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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 1:20-cv-22463

ASHLEY HODSON, 

Plaintiff,

v.

MSC CRUISES, S.A., 

Defendant. 

__________________________________/ 

COMPLAINT FOR DAMAGES 

AND DEMAND FOR TRIAL BY JURY

Plaintiff, ASHLEY HODSON (“Plaintiff”), through undersigned counsel, sues Defendant, 

MSC CRUISES, S.A. (“Defendant”), and demands trial by jury, stating as follows:

PARTIES AND JURISDICTION

1. Plaintiff seeks damages in excess of $75,000.00, exclusive of interest, costs and

attorney’s fees.

2. This Court has admiralty and maritime jurisdiction pursuant to 28 U.S.C.§ 1333 as

the causes of action asserted are maritime torts. 

3. This Court has Diversity Jurisdiction pursuant to 28 U.S.C. § 1332, as the matter in

controversy exceeds the sum or value of $75,000.00, exclusive of interest and costs, and is between 

citizens of different States and/or citizens of a State and citizens or subjects of a foreign state. 

4. Suit is filed in Federal Court because of the federal forum selection clause in the

Passenger Contract Ticket issued by the Defendant.

5. Plaintiff is sui juris and is a resident and citizen of Florida.

6. Defendant is a foreign corporation who is authorized to conduct and who does

conduct business in the State of Florida, who at all times material hereto was and is doing business 

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in Broward County, Florida, and who maintains its corporate headquarters and principal place of 

business in Broward County, Florida, and Defendant is a citizen of the State of Florida.

7. Plaintiff is entitled to a jury trial pursuant to Leslie v. Carnival Corp., 22 So. 3d 

561,562 (Fla. 3d DCA 2008).

8. Defendant, at all times material hereto, personally or through an agent, in the County 

and in the District in which this Complaint is filed:

a. Operated, conducted, engaged in or carried on a business venture in thisstate

and/or county; and/or

b. Had an office or agency in this state and/or county; and/or

c. Engaged in substantial activity within this state; and/or

d. Committed one or more of the acts stated in Florida Statutes, Sections 

48.081, 48.181 or 48.193.

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

been waived, or do not apply.

FACTUAL ALLEGATIONS

10. At all times material hereto, Defendant, MSC CRUISES, S.A., owned, operated, 

managed, maintained, and/or controlled the vessel, the MSC Seaside.

11. On or about September 1, 2019 Plaintiff was a lawfully fare paying passenger aboard 

Defendant’s cruise ship vessel, the MSC Seaside.

12. On or about September 1, 2019, as Plaintiff descended the stairs from deck 17 to deck 

16 of the MSC Seaside in a normal and proper manner, she slipped and/or tripped on a wet, slippery,

water lodged, wet, deformed, warped, uneven, distorted, bunched up, and/or separated surface that

was not objectively reasonably perceivable. There were people with wet cloths/swimsuits using 

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the subject stairs, and these people were not required to dry before entering the interior of the ship 

and/or using the stairs, and there were no adequate measures and/or adequate devices for these 

people to dry before entering the interior of the ship and/or using the stairs. The area was also noisy 

from a nearby arcade, and the area was unreasonably crowded. Moreover, the lighting was 

inadequate. Furthermore, the handrail was inadequate to prevent or mitigate Plaintiff’s fall. As a 

result of the fall, the Plaintiff suffered traumatic injuries that included, but are not limited to, 

multiple tibia, ankle, and other fractures. However, the ship’s medical center failed to diagnose all 

of Plaintiff’s injuries, its personnel wrapped Plaintiff’s leg incorrectly, its ship doctor failed to 

remedy this incorrect wrapping, it did not take adequate measures to prevent water from getting 

into Plaintiff’s splint/wrapping, it failed to give adequate pain medicine, it failed to properly 

administer and/or continue to administer medicine and/or treatment for blood clots, it failed to 

provide Plaintiff with an adequate wheelchair to use initially when it treated plaintiff, and it failed 

to provide adequate care for Plaintiff’s injuries and failed to provide adequate follow up care, 

causing further injuries and/or worsening/prolonging Plaintiff’s injuries. Plaintiff was also not 

initially provided with an adequate handicap room, and Plaintiff had to endure additional pain, 

suffering, and other complications from having to maneuver in a non-handicap room. 

COUNT I –

NEGLIGENCE

Plaintiff incorporates by reference and re-alleges as though originally alleged herein the 

allegations of paragraphs 1 through 12 and further alleges:

13. Defendant, MSC CRUISES, S.A., owed Plaintiff the duty to exercise reasonable care 

under the circumstances for the safety of its passengers. 

14. This duty includes, but is not limited to, the duty to provide its passengers reasonable 

care to inspect for, and resolve or repair dangerous, hazardous, and/or risk- creating conditions 

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that passengers, including the Plaintiff, will likely encounter.

15. This duty also includes, but is not limited to, the duty to maintain Defendant’s ship in 

a reasonably safe condition for the use and enjoyment of its passengers

16. This duty also includes, but is not limited to, the duty to warn passengers of hazards 

which passengers may reasonably be expected to encounter.

17. At all times material hereto, Defendant, through its vessel, crew, agents, employees, 

staff, and/or representatives, who were acting in the course and scope of their employment and/or 

agency with the Defendant, breached the duty of reasonable care owed to the Plaintiff and were 

negligent in one or more of the following ways: 

a. Failing to keep and maintain the stairways, and the adjacent areas, including the

handrails, in a reasonably safe condition, so as to adequately prevent and/or 

mitigate hazards to its passengers; and/or

b. Failing to inspect, clean, keep and maintain the subject area in a reasonably safe 

condition; and/or;

c. Failing to provide adequate lighting in the subject area to enable passengers to 

notice any hazards;

d. Failing to take proper precautions for the safety of the passengers entering the 

subject area; and/or

e. Failing to warn Plaintiff of the risk-creating and/or hazardous conditions of its 

stairways, and the adjacent areas; and/or

f. Failing to have adequate policies and procedures in place for inspection, 

cleaning and maintenance of its stairways, and the adjacent areas, including the 

handrails; and/or

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g. Creating a risk-creating condition and/or failing to remedy a risk-creating 

condition which was known by the Defendant and which in the exercise of 

reasonable care should have been known by the Defendant; and/or

h. Negligently designing and/or approving/accepting/failing to object to the design 

of the MSC Seaside’s stairways and the adjacent areas (this includes, but is not 

limited to, the handrails and metal strips on the subject stairways); and/or

i. Allowing and/or failing to prevent people with wet swimsuits/cloths to use the 

subject stairs, and/or failing to take adequate measures and/or failing to have

adequate devices and/or measures to dry them before entering the interior of the 

ship and/or using the stairs; and/or

j. Failing to adequately train its crew to keep its stairways, and the adjacent areas 

clean and free of hazards; and/or

k. Failing to employ sufficient crewmembers or adequately trained crewmembers 

to properly supervise, inspect, repair, clean, and maintain the area of the ship 

where Plaintiff’s incident occurred, and/or

l. Failing to treat its stairways, and adjacent areas to prevent them from becoming 

unreasonable slippery, and/or to prevent their carpets/rugs from becoming 

unreasonably water lodged, wet, deformed, warped, uneven, slippery, distorted, 

bunched up, and/or separated, or otherwise unreasonably dangerous; and/or

m. Failing to comply with applicable industry standards, statutes, or regulations the 

violation of which is negligence per se and/or evidence of negligence; and/or

n. Failing to otherwise maintain the area and the premises in a safe and reasonable 

manner; and/or

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o. Failing to properly and safely instruct passengers traversing the subject area of 

the risks involved; and/or

p. Failing to properly and adequately supervise the passengers traversing the 

subject area; and/or

q. Failing to take proper precautions for the safety of passengers when 

encouraging passengers to traverse the subject area; and/or

r. Failing to promulgate and/or enforce rules, restrictions, or procedures to ensure 

the safety of passengers traversing the subject area; and/or

s. Failing to promulgate and/or enforce rules or procedures to ensure that crew 

members are adequately supervising the subject area; and/or

t. Failing to take/engage proper and reasonable safeguards to prevent passengers 

from being injured while traversing the subject area; and/or

u. Failing to adequately warn passengers of the dangers of traversing wet and/or 

slippery surfaces and/or stairs; and/or

v. Failing to adequately train its employees/agents whose duty it was to warn 

passengers traversing the subject area of the dangers and risks associated with 

the use of the subject area; and/or

w. Failing to adequately convey to passengers the risk of serious injury from 

traversing the subject area; and/or

x. Failing to prevent unreasonable noise in the subject area; and/or

y. Failure to adequately inspect and/or maintain the subject area, so as to ensure 

that the subject area was reasonably safe for passengers to use; and/or

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z. Failing to promulgate and/or enforce adequate policies and/or procedures 

regarding the inspection and/or maintenance to identify and/or warn passengers 

of the risk-creating condition in the subject area; and/or

aa. Failing to control the number of guests in the subject area and the wetness of 

the guests in the subject area; and/or

bb. Through other acts or omissions constituting a breach of the duty to use 

reasonable care which will be revealed through discovery;

18. Defendant’s negligence proximately caused Plaintiff great bodily harm in that, but

for the Defendant’s negligence, Plaintiff’s injuries would not have occurred.

19. Defendant either (a) had actual knowledge of the risk-creating conditions; (b) had

constructive knowledge of the risk-creating conditions; (c) would have had knowledge of the riskcreating conditions had the Defendant implemented proper methods of inspection; and/or (d) created 

the risk-creating conditions.

20. As a result of Defendant’s negligence, Plaintiff suffered severe bodily injury resulting 

in pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment 

of life, expense of hospitalization, medical and nursing care and treatment, lost wages, a lost job 

opportunity that Plaintiff would have otherwise been able to obtain, and loss of future earning 

capacity. 

21. The losses are either permanent or continuing in nature.

22. Plaintiff has suffered these losses in the past and will continue to suffer such losses

in the future.

WHEREFORE, Plaintiff, ASHLEY HODSON, demands judgment against Defendant,

MSC CRUISES, S.A., for damages suffered and costs incurred, as well as for damages and costs that 

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Plaintiff will suffer and incur in the future, as a result of Plaintiff’s bodily injury, pain and suffering, 

disability, disfigurement, scarring, mental anguish, hospitalization, medical care and treatment, nursing 

care and treatment, lost wages, a lost job opportunity that Plaintiff would have otherwise been able to 

obtain, loss of future earning capacity, loss of important bodily functions, and loss of capacity for the 

enjoyment of life; for all court costs, pre- and post-judgment interest, and for any and all other relief 

which the Court deems just or appropriate. In addition, Plaintiff lost the benefit of Plaintiff’s 

vacation, cruise, and transportation costs.

COUNT II 

VICARIOUS LIABILITY AGAINST DEFENDANT

FOR THE NEGLIGENCE OF THE SHIP’S MEDICAL STAFF

Plaintiff incorporates by reference and re-alleges as though originally alleged herein the 

allegations of paragraphs 1 through 12 and further alleges:

23. Defendant, through the ship’s medical staff (including its physicians and nurses), and 

the ship’s crew, owed a duty to exercise reasonable care under the circumstances for the safety of 

its passengers.

24. Such duties include, but are not limited to, providing such medical care and 

assistance as would an ordinarily prudent person under the circumstances.

25. At all times material, the ship’s medical staff (including its physicians and nurses), 

and the ship’s crew, were full time employees and agents of Defendant, subject to its direction 

and control, who were engaged in the activity of discharging Defendant’s obligation to make such 

medical aid and assistance available to its passengers as would an ordinarily prudent person under 

the circumstances.

26. Defendant is estopped to deny that the ship’s medical staff (including its physicians 

and nurses), and the ship’s crew, were its agents and/or employees and/or servants.

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27. Defendant directly paid the ship’s medical personnel and regular crew a salary (i.e., 

payment by time) for their work in the ship’s hospital and in treating passengers.

28. Defendant created, owned, directly provided, and operated, the medical center to be 

used by the ship’s medical personnel and passengers.

29. Defendant pays to stock the medical center with all supplies, medical machinery, 

various medicines, and equipment to be used therein, regularly stocking and restocking same.

30. Defendant collected all medical revenues directly from passengers and generated a 

profit on the sale of medical services, supplies, and equipment made by the ship’s medical 

personnel to the passengers of the vessel.

31. Defendant’s marketing materials described the infirmary in proprietary language.

32. The ship’s medical personnel were members of the ship’s crew; they were subject to 

the ship’s discipline; they were required to wear the ship’s uniforms; they (and, in particular, the 

ship’s physicians) were members of the ship’s officer’s compliment, and at all times they were 

subject to termination, or other discipline, by Defendant.

33. Defendant provided the ship’s medical personnel certain forms of liability insurance 

and/or indemnification rights.

34. Defendant, through the ship’s medical staff (including its physicians and nurses), 

and the ship’s crew, breached its duties, and was negligent by failing to adequately examine, 

diagnose, and/ or treat Plaintiff’s injuries.

35. Furthermore, Defendant, through the ship’s medical staff (including its physicians 

and nurses), and the ship’s crew, breached its duties, and was negligent because the physicians 

and/or other crew members that were responsible for treating Plaintiff lacked adequate experience 

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in treating injuries such as the one Plaintiff suffered.

36. Defendant, through the ship’s medical staff (including its physicians and nurses), 

and the ship’s crew, also breached its duties and was negligent by failing to adequately supply 

and equip its medical center to be able to adequately examine, diagnose, and treat Plaintiff’s 

injuries.

37. Moreover, Defendant, through the ship’s medical staff (including its physicians and 

nurses), and the ship’s crew, breached its duties, and was negligent by failing to take proper 

measures to ensure that Plaintiff was able to obtain the medical treatment Plaintiff needed in a 

reasonable amount of time, and as a result, Plaintiff suffered additional injuries and/or Plaintiff’s 

injuries were aggravated and made worse.

38. Additionally, at all times material hereto, Defendant, through the ship’s medical staff 

(including its physicians and nurses), and the ship’s crew, was careless, negligent, and breached 

its duties as follows:

a. Failing to promptly provide Plaintiff with proper and/or adequate medical 

care and attention;

b. Failing to adequately wrap Plaintiff’s injuries;

c. Failing to adequately remedy the inadequate wrapping of Plaintiff’s 

injuries;

d. Failing to adequately address Plaintiff’s wrapping becoming wet;

e. Failing to timely and properly diagnose and/or assess Plaintiff’s medical

condition;

f. Failing to timely give Plaintiff adequate pain medicine;

g. Failing to properly administer and/or continue to administer medicine 

and/or treatment for blood clots;

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h. Failing to attend to the Plaintiff and Plaintiff’s injuries;

i. Failing to provide reasonable medical care;

j. Failing to properly treat and care for the Plaintiff;

k. Failing to properly examine the Plaintiff’s injuries;

l. Failing to timely provide an adequate wheelchair;

m. Failing to timely provide an adequate a handicap room;

n. Failing to take proper measures to secure adequate treatment for Plaintiff, 

including unreasonably delaying taking measures to secure such adequate 

treatment; and/or

o. Failing to give Plaintiff proper discharge instructions.

39. Under the doctrine of Respondeat Superior, employers are vicariously liable for the 

negligent acts or omissions by their employees and/or other agents within the course of 

employment and/or agency.

40. Defendant is therefore vicariously liable for all injuries and damages sustained by 

Plaintiff as a result of the negligence of the ship’s medical staff (including its physicians and 

nurses), and the ship’s crew.

41. At all times material hereto, the aforementioned acts or omissions on the part of the 

Defendant’s ship’s medical staff (including its physicians and nurses), and the ship’s crew, fell 

below the standard of care.

42. The negligence of Defendant’s ship’s medical staff (including its physicians and 

nurses), and the ship’s crew, proximately caused Plaintiff great bodily harm in that, but for 

Defendant’s negligence, Plaintiff’s injuries would not have occurred and/or said injuries would 

have been substantially lessened.

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43. Defendant, through its employees and agents, to wit, the ship’s medical staff, knew 

or should have known that the medical procedures they employed violated and/or did not meet 

reasonable standards of medical care.

44. As a result of the negligence of Defendant, the Plaintiff was injured about Plaintiff’s 

body and extremity, suffered physical pain, mental anguish, loss of enjoyment of life, disability, 

disfigurement, pain and suffering, aggravation of any previously existing conditions therefrom, 

incurred medical expenses in the care and treatment of Plaintiff’s injuries, suffered physical 

handicap, lost earnings, a lost job opportunity that Plaintiff would have otherwise been able to obtain,

and lost earning capacity, both past and future. The injuries are permanent or continuing in nature 

and Plaintiff will suffer the losses and impairments in the future. In addition, Plaintiff lost the 

benefit of Plaintiff’s vacation, cruise, and transportation costs.

WHEREFORE, the Plaintiff demands judgment for all damages recoverable under the 

law and demands trial by jury.

COUNT III

APPARENT AGENCY AS TO DEFENDANT 

FOR THE ACTS OF THE SHIP’S MEDICAL STAFF

Plaintiff incorporates by reference and re-alleges as though originally alleged herein the 

allegations of paragraphs 1 through 12 and further alleges:

45. At all times material hereto, the ship’s medical staff were represented to the Plaintiff 

and the ship’s passengers as employees and/or agents and/or servants of Defendant, in that:

a. The medical staff wore a ship’s uniform;

b. The medical staff ate with the ship’s crew;

c. The medical staff was under the commands of the ship’s officers;

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d. The medical staff worked in the ship’s medical department;

e. The medical staff was paid a salary by Defendant;

f. The medical staff worked aboard the vessel;

g. The medical staff spoke to the Plaintiff as though they had authority 

to do so by Defendant.

46. At no time did Defendant represent to the Plaintiff in particular, or the ship’s 

passengers in general, in a meaningful way that the vessel’s medical staff were not agents or 

employees of Defendant.

47. At all material times, Plaintiff reasonably relied on the representations to Plaintiff’s 

detriment that the medical staff were employees, and/or agents, and/or servants of Defendant.

48. It was reasonable to believe that the medical staff were Defendant’s agents because 

they wore a ship’s uniform. In addition, at all times material, the medical staff spoke and acted 

as though they were authorized to do so by Defendant.

49. This reasonable reliance was detrimental because it delayed Plaintiff from receiving 

proper medical treatment and/or Plaintiff would not have gone on the subject cruise with 

Defendant had Plaintiff known that the medical staff on the ship were not Defendant’s agents.

50. Defendant is estopped to deny that the medical staff were its apparent agents, and/or 

apparent employees, and/or apparent servants.

51. Defendant had a duty to provide Plaintiff with reasonable care under the 

circumstances and through the acts of its apparent agent breached its duty to provide Plaintiff 

with reasonable care under the circumstances.

52. Plaintiff’s injuries were accelerated due to the fault and/or negligence of Defendant

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through the acts of its apparent agents asfollows:

a. Failing to promptly provide Plaintiff with proper and/or adequate medical 

care and attention;

b. Failing to adequately wrap Plaintiff’s injuries;

c. Failing to adequately remedy the inadequate wrapping of Plaintiff’s 

injuries;

d. Failing to adequately address Plaintiff’s wrapping becoming wet;

e. Failing to timely and properly diagnose and/or assess Plaintiff’s medical

condition;

f. Failing to timely give Plaintiff adequate pain medicine;

g. Failing to properly administer and/or continue to administer medicine 

and/or treatment for blood clots;

h. Failing to attend to the Plaintiff and Plaintiff’s injuries;

i. Failing to provide reasonable medical care;

j. Failing to properly treat and care for the Plaintiff;

k. Failing to properly examine the Plaintiff’s injuries;

l. Failing to timely provide an adequate wheelchair;

m. Failing to timely provide an adequate a handicap room;

n. Failing to take proper measures to secure adequate treatment for Plaintiff, 

including unreasonably delaying taking measures to secure such adequate 

treatment; and/or

o. Failing to give Plaintiff proper discharge instructions.

53. As a result of the negligence of Defendant, the Plaintiff was injured about Plaintiff’s 

body and extremity, suffered physical pain, mental anguish, loss of enjoyment of life, disability, 

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disfigurement, pain and suffering, aggravation of any previously existing conditions therefrom, 

incurred medical expenses in the care and treatment of Plaintiff’s injuries, suffered physical 

handicap, lost earnings, a lost job opportunity that Plaintiff would have otherwise been able to obtain,

and lost earning capacity, both past and future. The injuries are permanent or continuing in nature 

and Plaintiff will suffer the losses and impairments in the future. In addition, Plaintiff lost the 

benefit of Plaintiff’s vacation, cruise, and transportation costs.

WHEREFORE, the Plaintiff demands judgment for all damages recoverable under the 

law and demands trial by jury.

COUNT IV

ASSUMPTION OF DUTY AS TO DEFENDANT

NEGLIGENCE OF THE SHIP’S MEDICAL STAFF

Plaintiff incorporates by reference and re-alleges as though originally alleged herein the 

allegations of paragraphs 1 through 12 and further alleges:

54. Defendant owed Plaintiff the duty to exercise reasonable care under the 

circumstances for the safety of its passengers.

55. Such duties include, but are not limited to, providing such medical care and

assistance as would an ordinarily prudent person under the circumstances.

56. Defendant elected to discharge this duty by having Plaintiff seen by its own ship’s 

physicians and/or other crew members.

57. As such, Defendant voluntarily assumed a duty for the benefit of Plaintiff to use 

reasonable care in the provision of medical services to the Plaintiff.

58. Defendant breached its duties, and was negligent by failing to adequately examine, 

diagnose, and/or treat Plaintiff’s injuries.

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59. Furthermore, Defendant breached its duties, and was negligent because the 

physicians and/or other crew members that were responsible for treating Plaintiff lacked adequate 

experience in treating injuries such as the one Plaintiff suffered.

60. Defendant also breached its duties and was negligent by failing to adequately supply 

its medical center to be able to adequately examine, diagnose, and treat Plaintiff’s injuries.

61. Defendant breached its duties and was negligent by failing to take proper measures 

to ensure that Plaintiff was able to obtain the medical treatment Plaintiff needed in a reasonable 

amount of time, and as a result, Plaintiff suffered additional injuries and/or Plaintiff’s injuries 

were aggravated and made worse.

62. Additionally, at all times material hereto, Defendant was careless, negligent, and 

breached its duties as follows:

a. Failing to promptly provide Plaintiff with proper and/or adequate medical 

care and attention;

b. Failing to adequately wrap Plaintiff’s injuries;

c. Failing to adequately remedy the inadequate wrapping of Plaintiff’s 

injuries;

d. Failing to adequately address Plaintiff’s wrapping becoming wet;

e. Failing to timely and properly diagnose and/or assess Plaintiff’s medical

condition;

f. Failing to timely give Plaintiff adequate pain medicine;

g. Failing to properly administer and/or continue to administer medicine 

and/or treatment for blood clots;

h. Failing to attend to the Plaintiff and Plaintiff’s injuries;

i. Failing to provide reasonable medical care;

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j. Failing to properly treat and care for the Plaintiff;

k. Failing to properly examine the Plaintiff’s injuries;

l. Failing to timely provide an adequate wheelchair;

m. Failing to timely provide an adequate a handicap room;

n. Failing to take proper measures to secure adequate treatment for Plaintiff, 

including unreasonably delaying taking measures to secure such adequate 

treatment; and/or

o. Failing to give Plaintiff proper discharge instructions.

63. At all times material hereto, the aforementioned acts or omissions on the part of 

Defendant fell below the standard of care.

64. Defendant’s negligence proximately caused Plaintiff great bodily harm in that, but for

Defendant’s negligence, Plaintiff’s injuries would not have occurred, would have been 

substantially lessened, and/or would not have been aggravated.

65. Defendant, through its employees and agents, to wit, the ship’s medical staff, knew, or 

should have known, that the medical procedures they employed violated reasonable standards of 

medical care.

66. As a result of the negligence of Defendant, the Plaintiff was injured about Plaintiff’s 

body and extremity, suffered physical pain, mental anguish, loss of enjoyment of life, disability, 

disfigurement, pain and suffering, aggravation of any previously existing conditions therefrom, 

incurred medical expenses in the care and treatment of Plaintiff’s injuries, suffered physical 

handicap, lost earnings, a lost job opportunity that Plaintiff would have otherwise been able to obtain,

and lost earning capacity, both past and future. The injuries are permanent or continuing in nature 

and Plaintiff will suffer the losses and impairments in the future. In addition, Plaintiff lost the 

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benefit of Plaintiff’s vacation, cruise, and transportation costs.

WHEREFORE, the Plaintiff demands judgment for all damages recoverable under the 

law and demands trial by jury.

DEMAND FOR JURY TRIAL

Plaintiff, ASHLEY HODSON, demands trial by jury on all issues so triable.

Dated: June 15, 2020.

Respectfully submitted,

/s/ Spencer M. Aronfeld 

Spencer M. Aronfeld, Esq.

Florida Bar No.: 905161

aronfeld@Aronfeld.com 

Abby H. Ivey, Esq.

Florida Bar No.: 1002774

aivey@aronfeld.com

Matthias M. Hayashi

Florida Bar No.: 115973

mhayashi@aronfeld.com

ARONFELD TRIAL LAWYERS

One Alhambra Plaza, Penthouse

Coral Gables, Florida 33134

P: (305) 441.0440

F: (305) 441.0198

Attorneys for Plaintiff

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