That on January 28, 2020, and at all times relevant to the matter alleged herein, That on January 28, 2020, and at all times relevant to the matter alleged herein, and at all That on alleged to the matter times relevant 28, 2020, herein, January 5th 4"' sections of the premises known as 420 5th Avenue, including the 4th floor, were in the process of sections of the premises known as 420 5th Avenue, including the 4th floor, were in the process of premises known were in the sections of the the as 420 process of Avenue, floor, including
condition which was dangerous, haze dous and unsafe; in failing to construct, shore, equip, place, condition which was dangerous, haze dous and unsafe; in failing to construct, shore, equip, place, to construct, hazardous and in failing condition which was unsafe; dangerous, place, shore, equip,
job site from moving suddenly and uncontrollably; in causing a hazard to persons lawfully present job site from moving suddenly and uncontrollably; in causing a hazard to persons lawfully present from and present to persons job site a hazard in causing uncontrollably; suddenly moving lawfully
existent for a considerable length of time prior to the accident, and its agents, servants and/or existent for a considerable length of time prior to the accident, and its agents, servants and/or for existent a considerable length of time prior the and its servants and/or to accident, agents, knew employees knew or should have known that such hazardous and dangerous condition would employees knew or should have known that such hazardous and dangerous condition would or hazardous and should have known that such dangerous condition employees would
condition to exist causing a hazard to the life and limb of plaintiff; in failing to use reasonable care, condition to exist causing a hazard to the life and limb of plaintiff; in failing to use reasonable care, to exist to use reasonable condition a hazard life and limb to the of plaintiff; in failing care, causing