SOUTHEAST TEXAS RECORD

While serving as a seaman aboard the vessel Canyon Horizon, Roderick Gray tripped and feel down some stairs.

Invoking the Jones Act and filing suit against his employers, Gray is claiming he tripped because of the negligence of Coastal Catering Inc. and Horizon Offshore Contractors Inc. and because of the unseaworthiness of the vessel.

Gray filed his personal injury lawsuit with the Jefferson County District Court on June 20. Judge Milton Shuffield, 136th District Court, has been assigned to the case.

According to the plaintiff's original petition, on April 29, 2007, Gray was employed as a seaman aboard the Canyon Horizon, a vessel owned and operated by the defendants Coastal Catering and Horizon Offshore.

While at the Port of Port Arthur, Gray "descending an interior set of stairs he tripped on a piece of rug and fell several feet to the deck below suddenly and without warning and due to the negligence
of the defendants and/or the unseaworthiness of the vessel," the suit said.

"Plaintiff was caused to sustain severe and disabling injury...and was in no manner negligent," the suit said.

The suit says the defendants were negligent for failing to provide plaintiff with a safe place in which to work, failing to provide plaintiff with the proper equipment and/or personnel to accomplish
his job in a reasonably safe manner, failing to warn the plaintiff, and failing to exercise reasonable care in discovering and correcting any and all unsafe conditions existing on the vessel.

In addition, the suit also faults the defendants for creation and maintenance of an unseaworthy vessel, and failure to properly maintain and repair the vessel, hiring untrained and unskilled co-employees, breach of legally imposed duties of reasonable care owed by the defendant(s) to the plaintiff, and failure to provide prompt and adequate medical care, treatment, maintenance and cure.

Gray is suing for past and future physical pain, impairment and disfigurement, past and future mental anguish, loss of earning capacity, loss of household services and medical expenses.

"Plaintiff, Roderick Gray, respectfully prays that the defendants be cited to appear and answer herein, and that upon a final hearing of the cause, judgment be entered for the plaintiff against defendants for damages, including attorney fees, in an amount within the jurisdictional limits of the Court," the suit said.

Gray intends that discovery be conducted under Level 3, which means the plaintiff is seeking damages in excess of $75,000.

He is represented by attorney Christopher D. Bertini of the Bertini & Associates law firm.

Case No. D179-534