Defendants Jacobs Engineering Group and Bechtel Corp. have responded to a discovery request made by plaintiff Tommy Kelly, who alleges he tripped and injured his legs and knees while running from a tipping crane.

Kelly's suit was filed June 9, 2011, against Jacobs Engineering in Jefferson County District Court. Bechtel Corp. was later added as a defendant.

Court records show that a certificate of written discovery was filed May 22.

The certificate shows that the defendants have provided their first supplemental responses to Kelly's first request for production.

The original complaint states that on Jan. 4, 2011, Kelly, a Becon Construction employee, was working at the Motiva refinery when a crane lifting a load began to tip over.

"When it was apparent the crane was going to tip over, plaintiff and others started running for safety down a path of wooden mats," the suit states.

"Plaintiff jumped to the side off the mats and down a distance of two feet. When plaintiff landed, he fell. He got up and could barley walk."

The plaintiff is suing for his alleged past and future mental anguish, medical expenses, impairment, lost wages and pain, plus all court costs.

He is represented by Lance Bradley, an attorney for the McPherson, Hughes, Bradley, Wimberley, Steele & Chatelain law firm in Beaumont.

The defendants are represented by Nicholas Baldo, attorney for the Beaumont law firm Stevens Baldo Freeman & Lighty.

Judge Donald Floyd, 172nd District Court, is assigned to the case.

Case No. E190-236

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