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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1:22-cv-22977 

ANGELINA LILES, 

Plaintiff,

v.

CARNIVAL CORPORATION & PLC, 

 Defendant. 

________________________________/ 

COMPLAINT FOR DAMAGES 

AND DEMAND FOR TRIAL BY JURY

Plaintiff, ANGELINA LILES (hereinafter “LILES”), through undersigned counsel, sues 

Defendant, CARNIVAL CORPORATION & PLC (hereinafter “CARNIVAL”), and demands trial 

by jury, stating as follows:

PARTIES AND JURISDICTION

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

attorneys’ fees.

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

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 CARNIVAL. 

5. LILES is sui juris and is a resident and citizen of the state of Texas. 

6. CARNIVAL is a citizen of the state of Florida and the nations of Panama and the U.K. 

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7. CARNIVAL 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. 

8. CARNIVAL, at all times material hereto, personally and/or through an agent, in 

Miami-Dade County, Florida, in the Southern District of Florida:

a. Operated, conducted, engaged in, or carried on a business venture; and/or

b. Had an office or agency; and/or 

c. Engaged in substantial activity; 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.

DEFINITIONS AND FACTUAL ALLEGATIONS

10. Hereinafter, the phrase, the “subject area,” shall include, but not be limited to, the tender

and ramp LILES’ incident occurred on, the surrounding area, the area, tender, and ramp’s design and/or 

visual condition, and all material and effects pertaining to the area, tender, and ramp. 

11. At all times material hereto, CARNIVAL owned, leased, chartered, operated, 

maintained, managed, and/or controlled the subject area involved in LILES’ incident.

12. At all times material hereto, CARNIVAL owned, leased, chartered, operated, 

maintained, managed, and/or controlled the subject cruise ship, the Vista, the subject tender, and 

the subject ramp.

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13. LILES’ incident occurred on or about July 27, 2022, while she was on a cruise as a 

fare paying passenger of CARNIVAL’S vessel, the Vista.

14. On or about July 27, 2022, at approximately 2:00 to 3:00 p.m., LILES was on a tender 

coming back to the Vista in Georgetown, Grand Cayman. LILES was going down the ramp that 

was supposed to be secured to the tender and dock. There was no adequate connecting point that

covered the gap between the tender and the ramp. When she stepped over the ramp, the tender 

separated from the ramp, causing her right leg to become crushed between the tender and ramp.

15. As a result, she sustained severe injuries that required surger(ies).

16. LILES had to wait for approximately an hour or two for CARNIVAL’S staff to attend 

to her injuries. When CARNIVAL’S staff finally took her to the ship’s medical center, the ship’s 

doctor took x-rays, but failed to diagnose her injuries. Moreover, LILES was prescribed an 

insufficiently strong pain medicine to alleviate her pain prior to seeking medical care shoreside, 

such that she was in great pain for a longer amount of time.

17. At all relevant times, the dangerous and/or risk creating conditions include, but are 

not limited to, the following:

a. The ramp was not reasonably secured to the tender and dock. 

b. There was no adequate connecting point that covered the gap between the 

tender and the ramp, and the ramp and the dock. 

c. The tender was not reasonably anchored.

d. LILES was holding the handrail when attempting to step on the ramp, but the 

handrail was inadequate to prevent or mitigate LILES’ incident.

e. The tender would rock violently because of wakes caused by other 

CARNIVAL boats in the area.

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f. The fact that CARNIVAL did not have crew members adequately supervising 

and assisting passengers in the subject area at the time of the incident. This 

includes, but is not limited to, approximately two crewmembers in the 

immediate vicinity who failed to assist LILES in traversing from the subject 

tender onto the subject ramp. 

g. Other dangerous conditions that will be revealed through discovery. 

18. Each of these dangerous conditions alone was sufficient to cause LILES’ incident and 

injuries, and LILES is alleging that CARNIVALwas negligent as to each of these conditionsseparately 

and not cumulatively. 

19. CARNIVAL either knew or should have known of these risk-creating and/or 

dangerous conditions, due to reasons that include, but are not limited to, the following: 

a. There was a sign/signs in the subject area that said “watch your step” (or in the 

alternative, something similar to the same effect), but a reasonable person would not 

have been able to see this sign prior to stepping off the tender. 

b. Upon information and belief, CARNIVAL provides verbal warnings and assistance 

to its passengers who step off tenders and onto ramps such as the one involved in 

LILES’ incident, but CARNIVAL provided no such verbal warnings or assistance to 

LILES while she attempted to step from the tender onto the ramp.

c. After LILIES’ incident, a young white gentleman told her in an elevator on the ship 

that his father-in-law had the exact same incident happen to him, just that CARNIVAL 

was able to catch him before he fell, indicating that CARNIVAL knew of the subject 

dangers prior to her fall. 

d. While LILES was waiting to leave the tender and step on the ramp, she did not observe 

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anyone unsecure the ramp, and she was in the area for at least ten to fifteen minutes 

prior to her incident, such that it is reasonable for the fact finder to infer that the tender 

was unsecured for over ten to fifteen minutes prior to LILES’ incident, and 

CARNIVAL should have known of this had it performed reasonable inspections to 

keep its tenders and ramps reasonably safe.

e. There were approximately two crewmembers in the subject area at the time of the 

incident, and these crewmembers were in the immediate vicinity, such that LILES

reasonably infers that these crew members regularly used, observed, and tended to the 

subject area, and therefore were or should have been aware of the dangerous and/or 

risk-creating conditions thereof, and warned of and/or removed these conditions

and/or assisted LILES.

f. CARNIVAL participated in the installation and/or design of the subject area, or 

alternatively, CARNIVAL accepted the area with its design defects present after 

having been given an opportunity to inspect the area and materials on it, including the 

subject tender and ramp, such that CARNIVAL should have known of the design 

defects of the subject area before providing the area for public use. These design 

defects include, but are not limited to, the dangers outlined in paragraph 17 of this 

complaint.

g. Both prior to LILES’ incident and after, CARNIVAL installed and/or refitted the 

subject ramp on the subject ship and other ships in CARNIVAL’s fleet that remedied 

the dangers thereof, but these remedies were not implemented at the time of LILES’

incident.

h. There are relevant safety standards/recommendations/other guidelines regarding the 

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safety of the subject area, including, but not limited to, prohibitions and/or 

recommendations against the deficiencies discussed in paragraph 17 of this 

Complaint, and CARNIVAL should have known of these 

standards/recommendations/other guidelines because whether such 

standards/recommendations/other guidelines are legally required for CARNIVAL to 

comply with or not, a fact-finder is entitled to determine, if it so choses, that these 

standards/recommendations/other guidelines show what a reasonable cruise line

should have done. 

i. CARNIVAL also knew or should have known of these dangerous conditions through 

inspecting the subject area involved in LILES’ incident, and if it did not know of these 

dangerous conditions, this was because CARNIVAL failed to adequately inspect the 

subject area prior to LILES’ incident. 

j. Previous passengers in prior cases suffered prior incidents involving similar tenders 

on Carnival cruises, including, but not limited to, Hollowell v. Carnival Corp., No. 

22-CV-21399, 2022 WL 2869738, at *1 (S.D. Fla. July 21, 2022), Upchurch v. 

Carnival Corp., No. 21-23469-CIV, 2022 WL 3154859, at *1 (S.D. Fla. May 13, 

2022), Pacinelli v. Carnival Corp., No. 18-22731-CIV, 2019 WL 3252133, at *1 (S.D. 

Fla. July 19, 2019) (“As Plaintiff stepped from the cruise ship, the tender suddenly 

lurched away from the ship and he began to fall forward with one knee landing on 

the tender and the other leg dangling between the tender and the ship.”) (emphasis 

added), and Reimer v. Carnival Corp., 1:10-cv-23036-JAL (same ramp separation). 

k. Moreover, CARNIVAL knew or should have known of these dangerous conditions 

for other reasons that will be revealed through discovery. 

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20. At all times relevant, the subject area was unreasonably dangerous, risk-creating, 

defective, improperly designed, improperly installed, and/or otherwise unsafe.

21. The subject area and the vicinity lacked adequate safety features to prevent or minimize 

LILES’incident and/or injuries.

22. These hazardous conditions were known, or should have been known, to CARNIVAL

in the exercise of reasonable care.

23. These hazardous conditions existed for a period of time before the incident.

24. These conditions were neither open nor obvious to LILES.

25. At all times relevant, CARNIVAL failed to adequately inspect the subject area and the 

vicinity for dangers, and CARNIVAL failed to adequately warn LILES of the dangers.

26. At all times relevant, CARNIVAL had the ability to cure the deficiencies and to eliminate 

the hazards, but failed to do so.

27. At all times relevant, CARNIVAL failed to maintain the subject area and the vicinity in 

a reasonably safe condition.

28. At all timesrelevant, CARNIVAL participated in the design and/or approved the design 

of the subject area and the vicinity involved in LILES’ incident.

29. At all times relevant, CARNIVAL participated in the installation and/or approved the 

installation of the subject area and the vicinity involved in LILES’ incident.

30. The crewmembers of the Vista and tender were in regular full-time employment of 

CARNIVAL and/or the ship, as salaried crewmembers. 

31. CARNIVAL’s crewmembers, employees, and/or agents were subject to the ship’s 

discipline and master’s orders, and CARNIVAL had the right to hire and fire its crewmembers, 

employees, and/or agents.

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32. CARNIVAL is directly responsible and liable for their actions and the actions of its

crewmembers, employees, and/or agents. 

33. The crewmembers, including the medical staff, were employees and/or actual agents 

and/or apparent agents of CARNIVAL, and acted within the course and scope of their employment 

and/or agency agreement and/or relationship.

34. The crewmembers were represented to LILES and the ship’s passengers as employees 

of CARNIVAL through signs, documents, and/or uniforms. The crewmembers were also paid a 

salary and/or hourly wage by CARNIVAL. CARNIVAL knew that the crewmembers represented 

themselves to be employees of CARNIVAL and allowed them to represent themselves as such. 

LILES detrimentally relied on these representations as LILES would not have proceeded on the 

subject cruise had LILES believed the crewmembers were not employees of CARNIVAL. 

COUNT I

NEGLIGENT FAILURE TO INSPECT 

35. LILES hereby adopts and re-alleges each and every allegation in paragraphs 1 through 

34, as if set forthherein.

36. CARNIVAL owed a duty to exercise reasonable care under the circumstances for the 

safety of its passengers. 

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

care by adequately inspecting the subject area and the vicinity to make sure the subject area and 

the vicinity were reasonably safe for the use and enjoyment of its passengers. 

38. At all times material, CARNIVAL, 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 CARNIVAL breached the duty of reasonable care owed to LILES and were negligent by 

failing to adequately inspect the subject area and the vicinity to make sure the subject area and the 

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vicinity were reasonably safe, such that the unreasonably risk creating and/or dangerous conditions 

discussed paragraph 17 of the instant Complaint were present at the time of LILES’ incident.

39. CARNIVAL either knew or should have known of these risk-creating and/or 

dangerous conditions, due to reasons that include, but are not limited to, the reasons discussed in 

paragraph 19 of the Complaint.

40. These risk-creating and/or dangerous conditions were caused by CARNIVAL’S

failure to adequately inspect the subject area and the vicinity to make sure the subject area and the 

vicinity were reasonably safe.

41. Furthermore, the subject area and the vicinity were also on a cruise ship in the water 

subject to numerous maritime conditions such as the ship’s movement, additional wear-and-tear 

due to maritime conditions not necessarily present on land, waves, and other conditions unique to 

maritime travel, and as such were “clearly linked to nautical adventure.”

42. CARNIVAL’S breach was the cause in-fact of LILES’ great bodily harm in that, but 

for CARNIVAL’S breach, LILES’ injuries would not have occurred.

43. CARNIVAL’S breach proximately caused LILES great bodily harm in that the 

incident that occurred was a foreseeable result of CARNIVAL’S breach.

44. As a result of CARNIVAL’S negligence, LILES has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

independence, lost wages, lost earning capacity, loss of capacity for the enjoyment of life, expense 

of hospitalization, medical and nursing care and treatment, and loss of the value of LILES’ vacation, 

cruise, and transportation costs.

45. The losses are permanent and/or continuing in nature.

46. LILES suffered these losses in the past and will continue to suffer such loses in the 

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future. 

WHEREFORE, Plaintiff, ANGELINA LILES, demands judgment against Defendant, 

CARNIVAL CORPORATION & PLC, for damages suffered and costs incurred, as well as for 

damages and costs that LILES will suffer and incur in the future, as a result of LILES’ bodily 

injury, pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, 

medical care and treatment, nursing care and treatment, lost wages, lost earning capacity, loss of 

the value of LILES’ vacation, cruise, transportation costs, loss of important bodily functions, loss of 

independence, and loss of capacity for the enjoyment of life, for all court costs, pre- and postjudgment interest, and for any and all other relief which this Court deems just or appropriate. 

COUNT II

NEGLIGENT FAILURE TO MAINTAIN

47. LILES hereby adopts and re-alleges each and every allegation in paragraphs 1 

through 34, as if set forth herein. 

48. CARNIVAL owed a duty to exercise reasonable care under the circumstances for the

safety of its passengers. 

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

care by adequately maintaining the subject area and the vicinity.

50. At all times material, CARNIVAL, 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 CARNIVAL, breached the duty of reasonable care owed to LILES and were negligent by

failing to adequately maintain the subject area and the vicinity, such that the unreasonably risk 

creating and/or dangerous conditions discussed paragraph 17 of the instant Complaint were present 

at the time of LILES’ incident.

51. CARNIVAL either knew or should have known of these risk-creating and/or 

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dangerous conditions, due to reasons that include, but are not limited to, the reasons discussed in 

paragraph 19 of the instant complaint.

52. Moreover, these risk-creating and/or dangerous conditions were caused by

CARNIVAL’S failure to adequately maintain the subject area and the vicinity.

53. Furthermore, the subject area and the vicinity were also on a cruise ship in the water 

subject to numerous maritime conditions such as the ship’s movement, additional wear-and-tear 

due to maritime conditions not necessarily present on land, waves, and other conditions unique to 

maritime travel, and as such were “clearly linked to nautical adventure.”

54. CARNIVAL’S breach was the cause in-fact of LILES’ great bodily harm in that, but 

for CARNIVAL’S breach, LILES’ injuries would not have occurred.

55. CARNIVAL’S breach proximately caused LILES great bodily harm in that the 

incident that occurred was a foreseeable result of CARNIVAL’S breach.

56. As a result of CARNIVAL’S negligence, LILES has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

independence, lost wages, lost earning capacity, loss of capacity for the enjoyment of life, expense 

of hospitalization, medical and nursing care and treatment, and loss of the value of LILES’ vacation, 

cruise, and transportation costs.

57. The losses are permanent and/or continuing in nature.

58. LILES has suffered these losses in the past and will continue to suffer such losses in 

the future.

WHEREFORE, Plaintiff, ANGELINA LILES, demands judgment against Defendant, 

CARNIVAL CORPORATION & PLC, for damages suffered and costs incurred, as well as for 

damages and costs that LILES will suffer and incur in the future, as a result of LILES’ bodily

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injury, pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, 

medical care and treatment, nursing care and treatment, lost wages, lost earning capacity, loss of 

the value of LILES’ vacation, cruise, transportation costs, loss of important bodily functions, loss of 

independence, and loss of capacity for the enjoyment of life, for all court costs, pre- and postjudgment interest, and for any and all other relief which this Court deems just or appropriate. 

COUNT III

NEGLIGENT FAILURE TO REMEDY 

59. LILES hereby adopts and re-alleges each and every allegation in paragraphs 1 

through 34, as if set forth herein. 

60. CARNIVAL owed a duty to exercise reasonable care under the circumstances for the 

safety of its passengers. 

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

care by adequately remedying the subject area and the vicinity.

62. At all times material, CARNIVAL, 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 CARNIVAL, breached the duty of reasonable care owed to LILES and were negligent by 

failing to adequately remedy the subject area and the vicinity, such that the unreasonably risk 

creating and/or dangerous conditions discussed in paragraph 17 of the instant Complaint were 

present at the time of LILES’ incident.

63. CARNIVAL either knew or should have known of these risk-creating and/or 

dangerous conditions, due to reasons that include, but are not limited to, the reasons discussed in 

paragraph 19 of the instant Complaint.

64. Moreover, these risk-creating and/or dangerous conditions were caused by 

CARNIVAL’S failure to adequately remedy the subject area.

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65. Furthermore, the subject area and the vicinity were also on a cruise ship in the water 

subject to numerous maritime conditions such as the ship’s movement, additional wear-and-tear 

due to maritime conditions not necessarily present on land, waves, and other conditions unique to 

maritime travel, and as such were “clearly linked to nautical adventure.”

66. CARNIVAL’S breach was the cause in-fact of LILES’ great bodily harm in that, but 

for CARNIVAL’S breach, LILES’ injuries would not have occurred.

67. CARNIVAL’S breach proximately caused LILES great bodily harm in that the 

incident that occurred was a foreseeable result of CARNIVAL’S breach.

68. As a result of CARNIVAL’S negligence, LILES has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

independence, lost wages, lost earning capacity, loss of capacity for the enjoyment of life, expense 

of hospitalization, medical and nursing care and treatment, and loss of the value of LILES’ vacation, 

cruise, and transportation costs.

69. The losses are permanent and/or continuing in nature.

70. LILES has suffered these losses in the past and will continue to suffer such losses in 

the future.

WHEREFORE, Plaintiff, ANGELINA LILES, demands judgment against Defendant, 

CARNIVAL CORPORATION & PLC, for damages suffered and costs incurred, as well as for 

damages and costs that LILES will suffer and incur in the future, as a result of LILES’ bodily

injury, pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, 

medical care and treatment, nursing care and treatment, lost wages, lost earning capacity, loss of 

the value of LILES’ vacation, cruise, transportation costs, loss of important bodily functions, loss of 

independence, and loss of capacity for the enjoyment of life, for all court costs, pre- and postCase 1:22-cv-22977-BB Document 1 Entered on FLSD Docket 09/16/2022 Page 13 of 31
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judgment interest, and for any and all other relief which this Court deems just or appropriate. 

COUNT IV 

NEGLIGENT FAILURE TO WARN OF DANGEROUS CONDITION

71. LILES hereby adopts and re-alleges each and every allegation in paragraphs 1 through 

34, as if set forth herein. 

72. At all times relevant, CARNIVAL owed a duty to exercise reasonable care under the 

circumstances for the safety of its passengers, including LILES. 

73. Such duty includes, but is not limited to, the duty that CARNIVAL owes to warn 

passengers of any dangers that it knew or should have known were not open and obvious to LILES. 

74. Such duty also includes, but is not limited to, the duty to warn passengers of hazards, 

which passengers may reasonably be expected to encounter. 

75. At all times material, CARNIVAL, 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 CARNIVAL, breached the duty of reasonable care owed to LILES and was negligent by 

failing to warn LILES of the dangerous conditions discussed in paragraph 17 of the instant 

Complaint.

76. Furthermore, CARNIVAL knew or should have known of these dangerous conditions 

for the reasons discussed in paragraph 19 of this Complaint.

77. These dangerous conditions were also created by CARNIVAL. 

78. CARNIVAL failed to adequately ensure there were no dangerous conditions that 

passengers needed to be warned of, and/or CARNIVAL failed to warn LILES despite knowing of 

the dangers. 

79. These dangerous conditions existed for a period of time before the incident. 

80. These conditions were neither open nor obvious to LILES. 

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81. Furthermore, the subject area and the vicinity were also on a cruise ship in the water 

subject to numerous maritime conditions such as the ship’s movement, additional wear-and-tear 

due to maritime conditions not necessarily present on land, waves, and other conditions unique to 

maritime travel, and as such were “clearly linked to nautical adventure.”

82. CARNIVAL’S breach was the cause in-fact of LILES’ great bodily harm in that, but 

for CARNIVAL’S breach, LILES’ injuries would not have occurred.

83. CARNIVAL’S breach proximately caused LILES great bodily harm in that the 

incident that occurred was a foreseeable result of CARNIVAL’S breach.

84. As a result of CARNIVAL’S negligence, LILES has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

independence, lost wages, lost earning capacity, loss of capacity for the enjoyment of life, expense 

of hospitalization, medical and nursing care and treatment, and loss of the value of LILES’ vacation, 

cruise, and transportation costs.

85. The losses are permanent and/or continuing in nature.

86. LILES has suffered these losses in the past and will continue to suffer such loses in 

the future.

 WHEREFORE, Plaintiff, ANGELINA LILES, demands judgment against Defendant, 

CARNIVAL CORPORATION & PLC, for damages suffered and costs incurred, as well as for 

damages and costs that LILES will suffer and incur in the future, as a result of LILES’ bodily

injury, pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, 

medical care and treatment, nursing care and treatment, lost wages, lost earning capacity, loss of 

the value of LILES’ vacation, cruise, transportation costs, loss of important bodily functions, loss 

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of independence, and loss of capacity for the enjoyment of life, for all court costs, pre- and postjudgment interest, and for any and all other relief which this Court deems just or appropriate.

COUNT V 

NEGLIGENT DESIGN, INSTALLATION, AND/OR APPROVAL OF THE SUBJECT 

AREA AND THE VICINITY

87. LILES hereby adopts and re-alleges each and every allegation in paragraphs 1 through 

34, as if set forth herein. 

88. At all times material hereto, CARNIVAL owed a duty to its passengers, and in 

particular a duty to LILES, not to permit dangerous conditions to be in places where they could 

harm passengers, such as those discussed in paragraph 17 in the instant Complaint, as well as to 

design and install reasonable safeguards. 

89. At all times material hereto, CARNIVAL participated in the design process of the 

subject vessel, tender, and ramp, by generating design specifications for the shipbuilder to follow, 

and to put the vessel, tender, and ramp, on which LILES was injured into the channels of trade, 

and/or CARNIVAL approved of the subject vessel, tender, and ramp’s design, including the design 

of the subject area and the vicinity.

90. At all times material hereto, CARNIVAL manufactured, designed, installed, and/or 

approved of the vessel, tender, and ramp, including providing specifications to the shipbuilder in 

the original build process, and/or during its refurbishments, and as such owed a duty to its 

passengers, and in particular a duty to LILES, to design, install and/or approve of the subject area 

and the vicinity without any defects.

91. At all times material hereto, CARNIVAL through its agents and/or employees who 

were acting in the course and scope of their employment and/or agency with CARNIVAL, 

designed, installed, and/or approved of the subject area and the vicinity involved in LILES’

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incident, which was also in violation of the applicable industry standards/recommendations and/or 

other guidelines.

92. CARNIVAL provides design elements of the vessel, tender, and ramp, to the ship 

builder and/or approves of design elements which include the subject area and the vicinity.

93. CARNIVAL maintains the contractual right to participate, review, modify, and/or 

reject the design plans and drawings of the vessel, tender, and ramp, during the new build process.

94. CARNIVAL has the right to enter the vessel, tender, and ramp, and inspect them 

during construction to ensure that they are being constructed in accordance with the design 

specifications, CARNIVAL and has a right to insist on changes when safety concerns are 

identified.

95. CARNIVAL has the right to inspect and reject design elements before taking 

possession of the vessel, tender, and ramp.

96. However, CARNIVAL permitted the dangerous conditions discussed in paragraph 17

of the instant complaint to be present in the subject area and the vicinity without correcting these 

design deficiencies and did not design and install reasonable safeguards.

97. Furthermore, CARNIVAL knew or should have known of these dangerous conditions 

for the reasons discussed in paragraph 19 of this Complaint.

98. The design flaws that made the subject area and the vicinity involved in LILES’

incident unreasonably dangerous were the direct and proximate cause of LILES’ injuries.

99. CARNIVAL is liable for the design flaws of the vessel, tender, and ramp, including 

of the subject area and the vicinity involved in LILES’ incident, which it knew or should have 

known of.

100. CARNIVAL failed to correct and/or remedy the defective conditions, despite the fact 

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that CARNIVAL knew or should have known of the danger(s).

101. Furthermore, the subject area and the vicinity were also on a cruise ship in the water 

subject to numerous maritime conditions such as the ship’s movement, additional wear-and-tear 

due to maritime conditions not necessarily present on land, waves, and other conditions unique to 

maritime travel, and as such were “clearly linked to nautical adventure.”

102. CARNIVAL’S breach was the cause in-fact of LILES’ great bodily harm in that, but 

for CARNIVAL’S breach, LILES’ injuries would not have occurred.

103. CARNIVAL’S breach proximately caused LILES great bodily harm in that the 

incident that occurred was a foreseeable result of CARNIVAL’S breach.

104. As a result of CARNIVAL’S negligence, LILES has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

independence, lost wages, lost earning capacity, loss of capacity for the enjoyment of life, expense 

of hospitalization, medical and nursing care and treatment, and loss of the value of LILES’ vacation, 

cruise, and transportation costs.

105. The losses are permanent and/or continuing in nature.

106. LILES has suffered these losses in the past and will continue to suffer such loses in 

the future.

WHEREFORE, Plaintiff, ANGELINA LILES, demands judgment against Defendant, 

CARNIVAL CORPORATION & PLC, for damages suffered and costs incurred, as well as for 

damages and costs that LILES will suffer and incur in the future, as a result of LILES’ bodily

injury, pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, 

medical care and treatment, nursing care and treatment, lost wages, lost earning capacity, loss of 

the value of LILES’ vacation, cruise, transportation costs, loss of important bodily functions, loss 

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of independence, and loss of capacity for the enjoyment of life, for all court costs, pre- and postjudgment interest, and for any and all other relief which this Court deems just or appropriate. 

COUNT VI

NEGLIGENCE FOR THE ACTS OF CARNIVAL’S CREW, STAFF, EMPLOYEES, 

AND/OR AGENTS, BASED ON VICARIOUS LIABILITY 

107. LILES hereby adopts and re-alleges each and every allegation in paragraphs 1 through 

34, as if set forth herein. 

108. CARNIVAL owed a duty to exercise reasonable care under the circumstances for the 

safety of its passengers. 

109. The crewmembers who were working in and/or who were and/or should have been 

responsible for inspecting, maintaining, cleaning, and/or securing the subject area, including 

specifically the crewmembers who were in the immediate vicinity, were agents of CARNIVAL

for the following reasons: 

a. They were the staff and/or employees of CARNIVAL, or were CARNIVAL’S 

agents, apparent agents, and/or servants; and/or 

b. These staff, employees, and/or agents were subject to the right of control by

CARNIVAL; and/or 

c. These staff, employees, and/or agents were acting within the scope of their 

employment or agency; and/or 

d. CARNIVAL acknowledged that these staff, employees, and/or agents would act on 

CARNIVAL’S behalf, and they accepted the undertaking. 

110. CARNIVAL is vicariously liable for the acts of its staff, employees, and/or agents, in 

failing to inspect, maintain, remedy, or warn of the dangerous conditions discussed in paragraph 

17 of the instant complaint.

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111. Furthermore, the subject area and the vicinity were also on a cruise ship in the water 

subject to numerous maritime conditions such as the ship’s movement, additional wear-and-tear 

due to maritime conditions not necessarily present on land, waves, and other conditions unique to 

maritime travel, and as such were “clearly linked to nautical adventure.”

112. CARNIVAL’S breach was the cause in-fact of LILES’ great bodily harm in that, but 

for CARNIVAL’S breach, LILES’ injuries would not have occurred.

113. CARNIVAL’S breach proximately caused LILES great bodily harm in that the 

incident that occurred was a foreseeable result of CARNIVAL’S breach.

114. As a result of CARNIVAL’S negligence, LILES has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

independence, lost wages, lost earning capacity, loss of capacity for the enjoyment of life, expense 

of hospitalization, medical and nursing care and treatment, and loss of the value of LILES’ vacation, 

cruise, and transportation costs.

115. The losses are permanent and/or continuing in nature.

116. LILES has suffered these losses in the past and will continue to suffer such loses in 

the future.

WHEREFORE, Plaintiff, ANGELINA LILES, demands judgment against Defendant, 

CARNIVAL CORPORATION & PLC, for damages suffered and costs incurred, as well as for 

damages and costs that LILES will suffer and incur in the future, as a result of LILES’ bodily 

injury, pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, 

medical care and treatment, nursing care and treatment, lost wages, lost earning capacity, loss of 

the value of LILES’ vacation, cruise, transportation costs, loss of important bodily functions, loss 

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of independence, and loss of capacity for the enjoyment of life, for all court costs, pre- and postjudgment interest, and for any and all other relief which this Court deems just or appropriate. 

COUNT VII

VICARIOUS LIABILITY AGAINST CARNIVAL FOR THE NEGLIGENCE OF THE 

SHIP’S MEDICAL STAFF

117. LILES hereby adopts and re-alleges each and every allegation in paragraphs 1 

through 34, as if set forth herein. 

118. CARNIVAL, 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. 

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

as would an ordinarily prudent person under the circumstances. 

120. 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 CARNIVAL, subject to its direction 

and control, who were engaged in the activity of discharging CARNIVAL’S obligation to make 

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

under the circumstances.

121. CARNIVAL 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.

122. CARNIVAL 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. 

123. CARNIVAL created, owned, directly provided, and operated, the medical center to 

be used by the ship’s medical personnel and passengers. 

124. CARNIVAL pays to stock the medical center with all supplies, medical machinery, 

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

125. CARNIVAL 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.

126. CARNIVAL’S marketing materials described the medical center in proprietary 

language.

127. 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 CARNIVAL.

128. CARNIVAL provided the ship’s medical personnel and regular crew certain forms 

of liability insurance and/or indemnification rights.

129. At all times material hereto, CARNIVAL, 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. LILES had to wait for approximately an hour or two for CARNIVAL’S staff 

to attend to her injuries. 

b. The ship’s doctor failed to diagnose LILES’ injuries. 

c. Moreover, LILES was prescribed an insufficiently strong pain medicine to 

alleviate her pain prior to seeking medical care shoreside, such that she was 

in great pain for a longer amount of time.

d. CARNIVAL failed to promptly provide LILES with proper medical and/or 

first aid care and attention.

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e. CARNIVAL failed to timely and properly attend to LILES, to her injuries, 

and to her pain.

f. CARNIVAL failed to provide reasonable medical and/or first aidcare.

g. CARNIVAL failed to timely and properly treat and care for LILES.

h. CARNIVAL failed to timely and properly examine LILES’ injuries.

i. CARNIVAL failed to take proper measures to secure proper treatment for

LILES, including unreasonably delaying taking measures to secure such 

proper treatment.

j. CARNIVAL failed to properly bring and/or arrange for LILES to be 

brought to a reasonable hospital/emergency room within a reasonable 

amount of time.

k. CARNIVAL failed to give LILES proper discharge instructions.

l. CARNIVAL failed to give LILES adequate pain medicine.

130. Pain is a frequently experienced, yet oftentimes overlooked factor in wound care and 

wound healing. It is undeniable that pain affects wound care practice, and unresolved pain 

negatively impacts both wound healing and a patient's quality of life.

131. 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 their 

employment and/or agency.

132. CARNIVAL is therefore vicariously liable for all injuries and damages sustained by 

LILES as a result of the negligence of the ship’s medical staff (including its physicians and nurses), 

and the ship’s crew.

133. At all times material hereto, the aforementioned acts and/or omissions on the part of 

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

below the standard of care.

134. The negligence of CARNIVAL’S ship’s medical staff (including its physicians and 

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

CARNIVAL’s negligence, LILES’ injuries would not have occurred and/or said injuries would 

have been substantially lessened.

135. CARNIVAL, through its employees and agents, including 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.

136. As a result of CARNIVAL’S negligence, LILES has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

independence, lost wages, lost earning capacity, loss of capacity for the enjoyment of life, expense 

of hospitalization, medical and nursing care and treatment, and loss of the value of LILES’ vacation, 

cruise, and transportation costs.

137. The losses are permanent and/or continuing in nature.

138. LILES has suffered these losses in the past and will continue to suffer such loses in 

the future.

WHEREFORE, Plaintiff, ANGELINA LILES, demands judgment against Defendant, 

CARNIVAL CORPORATION & PLC, for damages suffered and costs incurred, as well as for 

damages and costs that LILES will suffer and incur in the future, as a result of her bodily injury, 

pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, medical 

care and treatment, nursing care and treatment, lost wages, lost earning capacity, loss of the value 

of LILES’ vacation, cruise, transportation costs, loss of important bodily functions, loss of 

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independence, and loss of capacity for the enjoyment of life, for all court costs, pre- and postjudgment interest, and for any and all other relief which this Court deems just or appropriate. 

COUNT VIII

APPARENT AGENCY

FOR THE ACTS OF THE SHIP’S MEDICAL STAFF

139. LILES hereby adopts and re-alleges each and every allegation in paragraphs 1 

through 34, as if set forth herein. 

140. At all times material hereto, the ship’s medical staff and regular crew represented to 

LILES and to the ship’s passengers as employees and/or agents and/or servants of CARNIVAL, 

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 CARNIVAL;

f. The medical staff worked aboard the vessel; 

g. The medical staff spoke to LILES as though they had authority to do so by CARNIVAL. 

141. In addition, CARNIVAL further represented to LILES that the vessel’s medical staff 

and regular crew were agents and/or employees of CARNIVAL through its marketing materials 

and through other official statements that described the medical center in proprietary language, 

including language such as the “Carnival Vista’s Medical Center/our infirmary/our medical 

center,” and through encouraging LILES to make use of “its” infirmary/medical center if LILES

was in need of medical attention.

142. Furthermore, at no time did CARNIVAL represent to LILES in particular, or the 

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ship’s passengers in general, in a meaningful way that the vessel’s medical staff and regular crew 

were not agents or employees of CARNIVAL.

143. At all material times, LILES reasonably relied on the representations to LILES’

detriment that the medical staff and regular crew were employees, and/or agents, and/or servants 

of CARNIVAL.

144. It was reasonable to believe that the medical staff and regular crew were 

CARNIVAL’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 CARNIVAL.

145. This reasonable reliance was detrimental because it delayed LILES from receiving 

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

CARNIVAL had LILES known that the medical staff and regular crew on the ship were not 

CARNIVAL’S agents.

146. CARNIVAL is estopped to deny that the medical staff and regular crew were its 

apparent agents, and/or apparent employees, and/or apparent servants.

147. CARNIVAL had a duty to provide LILES with reasonable care under the 

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

reasonable care under the circumstances.

148. LILES’ injuries were aggravated due to the fault and/or negligence of CARNIVAL 

through the acts of its apparent agents as follows:

a. LILES had to wait for approximately an hour or two for CARNIVAL’S staff 

to attend to her injuries. 

b. The ship’s doctor failed to diagnose LILES’ injuries. 

c. Moreover, LILES was prescribed an insufficiently strong pain medicine to 

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alleviate her pain prior to seeking medical care shoreside, such that she was 

in great pain for a longer amount of time.

d. CARNIVAL failed to promptly provide LILES with proper medical and/or 

first aid care and attention.

e. CARNIVAL failed to timely and properly attend to LILES, to her injuries, 

and to her pain.

f. CARNIVAL failed to provide reasonable medical and/or first aidcare.

g. CARNIVAL failed to timely and properly treat and care for LILES.

h. CARNIVAL failed to timely and properly examine LILES’ injuries.

i. CARNIVAL failed to take proper measures to secure proper treatment for

LILES, including unreasonably delaying taking measures to secure such 

proper treatment.

j. CARNIVAL failed to properly bring and/or arrange for LILES to be 

brought to a reasonable hospital/emergency room within a reasonable 

amount of time.

k. CARNIVAL failed to give LILES proper discharge instructions.

l. CARNIVAL failed to give LILES adequate pain medicine.

149. Pain is a frequently experienced, yet oftentimes overlooked factor in wound care and 

wound healing. It is undeniable that pain affects wound care practice, and unresolved pain 

negatively impacts both wound healing and a patient's quality of life.

150. As a result of CARNIVAL’S negligence, LILES has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

independence, lost wages, lost earning capacity, loss of capacity for the enjoyment of life, expense 

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of hospitalization, medical and nursing care and treatment, and loss of the value of LILES’ vacation, 

cruise, and transportation costs.

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

152. LILES has suffered these losses in the past and will continue to suffer such loses in 

the future. 

WHEREFORE, Plaintiff, ANGELINA LILES, demands judgment against Defendant, 

CARNIVAL CORPORATION & PLC, for damages suffered and costs incurred, as well as for 

damages and costs that LILES will suffer and incur in the future, as a result of her bodily injury, 

pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, medical 

care and treatment, nursing care and treatment, lost wages, lost earning capacity, loss of the value 

of LILES’ vacation, cruise, transportation costs, loss of important bodily functions, loss of 

independence, and loss of capacity for the enjoyment of life, for all court costs, pre- and postjudgment interest, and for any and all other relief which this Court deems just or appropriate. 

COUNT IX

ASSUMPTION OF DUTY FOR THE

NEGLIGENCE OF THE SHIP’S MEDICAL STAFF

153. LILES hereby adopts and re-alleges each and every allegation in paragraphs 1 

through 34 as if set forth herein. 

154. CARNIVAL owed LILES the duty to exercise reasonable care under the 

circumstances for the safety of its passengers.

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

as would an ordinarily prudent person under the circumstances. 

156. CARNIVAL elected to discharge this duty by having LILES seen by its own ship’s 

physicians and/or other crew members. 

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157. As such, CARNIVAL voluntarily assumed a duty for the benefit of LILES to use 

reasonable care in the provision of medical services to LILES.

158. At all times material hereto, CARNIVAL, 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. LILES had to wait for approximately an hour or two for CARNIVAL’S staff 

to attend to her injuries. 

b. The ship’s doctor failed to diagnose LILES’ injuries. 

c. Moreover, LILES was prescribed an insufficiently strong pain medicine to 

alleviate her pain prior to seeking medical care shoreside, such that she was 

in great pain for a longer amount of time.

d. CARNIVAL failed to promptly provide LILES with proper medical and/or 

first aid care and attention.

e. CARNIVAL failed to timely and properly attend to LILES, to her injuries, 

and to her pain.

f. CARNIVAL failed to provide reasonable medical and/or first aidcare.

g. CARNIVAL failed to timely and properly treat and care for LILES.

h. CARNIVAL failed to timely and properly examine LILES’ injuries.

i. CARNIVAL failed to take proper measures to secure proper treatment for

LILES, including unreasonably delaying taking measures to secure such 

proper treatment.

j. CARNIVAL failed to properly bring and/or arrange for LILES to be 

brought to a reasonable hospital/emergency room within a reasonable 

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amount of time.

k. CARNIVAL failed to give LILES proper discharge instructions.

l. CARNIVAL failed to give LILES adequate pain medicine.

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

CARNIVAL fell below the standard of care.

160. CARNIVAL’S negligence proximately caused LILES great bodily harm in that, but 

for CARNIVAL’S negligence, LILES’ injuries would not have occurred, would have been 

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

161. CARNIVAL, through its employees and agents, to wit, the ship’s medical staff and 

regular crew, knew, or should have known, that the medical and first aid procedures they employed 

violated reasonable standards of medical care.

162. As a result of CARNIVAL’S negligence, LILES has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

independence, lost wages, lost earning capacity, loss of capacity for the enjoyment of life, expense 

of hospitalization, medical and nursing care and treatment, and loss of the value of LILES’ vacation, 

cruise, and transportation costs.

163. The losses are permanent and/or continuing in nature.

164. LILES has suffered these losses in the past and will continue to suffer such loses in 

the future.

WHEREFORE, Plaintiff, ANGELINA LILES, demands judgment against Defendant, 

CARNIVAL CORPORATION & PLC, for damages suffered and costs incurred, as well as for 

damages and costs that LILES will suffer and incur in the future, as a result of her bodily injury, 

pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, medical 

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care and treatment, nursing care and treatment, lost wages, lost earning capacity, loss of the value 

of LILES’ vacation, cruise, transportation costs, loss of important bodily functions, loss of 

independence, and loss of capacity for the enjoyment of life, for all court costs, pre- and postjudgment interest, and for any and all other relief which this Court deems just or appropriate. 

DEMAND FOR JURY TRIAL

Plaintiff, ANGELINA LILES, demands trial by jury on all issues so triable.

Dated: September 16, 2022. 

Respectfully submitted,

/s/ Matthias M. Hayashi 

Spencer M. Aronfeld, Esq.

Florida Bar No.: 905161

aronfeld@Aronfeld.com 

Matthias M. Hayashi

Florida Bar No.: 115973

mhayashi@aronfeld.com

Abby H. Ivey, Esq.

Florida Bar No.: 1002774 

aivey@aronfeld.com

ARONFELD TRIAL LAWYERS

One Alhambra Plaza, Penthouse 

Coral Gables, Florida 33134 

P: (305) 441.0440 

F: (305) 441.0198 

Attorneys for LILES

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