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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.

MARGARITA SALES DE HERNANDEZ, 

Plaintiff,

v.

ROYAL CARIBBEAN GROUP, LTD., 

A LIBERIAN CORPORATION, 

Defendant. 

__________________________________/ 

COMPLAINT FOR DAMAGES 

AND DEMAND FOR TRIAL BY JURY

Plaintiff, MARGARITA SALES DE HERNANDEZ (“Plaintiff”), through undersigned 

counsel, sues Defendant, ROYAL CARIBBEAN GROUP, LTD. (“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 Mexico.

1:20-cv-22965

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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 

in Miami-Dade County, Florida, and who maintains its corporate headquarters and principal place 

of business in Miami-Dade County Florida.

7. Defendant is a dual citizen of the State of Florida and the nation of Liberia.

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 this

state 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 owned, operated, managed, maintained, and/or 

controlled the vessel, the RCCL Freedom of the Seas.

11. On or about September 17, 2019, Plaintiff was a lawfully fare paying passenger aboard 

Defendant’s cruise ship vessel, the RCCL Freedom of the Seas.

12. As Plaintiff and her husband were leaving the buffet on the pool deck in a normal and 

proper manner, Plaintiff lost her footing on a wet and unreasonably slippery surface in a walkway 

that was unreasonably narrow due to chairs that were placed unreasonably close together, and the 

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wet substance had been on the surface for a long period of time and the chairs appeared to be 

arranged the way they did for a long period of time, and Royal Caribbean knew of or should have 

known of the dangers if it were exercising reasonable care under the circumstances. As a result of 

the fall, Plaintiff suffered traumatic injuries that included, but are not limited to, multiple fracturs 

to Plaintiff’s hip, and other injuries, which require surgery. Furthermore, when Plaintiff sought 

medical treatment on the ship, Defendant’s staff provided treatment for Plaintiff’s pain that was 

not adequate, Defendant’s staff failed to provide Plaintiff a hip immobilizer or a pelvic thigh splint 

necessary to avoid bleeding and pain, Defendant’s staff unreasonably rushed Plaintiff off the ship,

and the local medical facility Defendant initially sent Plaintiff was in a poor and/or dilapidated 

condition that was not adequate for Plaintiff’s treatment, and the staff at this facility wanted to 

perform a surgery on Plaintiff that was not adequate for Plaintiff’s treatment, also failed to provide

Plaintiff a hip immobilizer or a pelvic thigh splint, and inserted a catheter into Plaintiff’s body that 

did not function properly, and Defendant’s negligence in all of these regards caused Plaintiff to 

have to seek treatment back in Mexico, and caused Plaintiff to suffer additional and/or aggravated 

injuries, bleeding, pain, and/or suffering.

COUNT I – NEGLIGENCE

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

allegations of paragraphs 10-12 and further alleges:

13. Defendant owed Plaintiff the duty to exercise reasonable care under the circumstances 

for the safety of its passengers.

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

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

that passengers, including the Plaintiff, will likely encounter.

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15. Such duty also includes, but is not limited to, the duty to maintain its ship in a

reasonably safe condition for the use and enjoyment of its passengers

16. Such 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 deck, surface, walkway, area, and the vicinity in 

a reasonably safe condition, so as to help prevent hazards to its passengers; and/or

b. Failing to inspect, clean, keep and maintain the subject deck, surface, walkway, 

area, and the vicinity in a reasonably safe condition; and/or;

c. Failing to take proper precautions for the safety of the passengers using the 

subject area; and/or

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

deck, surface, walkway, area, and the vicinity; and/or

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

cleaning and maintenance of the deck, surface, walkway, area, and the vicinity; 

and/or

f. 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

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g. Negligently designing and/or approving the subject deck, surface, walkway, 

area, and the vicinity, as well as the floor plans, as it relates to the deck’s slipresistance or propensity to cause the accumulation of slippery 

substances/liquids in the walking path of passengers; and/or

h. Failing to adequately drain the slippery substance from the subject area, failing 

to have adequate drains in the subject area, and/or failing to warn Plaintiff of 

the same; and/or

i. Failing to adequately train its crew to keep the deck, surface, walkway, area, 

and the vicinity clean and free of hazards; and/or

j. Failing to employ sufficient crewmembers or adequately trained crewmembers 

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

Plaintiff’s incident occurred relating to the slippery nature of the deck, and/or

k. Failing to treat the deck, surface, walkway, area, and the vicinity to prevent 

them from becoming unreasonable slippery or otherwise unreasonably 

dangerous; and/or

l. 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

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

manner; and/or

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

the risks involved; and/or

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

subject area; and/or

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

encouraging passengers to traverse the subject area; and/or

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

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

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

members are adequately supervising the subject area; and/or

s. Failing to engage proper and reasonable safeguards to prevent passengers from 

being injured while traversing the subject area; and/or

t. Failing to warn passengers of the dangers of traversing wet or slippery floors; 

and/or

u. 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 to remedy such dangers; and/or

v. Providing a walkway that was unreasonably narrow and/or arranging chairs 

unreasonably close together so as to make the subject walkway unreasonably 

narrow, and/or failing to warn Plaintiff of the same; and/or

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

traversing the subject area; and/or

x. 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.

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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 and loss of 

future earning capacity. 

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

WHEREFORE, Plaintiff, MARGARITA SALES DE HERNANDEZ, demands 

judgment against Defendant, ROYAL CARIBBEAN GROUP, LTD., for damages suffered and 

costs incurred, as well as for damages and costs that 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, 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.

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 10-12 and further alleges:

22. 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 

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safety of its passengers.

23. Such duty includes, but is not limited to, providing such medical care and assistance 

as would an ordinarily prudent person under the circumstances.

24. 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.

25. 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.

26. 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.

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

used by the ship’s medical personnel and passengers.

28. 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.

29. 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.

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

31. 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 

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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.

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

and/or indemnification rights.

33. 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.

34. 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 

in treating injuries such as the one Plaintiff suffered.

35. 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.

36. 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, bleeding, pain, 

and/or suffering, and/or Plaintiff’s injuries, bleeding, pain, and/or suffering, were aggravated and 

made worse.

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

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

its duties as follows:

a. Providing treatment for Plaintiff’s pain that was not adequate:

b. Failing to provide Plaintiff with a hip immobilizer and/or a 

pelvic thigh splint necessary to avoid bleeding and pain;

c. Unreasonably rushing Plaintiff off the ship;

d. Sending Plaintiff to a local medical facility that was in a poor 

and/or dilapidated condition that was not adequate for 

Plaintiff’s treatment, where the staff wanted to perform a 

surgery on Plaintiff that was not adequate for Plaintiff’s 

treatment, and which failed to provide Plaintiff a hip 

immobilizer and/or a pelvic thigh splint, and which inserted a 

catheter into Plaintiff’s body that did not function properly;

e. Failing to promptly provide Plaintiff with proper and/or 

adequate medical care and attention;

f. Failing to timely and properly diagnose Plaintiff’s medical

condition;

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

h. Failing to provide reasonable medical care;

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

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

k. By failing to take proper measures to secure adequate 

treatment for Plaintiff, including unreasonably delaying 

taking measures to secure such adequate treatment; and/or

l. Failing to give Plaintiff proper discharge instructions.

38. 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.

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39. 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.

40. 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.

41. 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, bleeding, pain, and/or suffering, would not have 

occurred and/or said injuries, bleeding, pain, and/or suffering, would have been substantially

lessened.

42. 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.

43. 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 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.

WHEREFORE, Plaintiff, MARGARITA SALES DE HERNANDEZ, demands 

judgment against Defendant, ROYAL CARIBBEAN GROUP, LTD., for damages suffered and 

costs incurred, as well as for damages and costs that Plaintiff will suffer and incur in the future, as a 

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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, 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.

COUNT III

APPARENT AGENCY 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 10-12 and further alleges:

44. 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;

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.

45. 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.

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

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

47. 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.

48. 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.

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

apparent employees, and/or apparent servants.

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

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

with reasonable care under the circumstances.

51. Plaintiff’s injuries, bleeding, pain, and/or suffering were caused, accelerated, and/or 

exacerbated due to the fault and/or negligence of Defendant through the acts of its apparent agents 

asfollows:

a. Providing treatment for Plaintiff’s pain that was not adequate:

b. Failing to provide Plaintiff with a hip immobilizer and/or a 

pelvic thigh splint necessary to avoid bleeding and pain;

c. Unreasonably rushing Plaintiff off the ship;

d. Sending Plaintiff to a local medical facility that was in a poor 

and/or dilapidated condition that was not adequate for 

Plaintiff’s treatment, where the staff wanted to perform a 

surgery on Plaintiff that was not adequate for Plaintiff’s 

treatment, and which failed to provide Plaintiff a hip 

immobilizer and/or a pelvic thigh splint, and which inserted a 

catheter into Plaintiff’s body that did not function properly;

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e. Failing to promptly provide Plaintiff with proper and/or 

adequate medical care and attention;

f. Failing to timely and properly diagnose Plaintiff’s medical

condition;

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

h. Failing to provide reasonable medical care;

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

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

k. By failing to take proper measures to secure adequate 

treatment for Plaintiff, including unreasonably delaying 

taking measures to secure such adequate treatment; and/or

l. Failing to give Plaintiff proper discharge instructions.

52. 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 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.

WHEREFORE, Plaintiff, MARGARITA SALES DE HERNANDEZ, demands 

judgment against Defendant, ROYAL CARIBBEAN GROUP, LTD., for damages suffered and 

costs incurred, as well as for damages and costs that 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, loss of 

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

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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.

COUNT IV

ASSUMPTION OF DUTY, NEGLIGENCE OF THE SHIP’S MEDICAL STAFF

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

allegations of paragraphs 10-12 and further alleges:

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

circumstances for the safety of its passengers.

54. Such duty includes, but is not limited to, providing such medical care and assistance

as would an ordinarily prudent person under the circumstances.

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

physicians and/or other crew members.

56. 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.

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

diagnose, and/or treat Plaintiff’s injuries.

58. Furthermore, Defendant breached its duty, 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.

59. Defendant also breached its duty and was negligent by failing to adequately supply 

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

60. Defendant breached its duty and was negligent by failing to take proper measures to 

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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, bleeding, pain, and/or 

suffering, and/or Plaintiff’s injuries, bleeding, pain, and/or suffering, were aggravated and made

worse.

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

breached its duties as follows:

a. Providing treatment for Plaintiff’s pain that was not adequate:

b. Failing to provide Plaintiff with a hip immobilizer and/or a 

pelvic thigh splint necessary to avoid bleeding and pain;

c. Unreasonably rushing Plaintiff off the ship;

d. Sending Plaintiff to a local medical facility that was in a poor 

and/or dilapidated condition that was not adequate for 

Plaintiff’s treatment, where the staff wanted to perform a 

surgery on Plaintiff that was not adequate for Plaintiff’s 

treatment, and which failed to provide Plaintiff a hip 

immobilizer and/or a pelvic thigh splint, and which inserted a 

catheter into Plaintiff’s body that did not function properly;

e. Failing to promptly provide Plaintiff with proper and/or 

adequate medical care and attention;

f. Failing to timely and properly diagnose Plaintiff’s medical

condition;

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

h. Failing to provide reasonable medical care;

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

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

k. By failing to take proper measures to secure adequate 

treatment for Plaintiff, including unreasonably delaying 

taking measures to secure such adequate treatment; and/or

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l. Failing to give Plaintiff proper discharge instructions.

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

Defendant fell below the standard of care.

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

Defendant’s negligence, Plaintiff’s injuries, bleeding, pain, and/or suffering, would not have 

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

64. 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.

65. 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 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.

WHEREFORE, Plaintiff, MARGARITA SALES DE HERNANDEZ, demands 

judgment against Defendant, ROYAL CARIBBEAN GROUP, LTD., for damages suffered and 

costs incurred, as well as for damages and costs that 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, 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.

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DEMAND FOR JURY TRIAL

Plaintiff, MARGARITA SALES DE HERNANDEZ, demands trial by jury on all issues 

so triable.

Dated: July 17, 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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