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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 1:20-cv-21830-KMM

GABRIEL ANDRES CALDERON NUTT

as Parent and Natural Guardian of M.C. 

a Minor,

Plaintiff,

v.

ROYAL CARIBBEAN CRUISES LTD.,

Defendant.

_________________________________/

JOINT MOTION TO APPOINT GUARDIAN AD LITEM FOR PURPOSES OF AIDING 

IN THE PROCESS OF APPROVING SETTLEMENT OF A MINOR’S CLAIMS

The Plaintiff, GABRIEL ANDRES CALDERON NUTT, as Parent and Natural Guardian 

of M.C., a Minor, by and through undersigned counsel, hereby files this Motion to Appoint a 

Guardian ad Litem for purposes of aiding in the process of Approving a Settlement of a Minor 

jointly on behalf of ALL PARTIES, and state as follows:

1. All pending claims raised in this matter have been amicably settled among the parties.

2. The settlement involves claims on behalf of M.C., who is a minor.

3. Because the settlement involves the claims of a minor, it would be prudent to have a 

Guardian Ad Litem appointed to review the settlement and terms thereof. 

4. The parties hereby request the Court appoint a Guardian Ad Litem in order to ensure 

the minor child’s interest are protected. The Court appointed Guardian Ad Litem should review 

the settlement and reasonableness thereof and provide a written report and recommendation to 

this Court concerning the same. 

5. The parties hereby respectfully request that the Court appoint a Guardian Ad Litem 

who is willing to participate, on a pro bono basis if possible. 

WHEREFORE, the parties respectfully request this Court enter an Order appointing a 

Case 1:20-cv-21830-KMM Document 26 Entered on FLSD Docket 12/16/2020 Page 1 of 3
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Guardian Ad Litem in this matter.

CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1

Undersigned counsel certifies that he has conferred with counsel for Defendant, who advised 

that the Defendant agrees with the relief sought herein. 

Respectfully submitted,

LIPCON, MARGULIES, 

ALSINA & WINKLEMAN, P.A.

Attorneys for Plaintiffs

One Biscayne Tower, Suite 1776 

2 South Biscayne Boulevard

Miami, Florida 33131

Telephone No.: (305) 373-3016

Facsimile No.: (305) 373-6204

By: /s/ Jason R. Margulies

JASON R. MARGULIES

Florida Bar No. 57916

jmargulies@lipcon.com

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on December 16, 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 electronically receive Notices of Electronic Filing.

/s/ Jason R. Margulies

Jason R. Margulies, Esq.

Florida Bar No. 57916

jmargulies@lipcon.com

Andrew S. Freedman, Esq.

Florida Bar No. 091087

afreedman@lipcon.com

Daniel W. Grammes, Esq.

Florida Bar No. 1010507

dgrammes@lipcon.com

LIPCON, MARGULIES, 

ALSINA & WINKLEMAN, P.A.

One Biscayne Tower, Suite 1776

2 South Biscayne Boulevard 

Miami, Florida 33131

Telephone No.: (305) 373-3016

Facsimile No.: (305) 373-6204

Attorneys for the Plaintiff

/s/Bryan Probst

Bryan Probst, Esq.

Florida Bar No. 185485

rginsberg@rccl.com

ROYAL CARIBBEAN CRUISES LTD.

Tel.: (305) 539-6327

Fax: (305) 539-4457

Attorney for Defendant, ROYAL CARIBBEAN 

CRUISES LTD.

Case 1:20-cv-21830-KMM Document 26 Entered on FLSD Docket 12/16/2020 Page 3 of 3