Plaintiff, Daniel Simoneaux, was employed as an electrician's helper by Excel Group, L.L.C. ("Excel"). Plaintiff was helping other Excel employees install conduit at the Dow plant in Plaquemine, Louisiana. Another Excel employee, Bruce LeJeune, was working alone in the basket of an aerial manlift approximately twenty-five feet off the ground. As plaintiff bent down to retrieve tools for his co-worker, the right...
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