Chiquita Reply To Response Stay Mandate

Case No.
12-14898-BB

UNITED STATES COURT OF APPEALS
FOR THE ELEVENTH CIRCUIT
_________________________________________

IN RE: CHIQUITA BRANDS INTERNATIONAL, INC.
ALIEN TORT STATUTE AND SHAREHOLDER
DERIVATIVE LITIGATION

CASE NO. 08-01916-MD-MARRA

This Brief Relates to District Court Case Numbers:
No. 08-80465, No. 10-80652, No. 11-80404, No. 11-80405

__________________________________________

On Appeal from the United States District Court
for the Southern District of Florida
(The Honorable Kenneth A. Marra)
_________________________________________

APPELLEE'S REPLY TO RESPONSE
TO MOTION FOR STAY OF MANDATE
_________________________________________

Paul Wolf
P.O. Box 46213
Denver, CO 80201
(202) 431-6986
paulwolf@yahoo.com
Counsel for Does 1-144,
Does 1-976, Does 1-677,
and Does 1-254

October 12 2014
Case: 12-14898 Date Filed: 10/14/2014 Page: 1 of 29

TABLE OF CONTENTS

Certificate of Interested Persons ...................................... ii.

Table of Authorities .......................................................... xiii.

Summary of Argument ..................................................... 1.

Argument ........................................................................... 2.

I. The Doe Plaintiffs have shown that a substantial
question and good cause exist to stay the mandate. ........ 3.

A. The Doe Plaintiffs have shown a reasonable
probability that four justices would grant
certiorari. ......................................................... 3.

B. The Doe Plaintiffs have shown a significant
possibility of reversal of this Courts decision. 5.

C. Irreparable harm will ensue if the
mandate is not stayed, since there will be
further proceedings in the District Court. .... 7.

II. The Court should exercise its discretion to hear
the Plaintiff's interlocutory cross-appeal now, rather
than waiting for a final judgment. .................................. 9.

Conclusion ......................................................................... 12.

ii

CERTIFICATE OF INTERESTED PERSONS
Counsel certifies that, to the best of his knowledge, the
following is a complete list of the trial judge(s), all attorneys,
persons, associations of persons, firms, partnerships, or
corporations (noted with its stock symbol if publicly listed) that
have an interest in the outcome of the particular case on appeal,
including subsidiaries, conglomerates, affiliates, and parent
corporations, and other identifiable legal entities related to a
party, known to Appellees, are as follows:
1. The individual plaintiffs are listed in the Complaints as filed
in the Southern District of Florida in Case Nos. 08-80465, 10-
80652, 11-80404, and 11-80405.
2. Additional interested parties are:
Agrcola Longav Limitada
Agrcola Santa Marta Limitada
Agroindustria Santa Rosa de Lima, S.A.
Alamo Land Company
Alsama, Ltd.
American Produce Company
iii
Americana de Exportacin S.A.
Anacar LDC
Arvelo, Jos E.
Associated Santa Maria Minerals
B C Systems, Inc.
Baird, Bruce
Barbush Development Corp.
Bienes Del Rio, S.A.
BlackRock, Inc. (NYSE: BLK)
Blue Fish Holdings Establishment
Bocas Fruit Co. L.L.C.
In Re: Chiquita Brands Intl., Inc.
Boies Schiller & Flexner, LLP, Fort Lauderdale
Boies Schiller & Flexner, LLP, Miami
Boies Schiller & Flexner, LLP, New York
Boies Schiller & Flexner, LLP, Orlando
Brundicorpi S.A.
Cadavid Londoo, Paula
Carrillo, Arturo J.
iv
C.C.A. Fruit Service Company Limited
CB Containers, Inc.
Centro Global de Procesamiento Chiquita, S.R.L.
Charagres, Inc., S.A.
Childs, Robert
Chiquita (Canada) Inc.
Chiquita (Shanghai) Enterprise Management Consulting Co., Ltd.
Chiquita Banana Company B.V.
Chiquita Brands International Foundation
Chiquita Brands International Srl
Chiquita Brands International, Inc. (NYSE: CQB)
Chiquita Brands L.L.C.
Chiquita Central Europe, s.r.o.
Chiquita Compagnie des Bananes
Chiquita Deutschland GmbH
Chiquita Food Innovation B.V.
Chiquita for Charities
Chiquita Fresh B.V.B.A.
Chiquita Fresh Espaa, S.A.
v
Chiquita Fresh North America L.L.C.
Chiquita Fruit Bar (Belgium) BVBA
Chiquita Fruit Bar (Germany) GmbH
Chiquita Fruit Bar GmbH
Chiquita Frupac B.V.
Chiquita Hellas Anonimi Eteria Tropikon Ke Allon Frouton
Chiquita Hong Kong Limited
Chiquita International Services Group N.V.
Chiquita Italia, S.p.A.
Chiquita Logistic Services El Salvador Ltda.
Chiquita Logistic Services Guatemala, Limitada
Chiquita Logistic Services Honduras, S.de RL
Chiquita Melon Packers, Inc.
Chiquita Mexico, S. de R.L. de C.V.
Chiquita Nature and Community Foundation
Chiquita Nordic Oy
Chiquita Norway As
Chiquita Poland Spolka Z ograniczona odpowiedzialnoscia
Chiquita Portugal Venda E Comercializaao De Fruta,
vi
Unipessoal Lda
Chiquita Relief Fund - We Care
Chiquita Shared Services
Chiquita Singapore Pte. Ltd.
Chiquita Slovakia, S.r.o.
Chiquita Sweden AB
Chiquita Tropical Fruit Company B.V.
Chiquita UK Limited
ChiquitaStore.com L.L.C.
Chiriqui Land Company
CILPAC Establishment
Coast Citrus Distributors Holding Company
Cohen, Millstein, Sellers & Toll, PLLC
Collingsworth, Terrence P.
Compaa Agrcola de Nipe, S.A.
Compaa Agrcola de Rio Tinto
Compaa Agrcola del Guayas
Compaa Agrcola e Industrial Ecuaplantation, S.A.
Compaa Agrcola Sancti-Spiritus, S.A.
vii
Compaa Bananera Atlntica Limitada
Compaa Bananera Guatemateca Independinte, S.A.
Compaa Bananera La Estrella, S.A.
Compaa Bananera Los Laureles, S.A.
Compaa Bananera Monte Blanco, S.A.
Compaa Caronas, S.A.
Compaa Cubana de Navegacin Costanera
Compaa Frutera Amrica S.A.
Compaa La Cruz, S.A.
Compaa Mundimar, S.A.
Compaa Productos Agrcolas de Chiapas, S.A. de C.V.
Compaa Tropical de Seguros, S.A.
Conrad & Scherer LLP
Costa Frut S.A.C.
Covington & Burling LLP
Danone Chiquita Fruits SAS
Davies, Patrick
De La Calle Restrepo, Jos Miguel
De La Calle Londoo y Posada Abogados
viii
DeLeon, John
Dimensional Fund Advisors LP
Duraiswamy, Shankar
Dyer, Karen C.
Earthrights, International, Inc.
Exportadora Chiquita - Chile Ltda.
Exportadora de Frutas Frescas Ltda.
Financiera Agro-Exportaciones Limitada
Financiera Bananera Limitada
FMR LLC
Fresh Express Incorporated
Fresh Holding C.V.
Fresh International Corp.
Frutas Elegantes, S. de R.L. de C.V.
Fundacin Para El Desarrollo de Comunidades Sostenibles en el
Valle de Sula
G & V Farms, LLC
G W F Management Services Ltd.
Garland, James
ix
Girardi, Thomas V.
Gould, Kimberly
Gravante, Jr., Nicholas A.
Great White Fleet Liner Services Ltd.
Great White Fleet Ltd.
Green, James K.
Guralnick, Ronald S.
Hall, John
Heaton Holdings Ltd.
Heli Abel Torrado y Asociados
Hemisphere XII Investors Limited
Hospital La Lima, S.A. de C.V.
Ilara Holdings, Inc.
Inversiones Huemul Limitada
James K. Green, P.A.
Jimenez Train, Magda M.
Jones, Foster, Johnston & Stubbs, P.A.
King, William B.
Lack, Walter J.
x
Law Firm of Jonathan C. Reiter
Law Offices of Chavez-DeLeon
Leon, The Honorable Richard J.
Markman, Ligia
Marra, The Honorable Kenneth A.
Martin, David
Martinez Resly, Jaclyn
McCawley, Sigrid S.
Mosier, Mark
Mozabanana, Lda.
Parker Waichman LLP
Pras Cadavid Abogados
Pras, Juan Carlos
Procesados IQF, S.A. de C.V.
Processed Fruit Ingredients, BVBA
Promotion et Developpement de la Culture Bananiere
Puerto Armuelles Fruit Co., Ltd.
Rapp, Cristopher
Reiter, Jonathan C.
xi
Ronald Guralnick, P.A.
Scarola, Jack
Searcy Denney Scarola Barnhart & Shipley, P.A.
Seguridad Colosal, S.A.
Servicios Chiquita Chile Limitada
Servicios de Logstica Chiquita, S.A.
Servicios Logsticos Chiquita, S.R.L
Servicios Proem Limitada
Skinner, William
Sperling, Jonathan
Spiers N.V.
Sprague, Ashley M.
St. James Investments, Inc.
Stubbs, Sidney
Tela Railroad Company Ltd.
The Vanguard Group
TransFRESH Corporation
UNIPO G.V., S.A.
V.F. Transportation, L.L.C.
xii
Verdelli Farms, Inc.
Western Commercial International Ltd.
Wichmann, William J.
Wiesner & Asociados Ltda. Abogados
Wiesner, Eduardo A.
Wilkins, Robert
Wolf, Paul
Wolosky, Lee S.
Zack, Stephen N
Zhejiang Chiquita-Haitong Food Company Limited
Zuleta, Alberto

/s/ Paul Wolf
____________________
Paul Wolf DC Bar # 480285
Attorney for Doe Plaintiffs

xiii
Table of Authorities

Cases

Al Shimari v. CACI Premier Tech. Inc.,
2014 WL 2922840 (4th Cir. June 30, 2014) ..................... 1, 3-5.

Barefoot v. Estelle, 463 U.S. 880 (1983)........................... 2, 6.

California v. American Stores Co.,
492 U.S. 1301 (1989) ........................................................ 2.

Kiobel v. Royal Dutch Petroleum Co.,
569 U.S. __, 133 S. Ct. 1659 (2013) ................................. 1, 3-5, 7.

McFarlin v. Conseco Servs., LLC,
381 F.3d 1251 (11th Cir. 2004) ....................................... 11.

Morrison v. National Australia Bank Ltd.,
561 U.S. 247 (2010) ......................................................... 8.

Senne v. Vill. of Palatine, Ill.,
695 F.3d 617 (7th Cir. 2012) ........................................... 2.

Statutes

28 U.S.C. 1291 .............................................................. 11.

28 U.S.C. 1292(b) ......................................................... 9.

28 U.S.C. 1331 ............................................................. 10.

28 U.S.C. 1332 ............................................................. 10.

28 U.S.C. 1350 ............................................................. 6, 10.

28 U.S.C. 1350 note ..................................................... 6, 10.

xiv
Other

William S. Dodge, The Historical Origins of the
Alien Tort Statute: A Response to the Originalists.
19 Hastings Int'l & Comp. L. Rev. 221 (1996). ............. 12.
1

Summary of Argument

The Court should stay the mandate because the Doe
Plaintiffs have shown that a substantial question and good cause
exist. The Court's opinion conflicts with the decisions of the US
Supreme Court in Kiobel v. Shell, and with the 4th Circuit in Al
Shimari v. CACI. Irreparable harm will ensue because the
District Court will proceed using legal theories that may be
overturned.
The Court should exercise its discretion to hear the
Plaintiff's interlocutory cross-appeal because (1) it involves an
abstract question of law that does not rely on the record, (2) the
District Court itself expressed uncertaintly about the correct
answer, and (3) because resolution of the issue will also simplify
and streamline the litigation. Otherwise, the Doe Plaintiffs will
have to appeal the same issue, as of right, after the District Court
has entered a final judgment. This not only complicates the case,
but deprives the Supreme Court of the opportunity to consider the
extraterritorial application of the ATS and state tort law in the
same case.
2
Argument

I. The Doe Plaintiffs have shown that a substantial
question and good cause exist to stay the mandate.

When assessing whether a substantial question and good
cause exist, courts use a three-part test to determine whether
there is (1) a reasonable probability that four members of the
[Supreme] Court would consider the underlying issue sufficiently
meritorious for the grant of certiorari, (2) a significant
possibility of reversal of the lower courts decision, and (3) a
likelihood that irreparable harm will result if that decision is not
stayed. Barefoot v. Estelle, 463 U.S. 880, 895-96 (1983).
1
The

1
The Appellant proposes an altered version of this test used by
the 7th Circuit in Senne v. Vill. of Palatine, Ill., 695 F.3d 617, 619
(7th Cir. 2012). This case imposes an additional requirement of a
showing that five Supreme Court justices would vote to reverse.
Id. This "five justice rule" is unique to the Seventh Circuit and
appears based on the 7th Circuit's application of its own circuit
rules to the Supreme Court, which has different rules. The Senne
case purports to rely on California v. American Stores Co., 492
U.S. 1301, 1307 (1989), but there is nothing in American Stores
suggesting the Supreme Court has altered the test. The other two
7th Circuit cases cited in Senne are also the product of sloppy
work. It would be a mistake, and there would be no reason for the
Court to follow the 7th Circuit.
In the alternative, Justice Kennedy's separate, concurring
opinion in Kiobel suggests that he may be persuaded by the fact
3
Chiquita case conflicts with both Kiobel v. Royal Dutch Petroleum
Co., 569 U.S. __, 133 S. Ct. 1659 (2013), and Al Shimari v. CACI
Premier Tech. Inc., 2014 WL 2922840 (4th Cir. June 30, 2014).
A. The Doe Plaintiffs have shown a reasonable
probability that four justices would grant certiorari.

Although Kiobel was a unanimous opinion, the justices
sharply disagreed over the applicable legal standards. Justices
Breyer, Ginsberg, Sotomayor and Kagan joined in a concurring
opinion that would find jurisdiction under the ATS whenever (1)
the alleged tort occurs on American soil, (2) the defendant is an
American national, or (3) the defendants conduct substantially
and adversely affects an important American national interest,
including an interest in preventing the United States from
becoming a safe for torturers or other common enemies of
mankind. Kiobel, slip op., Breyer, J. concurring.
In the instant case, all three criteria are met. Chiquita is a
US corporation; the agreement to kill the decedents was made and
overseen in the US; and Chiquita was prosecuted in the United

that the Chiquita conspiracy was organized and overseen in the
US, and that all of the payments originated in the U.S.
4
States for the same conduct. Chiquita doesn't dispute that it is a
U.S. corporation, so it is easy to show that the test of these four
justices can be met.
Al Shimari v. CACI is about a private company that
allegedly tortured prisoners in Abu Ghraib, Iraq. The Fourth
Circuit found that the case "touched and concerned" the territory
of the United States because (1) CACI is a US corporation, (2) the
employees who allegedly tortured the prisoners were US citizens,
and (3) the injuries occurred on a US military base pursuant to a
contract with the US Government. Al Shimari v. CACI, 2014 WL
2922840 at *30-31.
Much of the post-Kiobel debate has centered around what
kind or amount of domestic conduct would be necessary for a case
to touch and concern the United States. In Al Shimari, the
Plaintiffs alleged that "in the 'command vacuum at Abu Ghraib,'
CACI interrogators operated with little to no supervision and
were perceived as superiors by United States military personnel.
Military personnel allegedly carried out orders issued by the CACI
civilian interrogators to 'soften up' and 'set conditions' for the
5
abuse of particular detainees, contrary to the terms of CACIs
contract with the United States government." Id. at *8. This is a
negligence standard, with more than one level of secondary
liability. CACI is liable for the conduct of its Iraqi employees in
Iraq, who were perceived by the military personnel to be their
superiors, and it is the military personnel who inflicted the
injuries. In Chiquita the Board of Directors of a U.S. Corporation
agreed to pay a terrorist organization on a monthly basis for
security, falsified its accounting records to hide the fact, and then
pled guilty when prosecuted. Chiquita's domestic conduct was
more than negligent, and is not mrely based on the fact that a
contract was signed on U.S. soil.
2
The Kiobel and Al Shimari
cases are two good reasons to believe the Supreme Court would
grant certiorari.

2
As Judge Martin argued in her dissent, Kiobel requires a fact-
based analysis of the contacts of the case with the territory of the
U.S., not unlike an analysis of personal jurisdiction or choice of
laws.
6
B. The Doe Plaintiffs have shown a shown a significant
possibility of reversal of this Courts decision.

The Doe Plaintiffs need only show a significant possibility of
reversal: not, as Appellants would argue, that more likely than
not, the Supreme Court would reverse. The Appellant relies on
Senne v. Vill. of Palatine, Ill., 695 F.3d 617, 619 (7th Cir. 2012),
which distorts the test set forth in Barefoot v. Estelle, 463 U.S.
880, 895-96 (1983) by replacing the "significant possibility"
standard with a "reasonable probability that ... five justices will
vote to reverse ..." 695 F.3d at 619. Luckily, the Court need not
resolve this inconsistency between the 7th Circuit and the
Supreme Court. See FN 1, supra,
There is a significant possibility that Justice Kennedy would
consider the instant case to be a serious violation of international
law principles protecting persons, and act as the "swing vote,"
along with those who concurred with Justice Breyer, and reverse.
Justice Kennedy wrote:
The opinion for the Court is careful to leave open a number
of significant questions regarding the reach and
interpretation of the Alien Tort Statute. In my view that is a
proper disposition. Many serious concerns with respect to
human rights abuses committed abroad have beenaddressed
7
by Congress in statutes such as the TortureVictim Protection
Act of 1991 (TVPA), 106 Stat. 73, note following 28 U. S. C.
1350, and that class of cases will be determined in the
future according to the detailed statutory scheme Congress
has enacted. Other cases may arise with allegations of
serious violations of international law principles protecting
persons, cases covered neither by the TVPA nor by the
reasoning and holding of todays case; and in those disputes
the proper implementation of the presumption against
extraterritorial application may require some further
elaboration and explanation.

Kiobel v. Royal Dutch Petroleum Company, 569 U. S. ____ (2013)
(Justice Kennedy, concurring). Therefore, there is a significant
possibility of reversal.
C. Irreparable harm will ensue if the mandate is not
stayed, since there will be further proceedings in the
District Court.

Irreparable harm may ensue if the mandate is not stayed
pending the Doe Plaintiffs' filing of a certiorari petition. It is not
in the best interest of the district court or the parties to begin
litigating this matter pursuant to this Courts mandate before
determining which claims have been dismissed. Considering we
have already been litigating this matter for more than seven
years, three months is a relatively short time to ask for.
8
First, the Supreme Court should be given an opportunity to
consider the petition. The Supreme Court should be interested in
this subject, since it decided two ATS cases last year. Since then,
the first two appellate courts to decide ATS cases (the Eleventh
and Fourth) are already split. The Supreme Court seemed
primarily motivated to reconcile a line of foreign securities cases,
including Morrison v. National Australia Bank Ltd., 561 U.S. 247
(2010), with foreign human rights litigation. Chiquita offers a
very simple, paradigm fact pattern, where only the place of injury
lies outside of the United States.
Second, this Court should consider the Plaintiff's
(interlocutory) cross-appeal now, rather than waiting for a final
judgment from the District Court. Questions about the
extraterrirorial application of federal and state law are obviously
related, and it's in the interest of judicial economy to resolve them
now.
Given the controversy and the substantial question posed by
the petition, it would be unreasonable to begin litigation under a
theory of law that could be overturned. There is a significant
9
possibility that the Supreme Court could vacate this Courts
opinion and remand the matter to the district court for a
subsequent trial. The unnecessary expense of resources by the
courts and the parties would result in irreparable harm.
Therefore, good cause exists to stay the mandate pending the
filing of a petition for a writ of certiorari

II. The Court should exercise its discretion to hear the
Plaintiff's interlocutory cross-appeal now, rather than
waiting for a final judgment.

Interlocutory appeals are at the discretion of the Circuit
Court. An interlocutory order may be appealed if (1) the District
Court issues a written statement that the order involves a
controlling question of law as to which there is a substantial
ground for a difference of opinion and that an immediate appeal
from the order may materially advance the ultimate termination
of the ligitation; and (2) the Circuit Court permits the appeal to be
taken. 28 U.S.C. 1292(b).
Here, the District Court certified the question "whether the
civil tort laws of Florida, New Jersey, Ohio, and the District of
Columbia apply to the extraterritorial conduct of Colombian
10
paramilitaries against Colombian civilians that occurred inside
Colombia as part of Colombias civil war." Memo Op. at 3-4. The
11th Circuit exercised its discretion to decline to decide this.
3

In exercising its discretion, the circuit court will not
normally grant permission to appeal unless: (1) the controlling
question of law is an abstract legal issue that the circuit court can
decide quickly and cleanly without having to study the record; (2)
it is not absolutely clear that the district court resolved the
question correctly; and (3) resolution of the question would serve

3
The Appelant's understanding of the Court's opinion can't be
right, and attributes to the Court a poor understanding of civil
procedure. In the Appellant's view, the Court could not reach
diversity claims brought under 28 U.S. Code 1332, unless it first
found it had jurisdiction over federal question claims brough
under 28 U.S. Code 1331. These claims clearly have different
and independent jurisdictional bases.
The state law tort claims were brought under the diversity
jurisdiction statute, 28 U.S. Code 1332. The Appellees in this
action are citizens and residents of Colombia, while the Appellant
is a US corporation, formerly headquartered in Ohio, and now in
North Carolina. The Appellant has no corporate presence in
Colombia. Since the claims are for wrongful death (and a few
personal injury cases involving very grave injuries), the amount
controversy between each Plaintiff and the Defendant exceeds
$75,000. In contrast, the claims pursuant to the Alien Tort
Statute, 28 U.S. Code 1350, and Torture Victim Protection Act ,
28 U.S. Code 1350 note, are federal claims brought under 28
U.S. Code 1331. The Appellant's construction must be wrong as
a matter of law.
11
to avoid a trial or otherwise substantially shorten the litigation.
McFarlin v. Conseco Servs., LLC, 381 F.3d 1251, 1256-1259 (11th
Cir. 2004)
Here, the Court should exercise its discretion and hear the
cross-appeal. The issue of whether state tort laws may apply
extraterritorially is abstract, and there isn't even a "record" to
review at this stage of the case. It is not absolutely clear that the
District Court resolved this correctly, as evidenced by the District
Court's own decision to raise the issue sua sponte in the
interlocutory appeal. The resolution of the issue should shorten
the litigation, for the same reasons given in I (C) supra; that is,
so that the parties and the District Court will know which claims
are proceeding.
The result of declining to hear the cross-appeal will be that,
once a final judgment has been obtained, the Doe Plaintiffs may
appeal the judgment as of right, pursuant to 28 US Code 1291.
Declining to decide this issue now will make a mess of this case,
12
and deprive the Supreme Court of the opportunity to decide the
ATS and state tort law extraterritoriality issues together.
4

Conclusion
For the foregoing reasons, the Court should stay the
mandate and exercise its discretion to decide the Plaintiffs' cross-
appeal.
Respectfully submitted,
/s/ Paul Wolf
____________________________________
Paul Wolf DC Bar #480285
Attorney for Does 1-144, 1-976, 1-677, 1-254
PO Box 46213
Denver CO 80201
(202) 431-6986
paulwolf@yahoo.com

October 12, 2014

4
Among the mysterious features of the Alien Tort Statute are its
brevity, and the Founder's legislative intent in enacting it.
Professor William S. Dodge persuasively argues that the original
intent of the "Alien Tort Clause," as it was then known, was to
provide a federal, rather than state court forum for cases involving
alien claims. By definition they concern foreign states and foreign
policy, and it was not seen as desirable for each state's courts to
act independently. See William S. Dodge, The Historical Origins
of the Alien Tort Statute: A Response to the Originalists. 19
Hastings Int'l & Comp. L. Rev. 221 (1996). This is the kind of
perspective that can become lost when issues are decided in
piecemeal fashion.
13
Certificate of Digital Submission
I hereby certify that with respect to the foregoing
(1) all required privacy redactions have been made;
(2) if required to file additional hard copies, that the ECF
submission is an exact copy of those documents;
(3) the digital submissions have been scanned for viruses with
the most recent version of VirusTotal, a commercial virus
scanning program.
/s/ Paul Wolf
____________________

Certificate of Service

I hereby certify that on the 12th day of October, 2014, I filed
the foregoing document with the clerk of the court through the
Court's Electronic Case Filing (ECF) system, which will send
notification to the attorneys of record for all other parties in this
litigation. I further certify that all parties required to be served
have been served.

14
/s/ Paul Wolf
____________________

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