Summary of the Complaint
Case No. 25-CV-1602, U.S. District Court for the District of Puerto Rico, filed November 11, 2025
Key Parties
- Plaintiff:
- Maria de Lourdes Ramos, 64 years old, citizen and resident of Massachusetts
- Defendants (jointly and severally liable):
- El Laundromat de Caguas – Puerto Rico company that owns/operates the laundromat at 32 Avenida Luis Muñoz Marín, Caguas, PR 00725
- ABC Insurance Companies – Unknown liability insurers for the laundromat
- Does I-X – Unknown additional joint tortfeasors
Core Facts Alleged
- On February 13, 2025, at approximately 11:00 a.m., Mrs. Ramos was leaving El Laundromat de Caguas with her husband and son.
- The only usable exit was the front door leading to a steep ramp; the side door was blocked.
- The ramp had:
- No warning signs
- No railings
- No slip-prevention strips
- Only a rug at the very bottom
- Mrs. Ramos slipped on the ramp, fell backwards, and severely injured her right ankle.
- A laundromat employee was dismissive (“there’s already a rug there to prevent accidents”) and provided no assistance.
- Her son carried her to the car.
- Taken to Menonita Hospital in Caguas:
- X-rays confirmed multiple fractures (displaced bimalleolar ankle fracture + syndesmotic injury) and lower-back bruising.
- Cast placed; morphine/Demerol given. No surgery in PR because her insurance would not cover it.
- Back in Massachusetts:
- Orthopedic consult (Dr. Craig Lareau) on Feb. 28, 2025 → surgery recommended.
- March 5, 2025 surgery: Open reduction internal fixation with 8 screws + 1 plate; ligament repair on both sides of the ankle.
- Recovery (still ongoing at filing):
- Wheelchair → walker + knee support + recovery boot.
- Physical therapy twice a week since April 22, 2025 (over 5 months by November 2025 filing).
- Still wears ankle brace; ongoing pain, swelling, burning sensation in ankle/foot; back pain from fall.
- Cannot stand long, shower standing, cook, clean, or drive (cannot use accelerator). Needs assistance with daily activities. Loss of enjoyment of life.
Legal Claims (Three Causes of Action)
- Negligence against El Laundromat:
- Failure to maintain safe premises: dangerously steep ramp not up to code, no warnings/railings/non-slip surface, inadequate inspection/maintenance, only one usable exit, and dismissive response by staff.
- Direct action against ABC Insurance Companies:
- Under Puerto Rico’s direct-action statute (26 P.R. Laws Ann. §§ 2001 & 2003).
- Against Does I-X:
- Joint and several liability.
Relief Sought
- Judgment against all defendants, jointly and severally, in an amount no less than $850,000 (physical, emotional, mental, and economic damages, including medical expenses).
- Doubling of the total compensation under Article 1538 for knowing/intentional/grossly negligent conduct.
- Costs, reasonable attorney’s fees, and any other appropriate relief.
- Jury trial demanded.
