UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA 

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

SERVICE LAMP CORPORATION PROFIT 

SHARING PLAN, individually, and on behalf 

of all other persons and entities similarly situated,

Plaintiffs,

v. 

CARNIVAL CORPORATION, ARNOLD W. 

DONALD, AND DAVID BERNSTEIN,

Defendants.

Case No. 1:20-cv-22319-MGC 

JOHN P. ELMENSDORP, individually and 

on behalf of all others similarly situated,

Plaintiffs,

v. 

CARNIVAL CORPORATION, CARNIVAL PLC, 

ARNOLD W. DONALD, DAVID BERNSTEIN, 

and MICKY ARISON,

Defendants.

JOINT MOTION FOR ENTRY OF A STIPULATION WAIVING SERVICE OF 

PROCESS AND EXTENDING TIME TO RESPOND TO COMPLAINTS

WHEREAS, on May 27, 2020, plaintiff Service Lamp Corporation Profit Sharing 

Plan (“Service Lamp”) filed a putative securities class action complaint (the “Service Lamp 

Complaint”) against defendants Carnival Corporation, Arnold W. Donald, and David Bernstein; 

and 

WHEREAS, on June 3, 2020, plaintiff John P. Elmensdorp (“Elmensdorp,” and 

together with Service Lamp, “Plaintiffs”) filed a putative securities class action complaint (the 

Case 1:20-cv-22202-KMM Document 8 Entered on FLSD Docket 06/26/2020 Page 1 of 6
2 

“Elmensdorp Complaint,” and together with the Service Lamp Complaint, the “Initial 

Complaints”) against defendants Carnival Corporation, Carnival plc, Arnold W. Donald, David 

Bernstein, and Micky Arison (collectively, “Defendants”); and 

WHEREAS, the Initial Complaints each relate to the same alleged conduct, 

involve common questions of law and fact, and assert the same causes of action arising under the 

Securities Exchange Act of 1934, which is governed by the Private Securities Litigation Reform 

Act of 1995 (the “PSLRA”), 15 U.S.C. § 78u-4, et seq.; and 

WHEREAS, the PSLRA provides a procedure for the appointment by the Court of 

a lead plaintiff and lead counsel to represent the putative class pursuant to motion practice, for 

which opening briefs are to be filed on or before the statutory deadline of July 27, 2020. See 15 

U.S.C. § 78u-4(a)(3); 

WHEREAS, the PSLRA allows “any member of the purported class,” whether or 

not they previously filed a complaint, to move the Court to serve as lead plaintiff by the statutory 

deadline. See 15 U.S.C. § 78u-4(a)(3)(A)(i)(II); and 

WHEREAS, lead plaintiff and lead counsel will not be appointed until after the 

completion of briefing on any lead plaintiff motions, and accordingly it is unclear at this time who 

will ultimately have the authority to act on behalf of the putative class, and whether the courtappointed lead plaintiff will file an amended complaint, a consolidated complaint, or stand on one 

of the Initial Complaints filed herein; and 

WHEREAS, no party has previously requested or received time for an extension 

to answer or otherwise respond to the complaints in the above-captioned actions; and 

WHEREAS, in order to avoid unnecessary expense to the parties and unnecessary 

expenditure of time by the Court prior to the appointment of lead plaintiff and lead counsel and 

Case 1:20-cv-22202-KMM Document 8 Entered on FLSD Docket 06/26/2020 Page 2 of 6
3 

the filing of an amended complaint, a consolidated compliant, or the designation of an operative 

complaint, the parties have agreed, subject to the Court’s approval, to set a schedule for the filing 

of an amended or consolidated (or designation of an operative) complaint and Defendants’ 

responses thereto. 

IT IS HEREBY STIPULATED AND AGREED, by and between the 

undersigned counsel for Plaintiffs and Defendants, and subject to Court approval, that: 

1. The above-captioned related actions are consolidated for all purposes under 

the docket number of the lead case, 20-cv-22202-KMM. Filings in the consolidated action shall 

bear the caption In re Carnival Corp. Securities Litigation. 

2. Undersigned counsel for Defendants are authorized to accept, and hereby 

do accept, service of the Initial Complaints in these matters on behalf of Defendants, without 

prejudice and without waiver of any of Defendants’ defenses, objections, or arguments, except as 

to sufficiency of service of process. 

3. The parties are not required to meet and confer and file a joint scheduling 

report and joint proposed scheduling order until sixty (60) days after the Court appoints a lead 

plaintiff. Any orders requiring the parties to meet and confer and file a joint scheduling report and 

joint proposed scheduling order prior to that date are vacated. In the event Defendants move to 

dismiss the operative complaint, the parties may submit a stipulation further postponing the 

requirement that the parties meet and confer and file a joint scheduling report and joint proposed 

scheduling order until after the Court rules on Defendants’ motions. 

4. Defendants are not required to answer, move against, or otherwise respond 

to Plaintiffs’ Initial Complaints unless one is designated as the operative complaint by the Courtappointed lead plaintiff under the schedule below. 

Case 1:20-cv-22202-KMM Document 8 Entered on FLSD Docket 06/26/2020 Page 3 of 6
4 

5. The Court-appointed lead plaintiff shall have sixty (60) days after 

appointment to file an amended or consolidated complaint, or to designate one of the Initial 

Complaints as the operative complaint. 

6. Defendants shall answer, move against, or otherwise respond to the 

operative complaint within sixty (60) days after the Court-appointed lead plaintiff files an amended 

or consolidated complaint, or designates one of the Initial Complaints as the operative complaint. 

7. The Court-appointed lead plaintiff shall have forty-five (45) days to oppose 

any motions Defendants may file to dismiss the operative complaint. 

8. Defendants’ replies shall be due thirty (30) days after the filing of the Courtappointed lead plaintiff’s opposition papers. 

IT IS SO STIPULATED

Dated: Miami, Florida 

June 26, 2020 

NELSON MULLINS BROAD AND 

CASSEL 

/s/ Mark F. Raymond

Mark F. Raymond, Esq.

2 South Biscayne Blvd. 

One Biscayne Tower, 21st Floor 

Miami, FL 33131

Tel.: 305.373.9425

Fax: 305.995.6384

E-mail: mark.raymond@nelsonmullins.com

Case 1:20-cv-22202-KMM Document 8 Entered on FLSD Docket 06/26/2020 Page 4 of 6
5 

PAUL, WEISS, RIFKIND, 

 WHARTON & GARRISON LLP 

Richard A. Rosen 

(pro hac vice application forthcoming) 

Daniel S. Sinnreich 

(pro hac vice application forthcoming) 

1285 Avenue of the Americas 

New York, New York 10019 

Tel: (212) 373-3000 

Fax: (212) 757-3990 

Email: rrosen@paulweiss.com 

 dsinnreich@paulweiss.com 

Counsel for Defendants 

CARELLA, BYRNE, CECCHI, OLSTEIN, 

 BRODY & AGNELLO, P.C. 

/s/ Zachary S. Bower 

Florida Bar No. 17506 

zbower@carellabyrne.com 

Security Building 

117 NE 1st Avenue 

Miami, Florida 33132-2125 

Tel: (973) 994-1700 

Fax: (973) 994-1744 

KESSLER TOPAZ MELTZER 

 & CHECK, LLP 

Naumon A. Amjed 

Ryan T. Degnan 

280 King of Prussia Road 

Radnor, PA 19087 

namjed@ktmc.com 

rdegnan@ktmc.com 

Tel: (610) 667-7706 

Fax: (610) 667-7056 

Counsel for Plaintiff John P. Elmensdorp

Case 1:20-cv-22202-KMM Document 8 Entered on FLSD Docket 06/26/2020 Page 5 of 6
6 

SHEPHERD, FINKELMAN, MILLER & 

SHAH, LLP 

/s/ Jayne A. Goldstein 

Jayne A. Goldstein 

1625 N. Commerce Pkwy, Suite 320 

Fort Lauderdale, FL 33326 

(866) 849-7545 

Fax: (866) 300-7367 

jgoldstein@sfmslaw.com 

BARRACK, RODOS & BACINE 

Daniel E. Bacine 

Jeffrey A. Barrack 

3300 Two Commerce Square 

2001 Market Street 

Philadelphia, PA 19103 

(215) 963-0600 

Fax: (215) 96300838 

dbacine@barrack.com 

jbarrack@barrack.com 

POMERANTZ LLP 

James M LoPiano 

600 Third Avenue 

New York, NY 10016 

(212) 661-1100 

Fax: (917) 463-1044 

jlopiano@pomlaw.com 

Counsel for Plaintiff Service Lamp 

Corporation Profit Sharing Plan 

SO ORDERED, this ___ day of _____ , 2020. 

___________________________ 

United States District Court Judge 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFIY that a true and correct copy of the foregoing was served by 

Electronic Filing generated by the CM/ECF, on this 26th day of June, 2020, which will provide 

notification of filing to all counsel of record. 

By: /s/ Mark F. Raymond 

Mark F. Raymond, Esq. 

Case 1:20-cv-22202-KMM Document 8 Entered on FLSD Docket 06/26/2020 Page 6 of 6