UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO.

LAURA PATT

Plaintiff,

v.

NCL (BAHAMAS) LTD. d/b/a

NORWEGIAN CRUISE LINE

Defendant.

____________________________/

COMPLAINT

Plaintiff, LAURA PATT, by and through her undersigned attorneys, sues the 

Defendant, NCL (BAHAMAS) LTD. d/b/a NORWEGIAN CRUISE LINE (“NCL”) and 

alleges as follows:

GENERAL ALLEGATIONS

1. This is an action involving the diversity of citizenship of the parties as more 

fully described below and for damages in excess of $75,000.00, exclusive of interest, 

costs and attorney’s fees; accordingly, this case falls within the jurisdiction of this Court 

pursuant to 28 U.S.C. §1332. Alternatively, this case falls within the admiralty jurisdiction 

of this Court pursuant to 28 U.S.C. §§ 1331 and 1333(1).

2. Pursuant to a forum selection clause in the subject Guest Ticket Contract 

drafted and issued by Defendant, this action must be brought in this Court.

3. Plaintiff is an individual and resident of Pepperell, Massachusetts.

4. The Defendant, NCL, is a foreign corporation doing business in Florida, 

which conducts business and maintains its principal place of business in Miami-Dade 

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County, Florida and was doing business as a carrier of passengers by water for hire at all 

material times hereto.

5. At all relevant times, the Defendant, NCL, owned, managed, chartered 

and/or operated the cruise vessel NORWEGIAN GEM (the “vessel”). 

6. On or about May 26, 2019, Mrs. Patt was transcending a staircase on board 

the vessel. The staircase was dimly lit and there was no contrast in the carpet. 

7. Mrs. Patt went to step down the stairs and immediately fell, and sustained

personal injuries as a result of the fall. 

COUNT I

GENERAL MARITIME LAW- NEGLIGENCE

8. Paragraphs 1-7 are realleged and incorporated herein.

9. At all times material hereto, the Defendant, NCL, owed a duty to the Plaintiff 

to exercise reasonable care under the circumstances for the Plaintiff’s safety.

10. The Defendant breached its duty of care to the Plaintiff: 

a) by creating a dangerous condition;

b) by failing to correct a dangerous condition;

c) by maintaining a method of operation which was inherently 

dangerous and/or the particular operation which resulted in the Plaintiff’s injury was

conducted in a wrongful manner;

d) using ineffective and improper management systems that increased 

danger to others, including the Plaintiff; and

11. As a direct and proximate result of the Defendant’s aforesaid negligence,

the Plaintiff, Laura Patt, has suffered, and continues to suffer, bodily injury and resulting 

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

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expenses of hospitalization, medical and nursing care and treatment. The losses are 

either permanent or continuing in nature and the Plaintiff will continue to suffer the losses 

in the future.

TRIAL BY JURY

12. Plaintiff demands a trial by jury on all issues.

WHEREFORE, the Plaintiff, LAURA PATT, demands judgment against the 

Defendant, NCL (BAHAMAS) LTD. d/b/a NORWEGIAN CRUISE LINE, for an amount to 

be determined at trial by a jury, together with interest and costs and other relief deemed

just and appropriate by this Honorable Court.

Respectfully submitted,

/s/ Stephen Field

Stephen D. Field, Esq. 

Florida Bar No. 554111

Email: steve@field-law.com

Stephen D. Field, P.A.

75 Miracle Mile, #347255

Coral Gables, Florida 33134-9997 

Office: (305) 909-1296

Direct Line: (305) 798-1335

Fax: (786) 631-5321

Counsel for Plaintiff – Laura Patt

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