Cole v. Carnival Corporation

District Court, S.D. Florida·Decided September 11, 2023·No. 0:23-cv-60532·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 23-CV-60532-RAR

EUREKA COLE,

Plaintiff,

v.

CARNIVAL CORPORATION,

Defendant. _____________________________________________/

ORDER GRANTING MOTION FOR ISSUANCE OF LETTER ROGATORY THIS CAUSE comes before the Court upon Plaintiff’s Amended Motion for Issuance of Letters Rogatory to Obtain Testimony (“Motion”), [ECF No. 46]. Pursuant to the Hague Convention on the Taking of Evidence Abroad in Civil or Commercial Matters (the “Hague Convention”), 28 U.S.C. § 1781, and Federal Rule of Civil Procedure 28(b), Plaintiff seeks a Letter Rogatory from this Court requesting judicial assistance from the Colombian Ministry of Foreign Affairs, as the appropriate judicial authority of the Republic of Colombia, to obtain witness testimony from Dr. Juan Esteban Vanegas Gonzalez concerning his personal knowledge of the facts alleged in Plaintiff’s Complaint, [ECF No. 1]. For the following reasons, the Motion is GRANTED. BACKGROUND This case involves a negligence lawsuit stemming from injuries Plaintiff claims she sustained as a commercial passenger while aboard the Carnival Conquest, a cruise ship owned and operated by the Defendant. See generally Compl. Specifically, Plaintiff alleges she was injured when “a crew member of the Carnival Conquest negligently dropped a container while walking across the ship’s lido deck resulting in severe injuries to the Plaintiff.” Id. ¶ 4. According to the Plaintiff, documents produced during discovery indicate that Dr. Gonzalez, in his capacity as the Defendant’s onboard physician, treated Plaintiff for injuries allegedly sustained while aboard Defendant’s ship. Mot. at 2. Initially, Plaintiff sought to depose Dr. Gonzalez through the regular

civil discovery mechanism, but in email correspondence between the parties dated August 16, 2023, Defendant informed Plaintiff’s counsel that Dr. Gonzalez was no longer in Defendant’s employ. See [ECF No. 46-1] at 2. In the same email, Defendant also provided Plaintiff’s counsel with Dr. Gonzalez’s last known address in Medellin, Colombia. Id. In the instant Motion, Plaintiff now asks the Court—for the second time—to issue a Letter Rogatory (i.e., a Letter of Request) for international judicial assistance to compel Dr. Gonzalez to testify and produce documentary evidence related to Plaintiff’s claims. See Mot. at 1. On August 25, 2023, this Court denied Plaintiff’s first request for a Letter Rogatory concerning Dr. Gonzalez without prejudice. [ECF No. 45]. In relevant part, that Order directed Plaintiff to first determine “whether Dr. Gonzalez is a United States national or resident” and stated that “[s]hould Plaintiff

determine the Court cannot issue the requested subpoena because Dr. Gonzalez is not a United States resident or national, Plaintiff may renew her request for a letter rogatory.” Id. Accordingly, Plaintiff now renews her request, stating in support that Defendant has not provided the requested information concerning whether Dr. Gonzalez “is a resident or national of the United States. Nor can Plaintiff state with certainty that Dr. Gonzalez is a US resident or national.” Mot. at 1. Plaintiff also adduces in support of its renewed request the parties’ August 16, 2023 email correspondence in which the Defendant stated it had no objection to Plaintiff contacting Dr. Gonzalez nor to serving him with process to obtain his testimony. [ECF No. 46-1] at 1-2. LEGAL STANDARD A letter of request, also known as a letter rogatory, is a “document issued by one court to a foreign court, requesting that the foreign court (1) take evidence from a specific person within the foreign jurisdiction or serve process on an individual or corporation within the foreign

jurisdiction and (2) return the testimony or proof of service for use in a pending case.” Letter of Request, Black’s Law Dictionary (11th ed. 2019) (citing Fed. R. Civ. P. 28). Pursuant to the Hague Convention and federal law, United States courts may “request the competent authority of another Contracting State, by means of a [l]etter of [r]equest, to obtain evidence, or to perform some other judicial act.” Convention Adopted at the Eleventh Session of the Hague Conf. on Priv. Int’l L. Oct. 26, 1968, T.I.A.S. No. 7444 (Oct. 7, 1972),1 reprinted in 28 U.S.C § 1781; Fed. R. Civ. P. 28(b) (permitting federal courts to issue letters of request to foreign countries); Yellow Pages Photos, Inc. v. Ziplocal, LP, 795 F.3d 1255, 1273 (11th Cir. 2015) (letters of request “are the means by which a court in one country requests a court of another country to assist in the production of evidence located in the foreign country.”).

Private parties, including corporations and natural persons, may seek the issuance of letters rogatory for use in underlying lawsuits. Intel Corp. v. Advanced Micro Devices, Inc., 542 U.S. 241, 248 n.1 (2004) (“[A] letter rogatory is the request by a domestic court to a foreign court to take evidence from a certain witness.”); Roche Diagnostics Corp. v. Priority Healthcare Corp., No. 2:18-cv-01479-KOB-HNJ, 2019 WL 4687016, at *3 (N.D. Ala. June 6, 2019). Obtaining evidence includes deposing non-party witnesses in a foreign country. See Fed. R. Civ. P. 28(b) (providing that “[a] deposition may be taken in a foreign country . . . under a letter of request, whether or not captioned a ‘letter rogatory’”).

1 See https://wwwhcch.net/en/instruments/conventions/status-table/?cid=82 (listing both the United States and Colombia as Contracting Parties to the Convention as of 2012). Both the issuance and enforcement of letters rogatory “rest entirely upon the comity of courts toward each other . . . .” 22 C.F.R. § 92.54 (2020). Comity is “the recognition which one nation allows within its territory to the . . . acts of another nation, having due regard both to international duty and convenience, and to the . . . persons who are under the protection of its

laws.” Hilton v. Guyot, 159 U.S. 113, 163-64 (1895). In order to “authoriz[e] a formal judicial request to a foreign authority, the Court, in the spirit of comity between nations, must be satisfied that the proposed discovery sought from a non-party is relevant, not overbroad and proportional to the needs of the case.” Wight v. Bluman, No. 20-81688, 2021 WL 8999538, at *2 (S.D. Fla. May 6, 2021). When considering traditional notions of comity, the Supreme Court has reasoned that the court is “responsib[le] . . . to base its [comity] analysis on . . . five factors” when considering a discovery request abroad. See Societe Nationale Industrielle Aerospatiale v. United States Dist. Court for S. Dist., 482 U.S. 522, 544 (1987). The five factors are as follows: (1) the importance to the litigation of the documents or other information requested; (2) the degree of specificity of

Free access — add to your briefcase to read the full text and ask questions with AI

Cole v. Carnival Corporation, (S.D. Fla. 2023).

Cole v. Carnival Corporation (Cole v. Carnival Corporation) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Hilton v. Guyot
159 U.S. 113 (Supreme Court, 1895)
Intel Corp. v. Advanced Micro Devices, Inc.
542 U.S. 241 (Supreme Court, 2004)
Yellow Pages Photos, Inc. v. Yellow Pages Group, LLC
795 F.3d 1255 (Eleventh Circuit, 2015)