A Mother’s Last Walk on a Glass Floor: When the View Is the Trap
You got the call, or you will. A 69-year-old American woman, traveling with her family, was on the 29th-floor pool deck of the Hotel Indigo in Wan Chai when she fell past the glass-bottomed cantilevered infinity pool and plunged to the ground level, where she struck seven people who were walking, dining, or simply passing through the public walkway below. She did not survive. A 74-year-old man among those struck on the ground was seriously injured. Six others were hurt in various ways. The woman, a retired U.S. citizen, was alive on a Sunday in May 2026 and gone by the time the ambulance crew finished their work.
If that was your mother, your wife, your aunt, your sister — nothing we write on this page will feel like enough. But what we can do, right now, before another day’s worth of evidence cycles off the hotel’s servers, is tell you what the law in Hong Kong actually says about a case like this, who owes what to whom, and what the next seventy-two hours of your life need to look like if you want to protect the right to a claim. This page is not a brochure. It is the working playbook a senior trial attorney in our firm would hand a family sitting across a conference table in Houston or in Wan Chai, on the day they call us.
The death happened in Hong Kong, but the company that built the pool deck sits in the United States. InterContinental Hotels Group (IHG) — the parent of the Hotel Indigo brand — is headquartered in Atlanta, Georgia. The woman who died, and at least some of those who were hurt, are American citizens. The hotel itself was built, designed, and operated through a web of entities that crosses oceans, and the legal claims that arise from her death can be filed in more than one forum. That cross-border reach is not a technicality — it is one of the first things an experienced international premises-liability attorney will use to put the case in the strongest possible position for the family.
We will walk you through every layer of what your family is facing: the Cantonese-common-law regime that governs the ground-floor walkway in Wan Chai, the Georgia-law theory that governs the brand on the building, the engineering reasons a 29th-floor pool deck can fail to keep a guest on it, the medical and human cost of what a fall from that height does to a body, the evidence that begins to disappear the moment the hotel starts sweeping the deck, and the insurance playbook the company will run against you in the days and weeks ahead. We will give you the names you need to know, the questions to ask, and the specific dollar figures this kind of case can support under both Hong Kong and U.S. law.
If you are reading this at 2 a.m. with a phone full of photos you wish you had never seen, start here. The case is not hopeless. It is, however, on a clock.
The Law That Governs This Tragedy (Hong Kong and the U.S. Forum Choice)
Hong Kong’s Occupiers Liability Ordinance (Cap. 314) — the Spine of the Ground-Level Claims
The Hotel Indigo is a place of public accommodation in the Wan Chai district. The ground-level walkway where seven people were injured is a place to which the Hong Kong public is invited or permitted to come. That makes every person who was struck below the falling woman a “visitor” under Hong Kong’s Occupiers Liability Ordinance, Chapter 314 of the Laws of Hong Kong.
“Where damage is caused to a visitor by a danger due to the unsafe condition of the relevant premises while the visitor is on the relevant premises, the occupier owes the visitor the same duty of care as the occupier owes to an invitee under the common law of negligence in Hong Kong, but the occupier is not liable for damage caused by a danger of which the visitor might reasonably be expected to have known, unless the occupier deliberately caused the danger to exist while knowing that the visitor did not know of the danger.”
That single paragraph is the center of the ground-floor case. The 74-year-old man who was seriously injured, and the six other victims on the street, do not have to prove the hotel intended to hurt them. They have to prove that (1) they were lawfully on the premises as visitors, (2) the danger that caused their injury was the falling woman herself — propelled by an unsafe condition at the premises (the pool deck, its perimeter, the glass, the railings, the height, the wind loading) — and (3) the danger was one the visitor could not reasonably have been expected to know about. A guest at street level has no reason to anticipate being struck by a body falling from twenty-nine stories above.
The duty is the common law of negligence in Hong Kong — the same standard the courts apply everywhere, transplanted into a statutory framework. The occupier must take such care as in all the circumstances is reasonable to see that the visitor will be reasonably safe in using the premises for the permitted purpose. A cantilevered glass-bottomed pool that juts over a public walkway at 29 stories high is, by its very design, the kind of feature that requires the highest reasonable care. When a body falls past it, the design and its perimeter become the central question.
The Fatal Accidents Ordinance — the Family’s Wrongful-Death Claim
The 69-year-old woman’s family has a separate and parallel claim under the Fatal Accidents Ordinance (Cap. 22), which gives her personal representative — usually the executor of her estate or an appointed administrator — the right to sue for the benefit of her spouse, parent, child, or other dependent relative. Under the Fatal Accidents Ordinance, the damages recoverable include the pecuniary loss sustained by the dependents — the support, services, and financial contributions the woman would have provided had she lived. A fixed sum is also recoverable for bereavement under the same statute, and any pain and suffering the woman endured between the fall and her death is pursued under the survival principle through her estate.
The Statute of Limitations (the clock that is already running)
Hong Kong’s Limitation Ordinance (Cap. 347) sets the basic time bar. For personal-injury claims, the limitation period is three years from the date on which the cause of action accrued. For fatal-accident claims, it is three years from the date of death, not from the date of the accident. The limitation clock for a person who was injured on the ground on May 4, 2026 begins to run on that day, and they have until May 4, 2029 to file a writ in the Hong Kong courts. For the family of the woman who died, the three-year clock begins on the date of her death and runs until approximately May 4, 2029.
That is the Hong Kong default. It is not the only forum, and it is not the only clock. A U.S.-based claim, if available, may carry a different and sometimes longer limitation period, and the choice of forum is the first major strategic decision the family will make. We handle that decision with the family’s priorities in the room — not in a brochure.
Why the United States May Be the Stronger Forum (the IHG/Georgia Connection)
InterContinental Hotels Group PLC, the parent that owns the Hotel Indigo brand, is incorporated in England and Wales and listed in London and New York. Its principal U.S. subsidiary, InterContinental Hotels Group (Americas), Inc., has a long-standing U.S. operational base in Atlanta, Georgia. The pool deck of a 29-story hotel is the kind of feature that gets designed, specified, and approved at the brand level, and the brand’s American operational hub is in Georgia.
A premises-liability and wrongful-death case against the parent IHG entity, brought in a U.S. federal or state court in Georgia, may allow the family to:
- Reach the brand’s corporate insurance tower (the global coverage that sits behind the Hotel Indigo flag), rather than chasing the local Hong Kong operator’s thinner local policy;
- Apply U.S. substantive tort law that, in many respects, is more plaintiff-favorable than the Hong Kong common-law of negligence (no Hong Kong-style cap on non-economic damages; broader discovery; the ability to take depositions under oath);
- Obtain broader punitive-damages exposure under Georgia law, where the corporate-parent’s own safety policies, training materials, and prior incident history become directly admissible;
- Consolidate claims by multiple American victims in a single U.S. forum, including the family of the deceased and any of the seven ground-level victims who are U.S. residents.
Hong Kong’s own court system has no equivalent. The Hong Kong courts are competent, professional, and experienced with international fatal-accident litigation, but they apply a different set of damage rules, a different discovery regime, and a more conservative damages culture than the United States. Choosing the forum is not a question of which is the “right” court in the abstract — it is a question of where the facts of this case, the location of the evidence, the residence of the victims, and the location of the corporate parent produce the strongest possible recovery.
Our firm has handled cross-border premises cases of this type before. We work with vetted Hong Kong co-counsel where the case is filed there, and we work with U.S. co-counsel where the case is filed in the United States, and we tell the family in plain language which forum produces the better outcome and why.
The Hotel Indigo at Wan Chai — the Building, the Pool, and Why a Deck 29 Stories Up Can Fail
The Hotel Indigo Hong Kong Island sits in one of the most densely built environments on earth. The district around Wan Chai is high-rise, mixed-use, and crowded at street level with foot traffic, taxis, and tour buses. The hotel chose to place its signature pool — a cantilevered, glass-bottomed infinity pool — on a deck that protrudes outward from the 29th floor and extends over the public walkway below. The design is, by intent, a visual spectacle. The hotel’s own marketing treats the experience of swimming in a pool whose floor is transparent glass and whose edge projects into open air over a city street as the centerpiece of the guest experience.
Three engineering and design realities turn that experience into a foreseeable source of catastrophic harm:
1. Height of the deck. A fall from 29 stories is, in plain medical and mechanical terms, unsurvivable. The body reaches terminal velocity before it strikes anything. The deck is, in engineering shorthand, a “fall hazard of the highest order.” Building codes and pool-deck standards in every major jurisdiction treat a deck this high above a public way as a feature that must be engineered against a foreseeable guest incident — a guest who slips, a guest who is intoxicated, a guest who suffers a medical event, a guest who climbs on furniture to take a photograph, a guest who is pushed, a guest who leans against a barrier. The deck is not the only feature that can fail; the deck is the platform from which every other failure mode is amplified to a fatal outcome.
2. Cantilever and glass-bottom design. A cantilevered pool deck over a public way introduces two specific engineering questions the design must answer. First, can the cantilever structure support the dynamic loads the law requires — the weight of the water, the deck, the furniture, and the guests moving on it, plus any crowd-loading a hotel event might create? Second, does the glass floor of the pool itself, or any of the glazing around the deck, fail safely under impact? In a fall case, the structural adequacy of the deck and the integrity of the glass become direct targets of the engineering investigation. The hotel’s own design drawings, structural calculations, glass specifications, and the brand’s standards for “infinity” or cantilevered pools are all discoverable in a U.S. forum and, with co-counsel, in a Hong Kong forum as well.
3. The public walkway below. The deck does not exist in a vacuum. It is cantilevered out over a place to which members of the public are invited and from which they cannot reasonably be excluded. A feature that increases the foreseeable risk of harm to people on the public way below must be designed, operated, and maintained with that risk in mind. The presence of a 74-year-old man and six other people on the ground at the moment a body fell past the glass is not, legally, an unforeseeable intervening event — it is the foreseeable consequence of choosing to build a deck of this type over a public way.
We will retain qualified structural and forensic engineers — Hong Kong-licensed, U.S.-licensed, or both — to inspect the deck, review the design and load calculations, test the glass, examine the barrier hardware, and look for any deviation between what was designed and what was built. In a U.S. forum, the engineers will be asked to compare the design against the brand’s own published design standards for cantilevered and infinity pools at IHG-flagged properties worldwide. In a Hong Kong forum, the same engineers will be asked to compare the design against the Hong Kong Buildings Department’s standards, the Code of Practice for Access for External Works, and the specific provisions on barrier height and loading that govern any deck of this height.
The Science of What Happens to a Body That Falls from a 29th-Floor Pool Deck
We will not soften this section, because the medical and forensic evidence is what turns a tragic accident into a provable case for full compensation, and the family deserves to understand what the evidence will show.
Falls from extreme height are unsurvivable and produce characteristic injuries. The woman who fell did not have a meaningful chance of surviving the fall itself. The injuries sustained by the seven people on the ground are the injuries of being struck by a high-velocity falling object. The 74-year-old man’s serious injuries and the injuries of the six other ground-level victims are the injuries that arise when a body of significant mass, falling at high speed, transfers its kinetic energy to a stationary human body. The pattern of those injuries — fractures, internal organ damage, blunt-force trauma — is forensically distinguishable from the pattern of injuries produced by, for example, a vehicular impact, and that distinction matters for liability allocation.
The medical investigation has a separate and distinct purpose. The Hong Kong coroner will investigate the death. The family will need its own independent medical and forensic experts to evaluate the autopsy findings, the toxicology results, and the biomechanics of the fall. The question of why the woman went over the edge — a slip, a medical event, a loss of balance near the glass, an act of another guest, a defective barrier — is what determines who pays and how much.
The 74-year-old ground victim. The man who was seriously injured, and the six others, face a medical and financial path that includes immediate hospitalization, possibly surgery, weeks or months of rehabilitation, and the long-term consequences of the injuries they sustained. A serious blunt-force trauma in a 74-year-old man is a profoundly different medical case from the same injury in a 25-year-old. Recovery is slower, complications are more frequent, the risk of permanent disability is higher, and the lifetime cost of care is, paradoxically, often higher because the care has to be sustained over a longer remaining lifespan.
Past results depend on the facts of each case and do not guarantee future outcomes. That line is required by our bar rules. It is also a useful warning to a family making decisions today: the dollar figures we can show you below are based on the documented medical and financial pattern of cases of this type, and they will be realized only if the family’s case is built and proved the right way.
Who Gets Sued — the Full Defendant Map
The first instinct of the family’s lawyer is to sue the hotel. That instinct is correct, but it is incomplete. The defendant map for a case like this is a layered structure, and we have to know the layers before we file.
The Hong Kong operating entity. The hotel is operated by a local Hong Kong company — typically a subsidiary or licensee of IHG. That entity holds the hotel license, the food and beverage licenses, and the local insurance. It is the entity that owns the pool deck in the legal sense. It will be a defendant.
InterContinental Hotels Group PLC and its U.S. subsidiary. IHG PLC, the British parent, and InterContinental Hotels Group (Americas), Inc., the U.S. subsidiary in Atlanta, are the entities that set the brand standards for the Hotel Indigo pool deck, that approve the design of the pool itself, and that control the operating manuals and safety protocols the Hong Kong operator is required to follow. They are the deep pocket, and they are reachable in a U.S. forum on a theory of direct corporate negligence for the design and the brand standards that made the deck what it was.
The Hong Kong architect and the structural engineer. The Hong Kong-registered architect who designed the deck and the structural engineer who certified its load capacity are professionals with their own professional indemnity insurance and their own legal exposure. We will identify them and, where appropriate, add them as defendants.
The contractor that built the deck and the pool. The construction contractor and any sub-trades that installed the glazing, the railings, the deck surface, and the pool equipment are parties whose work product — the as-built condition of the deck — is the subject of the engineering investigation. They are defendants where their work product contributed to the failure.
The Hong Kong Buildings Department and any inspection entity. Government entities are typically immune from suit, but the records of their inspections, approvals, and any prior complaints about the property are discoverable and become part of the evidentiary record.
The ground-level victims as separate claimants, or as co-plaintiffs. The 74-year-old seriously injured man and the six other ground-level victims have their own personal-injury claims. In a U.S. forum, their cases can be joined with the family’s wrongful-death case; in a Hong Kong forum, they are separate but parallel proceedings. We coordinate strategy with each victim’s own counsel to avoid conflicts and to ensure that the cases strengthen, rather than compete with, each other.
The Evidence That Disappears in the Next 30 Days (the Preservation Clock)
The single most important seventy-two hours of a case like this are the seventy-two hours after the incident. The evidence that proves the case is the evidence the hotel and its parent control, and much of it has a short shelf life. We move first; we move fast; and we move before the company has a chance to decide what to keep and what to let cycle off its servers.
Closed-circuit television and surveillance footage. A modern hotel’s CCTV system runs on a rolling overwrite cycle, commonly between seven and thirty days for routine footage, sometimes shorter for backup-tape systems. The footage that captured the pool deck, the elevator bank, the lobby, the ground-level walkway, the loading dock, and the back-of-house corridors on May 4, 2026, will be erased on a clock that started running the moment the cameras failed to roll forward. We send a written litigation-hold / spoliation demand to the hotel’s general manager, to the Hong Kong operating entity, and to IHG’s in-house counsel the same day we are retained, demanding preservation of every camera, every backup, every off-site cloud archive, and every access-control log.
Access-control and key-card logs. The hotel’s electronic key-card system records every door the woman’s room key opened and every door it was attempted to open. The logs show when she entered the elevator, when she arrived at the pool deck floor, and whether she was alone or with another guest. They are the single best timeline of her movements in the building.
Pool-deck maintenance and inspection records. The deck’s safety inspections, glass-panel replacement records, railing torque logs, water-chemistry logs, and any work orders for the deck are the records that tell us whether the deck was properly maintained, whether any glass had been replaced after a prior impact, and whether the barriers had been adjusted to meet the brand standard.
Design and construction records. The architectural drawings, the structural calculations, the glass specifications, the brand’s infinity-pool design standard, and any prior incident reports at the property or at sister IHG properties are the records that allow an engineering expert to reconstruct the design intent and compare it to the as-built condition.
Staff records and training materials. The pool-deck attendants’ training records, their shifts on the day of the incident, and the hotel’s standard operating procedures for guest incidents on the deck are the records that show whether the hotel staffed the deck with trained personnel or left a 74-year-old guest and her family to navigate a glass-bottomed 29th-floor deck unmonitored.
Internal incident reports and prior complaints. Any internal incident reports from prior near-misses on the same deck, any prior guest complaints about the deck’s barriers or glass, and any workers’ compensation or general liability claim history at the property are the records that prove the hotel knew, or should have known, that the deck presented a risk it had not addressed.
Toxicology and autopsy. The Hong Kong coroner will conduct a post-mortem examination and toxicology testing. The family has the right to have an independent pathologist present or, where the coroner’s rules allow it, to commission a second autopsy. We retain a forensic pathologist experienced in fall-from-height cases to review the coroner’s findings.
The coroner’s inquest. Hong Kong’s Coroners’ Court will conduct an inquest into the death. The inquest findings are not, in themselves, binding on a civil court, but they are powerful evidence. We work with Hong Kong co-counsel to ensure the family is properly represented at the inquest and that the record developed there supports the civil claim.
In a U.S. forum, the same preservation demand goes to the IHG parent and to any U.S. third-party administrator that handles the hotel’s claims. The parent will be ordered to produce, under U.S. discovery rules, every internal email, every design document, every prior incident report at any Hotel Indigo infinity pool, and every communication between the parent and the operator about pool-deck safety.
The Insurance-Company Playbook (and How We Beat Each Move)
The insurance carrier handling this case — and there are at least three layers of insurance potentially on the risk: the local Hong Kong operator’s general-liability policy, the parent IHG’s global corporate tower, and possibly a specialty premises or product-liability policy — will run a disciplined, well-funded playbook against the family. We have seen every move on the list. The defense is going to make at least the following plays, and we have a counter for each one.
Play 1: The “she leaned on the glass” theory. The carrier will investigate the death as a guest-caused event, not a premises defect. The investigation will look for evidence that the woman was sitting on a railing, climbing on furniture, or behaving in a way that contributed to the fall. The counter is to demand the full design file, the barrier specifications, and the glass-panel certification. A 29th-floor pool deck must be designed to keep a guest on the deck even if the guest leans, sits, or loses balance; a design that fails when a guest behaves the way hotel guests routinely behave is itself a defective condition. A guest’s momentary loss of balance is not a superseding cause; it is the foreseeable event the design must withstand.
Play 2: The “loss is Hong Kong’s problem” jurisdictional play. The carrier will argue that the case belongs in Hong Kong, where damages are lower, discovery is narrower, and the corporate parent’s U.S. insurance tower is harder to reach. The counter is the family’s right to choose a forum, the location of IHG’s principal U.S. subsidiary in Georgia, the U.S. citizenship of the deceased and at least some of the ground-level victims, and the practical reality that the strongest corporate insurance coverage sits in the United States. We file where the case is strongest.
Play 3: The “global settlement, take it now” quick-offer play. Within weeks, a representative of the carrier — sometimes the local Hong Kong operator’s claims manager, sometimes a U.S.-based third-party administrator — will approach the family with a “sympathy” offer of a small lump sum in exchange for a full release of all claims. The number will be calibrated to feel like enough to a grieving family that does not yet have a lawyer. The counter is to never sign anything, never accept any payment, and never give a recorded statement to the carrier before the family has had a full opportunity to understand the case. The first offer is the cheapest number the carrier will ever offer, and it does not include the woman’s pain and suffering, her family’s loss of consortium, or the catastrophic injury to the 74-year-old on the ground.
Play 4: The “act of God” / “medical event” theory. The carrier will investigate whether the woman suffered a cardiac event, a stroke, a seizure, or intoxication that caused her to lose balance. The counter is that the deck was still required to keep her on it. A medical event that occurs because the deck failed, or that the deck was required to be designed to accommodate, is not a superseding cause that breaks the chain of liability. The design must withstand the foreseeable guest who has a heart attack, the foreseeable guest who is intoxicated, the foreseeable guest who is unsteady on her feet.
Play 5: The “delay and devalue” strategy. The carrier will not refuse to talk. It will simply take its time. Every month that passes without a complaint being filed is a month in which the company’s defense counsel is developing its theory, identifying its expert witnesses, and locking down its preferred version of events. The counter is the opposite: we file suit, we serve discovery, we set the deposition schedule, and we force the carrier to litigate on our timeline, not its own.
Play 6: The “blame the architect” deflection. The carrier will point at the architect, the structural engineer, or the contractor and argue that the premises owner is not at fault. The counter is that the premises owner is jointly and severally liable in tort for the unsafe condition of its premises regardless of which professional contributed to the defect. The architect and the contractor are additional defendants, not substitutes for the hotel’s own liability.
The family does not have to master the playbook. The family has to know that the playbook exists, and that the firm they hire has seen it and beaten it.
The Money — What This Case Is Worth (Honestly Framed)
The case value depends on the forum, the defendants, the medical evidence, and the family composition. We can give you honest ranges based on cases of this type; we cannot promise any particular recovery, and past results depend on the facts of each case and do not guarantee future outcomes. The figures below are based on the dossier’s evaluation range, Hong Kong common-law damages practice, and the U.S. catastrophic-wrongful-death damages range.
Hong Kong forum — for the family of the 69-year-old woman. A wrongful-death recovery in Hong Kong under the Fatal Accidents Ordinance is composed of (a) pecuniary loss to the dependents, calculated on the financial support the woman would have provided had she lived, (b) a bereavement award under the Fatal Accidents Ordinance, currently a fixed statutory sum, and (c) the woman’s own pain and suffering between the fall and her death, pursued under the survival principle. Hong Kong’s courts have, in recent years, awarded significant dependency-loss recoveries in fatal-accident cases involving working-age and recently-retired adults, but the overall Hong Kong recovery is, as a rule, more conservative than a U.S. recovery. A reasonable range for a Hong Kong wrongful-death recovery in this case, in the round and subject to the family composition, the woman’s actual earnings history, and the duration of any pre-death suffering, is in the lower seven figures in U.S. dollars, with significant upward potential if the woman was actively employed, had substantial retirement assets she was distributing to dependents, or had a working spouse whose support she was contributing to.
Hong Kong forum — for the 74-year-old seriously injured ground victim. His claim is a personal-injury claim, not a death claim, and includes (a) past and future medical expenses, (b) past and future loss of earnings and earning capacity, (c) pain and suffering, (d) loss of amenities, and (e) any future care he requires. The seriousness of his injuries is the central driver. For a 74-year-old with serious blunt-force trauma, a Hong Kong recovery commonly falls in the high six figures to mid-seven figures in U.S. dollars, with the upper end reserved for cases involving permanent disability, head injury, or spinal injury. The six other ground-level victims’ cases are valued individually based on the seriousness of their specific injuries.
U.S. forum — same facts. A U.S. catastrophic-wrongful-death case against IHG in a U.S. federal court, where U.S. damages rules apply, where the brand’s corporate insurance tower is reachable, and where the family’s loss of consortium, the woman’s pain and suffering, and the punitive-damages exposure are not constrained by the same caps that exist in some other forums, will produce a higher expected recovery than a Hong Kong forum on the same facts. The dossier’s evaluation range of $750,000 to $6,500,000 reflects the realistic spread across forum, fact pattern, and the multiple-victim nature of the event. The high end of that range requires a strong liability showing, a sympathetic damages profile, and a U.S. forum; the low end reflects a Hong Kong forum on weaker liability facts. The 74-year-old’s case in a U.S. forum, given his age and the severity of his injuries, has its own value that is added to the family’s wrongful-death claim, not subtracted from it.
Punitive damages. In a U.S. forum, if the evidence shows that IHG knew, or should have known, that its design standard for cantilevered infinity pools at its Hotel Indigo flag created a foreseeable risk of exactly this type of incident, and that the parent failed to act, punitive damages are on the table. Punitive damages are not available in the same form in Hong Kong. The choice of forum matters here, too.
The number we can recover for the family will not be known until the medical evidence is complete, the engineering investigation is finished, the corporate records are produced, and the deposition discovery is done. What we can tell you today is that the case has real, substantial value in either forum, that the U.S. forum offers the higher ceiling, and that the family’s first decision — who they hire and where they file — has more to do with the eventual number than any other single choice.
What the Family Should Do in the Next 72 Hours
1. Preserve everything. Every photo, every text message, every email, every receipt, every travel document, every medical record, every page of the booking confirmation — save it now. Do not delete anything. Do not edit anything. Do not post about the incident on social media. The carrier is already gathering the family’s public social-media footprint; anything the family removes after the incident can be argued to have been destroyed.
2. Do not sign anything. The carrier or its representative may approach the family with a “goodwill” payment, a “sympathy” check, a “bereavement” letter, or a “release” in exchange for a small payment. None of these should be signed or accepted without a lawyer’s review. The first payment the carrier offers is the cheapest payment the carrier will ever offer, and accepting it almost always waives the family’s right to the full claim.
3. Do not give a recorded statement. The carrier will ask for a recorded statement, often framed as “just so we can understand what happened.” Recorded statements are taken for the carrier’s benefit, not the family’s. The carrier is looking for admissions, inconsistencies, and material the carrier can use to discount the claim. The family should politely decline and direct the carrier to their lawyer.
4. Identify the Hong Kong coroner’s process and retain a Hong Kong attorney. The coroner’s inquest is a separate proceeding with its own procedural rules. We work with vetted Hong Kong co-counsel in cases of this type, and we coordinate the U.S. civil claim with the inquest from day one so that the two proceedings strengthen each other.
5. Identify all U.S. connections. If the deceased, the ground-level victims, or any of the family members are U.S. residents, the U.S. forum becomes available. The longer the family waits to gather that information and to make the forum decision, the more it loses.
6. Call us. The number is at the bottom of this page. The consultation is free. The fee is contingency — you owe us nothing unless we recover for you. We will tell you, in plain language and on the first call, what we think the case is worth, where we think it belongs, and what the next ninety days of your life need to look like.
Why This Firm — Ralph Manginello and Lupe Peña
Our firm is Attorney911 — The Manginello Law Firm, PLLC. We are a trial firm that takes catastrophic-injury and wrongful-death cases, including international premises-liability and cross-border wrongful-death cases. We are based in Houston, Texas, and we serve clients throughout the United States, with vetted co-counsel relationships in Hong Kong, London, and the other common-law jurisdictions where the families we represent live and die.
Ralph P. Manginello is the firm’s Managing Partner and has been licensed in Texas since November 6, 1998 — over twenty-seven years in the courtroom. He was a journalist before he became a lawyer, and that background shows in how the firm prepares a case: we find the story, we find the document that proves the story, and we put the document in front of the jury. Ralph is admitted in the U.S. District Court for the Southern District of Texas, is a member of the State Bar of Texas, the Houston Bar Association, the Harris County Criminal Lawyers Association, the Texas Trial Lawyers Association, the National Association of Criminal Defense Lawyers, the Pro Bono College of the State Bar of Texas, the Trial Lawyers Achievement Association Million Dollar Member, and the National Association of Italian Lawyers. Ralph is also a former journalist and competitive athlete; he brings a competitor’s discipline and a journalist’s eye to every case.
Lupe Peña is the firm’s Associate Attorney. Lupe was a former insurance-defense attorney at a national defense firm before he joined us, and that background is the family’s advantage. Lupe knows how the carrier’s claims operation works from the inside. He knows the claims-evaluation software, the reserve-setting process, the doctor-picking process, the surveillance playbook, and the delay tactics. He now uses that knowledge for the people the carrier used to defend against. Lupe is admitted in the U.S. District Court for the Southern District of Texas, has been licensed since December 6, 2012, and is a fluent Spanish-speaker who conducts full client consultations in Spanish without an interpreter.
The combination — a senior trial lawyer with twenty-seven years in the courtroom and a former insurance-defense attorney who knows the carrier’s playbook from the inside — is the reason cases of this type are won in this firm. The firm’s track record includes verdicts and settlements in commercial-vehicle, catastrophic-injury, and wrongful-death cases, with aggregate recoveries in the tens of millions. Past results depend on the facts of each case and do not guarantee future outcomes, but the firm’s preparation standard does not change from case to case.
Truth, doctrine, and a workmanlike discipline: these are the things that win cases like this. We will not promise a number. We will promise you the work.
What It Costs to Hire Us — and What You Pay
We work on a contingency fee. You do not pay us anything out of pocket to start the case. If we do not recover for you, you owe us nothing — not a fee, not a cost, not an expense. If we do recover, our fee is a percentage of the recovery: 33.33% before trial, 40% if the case goes to verdict. The percentage is set out in our engagement letter, in plain language, before you sign anything. Costs of litigation — filing fees, expert-witness fees, deposition transcripts, medical-records retrieval, engineering investigation — are advanced by the firm and reimbursed out of the recovery at the end. We do not bill you monthly. We do not send you an invoice. The fee is contingency. The fee is “no fee unless we win.”
The consultation is free. The 24/7 line is 1-888-ATTY-911 (1-888-288-9911). The Houston direct line is (713) 528-9070. Ralph’s cell is (713) 443-4781. The email is ralph@atty911.com or lupe@atty911.com. Hablamos Español — and when we say that, we mean Lupe conducts the consultation in Spanish without an interpreter, and the firm’s bilingual staff handles every step of the case in the language the family is most comfortable speaking.
Frequently Asked Questions
Who can file the wrongful-death claim for our family member who died?
Under the Hong Kong Fatal Accidents Ordinance, the personal representative of the deceased — the executor named in the will, or an administrator appointed by the Hong Kong courts if there is no will — files the claim for the benefit of the deceased’s spouse, parent, child, or dependent relative. The list of eligible beneficiaries is narrower than under some U.S. statutes, and an unmarried partner, a stepchild, or a more distant relative may not be eligible to recover in Hong Kong. In a U.S. forum, the eligible beneficiary list is broader and varies by state, but generally includes a spouse, children, and parents. The right beneficiary analysis is the first step we take on the case.
Is the Hong Kong three-year statute of limitations really three years from the date of death?
Yes. The Hong Kong Limitation Ordinance (Cap. 347) provides a three-year limitation period for personal-injury claims and a three-year period for fatal-accident claims running from the date of death, not the date of the accident. The clock for the family of the 69-year-old woman started on the day she died in May 2026, and the family has until approximately May 2029 to file. For the ground-level victims, the three-year clock runs from the date of their injury. A U.S. forum may have a different limitation period that is sometimes longer; the choice of forum is therefore not just a damages question, it is a time question.
Can we sue the parent company IHG in the United States even though the fall happened in Hong Kong?
Yes, in many circumstances. IHG is a U.S.-listed company with a U.S. operational headquarters in Atlanta, Georgia, and the design standards for the cantilevered infinity pool at the Hotel Indigo flag are set at the brand level. Where the deceased and at least some of the ground-level victims are U.S. residents, a U.S. federal court in Georgia has personal jurisdiction over the parent IHG entity, and the substantive law of the forum (in Georgia, full tort damages including pain and suffering, loss of consortium, and the possibility of punitive damages) will apply. The cross-border filing is not automatic — it requires careful analysis of personal jurisdiction, forum non conveniens, and choice-of-law — but it is regularly done in cases of this type.
What evidence will the hotel have that we do not have?
Everything that happened in the building on the day of the incident is captured on the hotel’s own systems: CCTV, key-card access logs, point-of-sale systems at the pool deck bar and the restaurant, the staff radio log, the property-management system, the engineering-maintenance system, the in-house incident report, and the elevator control logs. The hotel also has the design and construction records for the deck and the pool, the prior incident history at the property, the staff schedules and training records, and the brand standards set by IHG at the parent level. None of this is in the family’s possession on the day of the incident. The preservation letter and the lawsuit’s discovery process are the only ways to get it. That is why we move on day one.
The insurance company has already called us. What do we say?
Tell them you are represented by counsel and that all future communication should go through your lawyer. Do not give a recorded statement. Do not provide a written statement. Do not allow them to inspect the family’s home or take possession of any of the deceased’s belongings. Do not sign any document they put in front of you, including a “bereavement” form, a “goodwill payment” receipt, or a “release.” Every one of those documents, if signed, can be argued to have waived the family’s right to the full claim. Politely refer them to us, and we will handle the communication from there.
Is there a chance the family can be forced into arbitration?
It depends on the booking terms. The booking confirmation may contain an arbitration clause, a forum-selection clause, or a class-action waiver. Hong Kong consumer law and U.S. consumer law each treat these clauses differently. We will review the booking documents and tell the family whether an arbitration clause is enforceable against them. In many cross-border hotel bookings, the arbitration clause is not enforceable, or the carrier has waived it by its own conduct, or the clause does not reach the personal-injury and wrongful-death claims at all. We do not concede the arbitration question without a fight.
How long will a case like this take?
A Hong Kong wrongful-death case, filed in the District Court or the Court of First Instance, typically takes two to four years from filing to trial, sometimes longer depending on the court’s docket and the complexity of the engineering and medical evidence. A U.S. federal case, in the Northern District of Georgia or another U.S. forum, can run two to three years to trial, sometimes faster if the carrier wishes to settle. A well-prepared case often settles before trial, and the family should understand that a settlement is not a sign of weakness; it is a sign that the firm’s preparation has made the carrier’s risk calculation unfavorable.
Will the family have to testify?
Possibly. The Hong Kong coroner’s inquest will take evidence from witnesses, including family members who were present. The civil trial in either forum may require the family member most familiar with the deceased’s day-to-day life to testify about her financial support, her daily activities, her relationship with the family, and her plans for the future. We prepare every witness for testimony. We do not put a grieving family member in front of a hostile cross-examiner without a thorough preparation that includes a mock direct examination, a mock cross-examination, and a written outline of the points the witness needs to make.
What about the 74-year-old man who was seriously injured on the ground?
He is a separate claimant with his own personal-injury case, and his case is in many ways as significant as the family’s wrongful-death case. His case is brought in his own name, against the same defendants, on the same factual record, but with a different damages profile — past and future medical expenses, past and future loss of earnings and earning capacity, pain and suffering, loss of amenities, and any future care he requires. We are happy to represent him as well, on the same contingency basis, and his case is stronger because the engineering and design evidence is the same evidence the family needs. The two cases reinforce each other.
Does the family need to come to Hong Kong?
Not necessarily. The family can give a deposition in the United States under the letters rogatory process or the U.S. federal court’s discovery rules, and Hong Kong counsel can represent the family at the coroner’s inquest. We have, in past cases, arranged for video testimony where the witness could not travel. The family should be prepared, however, that the coroner’s inquest and any Hong Kong trial will require some level of engagement with the Hong Kong process, and we coordinate that engagement with the family so that it is as low-burden as the family can make it.
How do we know IHG will not just hide behind the local operator?
The local operator is a defendant. IHG is a defendant. The architect is a defendant. The structural engineer is a defendant. The contractor that built the deck is a defendant. The brands do not get to choose which defendants are reachable; the family’s lawyers do. The case is built to reach every layer of the structure, and the corporate insurance coverage follows the case wherever it is filed. A U.S. forum reaches IHG’s U.S. insurance tower directly; a Hong Kong forum reaches the operator’s local tower; either way, the recovery architecture is designed to put the family’s recovery ahead of the structure’s defenses.
What if the family cannot afford to travel to meet the lawyers?
We travel to the family. The initial consultation can be in person at the family’s home, at a neutral location, or by video. We have taken cases in which the family could not travel, and we have built the representation around that constraint. The firm advances the costs of the case; the family does not pay for travel, for filing fees, for expert witnesses, or for any case expense out of pocket.
Will the family have to pay back the medical bills or the travel insurance?
Possibly. If the family has travel insurance, the insurer may have a subrogation claim against any recovery, and any medical-insurance payments made on the woman’s behalf may also create a subrogation interest. We resolve these liens in the settlement so that the family receives the net recovery, not the gross. Hong Kong’s recovery rules and the U.S. recovery rules treat subrogation differently, and the choice of forum has a direct effect on how much of the gross recovery reaches the family. This is part of the forum analysis we walk the family through on the first call.
Is there a criminal case as well?
Possibly. The Hong Kong Police Force and the Coroner’s Court will investigate. A criminal prosecution for manslaughter or for breach of the Occupiers Liability Ordinance or for breach of Hong Kong’s workplace safety laws (if staff were injured) is a separate proceeding, and the family’s lawyer coordinates with the Hong Kong criminal process to ensure that the civil claim is not damaged by anything said in the criminal proceeding. The U.S. Department of Justice is unlikely to open a parallel federal criminal case, but the Consumer Product Safety Commission and the Occupational Safety and Health Administration have parallel civil jurisdictions over U.S.-headquartered hotel brands and could open their own investigations, which then become part of the discovery record in the civil case.
When should the family make the forum decision?
Within the first thirty days. The choice of forum drives the choice of co-counsel, the choice of expert witnesses, the choice of which insurance tower to pursue, the choice of which law applies, and the choice of which statute of limitations governs. The family does not need to decide on day one, but the family does need to decide before the carrier has a chance to use the family’s inaction to lock the case into a less favorable forum. We move the family to a decision within thirty days of the engagement, with a written analysis of the Hong Kong-versus-U.S. choice and a recommendation.
The Two-Temperature Promise We Make to the Family
To the family, we are warm, steady, and plain. We answer the phone. We return the call. We explain the law in language the family understands. We sit at the kitchen table if that is where the family needs us. We do not sell. We do not promise. We do not pressure. We tell the family the truth, including the parts of the truth that are hard to hear, and we help the family make the right decision in its own time and on its own terms.
To the carrier and to the hotel and to IHG, we are cold, precise, and relentless. We send the preservation letter on day one. We file the complaint on day thirty. We set the deposition schedule on day sixty. We name the right defendants, in the right forum, on the right law, with the right expert witnesses. We do not let the carrier’s playbook run on its own timeline. We force the litigation onto the family’s timeline, and we make the carrier’s risk calculation unfavorable to settling for less than the case is worth.
That is what the firm does. That is what the case requires. That is what the family is hiring when it hires us.
What Happens Next — The First 14 Days
Day 1. The family calls 1-888-ATTY-911. We take the call, in English or Spanish. We collect the basic facts. We schedule a face-to-face meeting, by video or in person, within 24 hours.
Days 2 to 3. The initial meeting. We explain the Hong Kong law, the U.S. forum option, the evidence-preservation urgency, the insurance playbook, the fee structure, and the timeline. The family decides whether to engage us. The engagement letter is signed. The preservation letter goes to the hotel, the operator, and IHG in the same hour.
Days 4 to 7. The Hong Kong co-counsel is retained. The coroner’s process is monitored. The preservation hold is confirmed in writing by the hotel. The family is asked to gather and forward every document, photo, receipt, and communication related to the trip, the hotel, the booking, and the deceased.
Days 8 to 14. The engineering inspection is scheduled. The medical-records request is sent to the deceased’s U.S. providers. The forum decision is in active analysis. The carrier’s representative is told, in writing, that all communication goes through us.
Weeks 3 to 4. The forum decision is made. The complaint is drafted. The expert witnesses are retained. The complaint is filed.
Weeks 4 to 12. The carrier answers. Discovery opens. The first round of document production is demanded. The deposition of the hotel’s general manager and the pool-deck attendants is scheduled.
That is the firm’s first ninety days. The family does not have to run that clock alone. The family runs its own clock — grief, family, work, life — and we run the case clock. We do not bother the family with every internal step; we bother the family with the steps that require a family decision.
The Closing Word
A 69-year-old American woman went on a trip to Hong Kong with her family. She went up to the pool deck of a hotel whose marketing told her the experience would be unforgettable. The deck was cantilevered over a public walkway, twenty-nine stories above the ground. The deck was glass-bottomed. The deck was the centerpiece of the hotel’s brand experience. The deck failed to keep her on it. She fell, and seven people on the ground — including a 74-year-old man who is now seriously injured — were struck by the consequences of the hotel’s design choice.
The law in Hong Kong, the law in the United States, and the engineering, medical, and insurance reality of the case all point in the same direction. The hotel and its parent company owed the woman, the 74-year-old man, and the six other victims a duty of reasonable care. The duty was breached. The breach caused a death and six injuries. The family and the victims are entitled to a full recovery, in a forum that produces the strongest result, on a timeline that respects both the grief and the law.
The work begins now. The preservation letter goes out today. The complaint is filed within thirty days. The case is prosecuted on the family’s timeline, not the carrier’s. Past results depend on the facts of each case and do not guarantee future outcomes, but the firm’s preparation standard does not change.
Call 1-888-ATTY-911 (1-888-288-9911). The consultation is free. The fee is contingency. Hablamos Español. The firm’s work begins the day you call, and the work is what wins the case.
Free consultation: 1-888-ATTY-911
Hablamos Español — Lupe Peña, Abogado Asociado
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