John Doe v. Carnival Corp., et al – Part 1

Lipcon, Margulies, Alsina & Winkleman, P.A - Maritime Lawyer

October 26, 2012

John Doe v. Carnival Corp., et al – Part 1

Notice and Agreement

Often times, the most important thing our experienced maritime attorneys can bring to your case is their ability to negotiate and reach reasonable agreements with all parties involved. In this notice of filing and agreement between the parties, our experienced maritime attorneys reached an agreement with the Medical Defendants in a cruise ship injury case. This agreement persuaded the Defendants to drop their challenge to the Plaintiff’s service of a summons.

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 12-CV-23345 – UNGARO
JOHN DOE,
Plaintiff,

v.

CARNIVAL CORPORATION,
WILLIAM PRETORIUS (Ship’s Doctor),
JACQUELINE GOBEIL, (Ship’s Nurse),
BRYAN PATIU, (Ship’s Nurse),
Defendant
___________________________/

Joint Notice of Filing Service Waivers and Agreement to File New Motions to Dismiss

Plaintiff, JOHN DOE, and Defendants WILLIAM PRETORIUS, BRYAN PATIU, and JACQUELINE GOBEIL (hereinafter the “Medical Defendants”), hereby file this Joint Notice of Filing Service Waivers and Agreement Between the Parties.

In effort to expedite the procedural issues associated with this case, the Defendants WILLIAM PRETORIUS, BRYAN PATIU, and JACQUELINE GOBEIL have agreed to waive service of a summons and execute the attached service waivers. Exhibit 1. Pursuant to the agreement of the parties, the Defendants are hereby withdrawing [D.E. 8], [D.E. 9] and [D.E. 10] while specifically reserving all other applicable defenses or objections to the lawsuit, including but not limited to, challenging the court’s jurisdiction. Accordingly, the Plaintiff has agreed that the Medical Defendants may file new motions to dismiss for lack of personal jurisdiction within (30) thirty days.

Respectfully submitted,

Fowler, White, Burnett, P.A. Lipcon, Margulies, Alsina & Winkleman, P.A.

Espirito Santo Plaza, 14th Floor One Biscayne Tower, Suite 1776
Miami, Florida 33131 Miami, Florida 33131
Tel. (305) 789-9259 Tel. (305) 373-3016
Fax (305) 789-9201 Fax (305) 373-6204
Attorneys for Medical Defendants Attorneys for Plaintiff

By: /s/ Michael J. Drahos_______ By: /s/ Eric C. Morales_______

Michael J. Drahos Eric C. Morales, Esq.

Florida Bar No.: 617059 Florida Bar No.: 91875