UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO.: 0:22-cv-61704-XXXX

 JURY TRIAL DEMANDED 

NADEJDA JASTRJEMBSKAIA and 

AURORA CRUISES AND TRAVEL, LLC, 

 

 Plaintiffs, 

v. 

INCRUISES, LLC and INGROUP 

INTERNATIONAL, LLC f/k/a and d/b/a 

INCRUISES INTERNATIONAL, LLC, 

 

 Defendants. 

_________________________________/ 

COMPLAINT 

 Plaintiffs, NADEJDA JASTRJEMBSKAI and AURORA CRUISES AND TRAVEL, 

LLC (collectively “Plaintiffs”), by and through the undersigned counsel, file this action for 

damages and injunctive relief against INCRUISES, LLC and INGROUP 

INTERNATIONAL, LLC, f/k/a INCRUISES INTERNATIONAL, LLC (collectively 

“Defendants” or “inCruises”). 

JURISDICTION AND VENUE 

1. Jurisdiction for this cause of action lies within this Court by virtue of 28 USC 

§ 1332(c)(1) because this is an action for damages in excess of $75,000 and the parties 

are diverse in citizenship. 

2. Plaintiff, NADEJDA JASTRJEMBSKAIA (“Nadia”),1 is an individual over the 

age of 18 and a resident of Port St. Lucie, Florida. 

1. The Russian spelling for Nadejda Jastrjembskai is Надежда 

Ястржембская (Nadezhda Yastrzhembskaia). Dr. Jastrjembskai received her 

international passport in 1991 when Russia used the French spelling for names (Nadejda 

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3. Plaintiff, AURORA CRUISES AND TRAVEL, LLC (“Aurora”) is a Florida 

Limited Liability Company headquartered in Port St. Lucie, Florida. 

4. INCRUISES, LLC (“inCruises LLC”) is a foreign limited liability company 

incorporated, organized, and formed in Delaware and has its headquarters and principal 

place of business in Puerto Rico. 

5. INGROUP INTERNATIONAL, LLC d/b/a and f/k/a INCRUISES 

INTERNATIONAL, LLC (“inCruises International”) is a foreign limited liability company 

incorporated, organized, and formed in Puerto Rico and has its headquarters and 

principal place of business in Puerto Rico. 

6. inCruises International rebranded in 2018 and registered under its new 

corporate name, inGroup International, LLC, in San Juan, Puerto Rico on September 6, 

2018, Register No. 415291. 

7. Venue is proper in the Southern District of Florida under 28 U.S.C. § 1391(c) 

because Defendants are registered with the Florida Division of Corporations to do 

business in Florida as foreign limited liability companies and have registered agents for 

service of process in Pembroke Pines and Plantation, Broward County, Florida. 

 

Jastrjembskaia). Dr. Jastrjembskai built her professional reputation using the French 

translation of her name. She thus continued using the French translation even after 

Russia started translating her name to English. (See Exhibit “A.”) See also 

https://www.akm.ru/eng/press/the-central-bank-of-the-russian-federation-officiallyrecognized-incruises-as-a-pyramid-scheme/ (spelling Nadia’s name, Nadezhda 

Yastrzhembskaya). 

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THE PARTIES 

I. Nadia and Aurora 

8. Nadia is the owner and managing director of Aurora, a travel agency 

specializing in high-end worldwide cruises. 

9. Nadia has spent decades working and developing a strong reputation as a 

travel industry expert. 

10. Nadia is certified by Cruise Line International Association (CLIA) as an Elite 

Cruise Counselor – CLIA’s highest rank. 

11. Nadia authored and published a book about cruises and regularly blogs 

about cruises. 

12. Among Plaintiffs’ clientele are the Russian-based cruise population and the 

Russian diaspora cruise population. 

13. Prior to 2020, Nadia’s reputation as an insightful and trustworthy cruise 

expert was celebrated by globetrotters worldwide. 

14. As an Elite travel counselor, philanthropist, and author, Nadia relies heavily 

on her reputation as a source of income. 

II. inCruises 

15. inCruises is a travel club that sells memberships for cruise trips with Seller 

of Travel registrations in California, Florida, and Washington under each state’s Seller of 

Travel regulations. 

16. inCruises solicits its “Members” to serve as “Partners” as its Sales Force to 

sell its travel club memberships and to recruit additional Members to become Partners 

and sell inCruise’s travel club memberships. 

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17. According to its “Independent Partner Agreement,” inCruises Partners are 

“independent contractors” and not employees of inCruises. 

18. In 2021, the Central Bank of the Russian Federation officially recognized 

InCruises as a “pyramid scheme” and included inCruises in its “List of companies with 

identified signs of illegal activity in the financial market.”2

GENERAL ALLEGATIONS 

19. On or about September 10, 2020, inCruises held a meeting with its some of 

its Partners and its executives, including CEO Michael Hutchinson. At the meeting, 

inCruises and the Partners in attendance agreed and conspired to publish false, 

misleading, or defamatory information about Nadia to other Partners and on social media 

sites as a part of a campaign to harm Nadia’s reputation and Plaintiffs’ business. 

20. inCruises and its conspiring Partners translated over 600 such statements 

into Russian and published them to Partners who then posted the statements on social 

media sites. See Exhibit A. 

21. Among the 600 statements that inCruises and/or its co-conspirators agreed 

to publish was a false claim that Nadia lied during an interview with a blogger about the 

nature of inCruises business by referring to inCruises as a “pyramid scheme.” 

22. inCruises and/or its co-conspirators also falsely published a false report that 

inCruises sued Nadia for defamation and recovered a judgment against Nadia.3 

2. ATOR Bulletin Nov. 18, 2021 The Central Bank of the Russian Federation 

officially recognized Incruises as a pyramid scheme (last visited Sept. 9, 2022). 

3. See e.g., Press Release dated Nov. 19, 2021 inCruises International 

clarifies statement made by the Central Bank of Russia (last visited Sept. 9, 2022). 

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23. inCruises’ campaign of denigration against Nadia was designed to destroy 

her business in the travel industry and to discredit her reputation as a travel expert by 

falsely portraying her as dishonest, incompetent, unreliable, and/or mentally and 

emotionally unstable. 

24. inCruises and its conspiring Partners published the statements about Nadia 

throughout the Russian cruise community and among the Russian diaspora in general. 

25. Plaintiffs received letters and questions by existing customers and referring 

agents about the statements. 

26. The publication of inCruises’ and its conspiring Partners’ social media posts 

caused Plaintiffs to lose business, revenue and clients and damaged the confidence of 

Plaintiffs’ customers and referring agents, many of whom no longer do business with 

Plaintiffs because of the conduct of inCruises and/or its conspiring Partners. 

27. inCruises and/or its conspiring Partners published false information about 

Nadia for the purpose of damaging her reputation and harming her business. 

28. The publication of the social media posts on Facebook and Instagram 

allowed the post to be easily forwarded and shared, thereby increasing the scope of the 

viewers of the statements and the magnitude of the harm and damages incurred by 

Plaintiffs. 

29. Defendants’ intentional and wrongful conduct actually and proximately 

caused damages to Plaintiffs, including but not limited to financial harm to Plaintiffs’ 

business, damage to Nadia’s personal and professional reputation, caused Nadia to 

suffer extreme emotional stress, mental anguish, embarrassment, and humiliation and 

exposed Plaintiffs to distrust, hatred, contempt, and ridicule, and impaired Nadia’s ability 

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to work the cruise community and her charitable work with the Ukrainian refugee 

population. 

30. The misconduct of Defendants and/or their employees, agents and/or coconspirators was intentional or grossly negligent in that: (1) they had actual knowledge of 

the wrongfulness of the conduct and the high probability that injury or damage to the 

claimant would result and, despite that knowledge, intentionally pursued that course of 

conduct, resulting in injury or damage; or (2) Defendant’s conduct was so reckless or 

wanting in care that it constituted a conscious disregard or indifference to the life, safety, 

or rights of persons exposed to such conduct. 

31. Defendants actively and knowingly participated in the conduct of their 

and/or their employees, agents and/or co-conspirators; Defendants’ officers, directors, or 

managers knowingly condoned, ratified, or consented to such conduct; or Defendants 

engaged in conduct that constituted gross negligence and that contributed to the loss, 

damages, or injury suffered by Plaintiffs. 

32. Plaintiffs have retained the law firm Hunker Appeals and have agreed to 

pay their attorneys a reasonable fee for their services in this action. 

COUNT I - DEFAMATION 

33. Plaintiffs re-allege paragraphs 1 through 30 of this Complaint as if set forth 

fully herein. 

34. Defendants and/or their co-conspirators knowingly, intentionally, willfully, or 

maliciously published statements about the Plaintiffs that Defendants knew to be false or 

otherwise published such statements with reckless disregard for their truth or falsity. 

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35. The false statements constitute defamation per se or general defamation as 

they substantially and falsely accuse the Plaintiffs of fraud, scams, or dishonesty, or 

combination of the foregoing. 

36. The false statements were not privileged, and Defendants and/or their coconspirators made the false statements to the public by posting the statements on 

Facebook and the Internet and knew that Defendants’ public statements about Plaintiffs 

would cause severe damage to the reputation, business opportunities, social 

relationships, and Nadia’s career. 

37. Defendants and/or their co-conspirators have made, and continue to make, 

these and similar false and defamatory statements regarding Plaintiff to third parties in an 

effort to harass, embarrass, and impugn Plaintiff and impact Plaintiffs life and well-being. 

38. Defendants’ and/or their co-conspirators’ defamatory statements have 

been, and are continuing to be, widely disseminated in blogs, podcasts, and otherwise 

published and posted on various websites on the Internet, causing Plaintiffs not only past 

and current harm, but perpetual harm. 

39. At the time of said publications, Defendants and/or their co-conspirators 

defamed Plaintiffs for their own personal gain and did so in bad faith and with ill will and 

malice. 

40. Alternatively, the defamatory statements constitute defamation by 

implication. 

41. Defendants and/or their co-conspirators, with no legal privilege to do so, 

maliciously, recklessly, in bad faith and in wanton disregard for the truth or falsity of the 

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implications juxtaposed a series of facts and/or omitted facts so as to imply a defamatory 

connection between them.

42. The statements falsely implied that the Plaintiffs engaged in scamming or 

acted with dishonesty and that Nadia was unstable and corrupt in her business cruise 

ship business practices.

COUNT II - UNFAIR TRADE PRACTICES 

43. Plaintiffs re-allege paragraphs 1 through 30 of this Complaint as if set forth 

fully herein. 

44. Defendants violated the Florida Deceptive and Unfair Trade Practices Act 

(FDUTPA) by engaging its Partners as part of a pyramid scheme to wage a social media 

campaign of publishing false and misleading information about Plaintiffs to harm Plaintiffs’ 

business and eliminate Plaintiffs as a competitor and a critic. 

45. Defendants’ conduct in the travel industry was in the course of trade or 

commerce as defined in FDUTPA.

46. Defendants’ conduct was a deceptive and unfair trade practice under the 

FDUTPA because it was designed to mislead the public, the cruise community, and 

Plaintiffs’ clients and business associates into believing false and negative statements 

about Plaintiffs’ business and Nadia’s character.

47. Plaintiffs suffered actual injury due to Defendant’s violation of in the Florida 

Deceptive and Unfair Trade Practices Act. 

48. Plaintiffs are entitled to recover reasonable attorney’s fees in this action 

because FDUTPA provides for recovery of attorney’s fees upon entry of a favorable final 

judgment. 

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COUNT III – CIVIL CONSPIRACY

49. Plaintiffs re-allege paragraphs 1 through 30 of this Complaint as if set forth 

fully herein. 

50. Defendants and their Partners conspired and agreed among themselves to 

wage a campaign of false or misleading social media posts and other publications to 

destroy Plaintiffs’ business and Nadia’s reputation. 

51. Pursuant to the conspiracy agreement and in furtherance of the conspiracy, 

Defendants and/or their Partners published over 600 false or misleading social media 

posts and other publications about Nadia to the public, the cruise community, and among 

the Russian diaspora including to Plaintiffs’ clients and business associates. 

52. Defendants and their conspiring Partners: (1) committed the tort of 

defamation; (2) engaged in deceptive or unfair trade practices; and/or (3) by force of 

numbers possessed a power of coercion by virtue of having acted in combination that an 

individual acting alone would not possess amounting to an actionable wrong and an 

independent tort. 

PRAYER FOR RELIEF 

Plaintiff seeks a judgment against the Defendants as follows: 

a. For compensatory and punitive damages in an amount to be proved 

at time of trial; 

b. For injunctive relief requiring Defendants to: (1) remove the 

statements about Plaintiffs, (2) issue retractions acknowledging and 

correcting their statements about Plaintiffs, and (3) prohibiting 

Defendants from continuing to engage in such conduct against the 

Plaintiffs; 

c. For recovery of attorneys’ fees and costs; and 

d. For such other and further relief as the Court deems just and 

equitable. 

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DEMAND FOR JURY TRIAL 

 Plaintiffs hereby demand a trial by jury on all issues so triable. 

Dated: September 10, 2022. 

Respectfully Submitted, 

/s/ Thomas L. Hunker 

Thomas L. Hunker, Esq. 

Florida Bar No. 38325 

Virginia A. Paxton, Esq. 

Florida Bar No. 1003907 

HUNKER APPEALS 

110 SE 6th St., Suite 2330 

Fort Lauderdale, FL 33301 

Phone: (877) 841-8808 

Fax: (954) 477-7313 

thomas.hunker@hunkerappeals.com 

ashley.paxton@hunkerappeals.com 

kristopher.cameron@hunkerappeals.com 

cyndy.wald@hunkerappeals.com 

carly.dawson@hunkerappeals.com 

Counsel for Plaintiff 

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