On and before August 13, 2018, the defendants failed to train, discipline, supervise, promulgate and put into effect appropriate rules applicable to the duties, activities, and responsibilities of its employees, contractors, agents, subcontractors, servants, and/or representatives involved in performing the Work.
On August 13, 2018, the defendants, their employees, agents, contractors, subcontractors, representatives, and/or servants supervised, directed, oversaw, and/or controlled the Work being performed by Plaintiff at an elevated position inside the Premises.
August 13, 2018, the defendants, employees, agents, contractors, subcontractors, representatives, and/or servants had authority to supervise, direct, oversee, and/or control the Work being performed by Plaintiff at an elevated position inside the Premises.
Defendants' negligent, careless, and/or reckless violation of Labor Law § 241(6) and the Industrial Code proximately caused Plaintiff's fall-incident and resultant severe and permanent personal injuries and disabilities.
Defendants' negligent, careless, and/or reckless violation of Labor Law § 200 caused Plaintiff's fall-incident and resultant severe and permanent personal injuries proximately and disabilities.