Response in Opposition To File Amicus Brief

Case: 19-13926 Date Filed: 06/08/2020 Page: 1 of 23
Case No. 19-13926-C
UNITED STATES COURT OF APPEALS

FOR THE ELEVENTH CIRCUIT
___________________________________________
IN RE: CHIQUITA BRANDS INTERNATONAL, INC.,

ALIEN TORT STATUTE LITIGATION
___________________________________________
On Appeal from the United States District Court

For the Southern District of Florida
No. 08-md-01916
(Nos. 08-80465, 11-80404)
(The Honorable Kenneth A. Marra)
____________________________________________
APPELLANTS DOE 378 AND DOE 840'S RESPONSE IN

OPPOSITION TO MOTION TO FILE AMICUS CURIAE BRIEF
____________________________________________
Paul Wolf, DC Bar #480285

P.O. Box 21840
Washington, D.C. 20009
Telephone (202) 431-6986
paulwolf@yahoo.com
Fax: n/a
Attorney for Plaintiff-
Appellants-Cross-Appellees
CERTIFICATE OF INTERESTED PERSONS
Counsel certifies that 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 Appellants, are as follows:
1. Doe 378, whose identity remains confidential under a Protective Order of
the District Court, and Ludy Rivas Borja, who is the daughter of deceased plaintiff
Doe 840, whose identity also remains confidential under the Order. In addition,
the plaintiffs bring their cases as personal representatives of the estates of the
deceased. They represent other legal heirs with interests, whose identities are
known to the Appellees, but remain confidential under the Protective Order.
2. The other plaintiffs in the complaints filed by undersigned counsel in the
Southern District of Florida, in Case Nos. 08-80465, 10-80652, 11-80404, 11-
80405 and 17-cv-80475. Undersigned counsel represents the legal heirs of
approximately 2,319 wrongful death cases. In addition, there are six other plaintiff
groups with a total of about 7500 "claims" in the MDL, all of whom have an
interest in this appeal.
3. Additional interested parties are:

Agrícola Longaví Limitada
Agrícola Santa Marta Limitada
Agroindustria Santa Rosa de Lima, S.A.
Aguirre, Fernando
Alamo Land Company
Alsama, Ltd.
American Produce Company
Americana de Exportación S.A.
Anacar LDC
Arnold & Porter
Arvelo, José E.
Associated Santa Maria Minerals
B C Systems, Inc.
Baird, Bruce
Bandy, Kevin
Barbush Development Corp.
Bienes Del Rio, S.A.
Blank Rome LLP
BlackRock, Inc. (NYSE: BLK)
Blue Fish Holdings Establishment

Bocas Fruit Co. L.L.C.
In Re: Chiquita Brands Int’l., Inc.
Boies Schiller & Flexner, LLP, Fort Lauderdale
Boies Schiller & Flexner, LLP, Miami
Boies Schiller & Flexner, LLP, New York
Boies Schiller & Flexner, LLP, Orlando
Bronson, Ardith
Brundicorpi S.A.
Cadavid Londoño, Paula
Carrillo, Arturo J.
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 Sàrl

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 España, S.A.
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 Comercializaçao De Fruta,

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
Cioffi, Michael
Coast Citrus Distributors Holding Company

Cohen, Millstein, Sellers & Toll, PLLC
Collingsworth, Terrence P.
Compañía Agrícola de Nipe, S.A.
Compañía Agrícola de Rio Tinto
Compañía Agrícola del Guayas
Compañía Agrícola e Industrial Ecuaplantation, S.A.
Compañía Agrícola Sancti-Spiritus, S.A.
Compañía Bananera Atlántica Limitada
Compañía Bananera Guatemateca Independinte, S.A.
Compañía Bananera La Estrella, S.A.
Compañía Bananera Los Laureles, S.A.
Compañía Bananera Monte Blanco, S.A.
Compañía Caronas, S.A.
Compañía Cubana de Navegación Costanera
Compañía Frutera América S.A.
Compañía La Cruz, S.A.
Compañía Mundimar, S.A.
Compañía Productos Agrícolas de Chiapas, S.A. de C.V.
Compañía Tropical de Seguros, S.A.
Conrad & Scherer LLP

Costa Frut S.A.C.
Covington & Burling LLP
Danone Chiquita Fruits SAS
Dante, Frank
Davies, Patrick
De La Calle Restrepo, José Miguel
De La Calle Londoño y Posada Abogados
DeLeon, John
Dimensional Fund Advisors LP
DLA Piper
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.
Friedheim, Cyrus
Frutas Elegantes, S. de R.L. de C.V.
Fundación Para El Desarrollo de Comunidades Sostenibles en el

Valle de Sula
G & V Farms, LLC
G W F Management Services Ltd.
Garland, James
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
Hills, Roderick, the Estate of
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.
Jones, Stanton
Keiser, Charles
King, William B.
Kistinger, Robert
Lack, Walter J.
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.
Olson, Robert
O'Melveny & Meyers
Ordman, John
Parker Waichman LLP
Philips, Layn
Prías Cadavid Abogados
Prías, Juan Carlos
Priedheim, Alissa
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.
Ronald Guralnick, P.A.
Scarola, Jack
Searcy Denney Scarola Barnhart & Shipley, P.A.
Seguridad Colosal, S.A.
Servicios Chiquita Chile Limitada
Servicios de Logística Chiquita, S.A.

Servicios Logísticos Chiquita, S.R.L
Servicios Proem Limitada
Silbert, Earl
Skinner, William
Sperling, Jonathan
Spiers N.V.
Sprague, Ashley M.
St. James Investments, Inc.
Stewart, Thomas
Stubbs, Sidney
Tela Railroad Company Ltd.
The Vanguard Group
TransFRESH Corporation
Tsacalis, William
UNIPO G.V., S.A.
V.F. Transportation, L.L.C.
Verdelli Farms, Inc.
Western Commercial International Ltd.
Wichmann, William J.
Wiesner & Asociados Ltda. Abogados

Wiesner, Eduardo A.
Wilkins, Robert
Willkie Farr & Gallagher
Wolf, Paul
Wolosky, Lee S.
Zack, Stephen N
Zhejiang Chiquita-Haitong Food Company Limited
Zuleta, Alberto
Certification
I hereby certify that to the best of my knowledge, the above is a complete

list of persons having an interest in this case.
/s/ Paul Wolf

________________________
Paul Wolf, D.C. Bar #480285
Attorney for Appellants
Doe 378 and Ludy Rivas Borja
November 12, 2019

ARGUMENT
The Court should deny the Motion because the intervenors have no
legitimate interest in this litigation of their own, and are merely working around
the court-ordered page limit on the non-Wolf Appellants' Opening Brief, which
was already a lot bigger than it had to be. The Court should discourage this
litigation tactic by denying the Motion. Instead, it should consider the arguments
made by attorneys with power of representation over actual plaintiffs in this
action.1
Moreover, the proposed amicus curiae brief adds nothing of substance to the
arguments already briefed by the Appellants. Undersigned counsel briefed the
"totality of the evidence" issue in his Opening Brief, filed on March 5, 2020, on
pages 19-21. ("The District Court erred by not considering the totality of the
evidence as a whole.") The intervenors' arguments are worse than cumulative,
though, because they're based on tainted evidence obtained through bribes, or the
promise of bribes. Worse than that is the fact that the bribery wasn't disclosed.
1
Undersigned counsel represents not only Does 1-976, but also Does 1-144, Does
1-677, and about 1,000 other "cases" in the MDL, with cases defined as injuries or
deaths, rather than claims made by named plaintiffs, of which there are often many
per case. This appears to be about half of the total number of cases in the MDL,
although the non-Wolf Appellants would never comply with the District Court's
orders to state how many cases they have. In contrast, Attorney Hoffman's
complaint lists half a dozen cases, and makes class action claims. A motion for
class certification of this mass tort case was denied by the District Court on May
31, 2019. See Order, DE 2471.
1
A. The intervenors' arguments are based on tainted evidence that

shouldn't even be considered.
The reason the non-Wolf Appellants don't want us to communicate with the
Court is that we've been complaining for years about the bribery of important
witnesses in the case. The Court of Appeals isn't supposed to know about this.
Nowhere in the non-Wolf Appellants' 144 page Opening Brief is the witness
bribery controversy disclosed. A keyword search of this document for "Hasbún"
results in 27 hits. A search for "Mangones" yields 52 hits. Their names appear
everywhere in the brief, which relies on tainted evidence to argue, over and over,
that the testimony of paramilitary commanders should be sufficient to survive
summary judgment.
Exhibit 1, attached hereto, is a page from the deposition of Mr. Hasbun, in
which he testifies about his understanding of his compensation for his testimony.
He thought he was supposed to get between $3-5 million dollars. Id. This
deposition is marked as highly confidential, and was filed under seal in the District
Court as a matter of course. Undersigned counsel is forced to disclose it.
Otherwise, yet another fraud will be perpetrated on yet another court. Is the Court
of Appeals supposed to decide this case without knowing that one party's
arguments are based almost entirely on the testimony of someone in prison who
thought he was going to get $3-5 million dollars? Shouldn't it be mandatory to
disclose this information to the Court? Isn't it a fraud on the Court to not disclose
2
it? The public also has the right to know about it, as do the plaintiffs themselves,
and there is no way to notify thousands of people of something without making the
information public. The disclosed information is limited to a small part of the
transcript, which relates only to the amount of Mr. Hasbun's compensation. It
clearly falls within the standard for the crime-fraud exception set forth in
Drummond Co. v. Conrad & Scherer, LLP, 885 F.3d 1324 (2018). Although the
disclosure does violate the terms of the protective order below, undersigned
counsel never agreed to keep quiet about witness bribery, and the District Court
only ordered that the time and place of the deposition would be confidential, for
reasons of security. Also, it's just not right to withhold this information from the
Court of Appeals.
Attached hereto as Exhibit 2 is the declaration of Jose Gregorio Mangones
Lugo in fraudulent litigation against Dole. Mangones alleges that both Chiquita
and the Dole Food Company provided him with the names of people to kill. Id. at
9. ("My men were contacted on a regular basis by Chiquita or Dole administrators
to respond to a criminal act or address some other problems. We would also get
calls from the Chiquita and Dole plantations identifying people as 'security
problems' or just 'problems.' Everyone knew this meant we were to execute the
identified person.") This is unbelievable, and evidence produced in discovery
3
showed that attorneys wrote a script for his testimony. Does 1-976 are suing
Chiquita for negligence, and don't want or need this kind of testimony in their trial.
Exhibit 3 is a Memorandum Opinion in Drummond v. Collingsworth,
authored by Judge Proctor in the Northern District of Alabama. It is one of the
more dramatic opinions out there, citing Lewis Carroll's Alice in Wonderland,
quoting comedian Steve Martin (the "I forgot" defense) and suggesting the case
would make a good subject for a John Grisham novel. Id. Adding to the drama is
the mysterious spoliage of many years of Attorney Collingsworth's emails, and an
ongoing battle with a Special Master over whether documents are "related to" or
"in furtherance of" defrauding the court. The 11th Circuit's ruling on the crime-
fraud exception has already been cited many times, even in other circuits, and has
rapidly become an imporant precedent nationwide. See Drummond Co. v. Conrad
& Scherer, LLP, 885 F.3d 1324 (2018) (crime fraud exception); Drummond Co. v.
Collingsworth, 816 F.3d 1319 (11th Cir. 2016) (Attorney Scarola in instant case
ordered to produce witness payment documents to Drummond). This case,
involving both Attorney Collingsworth and his employer, Conrad & Scherer, is set
for trial in April of 2021.
4
The "non-Wolf" Appellants' legal strategy has been to pay imprisoned
paramilitary commanders hundreds of thousands of dollars2 to testify that they
gave the orders to kill particular (bellwether) plaintiffs. This misguided idea is
based on a misunderstanding of the law. The Appellants don't have to show an
individualized intent to kill particular plaintiffs. They need only prove negligence.
Their strongest arguments have always been the substantial factor test, and joint
and several liability. The other claims, under the Torture Victim Protection Act, are
harder to prove, and mainly important to plaintiffs who missed D.C.'s three year
statute of limitations for ordinary negligence. Yet even for those claims, the
defendants are liable as co-conspirators, or aiders and abetters, and don't have to
pay someone in prison to testify that he personally gave the order.
2
This includes Jose Gregorio Mangones Lugo and Raul Emilio Hasbun Mendoza
in particular. Both are convicted AUC terrorists who spent many years in prison.
Various drafts of a contract to employ Mr. Hasbun as an "expert" were produced in
discovery, for a sum of $150,000 U.S. dollars, and emails suggesting an amount of
$200,000. However, in his deposition of Feb. 1, 2019, Hasbun disputed this, and
testified that his understanding was that he would receive between $3-5 million
dollars, depending on the amount of the settlement in the case. See Exhibit 1
attached hereto. Mangones Lugo was also used in fraudulent litigation against
Dole in California, which was voluntarily dismissed once another paramilitary
witness, Adolfo Enrique Guevara Cantillo, took out his Blackberry device during
his deposition and showed text messages offering him money in exchange for
helpful testimony. See Gomez et al v Dole, Case No, BC412620 in the Superior
Court of California, LA County. The conspiracy isn’t limited to these two other
cases, though, and apparently involved others that were supported by the testimony
of AUC members.
5
As outrageous as this may sound,3 these are business practices repeated over
and over by attorneys who portray themselves as human rights defenders. Suing a
wealthy corporation for something they didn't actually do doesn't count as human
rights work. Neither does paying imprisoned criminals to link corporations to
horrendous atrocities. The effect is to deflect blame from the real culprits onto the
board of directors of some corporation that has no idea what even happened. It's a
sad fact that bar counsel don't police this area of law, which is riddled with fraud.
B. The intervenors have no special interest in the litigation.
Court generally require an amicus to “ha[ve] a special interest that justifies
his having a say” in the litigation. Strasser v. Doorley, 432 F.2d 567, 569 (1st Cir.
1970); Neonatalogy Assocs., P.A. v. Comm’r, 293 F.3d 128, 132–33 (3d Cir.
2002) (an amicus must show “(1) an adequate interest, (2) desirability, and (3)
relevance”). In Neonatalogy, [then] Judge Alito found an adequate interest where
the amici were injured in the same incident, but declined to release their claims and
participate in a settlement, and filed claims in a different court instead. Id. In the
instant case, the intervenors are attorneys with no power of representation over any
person with interests in this case.
3
Judge Proctor has held that the conspiracy is ongoing, and allowed discovery of
attorney work product, including of Attorney Brad Smith, who represented
Collingsworth in the RICO action and whose own work was held to be in
furtherance of a continuing fraud on the court. Attorney Smith took the deposition
of undersigned counsel in the Drummond case.
6
F.R.A.P. 29(a)(3)(A)-(B) requires a potential amicus appearing without
party consent to provide a statement of interest to justify their position. According
to the amici, they have tremendous credentials, "and are concerned that upholding
the District Court’s ruling will undermine the well-established evidentiary
standards that are regularly utilized in [other human rights] litigation, both in the
United States and in international tribunals. Amici’s interest is in ensuring bedrock
principles of evidence common to complex litigation, particularly those involving
mass atrocity, are maintained." Proposed Amicus Brief at 3. This is not a
cognizable interest in the litigation.4
For example, providing legal representation pursuant to a statute doesn't
entitle an organization to file an amicus brief in a case challenging that statute. See
Donovan v. Gillmor, 535 F. Supp. 154, 159 (N.D. Ohio 1982). It's not unlike the
problem of standing that the cross-appellants have in this case. They want to argue
standing based on collateral estoppel effects on other cases, even though they won
and have nothing to appeal. They may not agree with the reasoning used by the
district court to reach its decision, but this is a textbook example of a person
without standing.
4
By intervening as purported amici, the Movants expose themselves to discovery
of their interest in the litigation. See FRCP 30(a)(2)(A); 3 Michael Dore, Law of
Toxic Torts § 22:10 (2018) (“Depositions of third parties are available under the
Federal Rules without any showing of special circumstances, as long as the number
of depositions does not exceed ten per side.”). However, this should not be
necessary since the burden is on the Movants to prove their legal interest.
7
The basic principle is that the issues raised in the litigation have to actually
affect the proposed amicus’ legal interests. See Massachusetts v. U.S. Dep’t of
Health & Human Servs., 2010 WL 1667622 (D. Mass. Apr. 22, 2010) (denying a
motion for leave to file an amicus brief for, inter alia, a failure to articulate a
special interest in the issues raised in the lawsuit).
C. The intervenors are alter egos of counsel for the non-Wolf

Appellants.
It should come as no surprise that the same attorneys who have bribed or
offered bribes of millions of dollars to Colombian paramilitaries for false
testimony would think nothing of organizing a group of colleagues to appear as
persons with their own, separate interests in the litigation. This isn't a clinic to
provide human rights credentials to students of the Harvard Law School. When
they apply to the bar and are evaluated for character and fitness, I hope they
mention their participation in a conspiracy to defraud this Court, by not mentioning
in their brief that the testimony relied on was tainted by bribery. They are starting
their careers off on the wrong foot. How did these privileged, ivy-league students
become entitled to speak on behalf of people murdered for their alleged support of
communist guerrillas? The testimony of important witnesses was ruined. The
students put their names on a well-known witness bribery conspiracy as if they
believed it would bring them prestige.
8
The Court has noted that parties frequently solicit amicus briefs as a means
to avoid court-imposed page limitations. Glassroth v. Moore, 347 F.3d 916 (11th
Cir. 2003) "It comes as no surprise to us that attorneys for parties solicit amicus
briefs in support of their position, nor are we shocked that counsel for a party
would have a hand in writing an amicus brief. In fact, we suspect that amicus
briefs are often used as a means of evading the page limitations on a party's briefs.
Id. at 919, citing Voices for Choices v. Illinois Bell Tel. Co., 339 F.3d 542, 544
(7th Cir.2003) (Posner, J.) ("[A]micus briefs, often solicited by parties, may be
used to make an end run around court-imposed limitations on the length of parties'
briefs."). Clearly this is what has happened here, and should not be condoned.
D. The intervenors' arguments address an issue that has already

been briefed by an attorney with real power of representation.
The non-Wolf Appellants could have joined in the arguments made by
undersigned counsel on pages 19-21 of our Opening Brief, or copied some of them
into their own Opening Brief, which was 144 pages long and didn't need nearly
that much space. Instead, they assigned part of their brief to the intervenors, in
defiance of the court-ordered page limit, which was already extended for them.
The amicus brief covers ground that has already been briefed, with the correct
citations that the Court should use.
9
Conclusion
For the foregoing reasons, the Court should DENY Attorney Claret Vargas'
Motion to file an amicus curiae brief in this appeal.
Respectfully submitted,
/s/ Paul Wolf

________________________
Paul Wolf, DC Bar #480285
Attorney for Does 1-976
June 6, 2020
Certificate of Service
I hereby certify, that on this 6th of June, 2020, I filed the foregoing response
and its three associated exhibits with the Clerk of the Court using the Court's
Electronic Case Filing (ECF) system, which will send notices to all counsel
entering appearances in this case.
/s/ Paul Wolf

_______________
Paul Wolf
Certificate of Compliance
Pursuant to FRAP 27 and 32(g)(1), I hereby certify that this response

complies with the type-limitation of 5,200 words, and contains 2,445 words,
excluding the caption and certifications.
/s/ Paul Wolf

_______________
Paul Wolf
10

Response in Opposition To File Amicus Brief

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Case: 19-13926 Date Filed: 06/08/2020 Page: 1 of 23

Case No. 19-13926-C

UNITED STATES COURT OF APPEALS

IN RE: CHIQUITA BRANDS INTERNATONAL, INC.,

On Appeal from the United States District Court

APPELLANTS DOE 378 AND DOE 840'S RESPONSE IN

Paul Wolf, DC Bar #480285

CERTIFICATE OF INTERESTED PERSONS

attorneys, persons, associations of persons, firms, partnerships, or corporations

of the particular case on appeal, including subsidiaries, conglomerates, affiliates,

known to Appellants, are as follows:

1. Doe 378, whose identity remains confidential under a Protective Order of

2. The other plaintiffs in the complaints filed by undersigned counsel in the

Southern District of Florida, in Case Nos. 08-80465, 10-80652, 11-80404, 11-

80405 and 17-cv-80475. Undersigned counsel represents the legal heirs of

interest in this appeal.

3. Additional interested parties are:

Agrícola Longaví Limitada

Agrícola Santa Marta Limitada

Agroindustria Santa Rosa de Lima, S.A.

Alamo Land Company

American Produce Company

Americana de Exportación S.A.

Arnold & Porter

Associated Santa Maria Minerals

Barbush Development Corp.

Bienes Del Rio, S.A.

Blank Rome LLP

BlackRock, Inc. (NYSE: BLK)

Blue Fish Holdings Establishment

Bocas Fruit Co. L.L.C.

In Re: Chiquita Brands Int’l., Inc.

Boies Schiller & Flexner, LLP, Fort Lauderdale

Boies Schiller & Flexner, LLP, Miami

Boies Schiller & Flexner, LLP, New York

Boies Schiller & Flexner, LLP, Orlando

Cadavid Londoño, Paula

C.C.A. Fruit Service Company Limited

Centro Global de Procesamiento Chiquita, S.R.L.

Charagres, Inc., S.A.

Chiquita (Canada) Inc.

Chiquita (Shanghai) Enterprise Management Consulting Co., Ltd.

Chiquita Banana Company B.V.

Chiquita Brands International Foundation

Chiquita Brands International Sàrl

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 España, S.A.

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.