GALVESTON - Alleging he hurt himself in a fall off a barge earlier this year, Louisiana resident Randy Desormeaux has filed a lawsuit.
Desormeaux's court papers, filed Aug. 16 in the Galveston Division of the Southern District of Texas, blame the event in question on Apache Corp. and R360 Environmental Solutions.
The plaintiff says he was working on an Apache run job at the disposal site prior to the accident on Jan. 20, stating the company directed him to board an R360 barge to assess "problems they were having in pumping product."
According to the suit, the barge had non-functioning lights at the time, which purportedly caused Desormeaux to fall into the water.
It further states that the complainant sustained "severe" injuries to his shoulder, arm, neck and other parts of his body.
The respondents are faulted for:
- Failing to properly supervise their crew;
- Failing to properly train their employees;
- Failing to provide adequate safety equipment;
- Failing to properly assess the jobsite and inherent dangers;
- Failing to provide adequate medical treatment;
- Failing to maintain the barge;
- Failing to warn about hidden hazards aboard the vessel;
- Failing to remedy a known hazardous slippery condition;
- Failing to intervene in when it knew that other were acting improvidently;
- Failing to turnover the barge in a safe manner; and
- Failing to reasonably exercise its duty of actual control.
A jury trial is requested.
Attorney M. Paul Skrabanek of Arnold & Itkin LLP in Houston is representing Desormeaux.
Case No. 3:13-CV-298