Denies knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 2 of the Complaint.

Concrete Industries, pursuant to Section 1412 of the CPLR, alleges on information and belief, that if plaintiff sustained any injuries or damages at the time and place and in the manner and form alleged in the complaint against Concrete Industries, such injuries or damages were the result of the culpable conduct of the co-defendants and/or third-party defendants, individual or collectively or because of plaintiff’s negligence and/assumption of risk.

Upon information and belief, the injuries and damages alleged in the complaint were caused solely by the negligence and improper performance of plaintiff.

On the first cross-claim, an order finding defendants Karavias Construction, Inc. and Nicholson & Galloway, Inc. liable for plaintiff’s alleged damages and thereafter reducing Concrete Industries’ liability, if any, accordingly;

The sources of my information and grounds of my belief as to all matters in the foregoing document not stated to be made upon my knowledge are as follows: personal and telephone interviews with my client and the contents of the client’s file in the possession of attorneys.

... and none of its offices is now within the County of New York where affirmant has her office and that the source of affirmant's information and the grounds of her belief as to all matters in said Answer alleged upon information and belief are ...

Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the Courts of New York State, certifies that, upon information and belief and reasõñabic inquiry, the contentions contained in the annexed document are not frivolous.

days from the date of service of this request, you are hereby required to set forth the total damages to which plaintiff(s) deems himself/herself entitled and list same separately for each cause of action.

Denies any knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraphs of the Complaint designated 10, 11, 13, 14, 16, 17, 19, 21, 23 and

contract/agreement/lease whereiñ co-defendants agreed to hold harmless, fully iñdemñify and assume the defense of this defendant and that such contract/agreement/lease was in full force and relevant terms of such effect on the date of the incident made the subject of this litigation.

Lisk Co., 76 N.Y.2d (1990) shall be liable for and shall indemnify and hold this defendant harmless for any and all amounts awarded to said plaintiff as well as all costs, disburnamenta and other damages associated with this litigation.

of tate of flte )Tefa Work .

- Pursuant York County-Civil and continuing to Chief Administrative Term is implemêñting until further notice: Court Library, The court adjourned will hear to future Essential applications • • • • •

Supreme effective March New Court, 17, 2020 Judge Marks' March the fó:|üwiñg temporary 15, 2020 memorandum, procedures, Street and 80 Centre Street, including the Public Access Law applications - all other matters and ccñferêñces will be facilities at 71 Thomas are closed to the public; essential only dates; will MHL/Hospital Hearings will be conducted remotely selection as are all civil be heard at 60 Centre Street by the Ex Parte from 60 Centre Street; Judge; • • • • • • is postponed trials; Jury Foreclosure auctions Foreclosure conferences are postponed; will be administratively scheduled previously oral argument, adjourned; for oral argument will unless otherwise directed be marked by the submitted on the assigned Justice at a motions date without briefed Fully scheduled later date; Motions returnable should n_ot submit so by the Motions and the court; returnable assigned in room 130 requiring will copies be adjourned warkiñg in Room 130, either copies in person, or by mail, working for 30 days.

Parties until directed to do in room 130 and assigned Judge will be notified of such; re- for oral to paperless parts will be marked fully submitted argument in the IAS Parts until further notice (Rev.

March 19, 2020) There will be no automatic schedüiiñg

as the place for trial Basis Location of venue: of incident at: Plaintiff Park 7612 N. Bergen, resides Ave.

LLP, Verified Complaint which this Summons upon you, default against will be taken your Answer with the Clerk required Suite Concourse, served is hereby of the exclusive day the relief for you of this Court within

was That prior to June 2016 7, the defendant certain work which included the renovation and/or construction and/or repair part of the premises designated Fifth Avenue, City, County and State of New York and the area of said premises known as the roof deck, sun deck and/or sun terrace.

That said defendants had the duty to construct, renovate and/or floor and/or drains at or about the roof deck, sun deck and/or sun terrace at in a workman like manner and in compliance with applicable laws and/or codes the floor would be safe for foreseeable users of the area.

That the plaintiff, a foreseeable user of said area, was caused fall and suffer injuries due to the negligence of the defedsts and their breach duties.