker Impacting Policies Toward Cuba Is 11 July 2022. Will There Be Demonstrations And How Will Diaz-Canel-Valdes Mesa Adminisration React.

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On July 11, spontaneous peaceful protests broke out across the island. In the largest and most widespread demonstrations in decades, tens of thousands of citizens across the country poured into the streets to demand an end to repression as well as to criticize the government’s failure to meet their basic needs and its poor response to COVID-19. Social media posts helped spread news of the protests among citizens.

LINK To 46-Page 2021 Cuba Human Rights Report

US Department Of Justice Files 47-Page Amicus Brief In Libertad Act Lawsuits Against Trivago And Four Cruise Lines. Both Plaintiffs And Defendants Will Have Issues. Who Can Sue? Was Travel Lawful?

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Excerpts From Amicus Brief:

"The United States deplores the nationalization and expropriation of property of U.S. nationals by the Cuban government in the strongest terms and has repeatedly communicated to the Cuban government the need to provide compensation for such takings of property. The United States also condemns the trafficking in nationalized and expropriated property by the Cuban government and others. It is the longstanding policy of the United States to achieve compensation for U.S. nationals with outstanding claims related to Cuban expropriations."

"As explained below, the application of the lawful travel exclusion is underdeveloped in the records of these cases."

"Relying on that well-established regulatory regime ensures that potentially sensitive foreign policy questions regarding the lawfulness of travel to Cuba are decided by the political branches."

"The Court asked for the United States’ views on the effect of the lawful travel exclusion on the plaintiffs’ claims. Because none of the district court decisions applied the lawful travel exclusion, and because the issue is generally underdeveloped in the record, the United States does not take a position on whether or how the exclusion might apply to the facts of these cases. But the United States does note that, in its view, a plaintiff does not bear the burden to plead specific allegations that would establish that the defendant’s travel-related transactions were not “incident to lawful travel.”

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)

Motion By The United States To File Over-Length Brief (4/11/22)
Brief For United States As Amicus Curiae (4/11/22)
USDOJ Appearance Counsel Form (1/25/22)
Notice Of Amicus Participation By The United States (3/22/22)
Del Valle v. Expedia Group Inc., No. 20-12407 - Rule 28(j) Letter Citing Supplemental Authority (4/4/22)
Libertad Act Lawsuit Filing Statistics

Excerpt From Amicus Brief:

“SUMMARY OF ARGUMENT I.A. 22 U.S.C. § 6082(a)(4)(B) and (C) partially define the class of “United States national[s]” who may bring suit under Title III of the LIBERTAD Act. As a matter of grammar and statutory structure, the “United States national” referred to in 22 U.S.C. § 6082(a)(4)(B) and (C) is the plaintiff bringing suit. Other provisions of the statute define different classes of “United States nationals,” but there is nothing inconsistent about interpreting those provisions as identifying different classes of United States nationals for the different ends furthered by the provisions. B. Under its ordinary meaning, the undefined term “acquire[]” in 22 U.S.C. § 6082(a)(4)(B) includes inheritance. The qualification in 22 U.S.C. § 6082(a)(4)(C) that a United States national may not bring suit related to property expropriated after March 12, 1996, if the person “acquires ownership of a claim to the property by assignment for value” demonstrates that Congress qualified the ordinary meaning of “acquire[]” when it intended to do so. Because there is no federal law governing when a claim is acquired by an heir, state or foreign law determines the date on which a LIBERTAD plaintiff acquired his interest in the relevant property through inheritance. II. The President’s statutory authority to suspend the effective date of Title III or the right of action does not affect the class of individuals who may bring suit under the LIBERTAD Act. Congress gave the President suspension authority to afford the President flexibility to respond to unfolding developments in Cuba. But nothing in the statute suggests that the grant of the President’s suspension authority alters the class of individuals who may sue or that the President’s exercise of that authority expands the class beyond that specified by the statute. III. Travel to Cuba by persons subject to U.S. jurisdiction is highly restricted under federal law and is lawful only if the transactions related to such travel are authorized by OFAC’s Cuban Assets Control Regulations. The Libertad Act’s lawful travel exclusion implicitly points to that body of law. The phrase “lawful travel to Cuba,” 22 U.S.C. § 6023(13)(B)(iii), thus means travel that is permissible under OFAC regulations. And “transactions and uses of property” are “incident to lawful travel to Cuba, to the extent that such transactions and uses of property are necessary to the conduct of such travel,” id., if the transactions and uses of property are “ordinarily incident to a licensed transaction” involving travel to Cuba “and necessary to give effect thereto,” 31 C.F.R. § 515.421(a). Transactions related to travel to Cuba are lawful only if they are authorized by OFAC regulations at the time of the transaction, so the possibility that OFAC may change its regulations does not affect the lawful travel exclusion in the LIBERTAD Act. OFAC provides various resources to assist persons in determining the legality of activities involving travel to Cuba, including examples in its regulations, answers to frequently asked questions on the agency’s website, and a telephone hotline. The record in these cases is not sufficiently developed for the United States to opine on the application of the lawful travel exclusion to plaintiffs’ claims. However, it is not the burden of a plaintiff asserting claims under Title III to plead that transactions related to travel to Cuba were unlawful. The facts to establish that a transaction was incident to lawful travel to Cuba are uniquely in the possession of the person engaging in the transaction, and it is unlikely that any plaintiff could have a basis to allege that the conduct at issue did not fall within the lawful travel exclusion. Accordingly, the better interpretation of the statute is that a plaintiff bringing suit under Title III does not have an obligation to plead that challenged activity does not come within the lawful travel exclusion.”

Background

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). 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?”

“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  

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.  March 25, 2022

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

Even If The Four Cruise Lines Are Found Guilty Or Settle Libertad Act Lawsuits Filed Against Them, U.S. Government Could Still Seize Their Vessels. OFAC Has Five-Years From 2019.

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If The Four Cruise Lines Are Found Guilty Or Settle The Libertad Act Lawsuits Filed Against Them, Might Then The U.S. Government Have Claim Upon Their Vessels?   

Libertad Act Authorizes Asset Forfeiture. 

OFAC Has Five Years To Commence Enforcement Action- Cruises Ceased On 4 June 2019. 

What Would U.S. Government Do With 2,000-Passenger Vessel?  Need To Re-flag?  Jones Act Implications?  Cruise Lines May Have Sold Vessels Used For Cuba Voyages. 

Sounds Outlandish?…. Who Thought The Libertad Act Would Be Suspended For Twenty-Three Years?  That The First Defendants Would Be American Companies Rather Than Foreign Companies? 

Link: 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?

The Trump Administration on 2 May 2019 made operational Title III of the Cuban Liberty and Democratic Solidarity Act of 1996 (known as “Libertad Act”).  Title III authorizes lawsuits in United States District Courts against companies and individuals who are using a certified claim or non-certified claim where the owner of the certified claim or non-certified claim has not received compensation from the Republic of Cuba or from a third-party who is using (“trafficking”) the asset.  To date, forty-four (44) lawsuits have been filed.   

From Libertad Act: (d) Trading with the Enemy Act.-- (1) Civil penalties.--Subsection (b) of section 16 of the Trading with the Enemy Act (50 U.S.C. App. 16(b)), as added by Public Law 102- 484, is amended to read as follows: (b)(1) A civil penalty of not to exceed $50,000 may be imposed by the Secretary of the Treasury on any person who violates any license, order, rule, or regulation issued in compliance with the provisions of this Act.  (2) Any property, funds, securities, papers, or other articles or documents, or any vessel, together with its tackle, apparel, furniture, and equipment, that is the subject of a violation under paragraph (1) shall, at the direction of the Secretary of the Treasury, be forfeited to the United States Government.  (3) The penalties provided under this subsection may be imposed only on the record after opportunity for an agency hearing in accordance with sections 554 through 557 of title 5, United States Code, with the right to prehearing discovery.  (4) Judicial review of any penalty imposed under this subsection may be had to the extent provided in section 702 of title 5, United States Code. 

From Jones Act: “The Merchant Marine Act of 1920, known as the Jones Act, is a federal statute establishing support for the development and maintenance of a merchant marine in order to support commercial activity and serve as a naval auxiliary in times of war or national emergency (See 46 USC § 50101).  The statute, among other things, requires shipping between US ports to be conducted by US-flag ships. (46 USC § 50102.)  46 U.S. Code § 50101 - Objectives and policy: (a) Objectives.—It is necessary for the national defense and the development of the domestic and foreign commerce of the United States that the United States have a merchant marine— (1) sufficient to carry the waterborne domestic commerce and a substantial part of the waterborne export and import foreign commerce of the United States and to provide shipping service essential for maintaining the flow of the waterborne domestic and foreign commerce at all times; (2) capable of serving as a naval and military auxiliary in time of war or national emergency; (3) owned and operated as vessels of the United States by citizens of the United States; (4)  composed of the best-equipped, safest, and most suitable types of vessels constructed in the United States and manned with a trained and efficient citizen personnel; and (5) supplemented by efficient facilities for building and repairing vessels.  (b) Policy.— It is the policy of the United States to encourage and aid the development and maintenance of a merchant marine satisfying the objectives described in subsection (a).  (Pub. L. 109–304, § 8(b), Oct. 6, 2006, 120 Stat. 1556; Pub. L. 111–84, div. C, title XXXV, § 3511, Oct. 28, 2009, 123 Stat. 2722.)” 

From Office Of Foreign Assets Control (OFAC): Forfeiture of property used in a violation of the Cuban Assets Control Regulations (CACR) exists independently of the Libertad Act. 

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)

JAVIER GARCIA-BENGOCHEA V. CARNIVAL CORPORATION D/B/A/ CARNIVAL CRUISE LINE, A FOREIGN CORPORATION [1:19-cv-21725 Southern Florida District; 20-12960 11th Circuit Court of Appeals]
Colson Hicks Eidson, P.A. (plaintiff)
Margol & Margol, P.A. (plaintiff)
Creed & Gowdy (plaintiff- appellate)
Jones Walker (defendant)
Boies Schiller Flexner LLP (defendant)
Akerman (defendant)

JAVIER GARCIA-BENGOCHEA V. NORWEGIAN CRUISE LINE HOLDINGS, LTD. [1:19-cv-23593; Southern Florida District]
Colson Hicks Eidson, P.A. (plaintiff)
Margol & Margol, P.A. (plaintiff)
Creed & Gowdy, P.A. (plaintiff)
Hogan Lovells US LLP (defendant)

JAVIER GARCIA-BENGOCHEA VS. ROYAL CARIBBEAN CRUISES, LTD. [1:19-cv-23592; Southern Florida District; 20-14251 11th Circuit Court of Appeals]
Colson Hicks Eidson, P.A. (plaintiff)
Margol & Margol, P.A. (plaintiff)
Creed & Gowdy, P.A. (plaintiff)
Holland & Knight (defendant)

LINK To Libertad Act Lawsuit Filing Statistics

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

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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

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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)

09/19/2021 220 

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)

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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)