Summary of the Complaint
Case No. 25-CV-1364, U.S. District Court for the District of Puerto Rico
Filed July 10, 2025
Nature of the Action
Personal Injury / Premises Liability Negligence
- Plaintiff: Connecticut resident slipped and fell on a wet floor at La Concha Renaissance San Juan Resort
- Seeking: $795,000+ in damages
- Based on: Puerto Rico negligence law (Articles 1536 & 1540, 31 L.P.R.A. §§ 10801, 10805)
- Direct actions against hotel’s insurers
Key Parties
- Plaintiff:
- Deandree Jaunai, 25, Connecticut resident
- Defendants (jointly and severally liable):
- Condado Duo La Concha SPV, LLC (Delaware LLC, owner/operator)
- International Hospitality Services, Inc. (Puerto Rico corporation, manager/operator)
- Chubb Insurance Company of Puerto Rico (liability insurer)
- ABC Insurance Companies (unknown insurers)
- Does I-X (unknown joint tortfeasors)
Core Facts Alleged
- Incident Date: September 20, 2024 (wettest day of the month, 0.54 inches rain)
- Location: Main lobby, La Concha Renaissance San Juan Resort
- Conditions:
- Only one wet rug inside each entrance
- No caution/wet-floor signs
- No staff warnings
- Wet, slippery marble/tile floor from rain tracked in
- Accident:
- Plaintiff slipped after drying footwear, fell in front of elevators
- Immediate pain, numbness; hotel security did not assist
- Incident report filed
- Medical Treatment:
- Taxi to Ashford Presbyterian Medical Hospital: diagnosed with dislocated right shoulder
- CT scan, MRI in Connecticut: Bankart tear, Hill-Sachs lesion
- Surgery (Bankart repair and remplissage) on January 2, 2025
- Arm sling for ~1 month, physical therapy until May 2025
- Ongoing pain, limited reach as of July 9, 2025
- Impact:
- Lost job at Simoniz USA Inc. (manual labor) on December 16, 2024
- Ongoing medical co-pays, lost wages, loss of enjoyment of life
Legal Claims (Four Causes of Action)
- Negligence against hotel entities:
- Failure to maintain safe premises during foreseeable heavy rain
- No warning signs/additional mats, inadequate inspection/maintenance, failure to train staff
- Wet, slippery marble floor in high-traffic lobby entrance = foreseeable hazard
- Direct action against Chubb Insurance
- Direct action against ABC Insurance
- Against Does I-X: Joint and several liability
Relief Sought
- Judgment against all defendants, jointly and severally, no less than $795,000
- $750,000 for physical/emotional/mental damages
- $45,000 for economic damages (lost wages, medical expenses)
- Costs, reasonable attorney’s fees, other appropriate relief
- Jury trial demanded
