THE NEXT PHASE IS SHAHLA RABIE VS. PALACE RESORTS. THE PLAINTIFF SELECTION IS ONLY GOING TO BE CHALLENGED WHEN THE DEFENDANT CAN SHOW THAT THE

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1 THE NEXT PHASE IS SHAHLA RABIE VS. PALACE RESORTS. THE PLAINTIFF SELECTION IS ONLY GOING TO BE CHALLENGED WHEN THE DEFENDANT CAN SHOW THAT THE PRIVATE INTEREST OF THE DEFENDANT IS INTERESTED IN PROTECTING OUR WAY OF CHOICE. SPAIN NOW ISN'T THE CASE THAT THE THIRD DISTRICT ACKNOWLEDGED IT? >> ACKNOWLEDGED THAT STATEMENT IS CORRECT BUT THEN IN ITS APPLICATION OF THAT STATEMENT THE COURT SIMPLY SAID THAT BECAUSE MS. RABIE WAS NOT A CITIZEN OF THE STATE OF FLORIDA THAT IN THIS PARTICULAR CASE WOULD NOT BE ENTITLED TO A SIGNIFICANT DEFERENCE THAT OTHERWISE WOULD BE ENTITLED TO. THAT IS IN CONFLICT WITH THIS COURT'S STATEMENT. >> IN KINNEY, KINNEY INVOLVED NOT A CITIZEN OF THE UNITED STATES. THEY WERE A DELAWARE CORPORATION. YOU MADE THE STATEMENT ABOUT THAT AND WE ADOPTED A RULE AND THE RULE, SO THE FACTS OF KINNEY INVOLVED AN OUT-OF-STATE PLAINTIFF, DID IT NOT? >> THAT IS CORRECT YOUR HONOR ABSOLUTELY AND I WOULD ARGUE IN KINNEY THE CONTEXT BOTH THE RESPECT TO THE PLAINTIFF AND DEFENDANT WERE MORE TENUOUS BECAUSE THEY DID AND DIDN'T IN KINNEY ONLY HAD A CONTINENTAL INSURANCE COMPANY ONLY HAD A REGIONAL OFFICE IN FLORIDA AND THERE WAS NO DISCUSSION WITHIN THE DECISION ITSELF AS TO WHAT ROLE THE OFFICE WAS PLAYING IN THE STATE OF FLORIDA. CONTRAST THAT WITH THE DEFENDANT AS JUDGE ROTHLENBERG POINTED OUT THE DEPENDENT IN THIS CASE ARE THE MANAGERIAL OPERATIONAL AND PUBLIC RELATION'S ARM OF THIS COMPANY. EVERYTHING THAT HAS TO DO WITH THIS CLAIM OF THE NEGLIGENT VACATION PACKAGING CLAIM WAS BIRTHED IN THE STATE. >> YOU KNOW, I WANT TO MAKE SURE

2 YOU HAVE ADDRESSED THE CONFLICT ISSUE BEFORE WE GO ON TO THE MAYOR MARAT. >> ABSOLUTELY. JUSTICE CANADY, IN ADOPTING KINNEY THE COURT WAS GOING TO APPLY FEDERAL LAW TO THE EXTENT WHICH HARMONIZED WITH EACH OF THE KINNEY STANDARDS. FEDERAL LAW MAKES PERFECTLY CLEAR THAT A U.S. CITIZEN, IN FACT 11TH CIRCUIT RECENTLY HAD A CASE THAT SAID THE DEFERENCE THAT IS OWED TO PLAINTIFF'S CHOICE OF FORUM IS AT ITS HIGHEST WHEN THAT PLAINTIFF IS EITHER A CITIZEN, RESIDENT OR CORPORATION OF THE UNITED STATES. >> YOU ARE SAYING THERE'S EXPRESSED AND DIRECT CONFLICT BECAUSE WE MAKE A GENERAL STATEMENT THAT WE ARE ADOPTING FEDERAL LAW AND WHEN YOU GO OVER TO LOOK AT WHAT THE FEDERAL LAW IS EXPRESSING INDIRECT CONFLICT? >> I AM SIMPLY EXPLAINING TO -- >> WE HAVE TO LOOK AT THE VISION ON REVIEW AND THE VISION THAT YOU ASSERT THAT IT CONFLICTS WITH AND I'M HAVING TROUBLE SEEING HOW, THERE IS A DIFFERENCE ABOUT HOW THE VARIOUS FACTORS IN KINNEY ARE APPLIED. IT LOOKS LIKE YOUR ARGUMENT ESSENTIALLY WOULD MEAN THAT THERE WOULD BE EXPRESSLY DIRECT CONFLICT UNDER YOUR UNDERSTANDING OF THAT ANYTIME THE CASE CAME ALONG WHERE WE DISAGREED WITH A PARTICULAR WEIGHT GIVEN TO THE VARIOUS FACTORS UNDER KINNEY. ISN'T THAT CORRECT? >> NO, YOUR HONOR BECAUSE WHAT HAS HAPPENED HERE -- WHAT HAS HAPPENED HERE JUDGE IS THE THIRD DISTRICT MAJORITY ACTUALLY CITES THE STANDARD AND IF IT WERE JUST CITING THE STANDARD THAT DOES NOT EXPRESS A DIRECT CONFLICT. I CONCEDE THAT POINT BUT THAT IS NOT WHAT HAPPENED HERE. THE MAJORITY DECISION HERE SUPPLIED THE STANDARD AND THEY SAID SURE MS. RABIE WILL BE

3 RECOGNIZED, THE PLAINTIFF'S CHOICE IS ENTITLED TO DEFERENCE AND WHAT DID THEY DO? THEY IGNORED THE STATEMENT AND WHAT THEY SAID WAS BECAUSE MS. RABIE WAS NOT A CITIZEN OF THE STATE OF FLORIDA SHE WAS NOT GOING TO RECEIVE THE DEFERENCE OF THE FEDERAL LAW WHICH THIS COURT INCORPORATED TO BE A MANDATE. >> THEY SAID WE ARE GOING TO GET INTO ALL THE FEDERAL CASES IN THE PROBLEM AND YOU TRY TO COMPARE THE FEDERAL CASES IS THAT THE FEDERAL JURISPRUDENCE, THE FEDERAL DISTRICT COURT CAN TRANSFER ANYWHERE IN THE UNITED STATES SO WHEN THEY TALK ABOUT A FOREIGN PLAINTIFF, THEY ARE REALLY TALKING ABOUT A PLAINTIFF THAT EITHER IS FROM MEXICO, SCOTLAND OR SOME OTHER COUNTRY BUT THE REASON I THINK AND WHAT I WAS TRYING TO ASK IS A FRIENDLY QUESTION TO YOU IS KINNEY INVOLVED NOT A FLORIDA PLAINTIFF. IT INVOLVES THE UNITED STATES PLAINTIFF, WHO WE STILL SAID AND WE ADOPTED THE RULE THAT CHOICE OF FORUM MAKES THEM TITLE TO GREAT DEFERENCE AND I DON'T THINK BY THE STATEMENT THERE THAT A FOREIGN PLAINTIFF IS GIVEN LESS DEFERENCE. WE NEVER SAID IN KINNEY THAT THE UNITED STATES CITIZEN CHOICE OF INITIAL FORUM IS GIVEN AS 4 DEFERENCE AND I THINK THAT IS WHERE THE CONFLICT IS BUT MY INTEREST HERE IS THAT IS THERE A PLACE IN THE UNITED STATES WHERE, WHICH HAD MORE OF A CONNECTION TO THIS LAWSUIT WHERE YOU COULD HAVE GOTTEN JURISDICTION OVER THE DEFENDANTS? TO MY UNDERSTANDING, THESE ARE AT LEAST THREE DEFENDANTS THAT ARE ACTUALLY DOING THEIR MAIN BUSINESS IN THE STATE OF FLORIDA. IS THAT RIGHT? >> YES. >> SO I'M TRYING TO UNDERSTAND HOW THEY --

4 THIS WHOLE IDEA OF NON-CONVENIENCE, THEY THINK IT'S GOING TO BE MORE CONVENIENT FOR THEM TO LITIGATE IN MEXICO WHEN WHAT YOU ARE SAYING IS THE CAUSE AGAINST THEM IS FOR A NEGLIGENT VACATIONING PACKAGING THAT AROSE WITHIN THE STATE? >> THAT IS ABSOLUTELY CORRECT. >> IT, FROM MY POINT OF VIEW, AND MAYBE THIS IS JUMPING AHEAD, WE HAVE HAD NEGLIGENT SUPERVISION CASES. WHERE CAN YOU MAKE A CONNECTION BETWEEN A SEXUAL ASSAULT THAT OCCURS IN MEXICO, WHERE THE SUPERVISOR, THE EMPLOYEES OR WHATEVER, ARE IN MEXICO AND SOMEBODY -- WHAT KIND OF NEGLIGENT VACATIONING -- WHERE DID YOU GET LEGAL CAUSATION? WHERE DID YOU GET CAUSE OF ACTION? MAYBE THAT COULD BE A MOTION TO DISMISS BUT I'M JUST NOT GETTING THE CONNECTION BETWEEN THEM TELLING PEOPLE YOU CAN GO DOWN TO MEXICO TO DO TIMESHARE AND THE FORESEEABILITY OF BEING SEXUALLY ASSAULTED BY A 5 MASSEUSE. >> TWO RESPONSES TO THAT QUESTION. THAT CHALLENGE THAT YOU ARE ARTICULATING NOW IS A PROPER CHALLENGE FOR A SUBSTANTIVE MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM IT TO GET TO THAT POINT BUT WITH RESPECT TO HOW WE ESTABLISH THE CONNECTION TO THIS FORUM, THIS IN FLORIDA REPRESENTS THE OPERATIONAL HUB OF PALACE RESORTS AND IN FACT IN DISCOVERY WE RECEIVED FROM COSTCO WE LEARNED THAT ALL THE COMPLAINTS REGARDING MS. RABIE'S SEXUAL ASSAULT-- SHE PAID FOR THIS VACATION AND WAS SENT TO THIS FORUM TO FLORIDA. WE LEARNED THE VACATION PACKAGE ITSELF WAS CREATED IN FLORIDA. THE COMPANY IS RUN IN FLORIDA. FLORIDA IS THE HUB FOR THIS COMPANY.

5 >> IS YOUR PERSONAL JURISDICTION OF THE DEFENDANT, BECAUSE THERE IS OBVIOUSLY JURISDICTION TO AN IMPROPER VENUE SO WE DON'T HAVE A -- IT ARISES OUT OF THEIR DOING BUSINESS. YOU DIDN'T ALLEGE ALSO THAT THEIR ACTIONS OR MAYBE YOU DIDN'T HAVE TO BECAUSE THEY DIDN'T CHALLENGE PERSONAL JURISDICTION, THAT THE ACTION IN FLORIDA GAVE RISE TO THE CAUSE OF ACTION HERE WHICH IS ANOTHER SEPARATE RACES FOR JURISDICTION? YOU NEVER HAD TO LITIGATE WHAT THEY WERE ASSERTING IN PERSONAL JURISDICTION? DO YOU KNOW WHAT I'M SAYING? >> YES JUSTICE PARIENTE, THAT IS CORRECT. >> BECAUSE IT STRIKES ME THAT IF YOU HAVE SOMETHING WHERE NOT ONLY ARE THE DEFENDANTS PRESENT IN THE STATE OF FLORIDA SO YOU HAVE PERSONAL JURISDICTION BASED ON THIS AS THEIR MAIN HEADQUARTERS BUT ALSO THAT THE ACTIONS IN WHICH IT GAVE RISE TO THAT JURISDICTION WAS IN THE STATE, THERE WOULDN'T EVER BE IN MY VIEW A BASIS THEN FOREVER INVOKING FOR NON-CONVENIENCE BECAUSE THE VERY TORT ARISES OUT OF THE ACTION AND THAT NEVER -- DID YOU EVER RAISE THAT IS THE ISSUE? >> I SEE WHAT YOU ARE SAYING JUSTICE PARIENTE. >> NO ONE IS GOING TO SAY FOR THE MOST PART, THAT IS GOING TO BE THE PROPER SIGHT. HERE YOU ARE SAYING THE CAUSE OF ACTION AROSE IN FLORIDA. AND I DIDN'T SEE IT WAS LITIGATED THAT WAY BECAUSE TO ME THAT WAS THE EASIEST ANSWER HERE. >> WE CERTAINLY ALLEGED IN OUR COMPLAINT WITH RESPECT TO THE ASPECT OF THE COUNCIL THAT REMAINED IN TERMS OF THE EFFECT OR CAUSE OF ACTION DOES ARISE IN THE STATE OF FLORIDA BECAUSE THEIR NEGLIGENCE FLOWS FROM THE ACTIONS TAKEN BY THESE DEFENDANTS IN THE STATE OF

6 FLORIDA. YES MS. RABIE WAS ASSAULTED IN MEXICO BUT THIS WAS NOT A CLAIM BASED ON A CIVIL ACTION AGAINST A INDIVIDUAL WHO ASSAULTED HER IN THE STATE OF MEXICO. THAT PROBABLY WOULD BE A MORE TENUOUS ISSUE FOR US. YOUR QUESTION ALSO RAISES A SECONDARY ISSUE WHICH ANY COURT OF APPEAL WONDERS WHY IT IS A DEFENDANT IN THE CONTEXT OF RAISING A FORUM NON-DEFENSE WHEN THEY ARE BEING SUED IN THEIR OWN BACKYARD'S? EVEN JUDGE ROTHLENBERG NOTED IN HER DISSENT, IT'S STRANGE THAT THE DEFENDANTS WERE JUST TALKING ABOUT THE ISSUE OF WHETHER OR NOT WE CAN EVEN LITIGATE IN THE STATE OF FLORIDA. IT MAY BE A JUDGE ON REMAND IF THESE JUDGE DOES REVERSE THIS CASE DOES DECIDE THERE IS NO SUBSTANTIVE CLAIM PLED AT ALL BUT RIGHT NOW WITH RESPECT TO MS. RABIE'S RIGHT, THE ISSUE BECOMES WHAT CONNECTION TO THESE DEFENDANTS HAVE? ALL THEY HAVE SAID INCREDIBLY IS THEY WOULD RATHER LITIGATE IN MEXICO IN CANCUN. >> AND THE OTHER PART ABOUT THIS STEMMING FROM MEXICO IS THAT FOR A UNITED STATES CITIZEN TO LITIGATE STUDENTS ARE EXPERT TALK ABOUT TRYING TO GET A LAWYER IN MEXICO TO ESTABLISH SEXUAL ASSAULT AND WHERE DOES THAT FIT INTO -- IT'S ONE THING AGAIN, IF IT'S A MEXICAN CITIZEN AND NOTHING AGAINST SOMEBODY FROM OUT OF THE COUNTRY BUT I THINK THAT IS WHERE A LOT OF THE UNITED STATES CASES CAME FROM. SOMEBODY AGAIN, THE SCOTTISH ONE WAS THE BIG ONE-- WHERE THERE WAS THIS PLANE CRASH IN SCOTLAND BUT DO YOU SEE ANY CASES WITHIN THE UNITED STATES THAT HAVE REALLY TALKED ABOUT THAT ISSUE. ONE THING IF YOU ARE GOING TO TRANSFER TO CALIFORNIA BUT TO HAVE A MEXICAN COURT EVALUATE WHETHER THIS CAUSE OF ACTION

7 FROM NEGLIGENT PACKAGING OF THE VACATION PACKAGE IN FLORIDA SEEMS STRANGE TO ME. >> MS. RABIE'S EXPERTS SPOKE DIRECTLY TO THAT ISSUE AND HER DECORATION GOES TO THE ISSUE OF THE ADEQUACY OF THE FORUM. WE POTENTIALLY COULD SEE THAT MEXICO IS AVAILABLE TO THE EXTENT THAT THE -- ALTHOUGH THAT IS AN ISSUE IN OUR EXPERTS SUGGEST IT WOULD NOT SEVERELY BE THE CASE BUT WITH RESPECT TO THE AVAILABILITY OR THE ADEQUACY OF THE FORUM GUESS THERE ARE SIGNIFICANT PROBLEMS THAT SOMEONE LIKE MS. RABIE THE VICTIM OF A SEXUAL ASSAULT AS OPPOSED TO SOMEONE WHO IS SIMPLY CEILING ON A COMMERCIAL OR AN OTHERWISE NON-TOWARD CIVIL MATTER WOULD FACE. SHE WOULD FACE THE POSSIBILITY OF NOT BEING ABLE TO RETAIN COUNSEL. SHE WOULD FACE THE POSSIBILITY OF RECEIVING NOMINAL DAMAGES ANYWHERE FROM FIVE TO $15,000. SHE WOULD FACE THE POSSIBILITY OF REDUCED ACCESS TO EVIDENCE BECAUSE IN FACT IT IS UNCLEAR BASED ON OUR EXPERTS TESTIMONY THAT SHE WOULD EVEN BE ABLE TO SUSTAIN ANY TYPE OF A CLAIM IN CANCUN IN MEXICO PRIMARILY BECAUSE THESE TYPES OF CASES ARE TYPICALLY NOT LITIGATED. IN FACT OUR EXPERTS HAVE TESTIFIED IN ABSOLUTE TERMS SHE COULD NOT THINK OF THIS SINGLE CASE AND SHE IS AN ACTIVE LITIGATOR IN THE STATE OF TAMURA MEXICO. SHE COULD NOT THINK OF A SINGLE CASE OF THIS NATURE. SO THE FACT THAT THIS IS EVEN A CASES IS VERY MUCH IN DISPUTE. >> WE REALLY DON'T KNOW THE CAUSE OF ACTION IS IN THE STATE OF FLORIDA, THE NEGLIGENT PACKAGING CASE. >> CERTAINLY. THAT IS NOT AN ISSUE THAT HAS BEEN LITIGATED, THAT IS ABSOLUTELY CORRECT JUSTICE PARIENTE BUT WITH RESPECT TO THE SECONDARY ISSUE THE OTHER

8 REBUTTED TESTIMONY FROM OUR EXPERT IS MS. RABIE WOULD NOT BE ABLE TO SUSTAIN A CLAIM IN MEXICO AND EVEN IF SHE COULD SUSTAIN A CLAIM THE REMEDY WOULD NOT BE SUFFICIENT REMEDY. >> AGAIN IF YOUR CLAIM AND AGAIN WE HAVE TO ASSUME A CAUSE OF ACTION FOR THE PURPOSE OF THIS DISCUSSION. IT DOESN'T MAKE SENSE THAT MEXICO HAS A PARTICULAR INTEREST IN HOW A BUSINESS, DOING BUSINESS IN FLORIDA, WOULD MARKET ITS VACATION TO CITIZENS OF THE UNITED STATES. >> IF THEY HAVE AN INTEREST IT'S A MINIMAL INTEREST. >> THEIR INTEREST MIGHT BE THAT THEY WANT THAT TO OCCUR. >> ABSOLUTELY AND PALACES BUSINESS IS BASED UPON THAT. THEY RUN THE TIMESHARE OPERATION OUT OF FLORIDA AS OPPOSED TO MEXICO BECAUSE THE INDIVIDUALS FOR THE TIMESHARE SALES ARE UNITED STATES CITIZENS. PALACE RESORTS RUN 70% OF ITS U.S. BUSINESS, SO THE INTEREST OF THE STATE IN ENSURING THAT PALACE RESORTS PROVIDES A NON-NEGLIGENT VACATION PACKAGE ASSUMING THAT IS ESTABLISHED AND THE MOTION TO DISMISS ON THE QUESTION OF A CLAIM WHETHER WE PLAY IT A CLAIM IS SIGNIFICANT WITH RESPECT TO OUR QUESTION HERE TODAY, THE CONTEXT OF WHETHER OR NOT THIS CASE THIS FORUM OF PUBLIC INTEREST RUBELLA TAKES KEEPING THE STATE OF FLORIDA. I SEE I AM INTO MY REBUTTAL TIME AND I WOULD LIKE TO RESERVE THE REMAINDER OF MY TIME. THANK YOU. >> GOOD MORNING YOUR HONOR. GOOD MORNING JUSTICE POULSEN AND HONORABLE MEMBERS OF THIS COURT. MY NAME IS RICARDO CATA AND THIS IS MY COLLEAGUE. WE REPRESENT THE RESPONDENTS IN THIS CASE. I DON'T THINK THERE IS ANY CONFLICT SHOWN, DIRECT CONFLICT SHOWN. THE CASES WE CITED FROM THE

9 THIRD DISTRICT WHICH WERE IN PLACE. [INAUDIBLE] YOU HAVE A CITIZEN OF THE UNITED STATES WHO -- THERE WAS A PACKAGE IN EGYPT AND THEY HAD AN OPERATION IN MIAMI AT THE TIME. THE COURT AFTER EXAMINING ALL THE FACTORS, WAITED ALL ITS FACTORS SENT THE CASE BACK TO EGYPT AND THE SAME THING IN INTERNATIONAL RESORTS VERSUS -- >> GIVE US THE FACTS IN KINNEY. WHERE WAS THE PLAINTIFF FROM? >> IN KINNEY, THEY MAINTAINED A MARKETING OFFICE IN FLORIDA. THE OFFICE ACTIVITIES -- THAT WAS THE FINDING IN THE ACCIDENT IN THE BAHAMAS. A BOATING ACCIDENT IF I REMEMBER CORRECTLY IN THE BAHAMAS. THE ACCIDENT OCCURRED IN THE BAHAMAS AND THE TRIAL COURT DISMISSED ON KINNEY. >> NO, NO I'M TALKING ABOUT KINNEY. >> OH KINNEY. >> THE CONFLICT CASE. I THOUGHT THAT WAS THAT WE ARE HERE ON. KINNEY WAS INVOLVED IN THE DISPUTE ABOUT WORKERS COMPENSATION INSURANCE PREMIUMS. WHERE WAS THE PLAINTIFF FROM? >> I BELIEVE YOUR HONOR IF I AM CORRECT THE PLAINTIFF WAS FROM I WANT TO SAY NEW YORK. >> YEAH ENDED AND WE HOLD IN THAT CASE AND WE ADOPTED A RULE THAT SAID THAT THE PLAINTIFFS CHOICE OF FORUM SHOULD BE ENTITLED TO, LET'S JUST MAKE SURE -- A STRONG PRESUMPTION AGAINST DISTURBING THE PLAINTIFF'S INITIAL FORUM CHOICE SO UNLESS THE CASE AND IN THE RULE FOR ALL DICTA, IT COULDN'T BE DICTA BECAUSE THE PLAINTIFF WAS NOT FROM FLORIDA. >> THAT IS CORRECT YOUR HONOR. >> THEY SAID THAT PLAINTIFF INITIAL CHOICE OF FORUM IS ENTITLED TO GREAT DEFERENCE. THEY DIDN'T SAY IT WAS LESS DEFERENCE BECAUSE THEY ARE FROM

10 NEW YORK. >> THAT IS WHAT THE CASES HAVE HELD. >> NOT FROM THIS COURT. >> YOUR HONOR BUT THE KINNEY DECISION SAID THAT HER ASSUMPTION CAN BE OVERRULED AND BE DEFEATED. >> IF IT'S FROM THE PRIVATE FACTORS AND THOSE OTHER THINGS, BUT I THOUGHT WHAT THE THIRD DISTRICT SAID WAS THE STRONG PRESUMPTION IS NOT AS STRONG IF IT IS AN OUT-OF-STATE PLAINTIFF AND THAT IS JUST CONTRADICTORY TO THE FACTS OF KINNEY. >> I DON'T THINK SO YOUR HONOR WITH ALL DUE RESPECT BECAUSE KINNEY SAID THE BOUNDARIES OF THE JURISDICTIONAL BOUNDARIES OF THE FLORIDA COURTS ARE -- THE FOUNDERS OF THE STATE AND THE FEDERAL COURT CAN TRANSFER CASES ANYWHERE IN THE UNITED STATES. THE FLORIDA COURTS CANNOT DO THAT. THEY WILL HAVE TO DISMISS THAT THIS IS NOT A FORUM. THE OTHER THING THAT IS THE MAJORITY DECISION IN KINNEY WHICH IS STILL THE CASE TODAY AND RAISED BY THE AMICUS BRIEF, THE FLORIDA COURTS NORMALLY ALL OVER THE UNITED STATES BUT -- >> I THINK KINNEY IS GOOD POLICY. I'M NOT ARGUING. I THOUGHT YOU WERE REALLY REDRESSING WHETHER THERE WAS CONFLICT AND IT SEEMS TO ME THAT WE HAVE TO RECEIVE IF WE AGREE WITH THE THIRD DISTRICT. IN MY VIEW WE WOULD HAVE TO RECEDE FROM KINNEY AND I UNDERSTAND THERE ARE CASES UNDER APPELLATE COURT AFTER THAT BUT ASSUMING WE GET TO THE CONFLICT ISSUE, DO YOU AGREE THAT YOUR DEFENDANTS NOW -- THOUGH THERE ARE THREE DEFENDANTS LEFT. >> THAT THEY ARE ALL PRIMARILY BASED IN FLORIDA? >> THEY HAVE THEIR PRIMARY BASE IN FLORIDA AND IF I MAY ADDRESS THE POINT YOU RAISED BEFORE -- THE FACT FINE BY THE TRIAL COURT

11 AND THE DECISION, THERE WAS ALSO SIGNIFICANT RECOGNITION OF THE COURTS. THERE WERE INTERROGATORY ANSWERS AND A SIGNIFICANT AMOUNT OF DOCUMENTATION AND THERE WERE ALSO THE PARTIES AND THE EXPERTS. THE FACT IS THAT PALACE RESORTS, INC. HAD NO INTEREST IN THIS CASE AND THAT WAS FOUND BY THE DISTRICT COURT OF APPEAL. IT HAD NOTHING TO DO WITH THE CASE WHATSOEVER. >> IF IT DOESN'T HAVE ANYTHING TO DO WITH THE CASE IT WON'T HAVE ANYTHING TO DO WITH THE CASE IN MEXICO EITHER WILL LET? >> THAT IS CORRECT. >> I GUESS MY PROBLEM ABOUT IT IS, THERE IS NO CAUSE OF ACTION, AND I'M SKEPTICAL ABOUT IT, IT SEEMS TO ME AGAINST CORPORATIONS THAT ARE PRIMARILY DOING BUSINESS IN FLORIDA, IT SEEMS TO ME THE FLORIDA COURTS ARE IN THE BEST POSITION TO DETERMINE THAT SO IF YOUR CLIENT REALLY HAD NOTHING TO DO WITH THE PACKAGING OF THIS VACATION, THAT HAS BEEN SUMMARY JUDGMENT OR A MOTION TO DISMISS ON UNDER CAUSE OF ACTION IS NOT A REASON BECAUSE THAT IS PRELIMINARY, TO TRANSFER IT TO MEXICO FOR MEXICO TO DECIDE WHETHER FLORIDA IS A CAUSE OF ACTION FOR NEGLIGENT PACKAGING AGAINST FLORIDA'S CORPORATION PRIMARILY DOING BUSINESS IN -- >> I WAS GOING TO GET TO THAT. THE ONE RESPONDENT INVOLVED DIRECTLY WITH VACATIONING -- I'M SORRY ARE GETTING PROMOTIONS IN THE UNITED STATES, IT HAS NO CONTACT WHATSOEVER WITH THE PETITIONER AND THAT IS IN THE RECORD. >> BUT ISN'T THAT A BASIS TO A JUDGMENT ON THE PROCEEDINGS? >> I'M GOING TO GET TO THAT. >> IF YOU LOOK AT THE AMENDED COMPLAINT IN THE THIRD DISTRICT, WHAT THEY ARE ALLEGING, THEY'RE ONLY COUNT AGAINST OUR CLIENT WHICH ALSO INCLUDED THE MEXICAN DEFENDANTS AS THEY WERE NEGLIGENT FOR NOT INSPECTING THE

12 SPOT AND MEXICO AND NEGLIGENT FOR NOT INVESTIGATING THE MASSEUSE AND MEXICO. EVERYTHING THEY ARE ALLEGING IS MY CLIENT IN FLORIDA HAS NOTHING TO DO WITH FLORIDA AND IT DOESN'T EVEN HAVE TO DO WITH ANYTHING WITH THE VACATION PACKAGING, WHATEVER THAT IS. I HAVE NEVER HEARD OF THAT BEFORE. IT HAS TO DO ALLEGEDLY WITH WHAT THEY DIDN'T DO IN MEXICO AND THAT IS WHY THE TRIAL COURT FOUND THAT IN ORDER TO ELIMINATE THIS WE HAVE TO BE IN MEXICO. ALL OF THE INVESTIGATION BY THE CRIMES SECTION HAD A SIGNIFICANT AMOUNT OF INTEREST. >> BUT ARE THOSE REALLY THE KINDS OF THINGS THAT YOU NEED TO DEAL WITH ASSUMING THAT THE NEGLIGENT PACKAGING OF THE VACATION THING'S -- ISN'T MORE IMPORTANT AS TO WHAT THEY DID, PUTTING THE PACKAGE TOGETHER AS OPPOSED TO WHAT HAPPENED AFTER SHE GOT TO MEXICO. >> YOUR HONOR WITH ALL DUE RESPECT THIS IS A VICARIOUS LIABILITY CLAIM. NO MATTER WHAT THEY CALL IT, IT'S A VICARIOUS LIABILITY CLAIM IN TORT AGAINST MY CLIENT FOR WHAT HAPPENED IN MEXICO. >> BUT IF YOU HAVE NO CONTROL -- IF YOUR DEFENDANT HAS DEPOSITION TESTIMONY AND ITS UNCONTROVERTED AND THEY HAD NO CONTROL OVER WHO WAS HIRED, THEN AGAIN THIS IS NOT A CLAIM FOR MOTION SUMMARY JUDGMENT HERE. YOU DON'T NEED TO GO TO MEXICO TO DO THAT. THE RECORDS OF WHAT YOU DID AT LEAST ACCORDING TO THE JUDGE ROTHLENBERG'S DISSENT IN FLORIDA? >> YOU HAVE TO TRY IN CONTRAST WITH WHAT HAPPENED -- >> I THINK YOU CAN GET IT, EITHER A SUMMARY JUDGMENT OR JUDGMENT BY THE PLEADINGS BECAUSE I DON'T SEE WHERE THE LAWSUIT IS THAT NEEDS TO BE TRIED IN MEXICO.

13 >> WHAT WE ARE SAYING AND THE TRIAL JUDGE AGREES WITH THAT, IF YOU WANT TO TRY A VICARIOUS LIABILITY TORT CLAIM AGAINST A FLORIDA CLIENT FOR WHAT YOU ARE ALLEGING HAPPENED ONLY IN MEXICO THOUGH THERE'S NO INDICATION OF ANYTHING HAPPENING IN FLORIDA -- THOUGH THEN YOU CAN TRY THE CASE IN MEXICO AND THAT IS WHAT ALL THE FACTS ARE. THAT IS WHERE ALL THE WITNESSES ARE. YOU ARE TALKING ABOUT SCREENING OF THE MASSEUSE, HIRING AND SUPERVISING A MASSEUSE BECAUSE THAT IS WHAT YOU ARE ALLEGING. THERE IS NO INDICATION THAT -- [INAUDIBLE]5 WHATEVER THE COST TO HER IN MEXICO -- [INAUDIBLE] EVERYTHING THAT SHE IS ALLEGING TO ALLEGE THE VACATION PACKAGE IS IN MEXICO. EVERY FACT, EVERY RECORD ON EVERYTHING IS BASED IN MEXICO. THAT IS WHAT THE TRIAL COURT FOUND. >> THE FINDINGS IS THERE WAS NO EVIDENTIARY HEARING. >> THERE WAS NO EVIDENTIARY HEARING AND THEN WAS REQUIRED. >> LOOK AT WHAT JUDGE ROTHLENBERG SAID THAT MIAMI IS THE OPERATIONAL MANAGERIAL AND MARKETING CENTER FOR THE ENTIRE PALACE RESORT GROUP AND THE CONTROL MARKETING SALES TO INDIVIDUALS, GROUPS TRAVEL AGENTS, CUSTOMER SERVICE, PRESS RELATIONS AND FINANCE FOR THE ENTIRE PALACE RESULTS GROUP. THEY MANAGE THE ENTIRE U.S. MARKET WHICH REPRESENTS 70% OF THE BUSINESS AND THE PRESIDENT LIVES AND WORKS IN MIAMI. THE FLORIDA DEFENDANT HAD NEARLY 100 EMPLOYEES IN MIAMI AND FURTHER STATES THAT THE DEFENDANTS AND MS. RODRIGUEZ ADMITS THE ALLEGATIONS THAT WERE PREVIOUSLY MADE WHETHER ANY MONEY WAS MADE OFF OF THIS THEY ADMIT ARE FALSE. NOW THAT IS SOME PRETTY SERIOUS STUFF FROM THE RECORD IN THIS

14 CASE. >> THAT IS WHAT JUDGE ROTHLENBERG FOUND. THAT IS NOT WHAT THE TRIAL COURT FOUND. AND THAT THE MAJORITY OF HER DISTRICT A COUPLE OF TIMES AT LEAST, AT LEAST ONCE BUT MAYBE A COUPLE OF TIMES, SAID THAT THE RESPONDENTS HAVE NO OWNERSHIP, MANAGERIAL OR OPERATIONAL CONTROL OF THE ENTITIES IN MEXICO. THERE ARE LESS THAN 100 EMPLOYEES HERE. THERE ARE DOZENS OF HOTELS IN CANCUN. THEY FOUND CLEARLY THAT THEY DO NOT CONTROL, THEY DO NOT MANAGE AND THEY DO NOT OWN. AS TO THE STATEMENT AND IN FACT SHE WAS THERE THE HEARING WITH ME BECAUSE SHE INSISTED SHE BE THERE, SHE MADE FACTUAL ERRORS. SHE EXPLAINED WHY SHE PROCESSED IT THAT WAY. THERE WAS AN ARGUMENT BY COUNSEL THAT THEY DON'T RECEIVE MONEY DIRECTLY FROM MS. RABIE. THEY RECEIVE AN ANNUAL BUDGET FROM THE MEXICAN ENTITY AND SHE EXPLAINED THAT AND SHE CORRECTED THAT A FEW MONTHS BEFORE. THEY ARE SERIOUS ALLEGATIONS AND SHE TOOK IT VERY SERIOUSLY HER ON YOUR HONOR. IN FACT I OFFERED -- AND HE DECLINED ANY OF THE ENTIRE RECORD IN FRONT OF HIM. GOING BACK TO THE ISSUE OF THE CONTROL, THAT WAS CLEARLY FOUND NOT TO BE THE CASE BY THE TRIAL COURT AND THE MAJORITY OF THE COURT OF APPEALS. WHETHER OR NOT THERE IS AN ABUSE OF DISCRETION, THE TRIAL COURT FOUND THAT ALL OF THE FACTORS HAVE TO BE CONSIDERED IN FAVOR OF DISMISSAL. >> AGAIN IF YOU DON'T CONTROL OR MANAGE -- AND THE RECORD REFLECTS THAT, WOULDN'T THE ALTERNATIVE HAS BEEN TO MOVE FOR JUDGMENT ON THE PLEADING IN FAVOR OF YOUR CLIENT BASED ON THE UNDISPUTED EVIDENCE THAT THEY HAD NOTHING TO DO WITH

15 SEXUAL ASSAULT AND THEY HAD NOTHING TO DO WITH HIRING THIS MASSEUSE. THEY HAD NOTHING TO DO WITH THE MANAGEMENT DOWN IN MEXICO AND THAT'S THE END OF THE CASE BUT IT ENDED IN FLORIDA. >> YOUR HONOR IT'S SOMETHING THAT HAPPENED IN MEXICO. EVERYTHING THEY ARE ALLEGING AGAINST US HAPPENED IN MEXICO. THE HIRING AND SO FORTH HAPPENED IN MEXICO. WE ARE SAYING IF YOU WANT TO SUE US FOR THAT IN ORDER FOR US TO PROVE THAT WE WERE NOT NEGLIGENT YOU NEED TO TRY THEM IN MEXICO AND TO YOUR PREVIOUS QUESTION YOUR HONOR ABOUT THE CAUSE OF ACTION IT IF I MAY, THIS IS NOT A CRIMINAL PROSECUTION THAT WOULD TAKE PLACE IN MEXICO. THIS IS NOT A PROSECUTION BY AN ACTION THAT WOULD REQUIRE A SEXUAL ASSAULT EVENT TO HAPPEN OR NOT. IN FACT SHE SAID SHE COULD PROVE THAT BY HER OWN TESTIMONY AND THE TESTIMONY OF HER CLIENT. OUR EXPERT MR. GARCIA SAID THE SAME THING. IN RESPONSE TO -- SHE COULD PROVE THAT THEIR OWN TESTIMONY BY THE TESTIMONY OF THE POLICE AND OTHER WITNESSES. THE POLICE SPENT A LOT OF TIME INVESTIGATING AND IS ALLOWING EVIDENCE ON THE RECORD -- THOUGH I DON'T KNOW ABOUT THE RECORD BUT IT'S ALLOWING THE POLICE AND PROSECUTORS WHO ARE VERY INTERESTED IN THIS. THE OTHER POINT YOU RAISE BEFORE IF I MAY, BOTH EXPERTS SAY SHE CAN -- [INAUDIBLE] SO IT'S AN ADEQUATE FORUM. SHE WAS KIND OF ALL OVER THE PLACE. SHE SAID I HAD NEVER SEEN IT BUT AT THE SAME TIME SHE SAID IF YOU BRING IT TO ME -- I DON'T KNOW WHERE SHE CAME UP WITH THAT. THE RESPONSE WAS THAT IT WAS A MEDICAL MALPRACTICE ACTION WHERE THERE WAS A RECOVERABLE ACTION

16 OF $4.5 MILLION. A LOT OF HER PAPERS THAT SHE HAD WRITTEN IS ON PRODUCT LIABILITY SO OBVIOUSLY SHE SAID CIVIL LIABILITY HAS NOT DEVELOPED IN MEXICO. SHE HERSELF HAS ALLOWED THAT THROUGH HER OWN ADMISSION. ALL OF THESE THINGS ARE IMPORTANT. THE JUDGE FOUND THAT ALL OF THOSE WEIGH HEAVILY IN FAVOR OF THE RESPONDENTS AND TO THE ORDER AND WE HAVE RESERVED THE ABILITY FOR HER FOR A LAWSUIT IN MEXICO IF SHE CHOSE TO DO SO. THE OTHER THING WE RACE YOUR HONOR WERE WHETHER OR NOT THERE WOULD BE AN EVIDENTIARY HEARING. WE SAID IN OUR BRIEF THAT FIRST OF ALL NO EVIDENTIARY HEARING WAS REQUESTED AND THERE IS NO CASE LAW THAT AN EVIDENTIARY HEARING WOULD BE REQUIRED. EXTENSIVE BRIEFING AND EXTENSIVE RECORD. THERE SHOULD BE NO ABUSE OF DISCRETION IN A NOBLER REVIEW. THE MAJORITY OF THE DECISION ITSELF FOUND IN THIS CASE BECAUSE THE TRIAL JUDGE CONSIDERED ALL OF THE KEY FACTORS NO USE OF DISCRETION IN THE NOBLER REVIEW WAS REQUIRED AND THE OTHER THING THEY SAY IS A LOT OF THE THINGS THEY RAISED FOR THE FIRST TIME ARE NOT IN THE INITIAL BRIEF. THE TRIAL JUDGE VIOLATED THE IMMUNITY CLAUSE OF THE U.S. CONSTITUTION. WE BELIEVE IT WAS DOUGLAS MAYFIELD FROM THE U.S. SUPREME COURT AND A DOZEN STATES IN CALIFORNIA WHERE A LESSER DEFERENCE IS GIVEN TO A PLAINTIFF FOR AN OUT-OF-STATE PLAINTIFF A LESSER DEFERENCE IS GIVEN TO THE PLAINTIFF IF HE OR SHE IS NOT A RESIDENT OF THAT STATE. THERE IS NOTHING IN CONFLICT WITH THE CONSTITUTION IN THAT SCENARIO. WE ALSO APPROVED THE PUBLIC INTEREST FACTOR WEIGHED HEAVILY IN FAVOR OF DISMISSAL AND THAT

17 WAS FOUND BY THE TRIAL COURT AND ALSO BY THE MAJORITY OF THE THIRD DISTRICT COURT OF APPEALS. IT WAS FOUND TO BE THE CASE BY THE THAT THE CIRCUIT JUDGE IN THE MAJORITY CIRCUIT COURT OF APPEAL AND I BELIEVE THAT DESERVES SIGNIFICANT CONSIDERATION. AGAIN GOING BACK TO THE USE OF THE DISCRETION STANDARD WHICH IS WHAT WE HAVE HERE, IT CAN DIFFER AND THAT IS THE DEFINITION WHETHER THERE'S THE USE OF DISCRETION. WE BELIEVE THAT THERE WAS NOT AND WE BELIEVE THAT THE ONLY WAY THAT WE CAN DEFEND THIS CAUSE OF ACTION IS SOLELY IN MEXICO, NOTHING IN FLORIDA. IT WOULD REQUIRE US TO -- OTHERWISE WE WOULD BE LITIGATING THE CASE IN MEXICO. >> THAT THE ALLOCATIONS ARE RELATED TO IT ACCIDENTS THAT OCCURRED IN FLORIDA. >> EXCUSE ME YOUR HONOR. THE ALLEGATION IS THAT WE FAILED TO INSPECT -- THAT WE FAILED TO WARN THE. [INAUDIBLE] IT SPEAKS ONLY TO MEXICO AND ALL OF THE FACTUAL ALLEGATIONS IN THE OPENING LITIGATIONS THAT THEY SET FORTH CLEARLY AND ONLY TALK ABOUT MEXICO. >> IT SEEMS LIKE THOSE ACTIONS TAKEN BY YOUR CLIENT TO THAT EXTENT.. >> EVERYTHING THEY ALLEGED IN COUNT SIX OF THEIR AMENDMENT THEY ALLEGE HAPPENED IN MEXICO. THAT IS THE BEGINNING OF THE ANALYSIS, THE PLEADING OF THE PLAINTIFF, WHERE THEY ARE ALLEGING THAT THING -- THINGS TO. >> IS THAT A QUESTION IN THE CASE? >> I DON'T THINK SO BECAUSE THAT IS WHAT THEY HAVE ALLEGED. THEY HAVE ALLEGED THAT WE DID ALL THESE THINGS IN MEXICO SO THE PRIVATE INTEREST FACTOR HAS TO BE IF IT BE ALLEGED -- TOOK PLACE IN MEXICO THAN THAT IS WHERE --

18 THANK YOU YOUR HONOR. >> WITH RESPECT TO THE CONFLICT ISSUE ITS MAJORITY OPINION THE THIRD DISTRICT COURT OF APPEAL WROTE QUOTE THE PRECEDING -- I'M SORRY THE APPELLATE CALIFORNIA RESIDENT CHOSE TO FILE SUIT IN FLORIDA A FORUM THAT IS NOT HER RESIDENCE THAT SHE IS NOT ENTITLED TO A STRONG PRESUMPTION IN FAVOR OF FLORIDA AS TO THE FORUM OF HER CHOICE. IT IS NOT THE LAW ARTICULATED BY KINNEY AND LAW ARTICULATED BY FEDERAL PRECEDENCE. >> SHE WASN'T ADDRESSING THAT CIRCUMSTANCE BECAUSE IN KINNEY THERE WERE TWO CORPORATIONS THAT ACTUALLY HAD ACTIVITIES GOING ON IN FLORIDA BUT THE PLAINTIFF AND THE DEFENDANT HAD OFFICES AND OPERATIONS IN FLORIDA AND THE ISN'T THAT THE FACT THAT THEY WERE ADJUSTING THERE? >> ACTUALLY I WOULD DISAGREE TO THE EXTENT THAT KINNEY AND RABIE ARE DISTINGUISHABLE BECAUSE DEFENDANTS IN KINNEY AND RABIE DO HAVE SIGNIFICANT OPERATIONS IN FLORIDA. ACTUALLY THE DEFENDANTS AND SUBTREE HAS ALLEGED THAT MORE SIGNIFICANT OPERATIONS IN THE STATE OF FLORIDA. >> POINT WITH THE PLAINTIFF ALSO HAD CONNECTIONS WITH FLORIDA AND HAD AN OFFICE AND OPERATIONS IN FLORIDA. THAT IS VERY DIFFERENT FROM THE PLAINTIFF IN THE SITUATION WHO SO FAR AS WE KNOW HAS NO CONNECTION AT ALL WITH FLORIDA. >> BUT WITH RESPECT TO THE PLAINTIFF'S CHOICE OF FORUM EXPANDED BY -- [INAUDIBLE] THE PROBLEM AND I WOULD AGREE WITH JUSTICE PARIENTE THAT KINNEY WORKS. WHAT IS HAPPENING IN A STATE OF FLORIDA NOW IN THE LOWER COURTS IS THAT IT'S NOT BEING APPLIED BY THIS COURT. WHAT WE HAVE AS NOTHING MORE THAN A BALANCING OF ACCOUNTS. THE COURTS ARE LOOKING AT TWO SIDES OF A SINGLE PIECE OF

19 PAPER. HOW MANY WITNESSES HERE AND HOW MANY DOCUMENTS THERE? THAT IS NOT HOW KINNEY WAS CONCEIVED. IT'S NOT HOW YOU BALANCE THE PRIVATE INTEREST FACTORS. IN FACT WHAT WITH MANY OF THE FEDERAL COURTS SAY AND JUDGE FOR RAYNO HAS SPOKEN TO THIS ISSUE, WITH TECHNOLOGY FOR EXAMPLE THE QUESTION OF WHERE THE DOCUMENTS ARE BECOMES A NONISSUE. THE QUESTION OF WHAT LANGUAGE THE DOCUMENTS ARE COMES AS A NONISSUE. WITNESSES BECOME A NON-ISSUE BECAUSE YOU CAN USE TECHNOLOGY TO SHOW IT TO A JURY BUT THAT IS NOT IN KINNEY. >> LET'S ASSUME THAT YOU ARE CORRECT ON YOUR ANALYSIS OF KINNEY. LET'S ASSUME THERE IS JURISDICTION. YOUR OPPOSITION MAKES CLEARLY THE POINT AND I DON'T KNOW HOW IT CAN BE CONTESTED, THAT THE UNDERLYING FACTS OF WHAT HAPPENED TO THE PLAINTIFF OCCURRED IN MEXICO. YOU CANNOT TRY THIS CASE IN A VACUUM AND THAT SEEMS TO BE WHAT THEY ARE SAYING, THAT YOU MAY HAVE MADE BAD DECISIONS BUT THAT CAN'T BE CONSIDERED IN A VACUUM. IT HAS TO BE CONSIDERED IN CONNECTION WITH WHAT IS ON THE GROUND IN MEXICO AND THEREFORE THE THINGS THAT WENT WRONG AND IN TWO PLACES SO I THINK YOUR OPPOSITION IS ARGUING THAT THE REAL CRAB OF WHAT HAPPENED IS WHAT HAPPENED TO THE LADY IN MEXICO. EVEN IF WE AGREE THAT KINNEY SAYS THEY SHOULD HAVE DEFERENCE, THIS IS NOT A LONG ARM JURISDICTION TYPE ANALYSIS. THIS IS NOT ONE OF THOSE FOREIGN CORPORATIONS, ARE THEY DOING BUSINESS? THAT IS NOT WHAT THIS IS SO HOW DOES THAT ANALYSIS TAKE PLACE HERE? IT'S INESCAPABLE WHAT THEY SAY, THAT THE UNDERLYING HARM, THE

20 BAD ACTS, AT LEAST HALF OF THEM AND THE DIRECT ACTS ON THE PLAINTIFF OCCURRED IN MEXICO. HELP WITH THAT ANALYSIS. HOW DO WE WALK-THROUGH THAT? >> JUSTICE LEWIS I HAVE TWO RESPONSES TO THAT QUESTION. THE FIRST IS IT IS CONCEDED THAT MS. RABIE WAS ASSAULTED IN MEXICO. >> FOR THE PURPOSES OF LITIGATION. >> THE ACTION TOOK PLACE IN MEXICO. >> THEY MAY SAY THIS DIDN'T HAPPEN SO YOU'LL HAVE TO PROVE THAT SOMETHING HAPPENED TO HER IN MEXICO. LET'S START WITH THAT PREMISE. >> IT THE FIRST RESPONSE IS IT IS CORRECT THERE ARE DIFFICULTIES ON BOTH SIDES BUT IN THIS INTERNATIONAL DISPUTE MS. RABIE'S CHOICE OF FORUM TIPS US OVER THE EDGE AND TAKES US TO FLORIDA IF THE PRIVATE, IF WE CAN SAY THE PRIVATE INTEREST, IT DOES SIDES ARE GOING TO FACE CHALLENGES AND THEY ARE CONCEIVABLY ALTHOUGH I WOULD SUGGEST TO THE COURT THAT BUT THE WAY MY COLLEAGUE PAINTS THE PICTURE IS NOT SO GREAT WITH RESPECT TO DEFENDING THIS LAWSUIT. THAT'S AN EXCELLENT EXAMPLE FOR WHY THIS CASE BELONGS IN FLORIDA. WHEN MS. RABIE REPORTED HER ASSAULT AND CONTACTED COSTCO WHO IS WAS ORIGINALLY THE DEFENDANT IN THIS CASE AND HE SOLD FOR THAT PACKAGE WHO DID THEY CONTACT? >> STATE OF FLORIDA. >> THEY CONTACTED THE FLORIDA DEFENDANTS. THE FLORIDA DEFENDANTS RECEIVED TREMENDOUS AMOUNTS OF DISCOVERY. >> THAT IS AFTER-THE-FACT, THE POINT BEING WHAT THEY ARE ARGUING IF THEY DID SOMETHING WRONG IT HAPPENED BEFORE THIS LADY WENT TO MEXICO. SO SHE IS ALLEGEDLY ATTACKED IN MEXICO AND THE FACTS OF THE HARM AND DEVASTATION OF THIS YOUNG

21 WOMAN ARE OCCURRING IN MEXICO. THE FACT THAT IT IS REPORTED LATER TO FLORIDA, IS THAT ENTITLED TO A HEAVIER BALANCING WHEN IT COMES DOWN TO THE PUBLIC INTEREST AS TO HOW THEY SHOULD BE? >> JUSTICE LEWIS AS YOU SAID BEFORE, IT IS THEIR PRE-ACT CONDUCT THAT I THINK IS RELEVANT AND PRESENTS A -- AND SECOND IT IS THEIR POST-CONDUCT, BOTH HOW THEY PACKAGE THIS VACATION WHAT THEY DID AFTER THEY WERE ALERTED TO THE FACT THAT THIS PARTICULAR PACKAGE HAD RESULTED IN MS. RABIE'S INJURIES. I SEE THAT MY TIME HAS LAPSED AND I THINK THE COURT VERY MUCH. >> THANK YOU FOR YOUR ARGUMENTS. THE COURT IS ADJOURNED UNTIL TOMORROW MORNING. >> ALL RISE.

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