US v. Norwegian Cruise Lines, Inc. and Norwegian ... - ADA.gov

facsimile the same day sought the appearance in Washington on August 6, 2001, pursuant to Rule30(b)(6), of “[t]he person with the most knowledge” to be deposed regarding topics including:1. Suits filed by the Department of Justice against cruise lines or owners of cruise ships forviolations of the Americans with Disabilities Act from January 1, 1992 to the present.2. The final result of all suits filed by the Department of Justice against cruise lines or owners ofcruise ships for violations of the Americans with Disabilities Act from January 1, 1992 to thepresent.3. Congress’ direction to the Attorney General and the Department of Transportation to issueregulations on or before July 26, 1991 to effectuate the Americans with Disabilities Act.4. Guidance as to what would constitute a reasonable modification of the policies, practices orprocedures set forth in the Complaint. . . .5. Guidance as to what would constitute the appropriate criteria for screening out potentialpassengers on foreign flagged cruise ships without violating the Americans with Disabilities Actnecessary for a foreign flagged cruise ship to provide the goods, services, facilities, privileges,advantages, or accommodations being offered. . . .6. Guidance as to how a foreign flagged cruise ship is required to modify its policies, practicesand procedures to avoid discrimination under the Americans with Disabilities Act.7. Guidance as to the extent of the individualized inquiry necessary to determine thereasonableness of modifications to cruise ship policies, practices and procedures set forth in theComplaint. . . .8. Guidance as to whether an individualized assessment must be made as to whether anindividual with a disability constitutes a direct threat to himself/herself or to others on a foreignflagged cruise ship.9. Guidance as to the extent of any individualized assessment that must be made to determinewhether an individual with a disability constitutes a direct threat to himself/herself or to otherson a foreign flagged cruise ship.10. Guidance as to whether a private entity that does not own, lease, lease to or operate a placeof public accommodation may properly be sued for discrimination under the Americans withDisabilities Act.11. Guidance as to how owners of the foreign flagged cruise ship may reconcile the laws of itshome state, international law applicable to cruise ships and the requirements imposed by theAmericans with Disabilities Act.noticed the deposition under Rule 30(b)(6), however, and because this Court is already conversantwith the legal issues involved in this lawsuit, the United States respectfully moves in this Court for aprotective order that will quash the deposition and document subpoena.3