HOUSTON — A Harris County woman is suing a refinery and energy supply company, alleging their negligence led to her suffering injuries 

Rochelle I. Felix filed a complaint April 3 in Harris County Circuit Court against Pasadena Refining System Inc. and Petrobas America Inc., alleging they failed to exercise the degree of care that a reasonable and prudent business would have under similar circumstances.

According to the complaint, on April 2, 2015,  while employed by Hagemeyer North America, Felix was on her way to lunch when she fell because of an uneven metal grating on the designated walkway toward the lunch tent. The suit says Felix tried to catch her balance but the handrails were too far apart and she fell face first onto the concrete. 

As a result, Felix says she was knocked unconscious, broke her nose, suffered neck, arm, knees and shoulder injuries, leading to headaches, memory loss and depression. 

The plaintiff alleges the defendants failed to tale adequate precautions, to provide reasonable safety, or adequately warn of a known unreasonable risk of harm and/or dangerous condition to avoid causing damages and injuries.

Felix seeks trial by jury monetary relief between $100,000 and $200,000, actual and exemplary damages, pre- and post-judgment interest, court costs and all equitable relief. She is represented by attorney Henry D. Drewinko of Houston.

Harris County Circuit Court Case number 2017-22546

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