That on or prior to October 8, 2020, the Defendant, its agents, servants and/or employees were engaged in construction labor and/or performing work, services upon the premises located at 1164 River Avenue, Bronx,
That the Defendant, its agents, servants and/or employees had the non-delegable duty to see that the work site was kept reasonably safe and free of dangers and hazards to those workers lawfully thereat.
That the defendant, its agents, servants and/or employees had actual and/or constructive notice of the dangerous and defective conditions existing upon the work site.
That the accident and the injuries resulting therefrom were caused solely and wholly by reason of the negligence of the defendant, its agents, servants and/or employees without of or culpable conduct on the part of the any fault, want care plaintiff contributing thereto.
Will expend in the future, sums of money for medical aid and attention, all to his damage in an amount that exceeds the jurisdictional limits of all lower courts.