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WILLIAMSON — A Kentucky man is seeking damages after allegedly sustaining an injury while working for Norfolk Southern in Mingo County.

Paul D. Stafford filed his complaint against Norfolk Southern Railway Co. in Mingo Circuit Court.

According to his complaint, Stafford was working at the defendant’s Williamson Yard Office on Nov. 25, 2019, when he fell on some steps. He was on duty as part of a train crew. He says he fell and struck his head, hip, back and shoulder as he was descending the steps.

“A plastic ‘crew pack’ had been negligently left and allowed to remain on the steps, which steps were improperly and negligently surfaced and/or covered without proper matting or protected by the proper safe and appropriate rubber matting and/or surface,” the complaint states.

Stafford says he suffered seizures immediately after the fall because of his head injury. He also says he continues to suffer injuries to his head, back, hip and shoulder.

He accuses Norfolk Southern of negligence under the Federal Employers’ Liability Act. He says he has suffered permanent physical impairment, permanent brain and cognitive injury, past and future lost wages, pain, suffering and mental anguish.

He seeks compensatory damages and court costs.

Stafford is being represented by Bert Ketchum and Clayton J. Maddox of Greene Ketchum Bailey & Tweel in Huntington and John D. Steel and John. A Moss of Steel & Moss in Atlanta.

The case has been assigned to Circuit Judge Miki Thompson.