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IN THE UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO.: 20-cv-23287-DPG

 

RODRIGUEZ, et al., ) 

 )

Plaintiffs, ) September 27, 2021

v. ) 

) 

IMPERIAL BRANDS PLC, et al., ) Pages 1 - 18

)

Defendants. ) 

______________________________/ 

DISCOVERY HEARING

BEFORE THE HONORABLE ALICIA M. OTAZO-REYES

UNITED STATES MAGISTRATE JUDGE

APPEARANCES:

Counsel on behalf of the Plaintiffs:

RODRIGUEZ TRAMONT & NUNEZ, P.A.

255 Alhambra Circle

Suite 1150,

Coral Gables, FL 33134

BY: FRANCISCO R. RODRIGUEZ, ESQ. 

BY: PAULINO A. NUNEZ, ESQ.

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APPEARANCES CONTINUED:

Counsel on behalf of the Plaintiffs:

BERENTHAL & ASSOCIATES, P.A.

777 Third Avenue

Suite 22D,

New York, NY 10017 

BY: JAMES L. BERENTHAL, ESQ.

BY: DAVID W. BERENTHAL, ESQ.

Counsel on behalf of Defendant Imperial Brands PLC:

NELSON MULLINS BROAD AND CASSEL

2 South Biscayne Boulevard

One Biscayne Tower, 21st Floor,

Miami, FL 33131 

BY: MARK F. RAYMOND, ESQ.

ALLEN AND OVERY, LLP.

1221 Avenue of the Americas

New York, NY 10020 

BY: ANDREW R. DAVIES, ESQ.

Counsel on behalf of Defendant Corporation Habanos:

RABINOWITZ, BOUDIN, STANDARD,

KRINSKY & LIEBERMAN, P.C.

320 West 85th Street

New York, NY 10024 

BY, MICHAEL R. KRINSKY, ESQ. 

Counsel on behalf of Defendant WPP PLC: 

WILMER CUTLER PICKERING HALE AND DORR LLP

1875 Pennsylvania Avenue, NW

Washington, DC 20006

BY: CHRISTOPHER DAVIES, ESQ.

Transcribed By:

BONNIE JOY LEWIS, R.P.R.

7001 SW 13 Street

Pembroke Pines, FL 33023

954-985-8875

caselawrptg@gmail.com

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(Thereupon, the following proceeding was held:) 

THE COURTROOM DEPUTY: The United States District 

Court is now in session. The Honorable Alicia M. Otazo-Reyes 

presiding. 

Calling the case of Rodriguez et al., versus Imperial 

Brands PLC, et al.; Case Number 20-cv-23287-Gayles. 

Counsel, please state your appearances for the record.

MR. RODRIGUEZ: Yes. On behalf of the Plaintiffs, 

Francisco R. Rodriguez and Paulino A. Nunez from the law firm 

of Rodriguez Tramont and Nunez.

MR. BERENTHAL: James Berenthal and David Berenthal 

co-counsel to Plaintiffs for the firm of Berenthal and 

Associates PC.

MR. RAYMOND: Good morning, Your Honor.

Mark Raymond, Nelson and Mullins, with my partner 

Jonathan Etra and our co-counsel Justin Ormand and Andrew Rhys 

Davies for Allen and Overy. 

Thank you.

MR. KRINSKY: Your Honor, Michael Krinsky, Rabinowitz, 

Boudin, Standard, Krinsky and Lieberman in New York. 

With me are Lindsey Frank and Nathan Yaffe, and our 

counsel and co-counsel in Florida, Charles Harris and Stephanie 

Lieb, for Corporation Habanos.

MR. DAVIES: Hello, Your Honor.

It's Chris Davies from Wilmer Hale on behalf of the 

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WPP Defendants. Also, on a call from Wilmer Hale, are Tico 

Almeida, Jessica Lutkenhaus and Ashley Leen. I believe both of 

our co-counsel are on as well; Naim Surgeon from Stroock and 

Pedro Freyre from Akerman. 

THE COURT: All right. Is that it? 

All right. So I set this matter for status 

conference. It was just referred to me recently and there are 

quite a few motions pending. There is also a request for 

jurisdictional discovery. 

There is also a statement of interest from the 

Government. I'm not quite sure if -- I don't think I heard the 

Government make an appearance. They are requesting that non 

constitutional issues be addressed first. 

So I wanted to kind of set up a roadmap for how we are 

going to proceed here. Let me first hear regarding the request 

for jurisdictional discovery because, obviously, that would 

effect how we proceed. 

MR. RODRIGUEZ: Yes, Your Honor.

THE COURT: Go ahead. Identify yourself and you are 

the movant. Go ahead.

MR. RODRIGUEZ: Yes. This is Frank R. Rodriguez. 

Your Honor, my office had contacted your office to 

determine if this was going to be a status conference where 

oral argument was going to be had. 

And we were told that this was a status conference 

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simply to set up, as Your Honor indicated, a roadmap and, you 

know, like a schedule. And I am not here today prepared to 

argue the merits of our motion seeking jurisdictional 

discovery. 

THE COURT: I'm sorry. Mr. Rodriguez, you must have 

misunderstood.

MR. RODRIGUEZ: Yes, I may have. 

THE COURT: The instructions given by my chambers were 

correct. I have no intention of entertaining argument. I have 

only set aside one hour. And unfortunately, due to traffic, I 

was a little bit late and my apologizes for that.

MR. RODRIGUEZ: Right. 

THE COURT: But, in any event, basically what I am 

looking for is for you to tell me exactly what it is that you 

are looking for. Do you want a delay in the proceeding with 

the motion? How much time are you looking for? 

And then, I will hear from whoever is opposing it. 

Your motion is Docket Entry 97, motion for jurisdictional 

discovery and to stay the time for Plaintiffs to respond to the 

motion to dismiss. 

So, obviously, that would impact on the sequence of 

events and that is why I asked you to please tell me what it is 

that you are looking nor.

MR. RODRIGUEZ: Yes, Your Honor. I am sorry. I did 

misunderstand. Excuse me.

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Judge, I think it makes sense that we resolve the 

motion for jurisdictional discovery initially. And then, 

address the motion to dismiss that are filed by the three 

individual groups of Defendants at a later date. 

There is a motion to dismiss that is a joint motion to 

dismiss. It may make sense to resolve that at some point in 

the near term, but I think sequentially what should occur is 

the Court respectfully should address the jurisdictional 

discovery motion and address our request for that discovery. 

I think that 40-45 minutes would be sufficient for 

that motion. And what we are looking for, at a minimum we are 

looking for the deposition of the affiants. There has been 

some -- the group of Defendants, the WPP Defendants, have filed 

a couple of affidavits in support of their motions to dismiss. 

We would be looking to depose those affiants and we 

would seek to take some written discovery. And perhaps, based 

on the jurisdictional discovery, seek to depose others. 

So when we've have laid out I think some timeframes in 

the motion, I think that there is a history of similar requests 

in a case that I am not sure that Your Honor was involved in, 

but I think Judge Gayles was involved in where there was I 

believe 90 days given to address.

In that case, the Court granted the motion for 

jurisdictional discovery and I believe awarded 90 days if I'm 

not mistaken. 

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THE COURT: All right. So let's see. I guess I 

should hear from Defense counsel, your position regarding this 

request for jurisdictional discovery hearing in 90-day period.

MR. DAVIES: Sure. Your Honor, this is Chris Davies 

from Wilbur Hale. I think we concur with the Plaintiffs that 

jurisdictional discovery should be resolved before the Court 

turns to the motions to dismiss. 

We believe that both judicial economy with respect to 

resolving the whole pending dispositive motions in a single 

timeframe and the pendency of certain appeals before the 

Eleventh Circuit that might effect the disposition of those 

motions invite some delay in addressing the dispositive motions 

while personal jurisdictional is being addressed. 

That said, as you will note in the papers that you 

received, we do not believe that jurisdictional discovery is 

necessary. Moreover, we believe that Plaintiffs' timing and 

their conduct over the course of the briefing today should 

disqualify them from seeking discovery on the jurisdictional 

questions. 

Then, with respect to the schedule and the scope of 

discovery, which of course is a matter we would prefer not to 

ever have to address, but if we do need to address it, we 

believe we have set forth in both a letter to the Plaintiffs 

and then, subsequently, our opposition to Plaintiffs' motion a 

more abbreviated schedule because unlike some of the other 

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cases with, which Your Honor is familiar, the scope and need 

for personal jurisdictional discovery here is much more limited 

and would, therefore, be much more cabined.

We, therefore, propose a much more abbreviated 

schedule. We think that also has the advantage of not imposing 

undue delay on the Court's ability to turn to the dispositive 

motions. 

But, in general, we would prefer a hearing on the 

jurisdictional discovery if possible, you know, within the week 

or two weeks. However long it takes Your Honor to get 

up-to-speed on the various papers in front of you. 

THE COURT: I'm sorry. You are saying you oppose 

jurisdictional discovery because of Plaintiffs' conduct? 

MR. DAVIES: Yes.

THE COURT: What do you mean by? 

MR. DAVIES: Sure. The Plaintiffs haven't done 

anything improper. Let me be clear. I don't mean to imply 

otherwise. 

THE COURT: Well, I'm glad you clarified that.

MR. DAVIES: Yes, I apologize. 

As we set out in our papers there is precedent for 

denying jurisdictional discovery when Plaintiffs are dilatory 

in seeking it and we believe they have been dilatory in this 

instance. 

Plaintiffs, of course, do not agree with our 

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characterization. But we think that, coupled with some of the 

other arguments we set out in our papers, are sufficient 

grounds for the Court to deny jurisdictional discovery at the 

outset before ever turning to the timing for that discovery. 

THE COURT: So you are saying in your opinion because 

they took too long to ask for jurisdictional discovery they are 

not entitled to it? That is your argument? 

MR. DAVIES: Well, I think that there is more nuance 

to it than that. They actually went so far as to file an 

amended complaint after they were already aware of affidavits 

that challenge personal jurisdiction. 

And rather than seek jurisdictional discovery at that 

juncture, which they had already begun to discuss with us, they 

instead simply filed an amended complaint that did nothing to 

cure the deficiencies with respect to personal jurisdiction 

that were present in their original complaint. There is 

precedent in this Court for denying jurisdictional discovery 

under those circumstances. 

THE COURT: That is an interesting approach.

All right. Okay. So assuming they do get 

jurisdictional discovery, which was your second argument, you 

are opposing the 90 days?

MR. DAVIES: We are. We don't believe it is 

necessary. As Plaintiff indicated, there are two affiants. 

There is a very, very narrow and circumscribed question, which 

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is the extent to which anything having to do with this case at 

all was conducted in the United States or by any U.S. entity 

subject to the jurisdiction of the Court. That can be resolved 

quite swiftly.

And the idea that they would need 90 days to take two 

very short depositions and receive whatever material they need 

to demonstrate, as we have indicated in the affidavit, that the 

services in question were provided by a Spanish national who 

was working for a Spanish entity just isn't plausible. 

THE COURT: All right. So what period of time do you 

think is necessary to conduct these two, in your words, very 

quick depositions? 

MR. DAVIES: We believe that those depositions should 

each be a half day or less. We believe that all of the 

discovery issues could be resolve within a month. 

THE COURT: So 30 days as opposed to 90 days?

MR. DAVIES: That's right. 

THE COURT: All right. Anyone else from the 

Defendants' side have any comments regarding the request for 

jurisdictional discovery? 

MR. A. DAVIES: Your Honor, this is Andrew Rhys Davies 

for Imperial Brands. 

Imperial Brands' motion to dismiss is fully briefed, 

including its motion on personal jurisdiction grounds, but 

there is no request for jurisdictional discovery from Imperial.

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That said, we share the view of the WPP Defendants 

that there is a deficiency in resolving the jurisdictional 

discovery issue as to them first so that all of the motions to 

dismiss can be resolved together. 

THE COURT: All right. 

MR. KRINSKY: Your Honor, this is Michael Krinsky on 

behalf of Corporation Habanos.

Like Imperial, there has been no demand for discovery 

from us and we think our motion, like Imperial's, is ready to 

go and to be heard by Your Honor. In the (inaudible) we argue 

venue and process. 

And you know, we think that they should be heard now. 

It is all ready to go and the Plaintiff has not argued their 

need for discovery, that the discovery that they seek from YNR 

and BCW is needed to resolve our motion. So we think it can be 

heard now and it makes sense to address the issues we raise. 

THE COURT: I see. So you have to be first in line 

and have your matter heard ahead of everybody else's? 

MR. KRINSKY: Well, it's up to Your Honor, but we see 

no reason for delay to have our motion heard given the fact 

they haven't (inaudible) discovery from us. 

THE COURT: It sounds like that is what you are asking 

for; put you ahead of the line, take care of your stuff, and 

the other people can wait behind you. 

Would that be a fair assessment? 

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MR. KRINSKY: That would be all right with us, Your 

Honor. I think it is a nuanced question about how Your Honor 

thinks is the most efficient way of dealing with the issues in 

the case. 

THE COURT: All right. Okay. Let me hear from Mr. 

Rodriguez on the issue of -- let me just say I am not persuaded 

that the jurisdictional discovery should be denied just on the 

fact that they went ahead and filed their amended complaint. 

You can address, Mr. Rodriguez, if you would like just 

for the record, your reasons for doing that. And let me also 

hear regarding the proposal that the jurisdictional discovery 

be limited to 30 days because all you need is two quick 

depositions.

MR. RODRIGUEZ: Yes, Your Honor.

First on the issue of the dilatory nature as alleged 

by Defendants, what happened is we filed a complaint. 

Defendants filed motions to dismiss. We saw that there may 

have been some merit on their motion to dismiss. So we amended 

the complaint and we didn't seek jurisdictional discovery at 

the time because we were waiting for their response to the 

amended complaint to see if they would change their positions. 

And in fact, they did on a nuanced basis. And we 

thought it would make perfect sense to wait until we saw their, 

what we anticipated, would be the new motion to dismiss with 

new affidavits for seeking jurisdictional discovery. We do not 

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think at all that we have been dilatory. Anyway, that's all I 

have to say there. 

With regard to the 90 days, I think 90 days is a very 

reasonable amount of time. Thirty days is too compact of a 

schedule. There are the two affiants that we seek to depose. 

I think there may be others that we want to depose. We need to 

take some written discovery to get a sense and get some detail 

as to who the persons that have been either mentioned or 

alluded to in the affidavits that were filed by these affiants. 

Obviously this is a critical point and jurisdiction is 

where the rubber meets the road in this case. And we think we 

should have an opportunity to take some discovery. And 90 days 

is not too long a period of time and we think that is what 

makes sense in this case. 

THE COURT: All right. Does anyone else have any 

further comments on the question of jurisdictional discovery? 

All right. Hearing no response I will, as I said 

grant the motion for jurisdictional discovery. However, I will 

only allow 60 days. 

And Mr. Rodriguez, I will hold you very strictly to 

that timeframe. I anticipate that the parties will cooperate 

in expediting this matter and not engage in any delays in terms 

of making the affiants available for deposition. Now that we 

do things by Zoom, travel and so on is cut down. So it should 

be doable in 60 days. 

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I will consider the request of the -- let me see. The 

counsel for Habanos that you want me to go ahead and address 

your matter ahead of everybody else because it is independent. 

Did I get that right, Defendant? 

MR. KRINSKY: Yes, Your Honor. 

THE COURT: I will consider that once I review more 

closely the motions because there is no point in holding off 

the hearing on your motion. I will go ahead and schedule it as 

soon as my calendar permits. 

I can't promise it, but if there is no overlap of 

issues, no point in having 20 people appear at a Zoom hearing 

on that if nobody else is needed, or at least we could have a 

bunch of observers, but not participants. 

So I will consider that. The other party, Imperial, 

says that they were okay with holding off until the 

jurisdictional discovery was done, but let me clarify. 

Were you doing that more out of courtesy and judicial 

economy or is there some issue that you believe would be a 

better approach to hold off on your motion? And I am 

addressing (inaudible).

MR. A. DAVIES: Thank you, Your Honor. This is Andrew 

Rhys Davies again. 

Yes, certainly it was judicial economy. And you know, 

we are all making motions to dismiss for lack of personal 

jurisdiction. There are no factual questions and no factual 

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discovery has been sought from Imperial. But, you know, 

obviously, it is the same broad standard that is applicable. 

The other thing that I would just draw to Your Honor's 

attention, if I could, is that a week from today the Eleventh 

Circuit is hearing argument on three of these (inaudible) 

cases. And it is possible that the Eleventh Circuit's ruling 

could shed some light on some of the issues that have to be 

adjudicated on these pending motions to dismiss. 

So that really was why we said that although there is 

no request for jurisdictional discovery from Imperial, it 

struck us that it would make sense to hold the motions to 

dismiss and decide them altogether. 

THE COURT: All right. Thank you. 

Let me hear from Habanos counsel. What is your 

position regarding the Eleventh Circuit pending matters? Is it 

your position that that has no effect whatsoever on your 

motion? 

MR. KRINSKY: I'm sorry, Your Honor. Were you 

addressing Corporation Habanos? 

THE COURT: Well, I said Habanos because that is the 

proper pronunciation.

MR. KRINSKY: No, we agree with Imperial that the 

Eleventh Circuit's decision may very well be dispositive. 

THE COURT: No use in rushing you.

MR. KRINSKY: There is good reason to wait for the 

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Eleventh Circuit, Your Honor -- 

THE COURT: Okay.

MR. KRINSKY: -- if that's your inclination for sure. 

THE COURT: No. I'm looking for your opinions at this 

point in time. I have not expressed my inclination yet.

MR. KRINSKY: Yes. Well, we think our motion is ready 

and we are relying on two District Court decisions that the 

Eleventh Circuit will hear appeals from. So we think that we 

are ready for Your Honor to address the issue. 

THE COURT: But for clarity, the Eleventh Circuit 

decision, or I guess they are just having a hearing. That does 

not mean the decision is coming right away.

But the Eleventh Circuit addressing officials does or 

does not impact your motion? I guess that is the clarity I'm 

seeking.

MR. KRINSKY: It does impact the motion, Your Honor, 

yes. 

THE COURT: Okay. For the moment, then, I will only 

ask the 60-day jurisdictional discovery. And then, depending 

on how my schedule looks, I may just go ahead and set the 

motions for hearing after that period. 

Again, a lot of it depends on how my schedule is 

looking and especially we are at the beginning of October. And 

Christmas, as you know, usually is the time that it is 

difficult to schedule things. 

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So I will look on my schedule. I will consider a time 

when I can set the matter for hearing. I will keep in mind, 

number one, the 60-day jurisdictional discovery period. Number 

two, the matters pending before the Eleventh Circuit. I will 

take both of those matters into consideration when coming up 

with a schedule. 

I will do the hearing still by Zoom because we are not 

quite ready to do in-person hearings here just yet. Zoom seems 

to work well with the sharing of screens. There is no problem 

with showing exhibits and things like that. If we need for it 

to be evidentiary, then, of course, people can just as easily 

testify. 

So that is the plan going forward; 60 days for 

jurisdictional discovery. Mr. Rodriguez, again, remember, I am 

going to hold you to that timeframe and you will receive an 

order scheduling the motion for hearing. 

Anything else that I can do for you at this time? 

MR. A. DAVIES: Your Honor, this is Andrew Rhys 

Davies.

Could I ask for just clarification of the paperless 

order of referral to Your Honor? 

THE COURT: Yes.

MR. A. DAVIES: There are several motions. One of 

which is non dispositive, of course, the discovery motions, and 

the rest are motions to dismiss and obviously by their nature 

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are dispositive. 

THE COURT: I did notice that. 

I would not do something outside of the scope of my 

authority under 28 USC 636. So I did notice that it did say 

for an order. Generally, on motions to dismiss, I do reports 

and recommendations and that is basically what the rules and 

the statute call for. 

Obviously, the jurisdictional discovery motion is non 

dispositive and I have moved on that.

MR. A. DAVIS: Thank you for that clarification, Your 

Honor. 

THE COURT: Of course. Anything else? 

MR. RODRIGUEZ: No. Responding to your question, 

Judge, Plaintiffs have nothing else. Thank you very much for 

your time. 

THE COURT: Thank you very much. Good luck to you 

all.

MR. KRINSKY: Have a good week, Your Honor. 

(Thereupon, the proceedings concluded.)

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CERTIFICATE

I hereby certify that the foregoing transcript is an 

accurate transcript of the audio recorded proceedings in the 

above-entitled matter. 

 

10/18/21 Bonnie Joy Lewis, 

 Registered Professional Reporter

 CASE LAW REPORTING, INC.

 7001 Southwest 13 Street,

 Pembroke Pines, Florida 33023

 954-985-8875

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