Case 0:08-md-01916-KAM Document 965 Entered on FLSD Docket 12/18/2015 Page 1 of 3

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
Case No. 08-01916-MD-MARRA/JOHNSON
IN RE: CHIQUITA BRANDS INTERNATIONAL, INC.,
ALIEN TORT STATUTE AND
SHAREHOLDER DERIVATIVE LITIGATION
____________________________________________/
This Document Relates To:
ATS ACTION
_______________________________________________/
Case No. 9:08-cv-80465-KAM
DOES (1-144), PEREZES (1-95), PEREZES (96-795),
and Carmen Tulia Cordoba Cuesta, et al.
Plaintiffs,
v.
CHIQUITA BRANDS INTERNATIONAL, INC., et al.
Defendants
____________________________________________/
MOTION TO SUBSTITUTE COUNSEL AND NOTICE OF APPEARANCE
International Rights Advocates, on behalf of Plaintiffs DOES (1-144), PEREZES (1-95),
PEREZES (96-795), and Carmen Tulia Cordoba Cuesta, et al., and Conrad & Scherer LLP
jointly request an order for substitution of counsel and state as follows:
1.

An order substituting International Rights Advocates for Conrad & Scherer LLP

as counsel for Plaintiffs is appropriate and necessary here.

2.

Terrence P. Collingsworth formerly represented Plaintiffs in this action while

working at Conrad & Scherer.

3.

Mr. Collingsworth now works at another organization, International Rights

Advocates, and continues to represent Plaintiffs.

4.

Mr. Collingsworth and Conrad & Scherer are in the process of making reasonable

Case 0:08-md-01916-KAM Document 965 Entered on FLSD Docket 12/18/2015 Page 2 of 3

efforts to provide Plaintiffs, who number over two thousand, with written notice indicating that
Conrad & Scherer and Mr. Collingsworth have agreed that Plaintiffs cases are being transferred
to Mr. Collingsworths organization.
5.

Two current Conrad & Scherer lawyers also represent Plaintiffs in this action:

William R. Scherer and Eric J. Hager. The requested substitution will result in Mr. Scherer and
Mr. Hager, and Conrad & Scherer more generally, no longer representing Plaintiffs. Mr. Scherer
and Mr. Hagers names should be removed from the CM/ECF docket upon entry of a substitution
order.
6.

Substitution should be allowed because Plaintiffs will continue to have adequate

legal representation. Mr. Collingsworth and others working with him at International Rights
Advocates have litigated human rights cases in courts throughout the U.S. for many years. Mr.
Collingsworth has been active in this litigation for several years and has been the lead lawyer for
Conrad & Scherer on this matter during that time. In addition, because this is a multi-district
litigation, there are several other capable law firms litigating the common issues in this action.
Mr. Collingsworth regularly collaborates with those other law firms.
7.

The requested substitution will not cause any delay in this action. A trial date has

not yet been set. Rather, motions to dismiss are pending and awaiting decision.
8.

This motion also serves as Mr. Collingsworths notice of appearance and notice of

change of contact information. Mr. Collingsworth originally entered an appearance on behalf of

Plaintiffs in the United States District Court for the District of Columbia. Mr. Collingsworths
mailing and physical business address, phone number, and email address have changed. His new
contact information is in the signature block below.
For the foregoing reasons, movants request that International Rights Advocates be

Case 0:08-md-01916-KAM Document 965 Entered on FLSD Docket 12/18/2015 Page 3 of 3

substituted as Plaintiffs attorneys in place of Conrad & Scherer LLP.

DATED: December 18, 2015

Respectfully submitted,
/s/ Terrence P. Collingsworth
International Rights Advocates
Terrence P. Collingsworth (admitted Pro Hac Vice)
621 Maryland Avenue NE
Washington, D.C. 20002
Phone: 202-255-2198
Email: tc@iradvocates.org
Attorney for Plaintiffs, DOES 1-144,
PEREZES 1-95, PEREZES 96-795,
and Carmen Tulia Cordoba Cuesta et al.
/s/ William R. Scherer
Conrad & Scherer LLP
William R. Scherer (Fla. Bar No. 169454)
633 South Federal Highway, 8th Floor
Fort Lauderdale, Florida 33301
Phone: 954-462-5500
Fax: 954-463-9244
Email: wscherer@conradscherer.com