UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

IN RE CARNIVAL CORP. SECURITIES 

LITIGATION 

Case No. 1:20-cv-22202-KMM 

CLASS ACTION 

ABRAHAM ATACHBARIAN, individually 

and on behalf of all others similarly situated, 

Plaintiff, 

v. 

CARNIVAL CORPORATION, CARNIVAL 

PLC, ARNOLD W. DONALD, DAVID 

BERNSTEIN, and MICKY ARISON, 

Defendants. 

Case No. 1:20-cv-23011-RNS 

CLASS ACTION 

MOTION OF THE NEW ENGLAND CARPENTERS PENSION AND 

GUARANTEED ANNUITY FUNDS AND THE MASSACHUSETTS LABORERS’ 

PENSION AND ANNUITY FUNDS FOR APPOINTMENT AS LEAD PLAINTIFF, 

APPROVAL OF THEIR SELECTION OF COUNSEL, AND CONSOLIDATION 

OF RELATED ACTIONS 

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PLEASE TAKE NOTICE that, on a date and at a time designated by the Court, before the 

Honorable K. Michael Moore, at the United States District Court for the Southern District of 

Florida, Wilkie D. Ferguson, Jr. United States Courthouse, located at 400 North Miami Avenue, 

Room 13-1, Miami, Florida, the New England Carpenters Pension and Guaranteed Annuity Funds 

(“New England Carpenters”) and the Massachusetts Laborers’ Pension and Annuity Funds 

(“Massachusetts Laborers”) will respectfully move this Court, pursuant to Section 21D(a)(3)(B) 

of the Securities Exchange Act of 1934, 15 U.S.C. § 78u-4(a)(3)(B), as amended by the Private 

Securities Litigation Reform Act of 1995 (the “PSLRA”), for the entry of an Order: (i) appointing 

New England Carpenters and Massachusetts Laborers as Lead Plaintiff; (ii) approving their 

selection of Bernstein Litowitz Berger & Grossmann LLP (“Bernstein Litowitz”) and Kessler 

Topaz Meltzer & Check, LLP (“Kessler Topaz”) as Lead Counsel and Carella, Byrne, Cecchi, 

Olstein, Brody & Agnello, P.C. (“Carella Byrne”) as Liaison Counsel for the Class; (iii) 

consolidating all related securities class actions pursuant to Rule 42(a) of the Federal Rules of 

Civil Procedure (“Rule 42(a)”); and (iv) granting such other relief as the Court may deem just and 

proper. 

This Motion is made on the grounds that New England Carpenters and Massachusetts 

Laborers believe they are the “most adequate plaintiff” under the PSLRA and should therefore be 

appointed Lead Plaintiff. Specifically, New England Carpenters and Massachusetts Laborers 

believe that they have the “largest financial interest” in the relief sought by the Class in this action 

by virtue of, among other things, the approximately $5.7 million in losses that they incurred on 

their purchases of 206,149 shares of Carnival Corporation stock between September 26, 2019 and 

May 1, 2020. New England Carpenters and Massachusetts Laborers also believe that they 

otherwise satisfy the requirements of Rule 23 of the Federal Rules of Civil Procedure because their 

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claims are typical of other Class members’ claims and because they will fairly and adequately 

represent the interests of the Class. New England Carpenters and Massachusetts Laborers are a 

paradigmatic Lead Plaintiff under the PSLRA because they are sophisticated institutional investors 

with a substantial financial interest in the litigation and the proven ability to supervise and monitor 

counsel. 

This Motion is supported by the accompanying Memorandum of Law, the Declaration of 

Zachary S. Bower and the exhibits annexed thereto, the prior pleadings and other filings herein, 

and such other written or oral argument as may be permitted by the Court. 

WHEREFORE, New England Carpenters and Massachusetts Laborers respectfully request 

that the Court: (i) appoint New England Carpenters and Massachusetts Laborers as Lead Plaintiff; 

(ii) approve their selection of Bernstein Litowitz and Kessler Topaz as Lead Counsel and Carella 

Byrne as Liaison Counsel for the Class; (iii) consolidate all related securities class actions pursuant 

to Rule 42(a); and (iv) grant such other relief as the Court may deem just and proper. 

CERTIFICATE REGARDING GOOD FAITH CONFERENCE 

Pursuant to Local Civil Rule 7.1(a)(3), counsel for New England Carpenters and 

Massachusetts Laborers state that they were not able to confer with counsel for the opposing 

movants prior to filing the instant motion. The statutory framework of the PSLRA requires all 

motions seeking Lead Plaintiff appointment to be filed within 60 days of the publication of the 

notice of pendency of the action. See 15 U.S.C. § 78u-4(a)(3)(A)(i)(II). No such motions were 

filed meaningfully in advance of New England Carpenters’ and Massachusetts Laborers’ motion, 

and it was not possible to confer with counsel for the other movants to determine whether the 

instant motion would be opposed or to attempt to resolve the issues raised by the motion. 

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Dated: July 27, 2020 Respectfully submitted, 

/s/ Zachary S. Bower 

ZACHARY S. BOWER 

Florida Bar No. 17506 

CARELLA, BYRNE, CECCHI, OLSTEIN, 

BRODY & AGNELLO, P.C. 

Security Building 

117 NE 1st Avenue 

Miami, FL 33132-2125 

zbower@carellabyrne.com 

Tel: (973) 994-1700 

Fax: (973) 994-1744 

Liaison Counsel for Proposed Lead Plaintiff New 

England Carpenters and Massachusetts Laborers

and Proposed Liaison Counsel for the Class 

Hannah Ross 

Avi Josefson 

Michael D. Blatchley 

BERNSTEIN LITOWITZ BERGER 

 & GROSSMANN LLP

1251 Avenue of the Americas 

New York, NY 10020 

Tel: (212) 554-1400 

Fax: (212) 554-1444 

hannah@blbglaw.com 

avi@blbglaw.com 

michaelb@blbglaw.com 

Counsel for Proposed Lead Plaintiff New 

England Carpenters and Massachusetts 

Laborers and Proposed Lead Counsel for the 

Class

Naumon A. Amjed 

Darren J. Check 

Ryan T. Degnan 

KESSLER TOPAZ MELTZER 

 & CHECK, LLP

280 King of Prussia Road 

Radnor, PA 19087 

namjed@ktmc.com 

dcheck@ktmc.com 

rdegnan@ktmc.com 

Tel: (610) 667-7706

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Fax: (610) 667-7056

Counsel for Proposed Lead Plaintiff 

Massachusetts Laborers and Proposed Lead 

Counsel for the Class

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CERTIFICATE OF SERVICE 

I hereby certify that on July 27, 2020, I caused a true and correct copy of the foregoing to 

be filed with the Clerk of Court using the CM/ECF system, which will send electronic notification 

of such filing to all counsel of record. 

/s/ Zachary S. Bower 

ZACHARY S. BOWER 

Florida Bar No. 17506 

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