GALVESTON � A Galveston County couple is suing two Houston-based residential building companies for an alleged head injury the husband sustained while he was painting an unfinished house in a League City subdivision, court papers say.

In a lawsuit filed before Galveston County District Court on Oct. 20, Raymundo and Claudia Tamez claim K. Hovnanian of Houston II LLC and Brighton Homes knew of a lack of barricades and railings inside the said residence yet ordered Raymundo Tamez and other members of his work crew to start painting the interior on Nov. 29, 2007.

Consequently, they say, Raymundo Tamez took a tumble down a staircase near his assigned area and seriously hurt his head.

"As Mr. Tamez was painting an area on the staircase, he stepped backwards, lost his balance, and fell to the floor below," the suit states. "Mr. Tamez suffered a severe head injury."

The original petition further explains that Raymundo Tamez was transferred via Life Flight to an unnamed hospital where it was determined he needed to go on the operating table.

"It was determined that surgery to remove a portion of his skull to relieve pressure on the brain due to swelling was needed," it says.

Raymundo Tamez was confined for a period of time and given additional medical treatment.

The suit accuses the defendants of negligence and gross negligence, asserting the Tamezes deserve exemplary damages and compensation for physical pain and suffering, impairment, mental anguish, loss of earnings, loss of mental function, and disfigurement.

Claudia Tamez was named a plaintiff because "the injuries suffered by Raymundo Tamez have had, and will continue to have, a significant negative impact on the family and the relationship of the plaintiffs." She maintains the incident deprived her of consortium and household services.

The Tamezes, who are represented by Houston attorney Jack C. Brock, also want a jury trial.

The case has been assigned to Galveston County 56th District Court Judge Lonnie Cox.

Case No. 08CV1056

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