UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO. _______________________

ROSALIND STEPTOE-JACKSON,

Plaintiff,

vs.

PARADISE CRUISE LINE OPERATOR LTD., INC.

d/b/a BAHAMAS PARADISE CRUISE LINE

Defendant.

_______________________________/

COMPLAINT 

COMES NOW the Plaintiff, ROSALIND STEPTOE-JACKSON, by and through the 

undersigned counsel, and hereby allege the following on information and belief:

JURISDICTION AND IDENTIFICATION OF PARTIES

1. At all times material hereto, the Plaintiff, ROSALIND STEPTOE-JACKSON was 

a citizen of the United States and is a resident of Prince George’s County, Maryland, and files 

this Complaint for Damages in an amount in excess of $75,000, exclusive of any fees and court 

costs. This Honorable Court possesses jurisdiction over the instant matter pursuant to the issued 

ticket by Defendant containing a venue clause which requires that all disputes and matters arising 

out of an in connection with cruise and travel associated with the ticket be litigated in the United

States District Court for the Southern District of Florida, in Miami and there is complete 

diversity between the parties, 28 United States District Court, Section 1332.

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2. At all times material hereto, the Defendant, PARADISE CRUISE LINE 

OPERATOR LTD., INC. d/b/a BAHAMAS PARADISE CRUISE LINES (hereinafter referred 

to as BAHAMAS PARADISE), was and is a business entity engaged in the shipping and 

passenger cruise business.

3. At all times material hereto, the Defendant, BAHAMAS PARADISE, was and is 

a corporation engaged in the shipping and passenger cruise business operated by and/or for the 

financial interests and/or benefits of the United States citizens. BAHAMAS PARADISE

maintains a fleet of cruise ships that provide travel and related activities in international waters 

and at seaports in the United States of America and around the world. BAHAMAS PARADISE

provides its passengers with travel packages, which include but are not limited to room and 

board, entertainment, and cruise-sponsored shore excursions at selected ports of call. 

4. At all times material hereto, the Defendant, BAHAMAS PARADISE, owned, 

operated, and managed the vessel Grand Celebration.

FACTS GIVING RISE TO CAUSES OF ACTION

5. At all times material hereto, the Plaintiff, ROSALIND STEPTOE-JACKSON, 

purchased a BAHAMAS PARADISE ticket for a vacation on BAHAMAS PARADISE’S cruise 

ship, Grand Celebration.

6. At all times material hereto, ROSALIND STEPTOE-JACKSON was lawfully and 

legally aboard the Grand Celebration as an invitee and paying passenger with the actual and/or 

constructive consent of BAHAMAS PARADISE to be physically present aboard such vessel. 

7. On or about July 28, 2019, the Plaintiff, ROSALIND STEPTOE-JACKSON, 

aboard the Grand Celebration, Plaintiff was hit on her head when she fell from a loose bunk bed 

ladder in her stateroom that was unreasonably dangerous by not being bolted correctly and 

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 STEPTOE-JACKSON v. BAHAMAS PARADISE 

otherwise fastened by the vessel’s steward. No warnings were given of the condition, causing 

Plaintiff to sustain permanent injuries. 

8. At all times material hereto, the Defendant should have been aware of the dangers 

of a loose bunk bed ladder presented and accordingly should have taken any and all 

precautionary measures available to ensure an invitee, like Plaintiff, on the ship would not be 

injured by such dangerous condition. Defendant, through its agents and/or employees failed to 

take any such precautionary measures and instead left this condition in place without any

warning signs of the danger presented to such invitees.

9. Due to Defendant BAHAMAS PARADISE’S negligence and failure to use 

reasonable care in maintaining the premises in a reasonably safe condition, the Plaintiff, 

ROSALIND STEPTOE-JACKSON, sustained severe injuries to her head.

COUNT I

NEGLIGENCE TO BAHAMAS PARADISE

10. The Plaintiff, ROSALIND STEPTOE-JACKSON, hereby adopts and realleges each 

and every allegation in paragraphs one (1) through nine (9), above. 

11. At all times material hereto, Defendant BAHAMAS PARADISE owed to 

Plaintiff,

ROSALIND STEPTOE-JACKSON, an invitee on the ship’s premises, the duty to use 

reasonable care in keeping and maintaining the premises in a reasonably safe condition.

12. Additionally, at all times material hereto, the Defendant, BAHAMAS 

PARADISE, owed to the Plaintiff, ROSALIND STEPTOE-JACKSON, the duty to give her 

warning of concealed perils which are known or should be known to Defendant, and which were 

unknown to Plaintiff and could not be discovered by her through the exercise of due care.

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13. The Defendant, BAHAMAS PARADISE, breached its duty to Plaintiff in one or 

more of the following ways:

a. Failing to use reasonable care in maintaining the premises in a reasonably 

safe condition. Specifically, the loose bunk bed ladder in the stateroom

which created an unsafe and dangerous condition unbeknownst to visitors;

b. Failing to give Plaintiff warning that the loose bunk bed ladder in the

stateroom created a dangerous condition, and that extra caution should be 

taken in that particular area, given the hidden dangers; 

c. Failing to maintain the premises in a reasonably safe condition for invitees 

and Plaintiff. Specifically, upon learning of the loose bunk bed ladder in 

the stateroom, BAHAMAS PARADISE’S agents and employees failed to 

take any remedial action to rectify the dangerous condition of the subject 

area;

d. Failing to properly train its agents and/or employees to keep the premises 

in a reasonably safe condition for invitees and specifically, for the 

Plaintiff;

e. Failing to properly monitor its agents and/or employees so as to 

reasonably assure that they were maintaining the premises in a reasonably 

safe condition for all invitees, and specifically, the Plaintiff;

f. Failing to implement and train its agents and/or employees in policies and 

procedures designed to reasonably assure the safety of invitees on the 

premises;

g. Failing to enforce the policies and procedures designed to reasonably 

assure the safety of invitees on the premises, 

h. Providing negligent maintenance to the area or to the premises; and

i. Other acts of negligence to be determined through discovery.

14. The above-described negligent acts and/or omissions are the direct and proximate 

cause of ROSALIND STEPTOE-JACKSON’ injuries. 

15. The Defendant created a dangerous condition on the subject ship and allowed the 

dangerous condition to exist thereby causing an accident on the date referenced above in which the 

Plaintiff was severely injured.

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16. The Defendant either (a) created the dangerous condition, through its agents or 

employees; (b) had actual knowledge of the dangerous condition; and/or (c) had constructive 

knowledge of the dangerous condition.

17. The Defendant had constructive knowledge of the dangerous condition by, inter alia, 

(a) the length of time the dangerous condition existed; (b) the size and/or nature of the dangerous 

condition; and/or (c) the fact that the dangerous condition, a similar dangerous condition, or the 

cause of the dangerous condition was repetitive, continuous, ongoing, recurring, or occurring with 

some regularity. Thus, the dangerous condition was reasonably foreseeable and in the exercise of 

reasonable care the Defendant should have known about it. 

18. In the alternative, notice to the Defendant is not required because the Defendant (a) 

engaged in and was guilty of negligent maintenance; and/or (b) engaged in and was guilty of 

negligent methods of operations.

19. The negligent condition was created by the Defendant; and was known to the 

Defendant; and had existed for a sufficient length of time so that Defendant should have known 

of it; and was a continuous or repetitive problem thus giving notice to the Defendant. 

 20. The negligent condition occurred with sufficient regularity so as to be foreseeable by 

the Defendant and should have been foreseeable by the Defendant.

CLAIM OF ROSALIND STEPTOE-JACKSON

21. The Plaintiff, ROSALIND STEPTOE-JACKSON, adopts and realleges all prior 

material paragraphs, and further states:

22. As a direct and proximate result of the above-described negligent acts and/or 

omissions, the Plaintiff, ROSALIND STEPTOE-JACKSON, makes the following claims for 

damages against BAHAMAS PARADISE:

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a. Permanent bodily injury;

b. Aggravation of a pre-existing condition;

c. Pain and suffering;

d. Permanent disability;

e. Permanent disfigurement;

f. Mental anguish;

g. Loss of earnings;

h. Loss of earning capacity;

i. Medical, nursing, and rehabilitative expenses;

j. Loss of capacity for the enjoyment of life; and

k. All other damages allowed by law.

 23. These losses are either permanent or continuing and Plaintiff, ROSALIND 

STEPTOE-JACKSON will suffer the losses in the future. 

WHEREFORE, the Plaintiff, ROSALIND STEPTOE-JACKSON, demands judgment 

against the Defendant, BAHAMAS PARADISE CORPORATION d/b/a BAHAMAS 

PARADISE CRUISE LINES, for the full value of her losses together with costs of suit to the 

extent allowable by law.

DEMAND FOR JURY TRIAL

The Plaintiffs hereby demand Trial by Jury of any issue triable of right by a jury.

Signed this 13th day of July, 2020.

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 STEPTOE-JACKSON v. BAHAMAS PARADISE 

Respectfully Submitted,

By: /s/ Jack Paris _ 

JACK PARIS, ESQ. 

Florida Bar No.: 984310

THE COCHRAN FIRM SOUTH FLORIDA

Attorney for Plaintiff

499 NW 70th Avenue, Suite 116

Plantation, FL 33317

Telephone: (954) 473-0011

Facsimile: (954) 530-1082

jparis@cochranfirm.com

vvina@cochranfirm.com

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