UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION

CASE NO.:

RAMONA MOSES,

Plaintiff, 

v.

ROYAL CARIBBEAN CRUISES, 

LTD., a Liberian Corporation,

Defendant.

/

COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

Plaintiff, RAMONA MOSES, by and through the undersigned attorney, hereby files this 

Complaint for Damages and Demand for Jury Trial and sues Defendant, ROYAL CARIBBEAN 

CRUISES, LTD., a Liberian Corporation (hereinafter “RCCL”), and alleges as follows:

GENERAL ALLEGATIONS

1. This is an action seeking damages in excess of seventy-five thousand dollars 

($75,000.00), exclusive of interest, costs, and attorneys’ fees.

2. This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1333 and 1332. 

Further, this matter is being filed in the United States District Court for the Southern District of 

Florida located in Miami-Dade County, Florida, as required by the forum selection clause 

contained within the Cruise Ticket Contract issued by Defendant. Upon information and belief, 

Defendant is in possession of a copy of the subject Ticket Contract.

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3. At all times material hereto, RAMONA MOSES is and was a resident of the state 

of California.

4. At all times material hereto, RCCL was incorporated in Liberia, and has its principal 

place of business in Miami, Florida.

5. All conditions precedent for filing and maintaining this action have been fulfilled, 

have been waived, or do not apply.

6. At all times material hereto, RCCL owned, operated, maintained, managed, and/or 

controlled the cruise ship the RCCL Liberty of the Seas.

7. On or about May 20, 2019, RAMONA MOSES was a fare-paying passenger aboard 

the RCCL Liberty of the Seas. 

8. On or about May 20, 2019, RAMONA MOSES was walking in a high-traffic

passenger area when she slipped and fell on the unreasonably slippery interior flooring near Guest 

Services that had water and/or another liquid substance on it. 

9. As a result of this incident, RAMONA MOSES sustained serious injury. 

10. NOTICE: RCCL knew or should have known that the subject flooring was 

unreasonably dangerous as a result of its knowledge of prior similar incidents that occurred on that 

flooring material aboard the Liberty of the Seas and other vessels in its fleet of cruise ships. See 

Cosmo v. RCCL Corporation, 272 F.Supp.3d 1336 (S.D. Fla. 2017)(J. Scola). Moreover, upon 

information and believe RCCL has received several passenger complaints/comments about the 

unreasonably dangerous nature of the interior flooring in its fleet. In addition, upon information 

and belief, RCCL knew or should have known that the interior flooring on Liberty of the Seas was

unreasonably dangerous as a result of its participation design and construction of the Liberty of the 

Seas. See Groves v. Royal Caribbean Cruises, Ltd., 463 F. Appx. 837 (11th Cir. 2012). RCCL

knew or should have known of the unreasonably dangerous condition of its interior flooring 

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surfaces because the design and operation methods used by RCCL for these interior flooring 

surfaces deviated from accepted industry safety practices and standards. See, Holderbaum v. 

RCCL, 87 F. Supp. 3d. 1345 (S.D. Fla. 2015)(J. Lenard). In addition, RCCL knew or should have 

known of the dangerous liquid substance on the floor because it had employees in the area and 

there was sufficient time for the employees to appropriately warn of and clean the dangerous 

substance. See Thomas v. NCL (Bahamas) Ltd., 203 F. Supp. 3d 1189, 1192 (S.D. Fla. 2016).

COUNT I

NEGLIGENT FAILURE TO WARN

Plaintiff hereby adopts and incorporates paragraphs 1 through 10 as if fully set-forth herein, 

and alleges as follows:

11. DUTIES OWED: At all times material hereto, RCCL had the duty to use reasonable 

care under the circumstances, and to maintain and operate its vessel, the Liberty of the Seas, in a 

reasonably safe condition and manner. See, Keefe v. Bahama Cruise Line, Inc., 867 F.2d 1318, 

1321 (11th Cir. 1989). Cruise lines owe their passengers a duty to warn of known or foreseeable 

dangers. See, Brown v. RCCL Corporation, 202 F.Supp. 3d 1332 (S.D. Fla. 2016)(J. Ungaro)(citing 

Witover v. Celebrity Cruises, Inc., 161 F. Supp. 3d. 1139, 1146 (S.D. Fla. 2016).

12. RCCL is vicariously liable for the negligent acts and omissions of its employees, 

agents, and/or independent contractors committed during the course and scope of their employment 

with RCCL including their failure to reasonably warn the Plaintiff about the unreasonably 

dangerous nature of the interior flooring when wet.

13. RCCL breached the aforementioned duties of care owed to RAMONA MOSES in 

the following ways:

a. Failing to reasonably warn passengers that the interior flooring

surface becomes unreasonably slippery when wet;

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b. Failing to warn passengers that the floor was wet;

c. Failing to place warning signs on the interior flooring indicating 

that the interior flooring was wet; and

d. Failing to exercise reasonable care under the circumstances;

14. As a direct and proximate result of the aforementioned negligence of RCCL, 

Plaintiff, RAMONA MOSES, was injured, suffered physical impairment and/or disability, mental 

anguish, loss of capacity for the enjoyment of life, pain and suffering, the aggravation of preexisting conditions, inconvenience, permanent disability, loss of earnings and/or wages, loss of 

earning potential, and incurred the costs of reasonable and necessary medical expenses for the 

treatment of her injuries. These losses and injuries are permanent and continuing in nature, and 

Plaintiff will continue to suffer them in the future. 

WHEREFORE, the Plaintiff demands Judgment against the Defendant for damages 

recoverable under the general maritime law and state law including but not limited to economic 

damages including medical, psychological, and other related expenses in the past and in the future; lost 

income in the past and lost income and earning capacity in the future; non-economic damages in the 

past and in the future including pain, suffering, disability, aggravation of a previously existing 

condition, physical impairment, scarring, disfigurement, mental anguish, inconvenience, and loss of 

capacity for the enjoyment of life; all court costs, all interest due under the applicable law including 

interest from the date of the subject incident under General Maritime Law, and any and all other 

damages which the Court deems just or appropriate.

COUNT II

NEGLIGENT FAILURE TO CLEAN

Plaintiff hereby adopts and incorporates paragraphs 1 through 10 as if fully set-forth herein, 

and alleges as follows:

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15. DUTIES OWED: At all times material hereto, RCCL had the duty to use reasonable 

care under the circumstances, and to maintain and operate its vessel, the Liberty of the Seas, in a 

reasonably safe condition and manner. See, Keefe v. Bahama Cruise Line, Inc., 867 F.2d 1318, 

1321 (11th Cir. 1989). 

16. RCCL is vicariously liable for the negligent acts and omissions of its employees, 

agents, and/or independent contractors committed during the course and scope of their employment 

with RCCL including their failure to reasonably warn the Plaintiff about the unreasonably 

dangerous nature of the interior flooring when wet.

17. RCCL breached the aforementioned duties of care owed to RAMONA MOSES in 

the following ways:

a. Failing to maintain the vessel, including the interior flooring

surface, in a reasonably safe condition by keeping it clean and dry;

b. Failing to take reasonable precautionary measures to prevent water 

and/or other liquid substances from spilling onto the floor in a hightraffic area used by passengers;

c. Failing to take reasonable precautionary measures to prevent water 

and/or other liquid substances from remaining on the floor in a 

high-traffic area used by passengers;

d. Failing to clean the liquid substance on the deck when RCCL, 

through its employees and agents, knew or should have known 

about the existence of the liquid substance on the interior flooring;

and

e. Failing to exercise reasonable care under the circumstances;

18. As a direct and proximate result of the aforementioned negligence of RCCL, 

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Plaintiff, RAMONA MOSES, was injured, suffered physical impairment and/or disability, mental 

anguish, loss of capacity for the enjoyment of life, pain and suffering, the aggravation of preexisting conditions, inconvenience, permanent disability, loss of earnings and/or wages, loss of 

earning potential, and incurred the costs of reasonable and necessary medical expenses for the 

treatment of her injuries. These losses and injuries are permanent and continuing in nature, and 

Plaintiff will continue to suffer them in the future. 

WHEREFORE, the Plaintiff demands Judgment against the Defendant for damages 

recoverable under the general maritime law and state law including but not limited to economic 

damages including medical, psychological, and other related expenses in the past and in the future; lost 

income in the past and lost income and earning capacity in the future; non-economic damages in the 

past and in the future including pain, suffering, disability, aggravation of a previously existing 

condition, physical impairment, scarring, disfigurement, mental anguish, inconvenience, and loss of 

capacity for the enjoyment of life; all court costs, all interest due under the applicable law including 

interest from the date of the subject incident under General Maritime Law, and any and all other 

damages which the Court deems just or appropriate.

COUNT III

NEGLIGENT DESIGN, CONSTRUCTION, AND/OR APPROVAL 

OF THE SUBJECT DECK

Plaintiff hereby adopts and incorporates paragraphs 1 through 10 as if fully set-forth herein, 

and alleges as follows:

19. DUTIES OWED: At all times material hereto, RCCL had the duty to use reasonable 

care under the circumstances, and to maintain and operate its vessel, the Liberty of the Seas, in a 

reasonably safe condition and manner. See, Keefe v. Bahama Cruise Line, Inc., 867 F.2d 1318, 

1321 (11th Cir. 1989). The cruise line had the duty to use reasonable care in designing, constructing, 

and approving the areas of the vessel that the cruise line participated in either designing, 

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construction, or approving. Groves v. Royal Caribbean Cruises, Ltd., 463 F. Appx. 837 (11th Cir. 

2012).

20. RCCL is vicariously liable for the negligent acts and omissions of its employees, 

agents, and/or independent contractors committed during the course and scope of their employment 

with RCCL including their failure to reasonably design, construct the subject area as well as their

negligent approval of the unreasonably dangerous interior flooring surface.

21. RCCL breached the aforementioned duties of care owed to RAMONA MOSES in 

the following ways:

a. Failing to provide a reasonably safe walking space for passengers, 

including RAMONA MOSES, for use under foreseeable 

conditions, including when wet;

b. Failing to provide a walking surface that was reasonably slipresistant under foreseeable operating conditions, including when 

wet;

c. Failing to comply with industry building, construction, design, and 

safety standards;

d. Failing to design a reasonably safe walking space for passengers, 

including RAMONA MOSES; 

e. Approving and implementing the design of the interior flooring, 

including the use of the specific flooring that caused RAMONA 

MOSES’ fall, despite RCCL’s knowledge that this material was 

unreasonably slippery when wet and therefore, unfit for use on an 

interior flooring; and

f. Other acts of negligence to be discovered throughout discovery.

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22. As a direct and proximate result of the aforementioned negligence of RCCL, 

Plaintiff, RAMONA MOSES, was injured, suffered physical impairment and/or disability, mental 

anguish, loss of capacity for the enjoyment of life, pain and suffering, the aggravation of preexisting conditions, inconvenience, permanent disability, loss of earnings and/or wages, loss of 

earning potential, and incurred the costs of reasonable and necessary medical expenses for the 

treatment of her injuries. These losses and injuries are permanent and continuing in nature, and 

Plaintiff will continue to suffer them in the future. 

WHEREFORE, the Plaintiff demands Judgment against the Defendant for damages 

recoverable under the general maritime law and state law including but not limited to economic 

damages including medical, psychological, and other related expenses in the past and in the future; lost 

income in the past and lost income and earning capacity in the future; non-economic damages in the 

past and in the future including pain, suffering, disability, aggravation of a previously existing 

condition, physical impairment, scarring, disfigurement, mental anguish, inconvenience, and loss of 

capacity for the enjoyment of life; all court costs, all interest due under the applicable law including 

interest from the date of the subject incident under General Maritime Law, and any and all other 

damages which the Court deems just or appropriate.

COUNT IV

NEGLIGENT MAINTENANCE OF THE FLOORING SURFACE

Plaintiff hereby adopts and incorporates paragraphs 1 through 10 as if fully set-forth herein, 

and alleges as follows:

23. DUTIES OWED: At all times material hereto, RCCL had the duty to use reasonable 

care under the circumstances, and to maintain and operate its vessel, the Liberty of the Seas, in a 

reasonably safe condition and manner. Carroll v. Carnival Corporation, No. 17-13602 (11th Cir. 

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2020); See, Keefe v. Bahama Cruise Line, Inc., 867 F.2d 1318, 1321 (11th Cir. 1989). 

24. RCCL is vicariously liable for the negligent acts and omissions of its employees, 

agents, and/or independent contractors committed during the course and scope of their employment 

with RCCL including their failure to reasonably warn the Plaintiff about the unreasonably 

dangerous nature of the interior decks when wet.

25. RCCL breached the aforementioned duties of care owed to RAMONA MOSES in 

the following ways:

a. Failing to comply with manufacturer standards/guidelines for cleaning the 

subject interior flooring;

b. Failing to utilize a reasonable and appropriate maintenance practice and 

schedule for the subject flooring material;

c. Failing to resurface the subject flooring material when appropriate;

d. Failing to use a maintenance practice to preserve the slip-resistance of the 

flooring surface as originally installed;

e. Failing to sufficiently de-grease the subject flooring surface, and

f. Failing to use reasonable care in the maintenance of the subject flooring 

material.

26. As a direct and proximate result of the aforementioned negligence of RCCL, 

Plaintiff, RAMONA MOSES, was injured, suffered physical impairment and/or disability, mental 

anguish, loss of capacity for the enjoyment of life, pain and suffering, the aggravation of preexisting conditions, inconvenience, permanent disability, loss of earnings and/or wages, loss of 

earning potential, and incurred the costs of reasonable and necessary medical expenses for the 

treatment of her injuries. These losses and injuries are permanent and continuing in nature, and 

Plaintiff will continue to suffer them in the future.

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WHEREFORE, the Plaintiff demands Judgment against the Defendant for damages 

recoverable under the general maritime law and state law including but not limited to economic 

damages including medical, psychological, and other related expenses in the past and in the future; lost 

income in the past and lost income and earning capacity in the future; non-economic damages in the 

past and in the future including pain, suffering, disability, aggravation of a previously existing 

condition, physical impairment, scarring, disfigurement, mental anguish, inconvenience, and loss of 

capacity for the enjoyment of life; all court costs, all interest due under the applicable law including 

interest from the date of the subject incident under General Maritime Law, and any and all other 

damages which the Court deems just or appropriate.

COUNT V

NEGLIGENT CREATION OF THE DANGEROUS CONDITION

Plaintiff hereby adopts and incorporates paragraphs 1 through 10 as if fully set-forth herein, 

and alleges as follows:

27. DUTIES OWED: At all times material hereto, RCCL had the duty to use reasonable 

care under the circumstances, and to maintain and operate its vessel, the Liberty of the Seas, in a 

reasonably safe condition and manner. Carroll v. Carnival Corporation, No. 17-13602 (11th Cir. 

2020); See, Keefe v. Bahama Cruise Line, Inc., 867 F.2d 1318, 1321 (11th Cir. 1989). 

28. RCCL is vicariously liable for the negligent acts and omissions of its employees, 

agents, and/or independent contractors committed during the course and scope of their employment 

with RCCL including their failure to reasonably warn the Plaintiff about the unreasonably 

dangerous nature of the interior decks.

29. RCCL breached the aforementioned duties of care owed to RAMONA MOSES in 

the following ways:

a. Creating the subject dangerous condition by spilling the liquid substance on the 

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floor;

b. Failing to use reasonable care in pouring champagne for guests which resulted 

in champagne spilling on the floor;

c. Failing to use reasonable care in handling glasses and bottles of champagne 

which resulted in champagne spilling on the floor; and

d. Failing to use reasonable care under the circumstances.

30. As a direct and proximate result of the aforementioned negligence of RCCL, 

Plaintiff, RAMONA MOSES, was injured, suffered physical impairment and/or disability, mental 

anguish, loss of capacity for the enjoyment of life, pain and suffering, the aggravation of preexisting conditions, inconvenience, permanent disability, loss of earnings and/or wages, loss of 

earning potential, and incurred the costs of reasonable and necessary medical expenses for the 

treatment of her injuries. These losses and injuries are permanent and continuing in nature, and 

Plaintiff will continue to suffer them in the future.

WHEREFORE, the Plaintiff demands Judgment against the Defendant for damages 

recoverable under the general maritime law and state law including but not limited to economic 

damages including medical, psychological, and other related expenses in the past and in the future; lost 

income in the past and lost income and earning capacity in the future; non-economic damages in the 

past and in the future including pain, suffering, disability, aggravation of a previously existing 

condition, physical impairment, scarring, disfigurement, mental anguish, inconvenience, and loss of 

capacity for the enjoyment of life; all court costs, all interest due under the applicable law including 

interest from the date of the subject incident under General Maritime Law, and any and all other 

damages which the Court deems just or appropriate.

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FLANAGAN PERSONAL INJURY & 

WRONGFUL DEATH LAW FIRM, P.A.

Counsel for Plaintiff

2 Alhambra Plaza

Suite 620

Coral Gables, Florida 33134 

Tel: (305) 638 – 4143

Fax: (305) 397 - 2636

By: /s/ Michael T. Flanagan

Michael T. Flanagan, Esq. 

Fla. Bar No. 0091072

Primary E-mail: mtf@Florida-Justice.com

Secondary E-mail: mtfassistant@Florida-Justice.com

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