Law Offices of

WALKER & O’NEILL, P.A.

M A R I T I M E L A W Y E RS

Plaza 57
7301 S.W. 57th Court, Suite 430
South Miami, Florida 33143
James M. Walker Telephone (305) 995-5300
Lisa O. O’Neill www.maritimelawyers.com Facsimile (305) 995-5310

November 16, 2017

Sent Via Regular Mail and Facsimile No. 305 406-4732

Carnival Corporation, Inc.

Risk Management Department
3655 NW 87th Avenue
Miami, FL 33178-2418

Attention: Passenger Claims

Re: Passengers: Chris White, Dana White and Nico White, a minor
Vessel: Carnival’s Fantasy
Incident Date: October 2017

SUBMITTED WITHOUT PREJUDICE

Dear Sir or Madam:

This firm represents Chris and Dana White, and their minor son, Nico (age 10), who
sailed aboard the Carnival Fantasy on October 9, 2017 for a large family reunion. This was
their tenth cruise with Carnival.

On the second full day of the cruise, to their shock and horror, Mr. and Ms. White
discovered a small video camera hidden in the bundled cables, behind the television in
their cabin, which pointed toward their bed. The camera was wired to a wireless
transmitter and was powered from the television power cable. Mr. and Ms. White became
extremely concerned that video images of them being intimate had been transmitted,
recorded and viewed by others and possibly uploaded to the internet. They are fearful that
images of their child dressing and undressing in the cabin were also transmitted, recorded
and viewed by others.

Mr. White reported the presence of the camera and transmitter in their cabin to the
cruise ship’s security department. One of Carnival’s security personnel arrived in the
White’s cabin. He disconnected and removed the camera and transmitter with no gloves
on and did not attempt to secure the room. Mr. White videoed the security officer
Carnival Corporation, Inc.
Risk Management Department / Passenger Claims
November 16, 2017
Page 2

removing the camera; you can hear Mr. White asking the officer why he was not wearing
gloves.

Mr. White thereafter communicated with the security staff to obtain an update. The
Carnival security personnel confirmed that the camera and transmitter: (1) were fully
operational; (2) were typically the type of devices used on video drones: and (3) the
transmitter was a long range device. To Mr. White’s knowledge, Carnival did not
promptly report the incident to the Federal Bureau of Investigation (FBI). Mr. White
learned that Carnival notified the Customs and Border Patrol (CBP), although the CBP told
Mr. White that it had no jurisdiction over the matter and it took no action.

Mr. and Ms. White have heard nothing from Carnival about these troubling
circumstances since returning from the cruise. At this point, Mr. and Ms. White remain
concerned that the Carnival security team did not properly investigate the incident, did not
properly preserve the cabin and the video and transmitter therein and, in fact, spoliated
this evidence, and failed to timely report the circumstances described above to the FBI as
required by law. The White family is concerned that they were not the only victims of this
secret recording and transmitting equipment, placed in their cabin on the Carnival cruise
ship, and that many other Carnival guests had their privacy invaded.

18 U.S. Code § 1801 (“Video Voyeurism”) states that it is a crime to have “the intent
to capture an image of a private area of an individual without their consent . . .” (and the
individual has a reasonable expectation of privacy). The term “capture” is defined as “to
videotape, photograph, film, record by any means, or broadcast” and the term “broadcast”
means to electronically transmit a visual image with the intent that it be viewed by a
person or persons.

We demand that Carnival retain the camera, transmitter and related wiring in this
matter and not permit this evidence to be lost, destroyed or altered in any way. We request
an explanation why the recording and transmitting devices were not preserved as evidence
in the cabin for an inspection and investigation by the FBI. It is likely that these devices
were surreptitiously placed in the White’s passenger cabin by a crew member or crew
members for the purposes of viewing the passengers in bed from their crew cabins where
transmission could be received and recorded. We request whether Carnival has conducted
an investigation regarding who received the transmitted images on the ship, and whether
Carnival has conducted a search of the crew cabins on the Fantasy and, if so, the results of
such an investigation and search. We demand Carnival preserve all images and recordings
taken and transmitted by these devices.
Carnival Corporation, Inc.
Risk Management Department / Passenger Claims
November 16, 2017
Page 3

If Carnival later reported the incident to the FBI, we request a copy of such
notification, the FBI case number, if applicable, and the names and contact information
regarding the FBI agents with involvement or knowledge regarding this matter.

We look forward to a prompt and meaningful response to this letter.

Thank you.

Very truly yours,

JAMES M. WALKER