HOUSTON — A Harris County man is suing a residential building and its workers, alleging their negligence led to his falling 20 feet. 

Daniel Hernandez filed a complaint April 18 in Harris County Circuit Court against Terra Cotta Homes LLC, Nicolas Faz, Sergio Reyes and John Doe alleging failure to exercise ordinary care in its performance of work, hiring, training retention, and supervision of its employees and/or contractors.

According to the complaint, on Dec. 6, 2016, Hernandez he was hired by the defendants to install molding on the exterior at Terra Cotta residence on Ebony Lane in Houston. While elevated approximately 20 feet off the ground on scaffolding, Hernandez says he lost his footing and fell head first, hitting a metal pole while falling to the ground. 

Without any fall protection equipment or personal protection equipment, the suit says, Hernandez suffered severe an debilitating injuries.

The plaintiff alleges the defendants failed to properly monitor and/or supervise employees working under its supervision, failed to inspect the premises for dangerous conditions and failed to ensure that proper fall protection and personal protection equipment were being utilized at the premises.

Hernandez seeks trial by jury, all damages in excess of $75,000, together with pre- and post-judgment interest, costs of suit and all other equitable relief. He is represented by attorneys John C. Ramsey and Joel B. Pardo of Ramsey Law Group in Houston.

Harris County Circuit Court Case number 2017-25942

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Harris County District Court
1201 Franklin Street
Houston, TX 77002

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