Stevenson v. Spirit Cruises, LLC.

Filing 1

COMPLAINT filed by Ashley Stevenson; Jury Demand. Filing fee $ 350, receipt number 0752-6539534.(O'Bryan, Dennis)

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
ASHLEY STEVENSON,
Plaintiff,
-vs-

Case No: 11-7839

SPIRIT CRUISES, LLC,
Defendant.
_____________________________________________/
O'BRYAN BAUN KARAMANIAN
DENNIS M. O'BRYAN (P30545)
Attorney for Plaintiff
401 S. Old Woodward, Suite 450
Birmingham, MI 48009
[phone]
[phone]
[e-mail]
-andFrederic Mendelsohn, (6193281)
Burke, Warren, MacKay & Serritella, P.C.
Local Counsel
22nd Floor
330 N. Wabash Ave.
Chicago, IL 60611-3607
312-840-7004
312-840-7900 - fax
[e-mail]
_____________________________________________/

COMPLAINT

NOW COMES Plaintiff, by and through counsel undersigned, O'BRYAN BAUN
KARAMANIAN, complaining against Defendant as follows:

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1.

Jurisdiction and venue lie in this action, Defendant conducting business within this

forum's boundaries.
2.

Jurisdiction is founded under the Jones Act (46 USCA 30104) for negligence, and

under the General Maritime Law for unseaworthiness, maintenance, cure and wages.
3.

At all times material to issues herein Plaintiff served as an employee of Defendant

serving as a crew member aboard its vessels, with all acts and/or omissions giving rise to this action
occurring in the course of Plaintiff's employment in the service of his ship.
4.

On or about September 1, 2011, Plaintiff was in the course of her employment when

she was required to negotiate on an inadequately lit stairway and as a result of said failure to provide
a safe place to work and seaworthy vessel she was injured.
5.

Defendant's tortuous acts aforesaid caused or contributed to Plaintiff's damages, inter

alia, as follows:
a.

Pain and suffering, past, present and future;

b.

Mortification, humiliation, fright
shock and embarrassment;

c.

Loss of earnings and earning capacity;

d.

Hospital, pharmaceutical and other
cure expenses;

e.

Aggravation of prior condition, if
any there be;

f.

Inability to engage in social, recreational,
and other pursuits previously enjoyed;

g.

Mental anguish;

h.

Found;
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i.

Maintenance, cure, wages, attorney fees and/or
punitive damages.

WHEREFORE, Plaintiff demands trial by jury and judgment against Defendant, together
with interest, costs, attorney fees and expenses, all to be methodically adjusted upwards during the
pendency of this cause.

O'BRYAN BAUN KARAMANIAN
/s/ Dennis M. O’Bryan
_________________________________
DENNIS M. O'BRYAN (P30545)
Attorneys for Plaintiff
40l S. Old Woodward, Suite 450
Birmingham, MI 48009
[phone]
[phone] - fax
[e-mail]
-and/s/ Frederic Mendelsohn (w/ consent)
______________________________________
Frederic Mendelsohn, (6193281)
Burke, Warren, MacKay & Serritella, P.C.
Local Counsel
22nd Floor
330 N. Wabash Ave.
Chicago, IL 60611-3607
312-840-7004
312-840-7900 - fax
[e-mail]
Dated:

November 4, 2011

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