
The complaint alleges Pitta was negligent and responsible for Mr. Rosales’ death due to his failure to:
- Provide a reasonably safe dive plan;
- Conduct the dive in a reasonably safe manner;
- Properly maintain Brownie’s Third Lung Hookah System;
- Properly operate the Brownie’s Third Lung Hookah System;
- Properly warn the dangers associated with the “hookah” from of diving; and,
- Make sure prior to the dive that he was qualified to participate in the dive.
The estate and family seek compensation for the wrongful death in the form of lost earnings, spousal/parental companionship, support, instruction, and guidance along with mental pain and suffering.