Case 1:20-Cv-24328-MGC Document 1 Entered on FLSD Docket 10/21/2020 Page 1 of 40
Case 1:20-cv-24328-MGC Document 1 Entered on FLSD Docket 10/21/2020 Page 1 of 40 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. ANA MARGARITA MARTINEZ, Plaintiff, v. NETFLIX, INC., ORANGE STUDIOS, S.A., and OLIVIER ASSAYAS Defendants. / COMPLAINT AND DEMAND FOR JURY TRIAL Plaintiff, ANA MARGARITA MARTINEZ (“Plaintiff” or “Ms. Martinez”), by and through undersigned counsel, hereby sues Defendants, NETFLIX, INC., ORANGE STUDIOS, S.A. and OLIVIER ASSAYAS, (collectively, “Defendants”) and alleges as follows: NATURE OF ACTION 1) This defamation action arises from Defendant Netflix, Inc.’s (“Netflix”) release of the film The Wasp Network (the “Film”) to its worldwide streaming service on June 19, 2020. Since then, the Film has been accessed by, and remains accessible to, more than 192 million Netflix subscribers and viewers.1 2) The Film romanticizes, or glorifies, the criminal activity conducted by agents of Cuba’s Ministry of the Interior, i.e., the “Cuban Five,” whose espionage work was responsible for the death of four Americans in 1996, as being based on “True Events.” 1 https://www.netflixinvestor.com/financials/sec-filings/default.aspx Case 1:20-cv-24328-MGC Document 1 Entered on FLSD Docket 10/21/2020 Page 2 of 40 Martinez v. Netflix, et al. 3) In doing so, the Film attempts to rewrite history in a dishonest and irresponsible way by legitimizing and justifying the communist Cuban government’s crimes of espionage against the United States; crimes of fraud, sexual battery, and rape against Ms. Martinez; and acts of terrorism in shooting down two unarmed civilian planes operated by Hermanos al Rescate (“Brothers to the Rescue”) on Saturday, February 24, 1996 during a humanitarian mission to search for and aid Cuban refugees fleeing on rafts in the Straits of Florida.
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