UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO.: 1: 20-CV-23287-DPG 

LUIS MANUEL RODRIGUEZ, et al., 

 Plaintiffs, 

 v. 

IMPERIAL BRANDS PLC, et al., 

 Defendants. 

DECLARATION OF MARTHA RIQUELME ARMENTEROS 

IN SUPPORT OF DEFENDANT CORPORACION HABANOS, S.A.’S 

MOTION TO DISMISS WITH PREJUDICE 

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

LUIS MANUEL RODRIGUEZ, et al.,

Plaintiffs, 

v.

IMPERIAL BRANDS PLC, et al., 

Defendants.

Case No.: 1:20-cv-23287-DPG

DECLARATION OF MARTHA RIQUELME ARMENTEROS

MARTHA RIQUELME ARMENTEROS declares under penalty of perjury under the laws 

of the United States of America that the following is true and correct:

1. My name is Martha Riquelme Armenteros, and I reside in Havana, Cuba. 

2. I have worked at the Empresa de Tabaco Torcido “José Martí” (the “Empresa”) 

from February 7, 2006 to the present. The Empresa is a commercial company in Cuba, founded 

on December 15, 1976, with its own legal personality, that produces hand-rolled Cuban cigars. 

There are numerous other companies that produce Cuban cigars.

3. From my work at the Empresa, I have knowledge of the matters set forth herein. I 

have been the head of the Puesto de Dirección at the Empresa since March 1, 2017. In my position

at the Empresa’s Puesto de Dirección, I obtain information concerning the Empresa’s production

and technical operations. From February 7, 2006 to March 1, 2017, I was the Jefa de Atención al 

Hombre at the Empresa. In that position, I attended to issues concerning all of the Empresa’s 

workers. 

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4. The Empresa discontinued any use of the factory building on Calle 23 between 

Calles 14 and 16 in Havana (the “Factory”) in January 2011 and moved all of its operations to 

another site because of the deterioration of the Factory’s physical condition. However, the 

Empresa continued to employ security guards to watch over the empty Factory from January 2011 

until February 2018, after which the Empresa no longer had any rights to the Factory. As part of 

my job responsibilities as Jefa de Atención al Hombre at the Empresa, I visited the security guards 

at the Factory at least once a week from January 2011 until February 2018. 

5. At no time from January 2011 until February 2018 were any operations concerning 

cigars carried on at the Factory, including the manufacture, processing, packaging, storing, 

transporting, shipping, distribution, purchase, marketing, advertising, publicizing, promotion or 

sale of cigars. 

6. The Factory remained in a state of physical deterioration at least until February 

2018, when I stopped visiting it, and no repairs of any significance had been undertaken in between 

January 2011 and February 2018 when I last visited the Factory.

7. The Empresa does not have, nor has it ever had, any operations or employees in the 

building next to and separate and apart from the Factory located on Calle 23 and the corner of 

Calle 16 in Havana.

Executed on: April 15, 2021

Havana, Cuba

By:

 Martha Riquelme Armenteros

[Signature]

Case 1:20-cv-23287-DPG Document 89-5 Entered on FLSD Docket 04/28/2021 Page 3 of 6
CERTIFICATE OF TRANSLATION

I, Nahum Hahn, am competent to translate from Spanish into English, and certify that the 

translation of the attached document, “Declaration of Martha Riquelme Armenteros”, is 

true and accurate to the best of my abilities.

April 24, 2021

Nahum Hahn

161 Gordonhurst Ave.

Montclair, NJ 07043

(917) 680-4699

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