Delgado Trial Attorneys • 10661 N. Kendall Drive, Suite 210 • Miami, FL 33176

(305) 596-7911 • (305) 927-3678 • Toll Free (877) 372-0817 • Fax (305) 397-2654 

www.CruiseLawyerMiami.com

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION

CASE NO.: 1:20-cv-22133-JEM

RYAN MAUNES MAGLANA, on 

his own behalf and as a class 

representative of all other similarly 

situated Filipino crewmembers 

trapped aboard CELEBRITY cruise 

vessels,

Plaintiffs,

CLASS ACTION & 

v DEMAND FOR

JURY TRIAL

CELEBRITY CRUISES INC.,

Defendant.

______________________________/

PLAINTIFFS MOTION FOR A PRELIMINARY MANDATORY INJUNCTION

COMPELLING DEFENDANT TO REPATRIATE ITS FILIPINO CREWMEMBERS 

Plaintiff, RYAN MAUNES MAGLANA, on his own behalf and on behalf of all 

other similarly situated Filipino crewmembers trapped onboard CELEBRITY cruise 

vessels (hereinafter “PLAINTIFFS”) through undersigned counsel and pursuant to 

Federal Rules of Civil Procedure 23 and 65, hereby move the Court to set a hearing on 

their Emergency Motion for a Preliminary Injunction for Hearing, and in support thereof, 

would state:

1. On May 21st, 2020, Plaintiffs filed their VERIFIED COMPLAINT FOR 

EMEREGENCY INJUNCTIVE RELIEF & DAMAGES alleging that Plaintiffs are entitled 

Case 1:20-cv-22133-JEM Document 7 Entered on FLSD Docket 05/26/2020 Page 1 of 4
MAGLANA V. CELEBRITY CRUISE INC.

CASE NO.: 1:20-cv-22133-JEM

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Delgado Trial Attorneys • 10661 N. Kendall Drive, Suite 210 • Miami, FL 33176

(305) 596-7911 • (305) 927-3678 • Toll Free (877) 372-0817 • Fax (305) 397-2654 

www.CruiseLawyerMiami.com

to relief from this Court for violations of their collective rights under Title VII of the Civil 

Rights Act of 1964 ("Title VII"), 42 U.S.C. § 2000e et seq., including but not limited 

to their right to not be discriminated against by their employer on the basis of 

their national identity, in addition to their rights as seafarers’ under the General 

Maritime Law of the United States, the Jones Act 46 U.S.C. § 30104, and 46 U.S.C. § 10313.

2. Plaintiffs seek a preliminary injunction requiring Defendants, their officers, 

employees, and agents, all persons acting in active concert or participation with 

Defendants, or under Defendants’ supervision, direction, or control, and all other persons 

within the scope of Federal Rule of Civil Procedure 65, to repatriate the approximate 1700 

Filipino seafarers that are being held captive aboard the ships in Defendant’s fleet, 

provide them with back pay wages that were not paid despite Defendant’s failure to 

repatriate them in accordance with its obligations under US and International maritime 

law. 

3. Federal Rule of Civil Procedure 65 provides for the issuance of a 

preliminary injunction under circumstances such as those that exist in the present case.

4. In support of this motion, Plaintiff submits a Memorandum of Law, 

addressing all necessary elements for the entry of a preliminary injunction and 

preliminary injunction.

5. Plaintiff’s Verified Complaint seeks emergency injunctive relief because the

longer Plaintiffs’ are collectively held against their will by Defendant in violation of the 

Plaintiffs’ right to repatriation has and will continue to cause Plaintiffs’ irreparable harm 

Case 1:20-cv-22133-JEM Document 7 Entered on FLSD Docket 05/26/2020 Page 2 of 4
MAGLANA V. CELEBRITY CRUISE INC.

CASE NO.: 1:20-cv-22133-JEM

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Delgado Trial Attorneys • 10661 N. Kendall Drive, Suite 210 • Miami, FL 33176

(305) 596-7911 • (305) 927-3678 • Toll Free (877) 372-0817 • Fax (305) 397-2654 

www.CruiseLawyerMiami.com

including the risk of suicide and emotional distress caused by Defendant’s intentional 

actions. 

6. Plaintiff seeks leave to present 30 minutes of oral argument in support of 

this motion pursuant to Local Civil Rule 7.1(b). 

WHEREFORE, for the foregoing reasons, and for those set forth in Plaintiff's 

supporting Memorandum of Law and the Declarations of Plaintiff RYAN MAUNES 

MAGLANA on his own behalf and on behalf of all similarly situated Filipino seafarers in 

CELEBRITY’S fleet in their VERIFIED COMPLAINT, Plaintiffs respectfully moves that 

the Court enter a preliminary injunction requiring Defendants, their officers, employees, 

and agents, all persons acting in active concert or participation with Defendants, or under 

Defendants' supervision, direction, or control, and all other persons within the scope of 

Federal Rule of Civil Procedure 65, to repatriate the approximately 1700 Filipino seafarers 

that are being held captive aboard the ships in Defendant’s fleet in addition to providing

them with back-pay wages that were not paid despite Defendant’s failure to repatriate 

them in accordance with its obligations under US and International maritime law and all 

other equitable relief or otherwise this Court deems fair and just.

Dated: May 25, 2020

BY: ________________________

RAUL G. DELGADO II, ESQ.

Florida Bar No. 094004 

raul@cruiselawyermiami.com

Raulsr@cruiselawyermiami.com

heidi@cruiselawyermiami.com

filing@cruiselawyermiami.com

DELGADO TRIAL ATTORNEYS

Case 1:20-cv-22133-JEM Document 7 Entered on FLSD Docket 05/26/2020 Page 3 of 4
MAGLANA V. CELEBRITY CRUISE INC.

CASE NO.: 1:20-cv-22133-JEM

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Delgado Trial Attorneys • 10661 N. Kendall Drive, Suite 210 • Miami, FL 33176

(305) 596-7911 • (305) 927-3678 • Toll Free (877) 372-0817 • Fax (305) 397-2654 

www.CruiseLawyerMiami.com

Attorneys for Plaintiff

10661 N. Kendall Drive, Suite 210 

Miami, FL 33176

Ph: (305) 596-7911

Cell: (305) 972-0817

Fax: (305) 397-2654

Toll Free: 1(877) 372-0817

Case 1:20-cv-22133-JEM Document 7 Entered on FLSD Docket 05/26/2020 Page 4 of 4