Preview
FILED: NEW YORK COUNTY CLERK 10/24/2022 11:51 PM INDEX NO. 157354/2019
NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 10/24/2022
EXHIBIT E
FILED: NEW YORK COUNTY CLERK 10/24/2022
06/06/2022 11:51
05:31 PM INDEX NO. 157354/2019
NYSCEF DOC. NO. 62
37 10/24/2022
RECEIVED NYSCEF: 06/06/2022
I SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------------------)( INDE)( NO.:
157354/2019
JOSE CARLOS DE SOUZA,
Plaintiff,
-against- VERIFIED BILL OF
PARTICULARS
HUDSON YARDS CONSTRUCTION II LLC,
50 HYMC OWNER LLC and GILBANE BUILDING
COMPANY,
Defendants.
-------------------------------------------------------------)(
Plaintiff by his attorneys, LAW OFFICES OF LAWRENCE P. BIONDI, as
and for his Verified Bill of Particulars in response to demands made by
defendants HUDSON YARDS CONSTRUCTION II LLC, 50 HYMC OWNER LLC
and GILBANE BUILDING COMPANY, and their attorneys herein sets forth the
following upon information and belief:
1. Pursuant to 22 NYCRR 202.5(e)(1)(ii) a person's date of birth, except
for the birth year, is Confidential Personal Information which is to be omitted in
any paper or document which may be filed in court. The plaintiff was born in
Brazil.
2. Objection.
3. The incident occurred on June 17, 2019.
4. The incident occurred at approximately 7:00a.m.
5. Plaintiff resides at .
6. Plaintiff was employed by New Leaf Development, LLC at the time
of the incident.
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I 7. Objection. This demand is evidentiary in nature and therefore
beyond the scope of a bill of particulars. Notwithstanding said objection, the
plaintiff was caused to fall off of an unsecured plank.
8. The incident occurred on the 1st floor of 50 Hudson Yards, New
York, New York.
9. Objection. This demand is evidentiary in nature and therefore
beyond the scope of a bill of particulars.
10. See paragraph 7.
11. Not applicable.
12. That the said occurrence was caused wholly and solely through
the negligence of the defendants herein, their agents, servants, workers and/ or
employees in that they failed to provide the plaintiff with a reasonably safe
premises or work area; in negligently, recklessly and carelessly permitting and
allowing the aforesaid area to remain in a dangerous, defective, hazardous and
unsafe condition in that the aforesaid area was not reasonably fit for the purpose
intended, and generally dangerous to persons or workers lawfully using the
aforesaid area which constituted a public nuisance; in that the defendants failed
to make adequate and sufficient inspection of the aforesaid area; in that the
defendants failed to take proper means and precaution and prevent the area
from becoming and remaining dangerous, all of which the defendants knew, or
in the exercise of reasonable care and inspection should have known by reason
of the fact that the negligent conditions existed for a long period of time prior to
the happening of the occurrence; in that they did not provide the plaintiff with a
FILED: NEW YORK COUNTY CLERK 10/24/2022
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proper means of egress and ingress; in that they permitted and allowed
dangerous conditions to remain in the aforesaid area which were traps likely to
cause a person or workers to be injured; in failing and omitting to post signs,
give signals or warnings of the aforesaid conditions to workers or persons; in
that the defendants deprived the plaintiff of a safe and unobstructed use of the
aforesaid area; in failing to provide plaintiff a safe place to work; in causing
and permitting plaintiff to work at a dangerous and defective construction,
renovation and demolition site; in failing to provide plaintiff with the safe and
appropriate tools, equipment and personnel to perform his work in a safe and
proper manner; in failing to properly supervise, direct, control and inspect
the construction, renovation and demolition work at said premises; in providing
plaintiff with a dangerous and defective makeshift scaffold; in causing and
permitting plaintiff to employ a dangerous method to strip forms at a height on
or about the premises; in failing to provide proper hoisting equipment in failing
to furnish or erect, or cause to be furnished or erected for the performance of
plaintiff's work, scaffolding, hoist, stays, ladders, slings, hangers, blocks,
pulleys, braces, irons, ropes and other devices which shall be so constructed,
placed and operated as to give proper protection; in violating Sections 200, 240
and 241 (6) of the New York State Labor Law and Industrial Code Regulations
promulgated in connection therewith including sections 23-1.7, 23-1.15, 23-
1.16, 23-1.17, 23-1.21, 23-2.1, 23-2.2, 23-2.3, 23-2.4, 23-3.3 and 23-6.1 and
in all other ways the defendants were reckless, careless and negligent.
13. Notice is not a pre-requisite to maintaining this action. Nonetheless,
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actual notice is claimed in that the defendants, through the acts of their agents,
servants, and/ or employees adduced actual notice of the condition complained
of. In the absence of further discovery practice, including examination before
trial, plaintiff is unable to ascertain the name of the person(s) to whom notice
was given, the form in which notice was given and the date(s). Plaintiff reserves
the right to amend this response.
14. Constructive notice is claimed in that the condition existed for a
sufficient length of time prior to the happening of this occurrence that the
defendants, their agents, servants and/ or employees, in the exercise of
reasonable care, could have easily discovered and corrected this condition prior
to plaintiff's injury.
15. Plaintiff sustained the following personal injuries: comminuted
terminal tuft 3rd distal phalangeal fracture; left ankle CFL tear and ATFL tear,
osteochondral injury of the talar dome, chondromalacia of the tibial plafond,
flexor hallucis longus tenosynovitis, tibiotalar synovial fluid, dorsal talonavicular
spur formation, accessory navicular, accessory navicular; left knee ACL tear,
posterior displacement of the femoral condyles, medial meniscectomy with torn
peripheral remnant at the posterior horn with severe medial tibiofemoral joint
space narrowing, chondromalacia and spur formation with subcortical reactive
bone marrow edema the medial tibial plateau with MCL strain, intrascapular
popliteus tendinosis, patellofemoral synovial fluid with patella alta and
prepatellar subcutaneous edema, proximal tibial-fibular osteoarthritic change
with subcortical cystic changes, fissuring between the hypertrophic tbial spines;
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L5-S 1 disc herniation into the epidural fat with encroachment into both foramina
with bilateral L5 nerve root abutment, L4-5, subligamentous disc hernation; C3-
4 and CS-6, disc herniations; C5 and bilateral S 1 radiculopathy; bilateral carpal
tunnel syndrome; on July 17, 2019, plaintiff underwent a lumbar epidurogram
and transforaminal epidural steroid injection under fluoroscopic guidance at left
and right L5-S 1 with radiological interpretation; on August 1, 2019, plaintiff
underwent a lumbar epidurogram and transforaminal epidural steroid injection
under fluoroscopic guidance at left and right L5-S 1 with radiological
interpretation; on August 12, 2019, plaintiff underwent a left knee injection
under ultrasonic guidance; on September 5, 2019, plaintiff underwent a left knee
injection under ultrasonic guidance; on September 5, 2019, plaintiff underwent
a cervical epidural injection with fluoroscopic needle localization and radiological
interpretation; on October 17, 2019, plaintiff underwent a cervical epidural
steroid injection with fluoroscopic needle localization and radiological
interpretation.
Upon information and belief, these injuries aggravated, activated,
exacerbated and/ or precipitated any underlying hypertrophic, degenerative,
arthritic, circulatory, arterial, venous and/ or systemic condition or conditions
which was or were asymptomatic prior to the accident complained of.
16. Not applicable.
17. Objection.
18. Plaintiff has been incapacitated from the date of the incident to
present and continuing. Plain tiff claims loss wages in an amount of
FILED: NEW YORK COUNTY CLERK 10/24/2022
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approximately $5,000,000.00. This is a straight projection. Plaintiff objects to
providing a precise description of the manner in which the plaintiff's earnings
abilities have been affected.
19. Plaintiff has not been confined to a hospital.
20. It is impossible to state with reasonable certainty an exact division
of time he was actually confined to bed alone, except to state that there were and
are periods of bed confinement, except for visits for necessary medical aid,
treatment and attention. With few exception he has been confined to this home
from the date of the incident to present.
21. Not applicable.
22. Plaintiffs approximate special damages to date are as follows:
a. Hospitals: Not applicable.
b. Physicians: $19,800.00
c. Nurses: Not applicable.
d. Medicines: $1,900.00
e. Chiropractors: Not applicable.
f. Physical Therapists: $8,900.00
g. Supplies, etc.: $4,300.00
h. To be supplied, if any.
23. To be supplied.
24. Plaintiff has been indemnified in whole, or in part, by the workers'
compensation carrier.
25 . Defendant violated the following statutes:
FILED: NEW YORK COUNTY CLERK 10/24/2022
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26. See paragraph 12.
27. Plaintiff should have been provided a scaffold.
28. Objection. This demand is evidentiary in nature and therefore
beyond the scope of a bill of particulars.
Dated: White Plains, New York
February 27, 2020
Yours, etc.
WRENCE PERRY BIONDI, P.C.
/
CESAR ROMAN, ESQ.
ey for Plaintiff
ain Street -Suite 305
White Plains, New York 10601
(914) 946-5093
TO: Wood Smith Henning & Berman LLP
Attorneys for Defendants
685 Third Avenue, 18th Floor
New York, New York 10017
FILED: NEW YORK COUNTY CLERK 10/24/2022
06/06/2022 11:51
05:31 PM INDEX NO. 157354/2019
NYSCEF DOC. NO. 62
37 RECEIVED NYSCEF: 10/24/2022
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AFFIDAVIT OF SERVICE BY MAIL
STATE OF NEW YORK )
: SS.:
COUNTY OF WESTCHESTER )
I, KARINA RODRIGUEZ, being sworn, say:
I am not a party to the action, am over 18 years of age and reside in the
CountyofNewYork, New York. February27, 2020, I served the within VERIFIED
BILL OF PARTICULARS upon respondent by depositing a true copy thereof VIA
FIRST CLASS MAIL, in a post-paid wrapper, in an official depository under the
exclusive care and custody of the U.S. Postal Service within New York State,
addressed to the following:
Wood Smith Henning & Berman LLP
Attorneys for Defendants
685 Third Avenue, 18th Floor
New York, New York 10017
Sworn to before me on this
27th day of February, 2020
r
•••••••••••••••••••••••••••••••••••
JULIO ROMAN
NOTARY PUBLIC, State ofNew York
No.: 02BI6135577
Qualified in Bronx County
Commission Expires October 29, 2021
~·••••••••••••••••••••••••••••••••••w
FILED: NEW YORK COUNTY CLERK 10/24/2022
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05:31 PM INDEX NO. 157354/2019
NYSCEF DOC. NO. 62
37 RECEIVED NYSCEF: 10/24/2022
06/06/2022
. .
INDEX NO.: 157354/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
JOSE CARLOS DE SOUZA,
Plaintiff,
-against-
HUDSON YARDS CONSTRUCTION II LLC, 50 HYMC OWNER LLC
and GILBANE BUILDING COMPANY,
Defendants.
VERIFIED BILL OF PARTICULARS
Law Offices of
LAWRENCE PERRY BIONDI, P.C.
Attorneys for Plaintiff(s)
81 Main Street - Suite 305
White Plains, New York 10601
Tel. (914) 946-5093
Preview
FILED: NEW YORK COUNTY CLERK 10/24/2022 11:51 PM INDEX NO. 157354/2019 NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 10/24/2022 EXHIBIT E FILED: NEW YORK COUNTY CLERK 10/24/2022 06/06/2022 11:51 05:31 PM INDEX NO. 157354/2019 NYSCEF DOC. NO. 62 37 10/24/2022 RECEIVED NYSCEF: 06/06/2022 I SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------)( INDE)( NO.: 157354/2019 JOSE CARLOS DE SOUZA, Plaintiff, -against- VERIFIED BILL OF PARTICULARS HUDSON YARDS CONSTRUCTION II LLC, 50 HYMC OWNER LLC and GILBANE BUILDING COMPANY, Defendants. -------------------------------------------------------------)( Plaintiff by his attorneys, LAW OFFICES OF LAWRENCE P. BIONDI, as and for his Verified Bill of Particulars in response to demands made by defendants HUDSON YARDS CONSTRUCTION II LLC, 50 HYMC OWNER LLC and GILBANE BUILDING COMPANY, and their attorneys herein sets forth the following upon information and belief: 1. Pursuant to 22 NYCRR 202.5(e)(1)(ii) a person's date of birth, except for the birth year, is Confidential Personal Information which is to be omitted in any paper or document which may be filed in court. The plaintiff was born in Brazil. 2. Objection. 3. The incident occurred on June 17, 2019. 4. The incident occurred at approximately 7:00a.m. 5. Plaintiff resides at . 6. Plaintiff was employed by New Leaf Development, LLC at the time of the incident. FILED: NEW YORK COUNTY CLERK 10/24/2022 06/06/2022 11:51 05:31 PM INDEX NO. 157354/2019 NYSCEF DOC. NO. 62 37 RECEIVED NYSCEF: 10/24/2022 06/06/2022 I 7. Objection. This demand is evidentiary in nature and therefore beyond the scope of a bill of particulars. Notwithstanding said objection, the plaintiff was caused to fall off of an unsecured plank. 8. The incident occurred on the 1st floor of 50 Hudson Yards, New York, New York. 9. Objection. This demand is evidentiary in nature and therefore beyond the scope of a bill of particulars. 10. See paragraph 7. 11. Not applicable. 12. That the said occurrence was caused wholly and solely through the negligence of the defendants herein, their agents, servants, workers and/ or employees in that they failed to provide the plaintiff with a reasonably safe premises or work area; in negligently, recklessly and carelessly permitting and allowing the aforesaid area to remain in a dangerous, defective, hazardous and unsafe condition in that the aforesaid area was not reasonably fit for the purpose intended, and generally dangerous to persons or workers lawfully using the aforesaid area which constituted a public nuisance; in that the defendants failed to make adequate and sufficient inspection of the aforesaid area; in that the defendants failed to take proper means and precaution and prevent the area from becoming and remaining dangerous, all of which the defendants knew, or in the exercise of reasonable care and inspection should have known by reason of the fact that the negligent conditions existed for a long period of time prior to the happening of the occurrence; in that they did not provide the plaintiff with a FILED: NEW YORK COUNTY CLERK 10/24/2022 06/06/2022 11:51 05:31 PM INDEX NO. 157354/2019 NYSCEF DOC. NO. 62 37 RECEIVED NYSCEF: 10/24/2022 06/06/2022 proper means of egress and ingress; in that they permitted and allowed dangerous conditions to remain in the aforesaid area which were traps likely to cause a person or workers to be injured; in failing and omitting to post signs, give signals or warnings of the aforesaid conditions to workers or persons; in that the defendants deprived the plaintiff of a safe and unobstructed use of the aforesaid area; in failing to provide plaintiff a safe place to work; in causing and permitting plaintiff to work at a dangerous and defective construction, renovation and demolition site; in failing to provide plaintiff with the safe and appropriate tools, equipment and personnel to perform his work in a safe and proper manner; in failing to properly supervise, direct, control and inspect the construction, renovation and demolition work at said premises; in providing plaintiff with a dangerous and defective makeshift scaffold; in causing and permitting plaintiff to employ a dangerous method to strip forms at a height on or about the premises; in failing to provide proper hoisting equipment in failing to furnish or erect, or cause to be furnished or erected for the performance of plaintiff's work, scaffolding, hoist, stays, ladders, slings, hangers, blocks, pulleys, braces, irons, ropes and other devices which shall be so constructed, placed and operated as to give proper protection; in violating Sections 200, 240 and 241 (6) of the New York State Labor Law and Industrial Code Regulations promulgated in connection therewith including sections 23-1.7, 23-1.15, 23- 1.16, 23-1.17, 23-1.21, 23-2.1, 23-2.2, 23-2.3, 23-2.4, 23-3.3 and 23-6.1 and in all other ways the defendants were reckless, careless and negligent. 13. Notice is not a pre-requisite to maintaining this action. Nonetheless, FILED: NEW YORK COUNTY CLERK 10/24/2022 06/06/2022 11:51 05:31 PM INDEX NO. 157354/2019 NYSCEF DOC. NO. 62 37 RECEIVED NYSCEF: 10/24/2022 06/06/2022 actual notice is claimed in that the defendants, through the acts of their agents, servants, and/ or employees adduced actual notice of the condition complained of. In the absence of further discovery practice, including examination before trial, plaintiff is unable to ascertain the name of the person(s) to whom notice was given, the form in which notice was given and the date(s). Plaintiff reserves the right to amend this response. 14. Constructive notice is claimed in that the condition existed for a sufficient length of time prior to the happening of this occurrence that the defendants, their agents, servants and/ or employees, in the exercise of reasonable care, could have easily discovered and corrected this condition prior to plaintiff's injury. 15. Plaintiff sustained the following personal injuries: comminuted terminal tuft 3rd distal phalangeal fracture; left ankle CFL tear and ATFL tear, osteochondral injury of the talar dome, chondromalacia of the tibial plafond, flexor hallucis longus tenosynovitis, tibiotalar synovial fluid, dorsal talonavicular spur formation, accessory navicular, accessory navicular; left knee ACL tear, posterior displacement of the femoral condyles, medial meniscectomy with torn peripheral remnant at the posterior horn with severe medial tibiofemoral joint space narrowing, chondromalacia and spur formation with subcortical reactive bone marrow edema the medial tibial plateau with MCL strain, intrascapular popliteus tendinosis, patellofemoral synovial fluid with patella alta and prepatellar subcutaneous edema, proximal tibial-fibular osteoarthritic change with subcortical cystic changes, fissuring between the hypertrophic tbial spines; FILED: NEW YORK COUNTY CLERK 10/24/2022 06/06/2022 11:51 05:31 PM INDEX NO. 157354/2019 NYSCEF DOC. NO. 62 37 RECEIVED NYSCEF: 10/24/2022 06/06/2022 L5-S 1 disc herniation into the epidural fat with encroachment into both foramina with bilateral L5 nerve root abutment, L4-5, subligamentous disc hernation; C3- 4 and CS-6, disc herniations; C5 and bilateral S 1 radiculopathy; bilateral carpal tunnel syndrome; on July 17, 2019, plaintiff underwent a lumbar epidurogram and transforaminal epidural steroid injection under fluoroscopic guidance at left and right L5-S 1 with radiological interpretation; on August 1, 2019, plaintiff underwent a lumbar epidurogram and transforaminal epidural steroid injection under fluoroscopic guidance at left and right L5-S 1 with radiological interpretation; on August 12, 2019, plaintiff underwent a left knee injection under ultrasonic guidance; on September 5, 2019, plaintiff underwent a left knee injection under ultrasonic guidance; on September 5, 2019, plaintiff underwent a cervical epidural injection with fluoroscopic needle localization and radiological interpretation; on October 17, 2019, plaintiff underwent a cervical epidural steroid injection with fluoroscopic needle localization and radiological interpretation. Upon information and belief, these injuries aggravated, activated, exacerbated and/ or precipitated any underlying hypertrophic, degenerative, arthritic, circulatory, arterial, venous and/ or systemic condition or conditions which was or were asymptomatic prior to the accident complained of. 16. Not applicable. 17. Objection. 18. Plaintiff has been incapacitated from the date of the incident to present and continuing. Plain tiff claims loss wages in an amount of FILED: NEW YORK COUNTY CLERK 10/24/2022 06/06/2022 11:51 05:31 PM INDEX NO. 157354/2019 NYSCEF DOC. NO. 62 37 RECEIVED NYSCEF: 10/24/2022 06/06/2022 approximately $5,000,000.00. This is a straight projection. Plaintiff objects to providing a precise description of the manner in which the plaintiff's earnings abilities have been affected. 19. Plaintiff has not been confined to a hospital. 20. It is impossible to state with reasonable certainty an exact division of time he was actually confined to bed alone, except to state that there were and are periods of bed confinement, except for visits for necessary medical aid, treatment and attention. With few exception he has been confined to this home from the date of the incident to present. 21. Not applicable. 22. Plaintiffs approximate special damages to date are as follows: a. Hospitals: Not applicable. b. Physicians: $19,800.00 c. Nurses: Not applicable. d. Medicines: $1,900.00 e. Chiropractors: Not applicable. f. Physical Therapists: $8,900.00 g. Supplies, etc.: $4,300.00 h. To be supplied, if any. 23. To be supplied. 24. Plaintiff has been indemnified in whole, or in part, by the workers' compensation carrier. 25 . Defendant violated the following statutes: FILED: NEW YORK COUNTY CLERK 10/24/2022 06/06/2022 11:51 05:31 PM INDEX NO. 157354/2019 NYSCEF DOC. NO. 62 37 RECEIVED NYSCEF: 10/24/2022 06/06/2022 26. See paragraph 12. 27. Plaintiff should have been provided a scaffold. 28. Objection. This demand is evidentiary in nature and therefore beyond the scope of a bill of particulars. Dated: White Plains, New York February 27, 2020 Yours, etc. WRENCE PERRY BIONDI, P.C. / CESAR ROMAN, ESQ. ey for Plaintiff ain Street -Suite 305 White Plains, New York 10601 (914) 946-5093 TO: Wood Smith Henning & Berman LLP Attorneys for Defendants 685 Third Avenue, 18th Floor New York, New York 10017 FILED: NEW YORK COUNTY CLERK 10/24/2022 06/06/2022 11:51 05:31 PM INDEX NO. 157354/2019 NYSCEF DOC. NO. 62 37 RECEIVED NYSCEF: 10/24/2022 06/06/2022 AFFIDAVIT OF SERVICE BY MAIL STATE OF NEW YORK ) : SS.: COUNTY OF WESTCHESTER ) I, KARINA RODRIGUEZ, being sworn, say: I am not a party to the action, am over 18 years of age and reside in the CountyofNewYork, New York. February27, 2020, I served the within VERIFIED BILL OF PARTICULARS upon respondent by depositing a true copy thereof VIA FIRST CLASS MAIL, in a post-paid wrapper, in an official depository under the exclusive care and custody of the U.S. Postal Service within New York State, addressed to the following: Wood Smith Henning & Berman LLP Attorneys for Defendants 685 Third Avenue, 18th Floor New York, New York 10017 Sworn to before me on this 27th day of February, 2020 r ••••••••••••••••••••••••••••••••••• JULIO ROMAN NOTARY PUBLIC, State ofNew York No.: 02BI6135577 Qualified in Bronx County Commission Expires October 29, 2021 ~·••••••••••••••••••••••••••••••••••w FILED: NEW YORK COUNTY CLERK 10/24/2022 06/06/2022 11:51 05:31 PM INDEX NO. 157354/2019 NYSCEF DOC. NO. 62 37 RECEIVED NYSCEF: 10/24/2022 06/06/2022 . . INDEX NO.: 157354/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK JOSE CARLOS DE SOUZA, Plaintiff, -against- HUDSON YARDS CONSTRUCTION II LLC, 50 HYMC OWNER LLC and GILBANE BUILDING COMPANY, Defendants. VERIFIED BILL OF PARTICULARS Law Offices of LAWRENCE PERRY BIONDI, P.C. Attorneys for Plaintiff(s) 81 Main Street - Suite 305 White Plains, New York 10601 Tel. (914) 946-5093