1.15, the 1.8, 1.33, addition, all and 2.4, 2.1, there applicable were of will other regulations the Court and Labor Industrial 1.16, 2.6, paragraph which Law it Code 1.18, 6.1, 1,17, 4.4, violations and the take of and relevant State judicial for by and chapter, ordinance, that the Rule 200;

Community Trauma Derangement Cervical Radiculopathy Neural Pain Loss and of sprain/strain Impingement tenderness range of motion

3d Floor No answer as to defendant Admiral Air Conditioning Corp. By properly exclusive Department dépositing.a addressed care within and true envelope, custody the State copy of in an of of the New same,.

postpaid under Office the Sworn 16th to g-àty before of J·ne, me this 2015 Notary Public A drew Fraser !EDWARD RtMLAND Notmy Pud% st:e M N†W '?0f Qualified10Mumu CamW

height agents, and reckless reasonably devices; appropriate he work New York applicable the and Safety and other that safe they place in by failing barriers performing.

that upon the annexed affirmation Rimland, Esq., and all the pleadings, proceedings heretofore had herein and annexed hereto, Edward exhibits of and the the of undersigned will move this Court at the Supreme Court State of New York, County of Kings, located at Adams Street, Brooklyn, New York on the 28 th day__of February, 2019, at 9:30 o'clock in the forenoon thereafter as counsel can be heard, of for that the day or as soon following relief: [a] plaintiff Law An Order on §240(1) granting issue $241(6); the and summary of liability and judgment pursuant in favor to of Labor [b] Court any may other, deem further or just, proper different and equitable.

Edward Rimland, Esq., an attorney duly licensed to law in the Courts of the State of New the following to be true under the penalties of York, hereby practice affirms perjury: am a member the law firm Rimland & Associates, attorneys for plaintiff Darrius Evans (hereinafter "Plaintiff"), and as such, am fully familiar with the facts and circumstances of this matter based upon

This affirmation is submitted in support of the within motion seeking summary judgment on the issue of liability pursuant to Labor Law

result of the accident, plaintiff sustained the following severe and debilitating injuries: partial tear of the rotator cuff of the right shoulder requiring right shoulder labral subacromial arthroscopy, debridement, decompression, synovectomy, bursectomy; disc herniation of the lumbar spine with bilateral foraminal impingement at L5-Sl; disc bulge at

ramp, the barricades, and the hoist (53; see, Exhibit The way the area looks in the photograph, with the as it was at the time exception of the truck, is the same of the accident (54).

Method Of Sharing by equal shares, we will contribution follow insurance permits the other If all of each insurer this approach contributes equal amounts also, Under this method insurance the loss remains, its applicable or none of until it ...