HAMILTON, MILLER & BIRTHISEL, LLP

150 Southeast Second Avenue, Suite 1200, · Miami, Florida 33131 Telephone: 305-379-3686 · Facsimile: 305-379-3690

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,

v.

CELEBRITY CRUISES INC.,

Defendant.

___________________________________________/

DEFENDANT’S MOTION COMPEL ARBITRATION AND 

DISMISS PLAINTIFF’S COMPLAINT

Defendant CELEBRITY CRUISES, INC. (“Celebrity”), petitions the Court to enter an 

Order directing Plaintiff, Ryan Maunes Maglana (“Plaintiff”), to proceed to arbitration in 

accordance with the terms of the Employment Agreement he signed with Celebrity, and 

dismissing Plaintiff’s Complaint (ECF No. 4-1).

I. Preliminary Statement

Plaintiff executed the Sign-On Employment Agreement and the Philippine Overseas 

Employment Administration Contract of Employment. Those contracts, which govern the 

parties’ relationship, are subject to the United Nations Convention on the Recognition and 

Enforcement of Foreign Arbitral Awards (“the Convention”) and require the resolution of all 

disputes by arbitration in the Philippines under Philippine law. Accordingly, the Court should 

enter an Order directing Plaintiff to proceed to arbitration, as he agreed to do when he signed his 

employment contract, and dismissing the Complaint.

1

 

 1 Celebrity does not raise at this stage its other defenses, such as the class action waiver and 

Plaintiff’s failure to satisfy conditions precedent by attending a conciliation conference as required 

by the Employment Agreement and class action waiver.

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II. Statement of Facts

1. Plaintiff, a crewmember and citizen of the Philippines, filed an 8-count Class 

Action Complaint against Celebrity alleging systemic company-wide discriminatory treatment of 

Filipino employees. Specifically, Plaintiff’s Complaint against Celebrity asserts claims for 

(1) Preliminary Mandatory Injunction Requiring Repatriation of Defendant’s Filipino 

Crewmembers; (2) Intentional Tort of False Imprisonment; (3) Employment Discrimination on 

the Basis of National Origin; (4) Jones Act Negligence; (5) Unseaworthiness; (6) Failure To 

Provide Maintenance and Cure; (7) Failure to Provide Prompt, Proper & Adequate Medical Care; 

and (8) Wages and Penalties Pursuant to 46 U.S.C. §10313. 

2. Plaintiff’s claims are governed by the terms of his Employment Agreement with 

Celebrity which requires all disputes between Plaintiff and Celebrity to be resolved by binding 

arbitration in the Philippines and decided under Philippine law. See “Sign-on Employment 

Agreement” dated October 23, 2019; “Collective Bargaining Agreement” (“CBA”);

2 “Contract 

of Employment” dated October 18, 2019; and “POEA’s Standard Terms and Conditions 

Governing Filipino Seafarers,” attached as Exhibits “A” through “D” (collectively “Employment 

Agreement”). These records are maintained by Celebrity in the ordinary course of business. See 

Exhibit “E.” Each document will be addressed below individually. 

3. Plaintiff executed a “Sign-On Employment Agreement” (“SOEA Contract”), for 

employment onboard the Celebrity Millennium as a Beverage Controller, that sets forth the basic 

terms and conditions of employment, including salary and hours. The SOEA requires all 

grievances to be resolved by arbitration in the Philippines:

All grievances and any other dispute whatsoever, whether in contract, regulatory, 

statutory, common law, tort or otherwise relating to or in anyway connected with 

the Seafarers service for the Owners/Company under the present Agreement, 

including but not limited to claims for personal injury/disability or death, no matter 

how described, pleaded or styled, and whether asserted against the 

Owners/Company, Master, Employer, Ship Owner, vessel or vessel operator shall 

be referred to and resolved exclusively by mandatory arbitration pursuant to 

the United Nations Convention on the Recognition and Enforcement of 

Foreign Arbitral Awards (New York 1958), 21 U.S.T. 2517, 330 U.N.T.S., (“The 

Convention”), except as provided by any government mandated contract.

 2 Collective Agreement Between Celebrity Cruises Inc. and Federazione Italiana Trasporti-CISLITF International Dept.-Italy on Behalf of Itself and Associated Marine Officers’ and Seamen’s 

Union of the Philippines, effective July 1, 2017.

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. . . 

Jurisdiction and venue over disputes between Filipino Seafears and the 

Owners/Company shall be governed by the terms of the standard Philippines 

Overseas Employment Administration Contract of Employment (“POEA” 

Contract”) and the POEA Contract jurisdictional and venue terms shall supersede 

and take precedence over any conflicting terms set forth in this agreement. 

(emphasis added). 

See Exhibit “A” at ARBITRATION PROCEDURE, ¶¶ 1 and 4. 

4. The SOEA Contract further delegates to the arbitrator broad authority to resolve 

disputes:

The arbitrator, not any federal, state or local court or agency shall have the 

exclusive authority to resolve any dispute relating to the interpretation, 

applicability, enforceability or formation of this Agreement including, but not 

limited to any claim that all or any part of this agreement is void or voidable and as

to choice of law.

See Exhibit “A” at ARBITRATION PROCEDURE, ¶ 14. 

5. The SOEA incorporates the CBA. The CBA contains language identical to the 

arbitration provision in the SOEA requiring arbitration of all disputes whatsoever. See Exhibit 

“B” at Art. 33(1), (4).

6. Plaintiff also signed a contract with the Philippine Overseas Employment 

Administration (“POEA Contract”) for employment that sets forth the basic terms and conditions 

of employment and incorporates by reference the Governing Board Resolution No. 9 and the 

Memorandum Circular No. 10, both series 2010. Exhibit “C.” 

7. The POEA Contract specifically incorporates the POEA’s Standard Terms and

Conditions Governing the Employment of Filipino Seafarers On Board Ocean-Going Vessels 

(“POEA’s Standard Terms and Conditions”). See Exhibit “C” at ¶ 2. The POEA’s 

Memorandum Circular No. 10 requires the incorporation of and sets the minimum requirements 

for the POEA’s Standard Terms and Conditions. See Exhibit “D.”

8. The Standard Terms and Conditions require that the parties submit their claims 

and disputes to arbitration. See Exhibit “D” at § 29. The Standard Terms and Conditions also 

state that any dispute, claim or grievance shall be governed by the laws of the Republic of the 

Philippines, international conventions, treaties and covenants where the Philippines is a 

signatory. Id. at § 31. Such provisions are ordinarily enforced. Asignacion v. Rickmers Genoa 

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HAMILTON, MILLER & BIRTHISEL, LLP

150 Southeast Second Avenue, Suite 1200, · Miami, Florida 33131 · Telephone: 305-379-3686 · Facsimile: 305-379-3690

Schiffahrtsgesellschaft mbH & Cie KG, 783 F.3d 1010, 1015 (5th Cir.2015) cert. denied, –––

U.S. ––––, 136 S.Ct. 795, 193 L.Ed.2d 764 (2016)(“Applying Philippine law to a Filipino 

seaman in a Philippine arbitration, by itself, is not cause for setting aside the award even if 

American choice of law principles would lead to the application of another nations law.”) 

9. Plaintiff filed the instant class action suit notwithstanding his binding written 

agreement to arbitrate the dispute in the Philippines under Philippine law.

MEMORANDUM OF LAW

Plaintiff’s claims arise out of his employment with Celebrity and are subject to the terms 

of the Employment Agreement which mandate arbitration in the Philippines under Philippine 

law. By failing to submit his claims to arbitration as required by the Employment Agreement, 

Plaintiff is acting in direct contravention to the terms of the contracts he signed and the directives 

of his own country which has established the POEA to supervise, regulate, promote, and monitor 

overseas employment programs for the purpose of ensuring the best terms and conditions of 

employment for Filipino contract workers. Plaintiff is also acting in direct contravention to the 

terms of his contract with Celebrity. The Court should order Plaintiff to submit to arbitration in 

the Philippines under Philippine law pursuant to the terms of his Employment Agreement. 

A. Federal Law Favors Arbitration

Federal law strongly favors agreements to arbitrate, particularly in international 

commercial transactions. See Scherk v. Alberto-Culver Co., 417 U.S. 506 (1974). In Mitsubishi 

Motor Corp. v. Soler Chrysler-Plymouth, Inc., 473 U.S. 614 (1985), the Supreme Court held:

Concerns of international comity, respect for the capacities of foreign and 

transnational tribunals, and sensitivity to the need of the international commercial 

system for predictability in the resolution of disputes require that we enforce the 

parties’ agreement, even assuming that a contrary result would be forthcoming in 

a domestic context.

Id. at 629. In Lindo v. NCL (Bahamas), Ltd., 652 F.3d 1257, 1275 (11th Cir. 2011), the Eleventh 

Circuit held that there is ample precedent “in favor of freely-negotiated contractual choice of law 

and forum selection provisions, and this presumption applies with special force in the field of 

international commerce.” “Questions of arbitrability must be addressed with a healthy regard for 

the federal policy favoring arbitration ... and doubts concerning the scope of arbitrable issues 

should be resolved in favor of arbitration.” Adolfo v. Carnival Corp., Case No. 02-23672, 2003 

U.S. Dist. LEXIS 24143 (S.D. Fla. Mar. 17, 2003) (relying upon Mitsubishi Motors Corp. 473 

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150 Southeast Second Avenue, Suite 1200, · Miami, Florida 33131 · Telephone: 305-379-3686 · Facsimile: 305-379-3690

U.S. at 626). See also Bautista v. Star Cruises, 396 F.3d 1289, 1295 (11th Cir. 2005)(The

Convention Act “generally establishes a strong presumption in favor of arbitration of 

international commercial disputes.”)

B. The Convention Act

International arbitration agreements are subject to the Convention which provides that a 

court possessing jurisdiction under the Convention must direct that arbitration be held in 

accordance with the agreement at any place therein provided for, whether that place is within or 

outside the United States. 9 U.S.C. § 206. The SOEA, CBA, POEA Contract and the POEA 

Terms and Conditions also expressly state that the arbitration is to be held pursuant to the 

Convention.

In light of the strong policy favoring arbitration, courts conduct “a very limited inquiry” 

in deciding whether to compel arbitration pursuant to the Convention. Escobar v. Celebration 

Cruise Operator, Inc., 805 F.3d 1279, 1285 (11th Cir. 2015) citing Bautista v. Star Cruises, 396 

F.3d 1289 (11th Cir. 2005); Francisco v. Stolt Achievement MT, 293 F.3d 270, 272 (5th Cir. 

2002); Ledee v. Ceramiche Ragno, 684 F.2d 184 (1st Cir. 1982). Quite simply, “the Act leaves 

no place for the exercise of discretion by a district court, but instead mandates that district courts

shall direct the parties to proceed to arbitration on the issues as to which an arbitration agreement 

has been signed.” Sedco v. Petroleos Mexicanos Mexican National Oil Co., 767 F.2d 1140, 1147 

(5th Cir. 1985). 

The Court must order arbitration if the following four conditions are met: (1) there is an 

agreement in writing to arbitrate the dispute, (2) the agreement provides for arbitration in the 

territory of a Convention signatory, (3) the agreement arises out of a commercial legal 

relationship, and (4) a party to the agreement is not an American citizen. See Lindo, 652 F.3d 

1276 (citing Bautista, 396 F.3d at 1294-95). See also Francisco, 293 F.3d at 273; Polychronakis 

v. Celebrity Cruises, Inc., 2008 WL 5191104 (S.D. Fla. 2008); Doe v. Royal Caribbean Cruises, 

365 F. Supp. 2d 1259 (S.D. Fla. Mar. 18, 2005); aff’d, Doe v. Royal Caribbean Cruises, 180 Fed. 

Appx. 893 (11th Cir. May 18, 2006). Here, all four conditions are met; thus, arbitration must be 

compelled.

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150 Southeast Second Avenue, Suite 1200, · Miami, Florida 33131 · Telephone: 305-379-3686 · Facsimile: 305-379-3690

1. There is an Agreement in Writing to Arbitrate

The Employment Agreement governs the relationship of the parties and requires 

arbitration of all disputes. Specifically, the SOEA executed by Plaintiff and Celebrity and the 

CBA incorporated into the SOEA mandate arbitration of all disputes whatsoever:

All grievances and any other dispute whatsoever, whether in contract, regulatory,

statutory, common law, tort or otherwise relating to or in anyway connected with 

the Seafarers service for the Owners/Company under the present Agreement, 

including but not limited to claims for personal injury/disability or death, no matter 

how described, pleated or styled, and whether asserted against the 

Owners/Company, Master, Employer, Ship Owner, vessel or vessel operator shall 

be referred to and resolved exclusively by mandatory arbitration pursuant to 

the United Nations Convention on the Recognition and Enforcement of 

Foreign Arbitral Awards (New York 1958), 21 U.S.T. 2517, 330 U.N.T.S., (“The 

Convention”), except as provided by any government mandated contract.

. . . 

Jurisdiction and venue over disputes between Filipino Seafears and the 

Owners/ Company shall be governed by the terms of the standard Philippines 

Overseas Employment Administration Contract of Employment (“POEA” 

Contract”) and the POEA Contract jurisdictional and venue terms shall supersede 

and take precedence over any conflicting terms set forth in this agreement. 

(emphasis added). 

See Exhibit “A” at ARBITRATION PROCEDURE, ¶¶ 1 and 4, and Exhibit “B” at Art. 33(1), (4).

Plaintiff also signed the POEA Contract, which was verified and approved by a POEA 

officer the same day. See Exhibit “C.” Paragraph 2 of Plaintiff’s POEA Contract states that the 

terms and conditions of the contract are to be observed in accordance with Governing Board 

Resolution No. 9 and Memorandum Circular No. 10, promulgated by the Department of Labor 

and the POEA in 2010.3 Governing Board Resolution No. 9 and Memorandum Circular No. 10, 

in turn, incorporate the Standard Terms and Conditions Governing The Overseas Employment of 

Filipino Seafarers On-Board Ocean-Going Ships. See Exhibit “D.” In relevant part, Section 29 of 

the Standard Terms and Conditions, reads as follows:

In cases of claims and disputes arising from this employment, the parties covered 

by a collective bargaining agreement shall submit the claim or dispute to the 

 3 The POEA supervises, regulates, promotes, and monitors overseas employment programs for 

the purpose of ensuring the best terms and conditions of employment for Filipino contract 

workers. Bautista v. Star Cruises, 286 F. Supp. 2d 1352, 1356 (S.D. Fla. 2003). To further this 

purpose, the POEA periodically issues memorandum circulars setting minimum requirements or 

standards of compensation and other benefits for overseas Filipino workers, especially seafarers, 

to keep them on par with prevailing international standards. Id.

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original and exclusive jurisdiction of the voluntary arbitrator or panel of arbitrators. 

If the parties are not covered by a collective bargaining agreement, the parties may 

at their option submit the claim or dispute to either the original and exclusive 

jurisdiction of the National Labor Relations Commission (NLRC), pursuant to 

Republic Act of 1995 or to the original and exclusive jurisdiction of the voluntary 

arbitrator or panel or arbitrators. If there is no provision as to the voluntary 

arbitrators to be appointed by the parties, the same shall be appointed from the 

accredited voluntary arbitrators of the National Conciliation and Mediation Board 

of the Department of Labor and Employment.

(See Exhibit “D” at § 29). Thus, the POEA mandates the arbitration of Filipino seamen’s claims.

The foregoing shows that Plaintiff signed two contracts that include an arbitration 

provision; therefore, the first condition is satisfied.

2. The Agreement Provides for Arbitration in the Territory of a 

Convention Signatory

The Philippines is a full signatory to the United Nations Convention on the Recognition 

and Enforcement of Foreign Arbitral Awards through its ratification of The Convention. 

Therefore, the second condition is satisfied. See

http://www.newyorkconvention.org/list+of+contracting+states

3. The Agreement Arises Out of a Commercial Legal 

Relationship

The third condition is satisfied because the agreement to arbitrate arises from a 

commercial legal relationship. Federal courts have consistently found that employment contracts 

similar to Plaintiff’s constitute a commercial legal relationship for the purposes of compelling 

arbitration. See Francisco, 293 F.3d at 273. Courts in this District have found that crew member 

employment contract containing an arbitration provision satisfied the commercial legal 

relationship requirement for purposes of compelling arbitration. See Amon v. Norwegian Cruise 

Lines, Ltd., Case No. 02-21025-CIV-HUCK, 2002 WL 32851545, at *4 (S.D. Fla. Sep. 25, 2002) 

(order granting motion to compel arbitration). See also Bautista v. Star Cruises and Norwegian 

Cruise Line, Ltd., 286 F. Supp. 2d at 1365, aff’d, Bautista v. Star Cruises, 396 F.3d 1289 (11th 

Cir. 2005) (affirming order granting motion to compel arbitration). Each of these courts 

concluded that the contract of employment and agreement to arbitrate therein arose out of a 

commercial legal relationship. Further, language of the SOEA and POEA Contracts clearly 

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HAMILTON, MILLER & BIRTHISEL, LLP

150 Southeast Second Avenue, Suite 1200, · Miami, Florida 33131 · Telephone: 305-379-3686 · Facsimile: 305-379-3690

express their commercial nature. (See Exhibit “B”). Accordingly, Plaintiff’s employment 

agreements with Celebrity satisfy the third condition.

4. At Least One Party to the Agreement Is Not An American 

Citizen

Finally, the fourth condition is satisfied because Plaintiff is a citizen of the Philippines 

(Compl., ¶2). Moreover, Plaintiff was employed aboard a ship flagged under the laws of Malta.

C. The District Courts Have Enforced POEA Contracts Such As The 

Employment Agreement Plaintiff Signed. 

The Southern District of Florida has enforced POEA contracts incorporating the Standard 

Terms and Conditions requiring arbitration for the resolution of disputes. See Navarette v. 

Silversea Cruises Ltd., No. 14-CV-20593, 2014 U.S. Dist. LEXIS 183318 (S.D. Fla. 2014) aff’d

Navarette v. Silversea Cruises Ltd., 620 F. App'x 793, 794-95 (11th Cir. Aug. 5, 2015). In 

Navarette, the court held that the POEA contract similar to the one here which incorporated the 

same Standard Terms and Conditions satisfied the “written agreement” requirement of The 

Convention. Id. at *6-7. In Pagaduan, the court held that the seaman’s contract of employment 

incorporated by reference the POEA’s Standard Terms and Conditions and its arbitration 

provision as a matter of law, foreclosing any material factual dispute. Pagaduan v. Carnival 

Corp., No. 16-465, 709 Fed. Appx. 713, 715-16 (E.D.N.Y. Sept. 18, 2017). Pagaduan signed a 

contract that clearly and unambiguously described the incorporated industry-wide standard 

documents whose terms applied to the seafarer’s employment. Id. at 716-17. Thus, the 

arbitration provision in the Standard Terms and Conditions was enforced. Id. at 718.

Celebrity submits that upon the entry on an order directing the parties to arbitration this 

cause should be dismissed because there is no need for the Court to retain jurisdiction. Caley v. 

Gulfstream Aerospace Corp., 333 F. Supp. 2d 1367, 1379 (N.D.Ga. 2004), aff’d, 428 F.3d 1359 

(11th Cir. 2005). There is ample authority requiring the dismissal of the plaintiff’s complaint 

when all of the issues raised in the district court are subject to mandatory arbitration. Id.

CONCLUSION

For the reasons set forth herein, Defendant CELEBRITY CRUISES INC. respectfully 

moves this Court to enter an Order directing the parties to proceed to arbitration in the 

Philippines pursuant to the terms of his Contract of Employment, and dismissing this action. 

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

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HAMILTON, MILLER & BIRTHISEL, LLP

150 Southeast Second Avenue, Suite 1200, · Miami, Florida 33131 · Telephone: 305-379-3686 · Facsimile: 305-379-3690

Respectfully submitted,

/s/ Jerry D. Hamilton

Jerry D. Hamilton

Florida Bar No. 970700

jhamilton@hamiltonmillerlaw.com

Evan Gutwein

Florida Bar No. 58741

egutwein@hamiltonmillerlaw.com

Annalisa Gutierrez

Florida Bar No. 97940

agutierrez@hamiltonmillerlaw.com

Gilda M. Chavez

Florida Bar No. 973173

gchavez@hamiltonmillerlaw.com

HAMILTON, MILLER & BIRTHISEL, LLP

150 Southeast Second Avenue, Suite 1200 

Miami, Florida 33131-2332

Telephone: (305) 379-3686

Facsimile: (305) 379-3690

Attorneys for Defendant

Sanford L. Bohrer 

Florida Bar No. 160643

sbohrer@hklaw.com

Alex M. Gonzalez 

Florida Bar No. 0991200

alex.gonzalez@hklaw.com

Scott D. Ponce 

Florida Bar No. 0169528

sponce@hklaw.com

HOLLAND & KNIGHT LLP

701 Brickell Avenue, Suite 3300

Miami, Florida 33131

Telephone: 305- 374-8500

Facsimile: 305- 789-7799 

Attorneys for Defendant

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HAMILTON, MILLER & BIRTHISEL, LLP

150 Southeast Second Avenue, Suite 1200, · Miami, Florida 33131 · Telephone: 305-379-3686 · Facsimile: 305-379-3690

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on June 8, 2020, I electronically filed the foregoing document 

with the Clerk of the court using CM/ECF. I also certify that the foregoing document is being 

served this day on all counsel of record or pro se parties identified on the attached Service List in the 

manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or 

in some other authorized manner for those counsel or parties who are not authorized to receive 

electronically Notices of Electronic Filing.

/s/ Jerry D. Hamilton

 Jerry D. Hamilton

SERVICE LIST

Raul G. Delgado, II 

Florida Bar No. 094004 

raul@cruiselawyermiami.com 

Raulsr@cruiselawyermiami.com 

heidi@cruiselawyermiami.com 

filing@cruiselawyermiami.com 

Delgado Trial Attorneys 

10661 N. Kendall Drive, Suite 210 

Miami, Florida 33176 

Telephone No.: (305) 596-7911 

Cell: (305) 972-0817 

Facsimile: (305) 397-2654 

Toll Free: 1 (877) 372-0817 

Attorneys for Plaintiff

Jerry D. Hamilton

Florida Bar No. 970700

jhamilton@hamiltonmillerlaw.com 

Evan Gutwein

Florida Bar No. 58741

egutwein@hamiltonmillerlaw.com 

Annalisa Gutierrez

Florida Bar No. 97940

agutierrez@hamiltonmillerlaw.com

Gilda M. Chavez

Florida Bar No. 973173

gchavez@hamiltonmillerlaw.com

Hamilton, Miller & Birthisel, LLP

150 Southeast Second Avenue

Suite 1200 

Miami, Florida 33131

Telephone: (305) 379-3686

Facsimile: (305) 379-3690

Attorneys for Defendant

Sanford L. Bohrer 

Florida Bar No. 160643

sbohrer@hklaw.com

Alex M. Gonzalez 

Florida Bar No. 0991200

alex.gonzalez@hklaw.com

Scott D. Ponce 

Florida Bar No. 0169528

sponce@hklaw.com

HOLLAND & KNIGHT LLP

701 Brickell Avenue, Suite 3300

Miami, Florida 33131

Telephone: 305- 374-8500

Facsimile: 305- 789-7799 

Attorneys for Defendant

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