UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

IN ADMIRALTY

CASE NO.:

ELIO ELISEO HODGSON CUNNINGHAM

 Plaintiff,

v. 

CELEBRITY CRUISES INC., a Foreign forprofit Corporation,

Defendant. 

________________________________________/

SEAMAN’S COMPLAINT AND DEMAND FOR JURY TRIAL

COMES NOW, the Plaintiff, ELIO ELISEO HODGSON CUNNINGHAM (hereinafter 

“Mr. HODGSON CUNNINGHAM”), by and through undersigned counsel, hereby files his 

Complaint and sues the Defendant, CELEBRITY CRUISES INC., (hereinafter “CELEBRITY"”), 

a foreign for-profit corporation whose principal place of business is 1050 Caribbean Way, Miami, 

FL 33132, and in support states as follows:

GENERAL ALLEGATIONS

I. JURISDICTION

1. This is an admiralty and maritime cause of action arising under the General

Maritime Laws of the United States as well as the Merchant Marine Act of 1920 (the “Jones Act”), 

46 USC § 30104, et seq., against the ship owner and/or operator for breach of its nondelegable 

duties owed to Seafarer and injuries incurred while aboard Defendant’s vessel, MV MEIN SCHIFF

2.

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2. Jurisdiction is vested in this Court pursuant to 28 U.S.C. § 1333, and pursuant to 

Article III, Section 2 of the U.S. Constitution.

3. The matter in controversy exceeds, exclusive of interest and costs, the sum 

specified by 28 U.S.C. § 1332.

4. Venue and jurisdiction is proper in this Court as a substantial part of Defendant,

CELEBRITY’S actions and/or omission occurred in the navigable waters of United States,

including the navigable waters of the State of Florida.

II. PARTIES

4. Plaintiff, Mr. ELIO ELISEO HODGSON CUNNINGHAM, is a citizen of 

Nicaragua, was a seaman, and a crew member aboard the MV MEIN SCHIFF 2 including but not 

limited to January 2020 through March 2020.

5. At all times material hereto, Plaintiff, Mr. HODGSON CUNNINGHAM worked 

aboard Defendant, CELEBRITY’s owned vessel, the MV MEIN SCHIFF 2, as an Assistant

Housekeeper which required him to constantly lift and carry heavy items, including king-sized 

mattresses, in a fast pace.

6. At all times material hereto, Defendant, CELEBRITY was and/or is the shipowner 

of the MV MEIN SCHIFF 2 and is responsible for the duties and responsibilities imposed on ShipOwners as defined in and in accordance with MLC, 2006. See, Box 5 of the Employment Contract 

dated December 17, 2019 marked as Exhibit 1.

7. Defendant, CELEBRITY, the owner of the subject vessel, was and/or is a foreign 

for-profit corporation, with its principal place of business and business headquarters located at 

1050 Caribbean Way, Miami, Miami-Dade County, Florida 33132. Id.

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8. At all times material hereto, Defendant, CELEBRITY is a citizen of the State of

Florida.

9. At all times material hereto, the MV MEIN SCHIFF 2 repeatedly sailed in United

States territorial waters, regularly calling upon several east coast U.S. ports, including the Port of 

Miami in Florida.

10. At all times material hereto, the MV MEIN SCHIFF 2, a Maltese flagged vessel, 

her engines, tackle and appurtenances, was, and/or is a self-propelled ocean-going cruise vessel,

bearing IMO number 9783576.

11. At all times material hereto, the MV MEIN SCHIFF 2 was, and/or is, and/or during 

the pendency of this action, will be in Miami-Dade County, Florida.

12. At all times material hereto, the MV MEIN SCHIFF 2 has engaged and is currently 

engaged in the business of trade and commerce within Miami-Dade County, Florida and is 

amenable to the jurisdiction of this Court.

13. At all times material hereto, Malta is a signatory and/or has ratified the Maritime

Labour Convention (2006) (hereinafter "MLC"), the governing international standards on ship

safety, human security and quality ship management.

14. At all times material hereto, Defendant, CELEBRITY as the shipowner of the MV

MEIN SCHIFF 2 handles all aspects of compliance with the MLC (2006), the governing

international standards on ship safety, human security and quality ship management, out of its

Miami headquarters. See, Exhibit 1.

15. At all times material hereto, Defendant, CELEBRITY as the shipowner of the MV

MEIN SCHIFF 2 must comply with the MLC (2006).

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16. At all times material hereto, Defendant, CELEBRITY as the shipowner of the MV

MEIN SCHIFF 2 handles all aspects of compliance with the MLC (2006) Title 2 “Conditions of

Employment” including Regulation 2.3 “Hours of Work and Hours of Rest” and Regulation 2.7

“Manning Levels”, out of its Miami headquarters.

17. At all times material hereto, Defendant, CELEBRITY as the shipowner of the MV

MEIN SCHIFF 2 handles all aspects of compliance with the MLC (2006) Title 4, “Health and

Safety Protection and Accident Prevention,” including Regulation 4.2 “Shipowners’ liability”, and 

Regulation 4.3 “Health and Safety Protection and Accident Prevention” out of its Miami

headquarters.

18. At all times material hereto, Defendant, CELEBRITY as the shipowner of the MV

MEIN SCHIFF 2 arranges, handles and/or coordinates material aspects of the vessel’s

management, operation, itinerary, maintenance, and inspections by the United States Coast Guard, 

P&I Club and Maltese’s competent authority.

19. At all times material hereto, Defendant, CELEBRITY as the shipowner of the MV

MEIN SCHIFF 2 accepted the responsibility imposed upon vessel owners as defined in and in

accordance with the MLC (2006).

20. At all times material hereto, Defendant, CELEBRITY, out of its Miami

headquarters, conducts, manages, and/or oversees its global advertisement and marketing, which

includes the subject vessel.

21. Defendant, CELEBRITY, as shipowner of the MV MEIN SCHIFF 2 has a

nondelegable duty to provide its crew, such as Seafarer, CALLEJAS, with a seaworthy vessel and 

a safe workplace.

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22. Defendant, CELEBRITY breached its duty and created an unseaworthy condition,

rendering the subject vessel unfit for her intended purpose and failed to provide Plaintiff with

enough seafarers to complete tasks assigned, work areas with proper air circulation, and competent 

medical personnel.

23. Defendant, CELEBRITY further breached its nondelegable duty to provide

Plaintiff with a safe workplace which rendered the vessel unseaworthy and caused and/or

contributed to the injuries, damages, pain and suffering experienced by the Plaintiff.

24. This Court can freely exercise personal jurisdiction over Defendant, CELEBRITY

and subject vessel, who at all times material hereto, personally, and/or through its agents:

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

in the State of Florida, or has an office or agency in this state and/or county;

b. Was engaged insubstantial activity within the State of Florida;

c. Operated vessels in the navigable waters of the State of Florida;

d. Contracted to supply services or things in whole, or in part in the State of

Florida;

e. Committed one or more of the acts stated in Florida Statutes, Section 48.081,

48.181, or 48.193; and

f. The acts of Defendant, CELEBRITY as set forth in this Complaint is whole or

in part of this county and/or state.

III. LIABILTY

25. On or about January 17, 2020, Plaintiff, Mr. HODGSON CUNNINGHAM joined 

the MV MEIN SCHIFF 2 which Defendant, CELEBRITY owned.

26. In March 2020, shortly after joining the vessel, there was an outbreak of the 

coronavirus worldwide, which forced cruise ships, including MV MEIN SCHIFF 2, to cease all 

carriage of passengers. Unfortunately, once passengers were debarked from the vessel, seafarers, 

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including Mr. HODGSON CUNNINGHAM, were required to remain on the vessel to work in 

unsafe conditions. 

27. In March 2020, Plaintiff, Mr. HODGSON CUNNINGHAM was required to work

all day on MV MEIN SCHIFF 2’s decks in sauna like conditions. As the vessel was located offshore 

the port of Barbados, these conditions were exacerbated by the heat and humidity. 

28. In March 2020, Plaintiff, Mr. HODGSON CUNNINGHAM was also required to 

work with other crew members in enclosed areas, doing special cleaning tasks. As the vessel was 

not on a voyage due to the pandemic, Defendant, CELEBRITY had MV MEIN SCHIFF 2’s air 

conditioning system turned off so enclosed areas during the coronavirus pandemic lacked 

circulated air. This exposed Plaintiff, Mr. HODGSON CUNNINGHAM to coronavirus on a daily 

basis. Plaintiff, Mr. HODGSON CUNNINGHAM was not provided with sufficient and/or 

adequate personal protective equipment (“PPE”) and often found himself out of breath when he 

was provided with PPEs.

29. As the vessel was operating with a limited number of seafarers, Plaintiff, Mr. 

HODGSON CUNNINGHAM was tasked with cleaning assignments that were usually performed 

by more than one seafarer. This forced Plaintiff to constantly overexert himself to complete the 

daily tasks he was assigned to do.

30. At all times material hereto, Defendant, CELEBRITY knew and was on notice that 

the subject vessel had an inadequate number of crew members assigned to the daily cleaning tasks 

during the pandemic that Plaintiff, Mr. HODGSON CUNNINGHAM was ordered to perform.

31. At all times material hereto, Defendant, CELEBRITY knew and was on notice that 

the subject vessel did not have an adequate and competent crew, including its medical staff, which 

rendered the unseaworthy. 

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32. In March 2020, Plaintiff, Mr. HODGSON CUNNINGHAM visited the ship’s 

infirmary complaining of a cough, congestion, and headaches. Based on his complaints, the ship’s 

medical personnel ordered him to take a combination of medications, including Novaminsulfon 

500 mg (an anti-inflammatory) and Moxifloxacin Hexal 400 mg (a powerful antibiotic).

33. Unfortunately, Moxifloxacin is a dangerous medication and is known to cause 

serious health risks. In fact, The U.S. Federal Drug Administration (“FDA”) has assigned 

Moxifloxacin its highest warning on any drug, known as a “black box” warning. The warnings 

from the FDA included a risk of central nervous system effects, including seizures, convulsions 

and increased pressure in the patient’s head. The FDA also noted that the drug was also known to 

be dangerous for persons with other health conditions. It warned that the drug could cause people 

with diabetes to develop low blood sugar which could result in a coma and/or death. It also warned 

that the drug could cause seizures and change a patient’s heart rhythm. As a result of the multiple 

warnings, the FDA recommended that this drug be used only to treat certain specific infectious 

conditions if no other treatment option existed.

34. Additionally, Defendant, CELEBRITY not only prescribed this dangerous drug, it 

also combined the drug with an anti-inflammatory agent that is banned in many countries including 

the United States and Western Europe because of toxic side effects. Based on FDA warnings, 

taking Moxifloxacin with certain medication, including NSAIDs, could increase potency and the 

risk of side effects. Despite this, the dangerous combination was prescribed to Plaintiff, Mr. 

HODGSON CUNNINGHAM.

35. At all times material hereto, Defendant, CELEBRITY knew and was on notice that 

Plaintiff, Mr. HODGSON CUNNINGHAM had prior medical conditions, including diabetes and 

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hypertension, and the medication prescribed had the potential of causing increased pressure in his 

head and severe neurological effects. 

36. At all times material hereto, Defendant, CELEBRITY knew and was on notice that 

if Plaintiff, Mr. HODGSON CUNNINGHAM took the combination of the medication ordered by 

its medical personnel, that could increase his risk of side effects.

37. Plaintiff, Mr. HODGSON CUNNINGHAM was never informed/warned of the 

dangers of taking any of the medication he was given. Trusting the competence of the medical 

personnel provided by Defendant, CELEBRITY, Plaintiff, Mr. HODGSON CUNNINGHAM took 

the medications and immediately returned to work as ordered. Plaintiff, Mr. HODGSON 

CUNNINGHAM was not given any work restrictions.

38. On March 22, 2020, Plaintiff, Mr. HODGSON CUNNINGHAM was ordered to 

clean the areas of Deck 6 on MV MEIN SCHIFF 2. Deck 6, like every other deck on the subject 

vessel, had no air circulation despite having sauna like conditions. As customary, he had to lift and 

carry heavy items including mattresses and do so at a fast pace. Upon completing those tasks, 

Plaintiff, Mr. HODGSON CUNNINGHAM was ordered to prepare for deep cleaning using 

electrostatic cleaning equipment. He proceeded to Deck 9 aft area where he and other crew 

members were ordered to lift, carry and transport approximately fifty (50) king size mattresses. He 

was also ordered to move the fifty mattresses to a crew area (away from the common areas), 

remove each mattress cover and sheet and take those items to the laundry located on Deck 1. This 

was hard and arduous work aggravated by the heat and diminished number of fellow crew 

members. 

39. While performing his duties (lifting and carrying heavy mattresses and mattress 

covers) on March 22, 2020, Plaintiff, Mr. HODGSON CUNNINGHAM began to feel dizzy, faint 

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and subsequently collapsed. The nearby crew members informed him that his left side was 

paralyzed. He began to convulse and became unconscious for nearly 60 minutes. Plaintiff, Mr. 

HODGSON CUNNINGHAM was told by Defendant, CELEBRITY’s shipboard doctor that he 

suffered “unclear consciousness disorder for 60 min suspected intercranial bleeding apoplectic 

insult.” Unfortunately, Defendant’s physicians, ignored and/or failed to consider the medications 

prescribed by shipboard personnel, the unsafe work conditions, and/or the nature and pace of his 

laborious job.

40. At all times material hereto, Defendant, CELEBRITY knew or was on notice that 

Plaintiff, Mr. HODGSON CUNNINGHAM and all housekeepers and assistant housekeepers that 

were on the vessel during the pandemic were repeatedly ordered to perform strenuous tasks at a 

rapid pace in sauna like conditions in areas with uncirculated air. 

41. At all times material hereto, Defendant, CELEBRITY’s vessel was undermanned 

and/or had inadequately trained crew for the proper transportation of heavy king-sized mattresses 

from Deck 9 to the crew area.

42. At all times material hereto, Defendant, CELEBRITY’s vessel had inadequately 

trained crew, including its medical personnel which prescribed dangerous medication to seafarers 

on its vessels, including Plaintiff, Mr. HODGSON CUNNINGHAM.

43. At all times material hereto, Defendant, CELEBRITY breached its ongoing 

nondelegable duties to provide a seaworthy vessel, and to take all reasonable precautions to protect 

Plaintiff, Mr. HODGSON CUNNINGHAM and other seafarers aboard its ships from future 

injuries.

44. Defendant, CELEBRITY knew or was on notice of the unsafe conditions of the 

vessel and failed to correct the unsafe condition(s).

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45. As a result of the unsafe conditions, Plaintiff, Mr. HODGSON CUNNINGHAM

was signed of the vessel and hospitalized in Barbados from March 22, 2020 to April 9, 2020 with 

sequelae of conditions relating to his stroke, including aphasia, pneumonia, right hemiparesis, and 

facial paralysis. Plaintiff, Mr. HODGSON CUNNINGHAM was provided physical therapy, 

occupational therapy and speech therapy. The doctors were concerned that he would have another 

stroke so he was placed on aspirin and atorvastatin for secondary stroke prevention. 

46. On April 9, 2020, Plaintiff, Mr. HODGSON CUNNINGHAM was transferred to a 

rehabilitation facility and was treated for right hemiparesis and global aphasia. 

47. On May 4, 2020, an audiometric evaluation revealed decreased hearing in his left 

ear with overall difficulty processing language.

48. Defendant, CELEBRITY, out of its Miami headquarters arranged, handled and/or

coordinated Plaintiff, Mr. HODGSON CUNNINGHAM debarkation from the vessel, and 

transportation to the hospital in Barbados. 

49. Defendant, CELEBRITY, out of its Miami headquarters paid for Plaintiff, Mr. 

HODGSON CUNNINGHAM’s medical treatment in Barbados utilizing a South Florida bank 

account.

50. Thereafter, Plaintiff, Mr. HODGSON CUNNINGHAM was returned to Nicaragua

for further medical care and treatment.

51. While in Nicaragua, Plaintiff, Mr. HODGSON CUNNINGHAM was evaluated by 

a neurologist at Vivian Pellas Hospital for a cerebral artery infarct with right upper extremity 

weakness. Unfortunately, on November 24, 2020, Plaintiff, Mr. HODGSON CUNNINGHAM

began to experience seizures again and had to be admitted to the hospital. 

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52. On January 29, 2021, Plaintiff, Mr. HODGSON CUNNINGHAM was diagnosed 

with abnormal language function with reduced communication.

53. An MRI done on February 21, 2021, revealed a chronic left middle cerebral artery 

infarct and an EEG revealed left-sided focal slowing.

54. Surprisingly, on April 30, 2021, Defendant, CELEBRITY’s chosen physical 

therapist found Plaintiff, Mr. HODGSON CUNNINGHAM to be at maximum medical 

improvement, even though he noted residual speech issues.

55. Only sixteen days later, on May 16, 2021, Plaintiff, Mr. HODGSON 

CUNNINGHAM had additional seizures and was once again hospitalized.

56. Unfortunately, Defendant, CELEBRITY abandoned Plaintiff, Mr. HODGSON 

CUNNINGHAM and has left the burden on his family to care for him.

57. On October 17, 2022, after performing a comprehensive neurological evaluation on 

Plaintiff, Mr. HODGSON CUNNINGHAM, American Board Certified Neurologist, Dr. Kenneth 

Fischer opined that as a result of his predisposed factors of hypertension and diabetes, being 

prescribed the unwarranted dangerous medications, specifically Moxifloxacin and Novaminsulfon, 

then being ordered to perform unusually heavy labor, are the proximate cause of his stroke. Dr. 

Fischer opined that Plaintiff, Mr. HODGSON CUNNINGHAM will need ongoing care to 

ameliorate the substantial effects of the stroke as well as further treatment for his secondary seizure 

disorder. Dr. Fischer opined that Plaintiff, Mr. HODGSON CUNNINGHAM is not at maximum 

medical treatment and required additional diagnostic and therapeutic interventions.

58. As a result of the unsafe conditions and prescribed medications which caused his 

stroke, at the tender age of forty-eight (48), Plaintiff, Mr. HODGSON CUNNINGHAM continues 

to suffer from convulsions and ischemic episodes. He continues to struggle with serious motor and 

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cognitive deficiencies and physical problems (including headaches, dizziness and body pain). He 

is unable to complete basic cognitive tasks like recognizing letters, challenges with short-term 

memory, frustrations communicating and on occasion unable to recognize family and friends. He 

also has difficulties with various motor skills (i.e., difficulties speaking, maintaining his balance 

and walking). Plaintiff, Mr. HODGSON CUNNINGHAM is also unable to care for himself and 

requires 24-hour monitoring and care. Plaintiff, Mr. HODGSON CUNNINGHAM undergoes

physical therapy, motor physiotherapy and speech therapy. He will require further treatment 

including occupational therapy. The treatment prescribed is in hope of regaining basis motor 

functions.

59. At all times material hereto, as a result of Defendant CELEBRITY's breach of its 

nondelegable duties caused Plaintiff, Mr. HODGSON CUNNINGHAM’s injuries.

60. At all times material hereto, Defendant, CELEBRITY had notice of the strenuous 

tasks housekeeping personnel were required to person in sauna like conditions in enclosed areas 

during the coronavirus pandemic and failed to take proper precautions to protect Plaintiff, Mr. 

HODGSON CUNNINGHAM.

61. At all times material hereto, Defendant, CELEBRITY had notice of the 

incompetence of its medical personnel and failed to take proper precautions to protect Plaintiff, 

Mr. HODGSON CUNNINGHAM.

62. Defendant, CELEBRITY knew and/or should have known of the unsafe condition

and failed to correct the condition which resulted in Plaintiff, Mr. HODGSON CUNNINGHAM’s

injuries.

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63. At all times material hereto, Plaintiff, Mr. HODGSON CUNNINGHAM’s injuries 

were reasonably foreseeable and the subject vessel, crew, appurtenances and operations were not 

reasonably fit for the vessel’s intended purpose.

COUNT I

UNSEAWORTHINESS

Plaintiff readopts and re-alleges paragraphs 1 to 63, as if stated herein verbatim and further 

alleges:

64. This action arises as an admiralty and maritime claim under the general maritime

law of the United States.

65. On or about the previously stated date, Plaintiff was a member of the crew of

Defendant’s vessel, which was in U.S. navigable waters.

66. At all times material hereto, the vessel was owned by Defendant, CELEBRITY out 

of its Miami office. See, Box 5 of the Employment Contract dated December 17, 2019 marked as 

Exhibit 1. 

67. Defendant had the absolute nondelegable duty to provide Plaintiff with a seaworthy 

vessel.

68. On or about the previously stated date, the unseaworthiness of Defendant's vessel

was a legal cause of injury and damage to Plaintiff by reason of the following:

a. Failure to use reasonable care to provide and maintain a safe place to work for 

Plaintiff;

b. Failure to promulgate and enforce reasonable rules and regulations to ensure 

the safety and health of the crew members and more particularly the Plaintiff, 

while working on said vessel;

c. Failure to use reasonable care to provide Plaintiff with a safe place to work by 

failing to use reasonable care to maintain the vessel in a safe condition;

d. Failure to establish a proper and safe method of operation;

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e. Failure to properly assign sufficient crew to perform the tasks performed by 

hotel personnel including assistant housekeepers;

f. Implementing unsafe procedures for crew members to carry out the tasks 

ordered;

g. Operational negligence on the part of CELEBRITY was pervasive and

repeatedly frequently resulted in reported slip and falls in the galley areas;

h. Failure to take proper work schedule precautions to avoid fatigue among crew 

members, including Plaintiff;

i. Failure to have proper lifting and carrying procedures for crew members and 

improperly requiring crew members to repeatedly lift and carry heavy loads for 

hours during a day;

j. Failure to perform occupational studies to avoid or reduce number of injuries 

to crew members aboard its vessel;

k. Failure to use reasonable care to provide Plaintiff a safe place to work by failing 

to warn Plaintiff of the potential dangers;

l. Failure to follow sound management practices aboard its vessel with the goal 

of providing Plaintiff a safe place to work;

m. Failure to provide adequate safety measures to guard against known risks of 

injury to crew members;

n. Failure to have a proper, adequate, and safe Safety Management System Manual 

aboard subject vessel and/or failed to follow it on board the vessel on which 

Plaintiff served, as referenced by the International Safety Management Code;

o. Failing to report, investigate, and conduct comprehensive statistics for analysis 

and publication of all occupational accidents, occupational injuries and diseases 

as required of all shipowners under the governing MLC (2006) and other 

international standards; and

p. Breaching its obligations under the MLC (2006) as the shipowner.

69. Under the general maritime law of the U.S., Defendant, CELEBRITY, as the owner 

of the subject vessel had the continuing duty to supply a vessel seaworthy in all its parts, including 

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personnel and gear. This nondelegable duty ensures the vessel seaworthiness which Defendant, 

CELEBRITY breached.

70. Defendant, CELEBRITY as the shipowner assumes the nondelegable legal

obligation and responsibilities under the general maritime law of the U.S. and is subject to MLC

(2006) and all its rules and standards.

71. Defendant, CELEBRITY breached its legal and continuous duty to supply a

seaworthy vessel and failed to take proper corrective measures to cure a systemic problem with

the unsafe method of galley operations.

72. Defendant, CELEBRITY’S failure to supply a vessel seaworthy in all her parts

directly caused Plaintiff’s injuries. Plaintiff’s serious motor and cognitive deficiencies, other 

physical problems and continued disability were a reasonably probable consequence of the unsafe 

work conditions and medication provided to him by Defendant’s medical personnel caused by the 

vessel's unseaworthiness.

73. As a direct and proximate result of the unseaworthiness of the Defendant,

CELEBRITY’S vessel, the Plaintiff was injured about his body and extremities, suffered pain

therefrom, incurred medical expenses in the care and treatment, suffered physical handicap,

permanent disability from shipboard employment, lost wages and his working ability has been

impaired. The injuries are permanent or continuing in nature and Plaintiff will suffer losses and

impairments in the future.

WHEREFORE, Plaintiff, ELIO ELISEO HODGSON CUNNINGHAM demands 

judgment against Defendant, CELEBRITY CRUISES INC., for actual and compensatory 

damages, prejudgment and post-judgment interest, and any further relief this Court deems just.

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DEMAND FOR TRIAL BY JURY

Plaintiff, ELIO ELISEO HODGSON CUNNINGHAM, demands a trial by jury of all

issues so triable as a matter of right.

Dated: November 4th, 2022

Respectfully submitted, 

Attorney for Plaintiff 

/s/Alejandro J. Gonzalez

Alejandro J. Gonzalez, Esq 

GONZALEZ,P.A.

19 S Krome Ave. Homestead, 

FL 33030 

Email: alex@agonzalezlaw.com

www.agonzalezlaw.com

FL Bar No. 015293 

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Exhibit 1

Employment Contract

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