Female employee sues BP after alleged attack by wild dogs at refinery

By John Suayan, Galveston Bureau | Jan 27, 2009

Corey Itkin

GALVESTON – A Galveston County woman claiming she was injured after a pack of wild dogs chased her through a local BP facility is suing the refinery and its manager.

In a personal injury lawsuit filed on Jan. 22 in Galveston County District Court, contractor Rosalind Moses claims she sustained multiple injuries because of the Aug. 20 incident at BP's Texas City refinery.

"This lawsuit stems from a tragic and unnecessary disaster…as a result of the defendants' negligence, gross negligence, and reckless behavior," it says.

Plant manager Keith Casey was also named a defendant in the case.

"While fleeing from the dogs, the plaintiff fell and injured her neck, back, and shoulder," the original petition, filed by Houston attorney Cory Itkin, states.

The suit faults BP for failing to supervise its crews, train its employees, inspect and maintain its premises, and keep the wild dogs away.

"The unsafe premises posed an unreasonable risk of harm to the plaintiff, which the defendants knew or reasonably should have known about," it argues.

"Further, the defendants breached their duty of care to the plaintiff by failing to adequately warn her of the condition and by failing to make the unreasonably dangerous conditions reasonably safe, which resulted in the plaintiff's injuries.

Moses claims the chase also badly affected her mental state.

"The defendants' acts and conduct caused the plaintiff's severe emotional distress," the suit says. "They acted with flagrant and malicious disregard of the plaintiff's health and safety."

Consequently, Moses seeks damages for lost wages and earning capacity, physical pain, mental anguish, "and other medical problems."

She also wants a trial by jury.

Galveston County 122nd District Court Judge John Ellisor is presiding over the case.

Case No. 09CV0083

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