IN THE UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:22-CV-22853-BB

CHARLOTTE SMITH, 

Plaintiff, 

v.

CARNIVAL CORPORATION, 

Defendant.

________________________________________/

PLAINTIFF’S MOTION FOR LEAVE FOR HER COUNSEL TO APPEAR AT THE

DECEMBER 12, 2023, CALENDAR CALL BY REMOTE MEANS

Plaintiff, CHARLOTTE SMITH, by and through undersigned counsel, hereby files this 

Motion for Leave to Appear at the December 12, 2023, Calendar Call by remote means, and 

in support thereof, respectfully states as follows:

1. Pursuant to this Honorable Court’s Trial Order [DE 68], calendar call is scheduled to 

take place on December 12, 2023, at 1:45 PM.

2. However, Plaintiff, Charlotte Smith, as well as lead counsel Spencer Aronfeld, Esq., 

undersigned counsel Matthias Hayashi, Esq., and Abby Ivey, Esq., respectfully request

the Court’s permission to attend the December 12, 2023, calendar call by telephone, 

Zoom, or by any other remote means the Court deems suitable.

3. Plaintiff, Charlotte Smith, resides in Richmond, Texas, but would like to attend the 

calendar call, if possible, but it is not feasible, logistically, financially, or health wise, 

for her to have to fly to Miami, fly back, then fly to Miami again for trial.

4. Lead counsel Spencer Aronfeld, Esq., is presently outside of the country and is not 

scheduled to return until after the calendar call, but also wishes to attend, if possible.

Case 1:22-cv-22853-BB Document 81 Entered on FLSD Docket 12/06/2023 Page 1 of 3
5. Counsel for Plaintiff, Abby Ivey, Esq., resides in Gainesville, FL, and works remotely 

from there, and it would also not be logistically feasible, especially considering that 

she has multiple small children who need her care, for her to drive down to Miami for 

the calendar call, drive back up, then drive back down again for trial. She also wishes 

to attend, if possible.

6. Undersigned counsel, Matthias Hayashi, respectfully submits that it would be more 

logistically feasible for him to be allowed to appear remotely as well, as well as counsel 

for Defendant if they wish, rather than for the partis to have to expend additional time 

and resources on their attorneys attending in person.

7. The parties have conferred and have agreed that a remote appearance would be the best

means of allowing Ms. Smith to appear at the December 12, 2023, calendar call.

8. Pursuant to S.D. Fla. L. R. 7.1(a)(3), counsel for Plaintiff certifies that counsel for 

Plaintiff has conferred with counsel for Defendant regarding this motion and represents 

that the Defendant objects to the relief herein requested except it does not object to Ms. 

Smith appearing remotely.

WHEREFORE, Plaintiff, CHARLOTTE SMITH, respectfully requests entry of an order 

allowing counsel to attend the December 12, 2023, discovery hearing by telephone, zoom, or 

any other remote means the Court deems suitable.

Respectfully submitted,

/s/ Matthias Hayashi ____________ 

Spencer M. Aronfeld, Esq.

Florida Bar No. 905161

aronfeld@aronfeld.com 

Matthias M. Hayashi, Esq.

Florida Bar No. 905161

mhayashi@aronfeld.com

Abby Hernández Ivey, Esq.

Case 1:22-cv-22853-BB Document 81 Entered on FLSD Docket 12/06/2023 Page 2 of 3
Florida Bar No. 1002774

aivey@aronfeld.com

ARONFELD TRIAL LAWYERS

One Alhambra Plaza, Penthouse

Coral Gables, Florida 33134

P: (305) 441.0440

F: (305) 441.0198

Attorneys for Plaintiffs

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on December 12, 2023, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF. I also certify that the foregoing is being 

served upon all counsel of record or pro se parties via transmissions 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 receive electronically Notices of Electronic Filing.

/s/ Matthias Hayashi____________ 

Matthias Hayashi, Esq.

Case 1:22-cv-22853-BB Document 81 Entered on FLSD Docket 12/06/2023 Page 3 of 3