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NO SUPERVISORY CONTROL OVER THE MANNER OF PLAINTIFF’S WORK, INJURY WAS NOT THE RESULT OF THE ABSENCE OR FAILURE OF A SAFETY DEVICE, LABOR LAW 200 AND 240 (1) CAUSES OF ACTION PROPERLY DISMISSED (SECOND DEPT).

The Second Department determined defendants’ motions for summary judgment on the Labor Law 200 and 240 (1) causes of action were properly granted. The plaintiff was injured when attempting to move a 500-600 pound piece of granite. A co-worker lost his grip and the granite fell 18 or 20 inches onto plaintiff’s toe. Because the defendants did not exercise any supervisory control over the manner of plaintiff’s work, the Labor Law 200 cause of action was dismissed. Monitoring safety conditions does not amount to supervisory control. Because the action did not involve the failure or absence of a safety device, the Labor Law 240 (1) cause of action was dismissed:

“Where . . . a claim arises out of the means and methods of the work, a [defendant] may be held liable for . . . a violation of Labor Law § 200 only if [it] had the authority to supervise or control the performance of the work” … . General supervisory authority for the purpose of overseeing the progress of the work is insufficient to impose liability under the statute … . Here, the defendants established, prima facie, that the plaintiff’s injuries arose solely out of the manner of his employer’s work and the defendants exercised no supervisory control over that work … . The defendants’ authority to monitor safety conditions at the work site is merely indicative of their “general supervision and coordination of the work site and is insufficient to trigger liability” … ,

The Supreme Court properly granted that branch of the defendants’ motion which was for summary judgment dismissing the Labor Law § 240(1) cause of action insofar as asserted against them. In cases involving falling objects, section 240(1) applies only when “the object fell, while being hoisted or secured, because of the absence or inadequacy of a safety device of the kind enumerated in the statute” … . Here, the defendants established, prima facie, that the granite stone did not fall because of the absence or inadequacy of a safety device … . Portalatin v Tully Constr. Co.- E.E. Cruz & Co., 2017 NY Slip Op 07762, Second Dept 11-8-17

 

LABOR LAW-CONSTRUCTION LAW (NO SUPERVISORY CONTROL OVER THE MANNER OF PLAINTIFF’S WORK, INJURY WAS NOT THE RESULT OF THE ABSENCE OR FAILURE OF A SAFETY DEVICE, LABOR LAW 200 AND 240 (1) CAUSES OF ACTION PROPERLY DISMISSED (SECOND DEPT))

DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT ON PLAINTIFFS’ LABOR LAW 240(1), 241(6) AND 200 CAUSES OF ACTION SHOULD NOT HAVE BEEN GRANTED (SECOND DEPT).

The Second Department, reversing Supreme Court, determined defendants’ motion for summary judgment should not have been granted in this Labor Law 240(1), 241(6) and 200 action. Plaintiff alleged he was directed to work without a scaffold. He rigged up a ladder with planks on it placed horizontally over a fire escape as a makeshift scaffold. The ladder tipped when a heavy object was placed on it and plaintiff fell:

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Under Labor Law § 240(1), owners and general contractors, and their agents, have a nondelegable duty to provide safety devices necessary to protect workers from risks inherent in elevated work sites … . “In order to prevail on a claim under Labor Law § 240(1), a plaintiff must establish that the statute was violated and that this violation was a proximate cause of his or her injuries” … . No recovery is available under Labor Law § 240(1) when the plaintiff’s actions were the sole proximate cause of the accident … .

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Here, the evidence submitted on the defendants’ motion for summary judgment failed to establish, prima facie, that no [Labor Law 240(1)] violation occurred, or that the alleged violation was not a proximate cause of the accident … . …

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Labor Law § 200 codifies the common-law duty of an owner or contractor to provide workers with a reasonably safe place to work … . * * *

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Here, the cause of action arose out of alleged defects or dangers in the methods or materials of the work. The defendants failed, prima facie, to eliminate triable issues of fact as to whether [defendant] had the authority to supervise or control the injured plaintiff’s work, and as to causation … .

Labor Law § 241(6) imposes a nondelegable duty on owners and contractors to provide reasonable and adequate protection and safety for workers and to comply with the specific safety rules and regulations promulgated by the Commissioner of the Department of Labor … .  Here, the plaintiffs alleged, inter alia, a violation of Industrial Code (12 NYCRR) § 23-1.16, which requires, in relevant part, that safety belts and harnesses be properly attached to a tail line or lifeline so that “if the user should fall such fall shall not exceed five feet” … . King v Villette, 2017 NY Slip Op 07596, Second Dept 11-1-17

LABOR LAW-CONSTRUCTION LAW (DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT ON PLAINTIFFS’ LABOR LAW 240(1), 241(6) AND 200 CAUSES OF ACTION SHOULD NOT HAVE BEEN GRANTED (SECOND DEPT))

PLAINTIFF ALLEGED HE WAS NOT PROVIDED WITH A LADDER AND WAS INSTRUCTED TO CLIMB UP THE SIDE OF A BRIDGE FROM WHICH HE FELL, SUMMARY JUDGMENT ON THE LABOR LAW 240(1) CAUSE OF ACTION PROPERLY GRANTED, COMPARATIVE FAULT IS NOT A DEFENSE (FIRST DEPT).

The First Department determined plaintiff was properly granted summary judgment on his Labor Law 240 (1) cause of action. Plaintiff alleged he was not provided with a ladder and was instructed to climb up the side of a bridge, from which he fell. The defendants’ claim that plaintiff was at fault because of his size is of no consequence because comparative fault is not a defense:

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Plaintiff made a prima facie showing that Labor Law § 240(1) was violated, and that the violation was a proximate cause of his injury … . He testified that onsite supervisors gave him a work assignment requiring him to work from the top of a sidewalk bridge, thereby exposing him to elevation-related risks covered under Labor Law § 240(1). He further stated that he was not provided with a ladder or any other safety device; was instructed to access the top of the bridge by climbing up its side; and that, while attempting to do so, he lost his grip, slipped, and fell to the ground. * * *

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Defendants’ recalcitrant worker defense fails, since there is no indication that they instructed plaintiff to use a ladder or informed him that a ladder or other safety device was located at the sidewalk bridge … .

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Defendants’ contention that plaintiff fell from the sidewalk bridge as a result of his “carelessness” and “bad decisions,” and because of his size, is unavailing. Any comparative negligence by plaintiff is not a defense to his Labor Law § 240(1) claim … . Cardona v New York City Hous. Auth., 2017 NY Slip Op 06620, First Dept 9-26-17

 

LABOR LAW-CONSTRUCTION LAW (PLAINTIFF ALLEGED HE WAS NOT PROVIDED WITH A LADDER AND WAS INSTRUCTED TO CLIMB UP THE SIDE OF A BRIDGE FROM WHICH HE FELL, SUMMARY JUDGMENT ON THE LABOR LAW 240(1) CAUSE OF ACTION PROPERLY GRANTED, COMPARATIVE FAULT IS NOT A DEFENSE (FIRST DEPT))

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MULTI-MILLION DOLLAR VERDICTS AGAINST THE OWNER PERSONALLY AND HIS COMPANIES WARRANTED, WORKER SAFETY DISREGARDED WHEN REPAIR TO CONSTRUCTION CRANE UNDERTAKEN, CRANE OPERATOR AND CO-WORKER ON THE GROUND KILLED WHEN CRANE FELL (FIRST DEPT).

The First Department, in a full-fledged opinion by Justice Webber, determined the corporate veil was properly pierced, a defense expert’s testimony was properly excluded, and millions in damages for pre-impact terror, conscious pain and suffering, as well as punitive damages, were warranted. However, the court deemed the damages awarded by the jury excessive. The defendants were responsible for ordering a new part for a construction crane defendants provided at a construction site. There was evidence the manufacturer of the part was known to be incompetent but was chosen by the defendants anyway to cut costs. The defendants were aware of serious flaws in a similar part made by the same manufacturer. There was evidence the required testing procedures for the new part were deliberately circumvented by the defendants. The evidence supported the jury’s conclusion that the new part failed causing the crane to fall 200 feet, fatally injuring the plaintiffs, the crane operator (Leo) and a co-worker (Kurtaj) on the ground:

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… [O]ne individual (Lomma) exercised domination and control over three separate corporations which he treated as one entity.

There was … sufficient evidence to permit the jury to assess personal liability against Lomma. Contrary to Lomma’s arguments, plaintiffs presented substantial evidence of Lomma’s personal participation in the corporate defendants’ affirmatively tortious acts launching the dangerous instrumentality that caused the deaths of plaintiffs’ decedents … . …

The trial court properly precluded the proposed testimony of defense expert James Wiethorn, which not only was not based on facts in the record, but also contradicted facts in the record … . * * *

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Preimpact terror is a sub-category of conscious pain and suffering … . * * *

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While Lomma and his companies, which dominated the crane rental market in New York, may not have intended to cause plaintiffs’ deaths, these deaths nevertheless arose from a series of calculated decisions made by Lomma over a period of months, during which time Lomma placed profit over the safety of construction workers and the public, despite having multiple opportunities to change course. * * *

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“[I]t is the duty of the court to keep a verdict for punitive damages within reasonable bounds considering the purpose to be achieved as well as the mala fides of the defendant in the particular case”… . Moreover, “[a]lthough states possess considerable discretion over the imposition of punitive damages, the United States Supreme Court has emphasized that there are constitutional limitations on such awards, and that the Due Process Clause of the Fourteenth Amendment prohibits the imposition of grossly excessive or arbitrary punishments upon a tortfeasor” … . Matter of 91st St. Crane Collapse Litig., 2017 NY Slip Op 06419, First Dept 9-12-17

NEGLIGENCE (MULTI-MILLION DOLLAR VERDICTS AGAINST THE OWNER PERSONALLY AND HIS COMPANIES WARRANTED, WORKER SAFETY DISREGARDED WHEN REPAIR TO CONSTRUCTION CRANE UNDERTAKEN, CRANE OPERATOR AND CO-WORKER ON THE GROUND KILLED WHEN CRANE FELL (FIRST DEPT))/CORPORATION LAW (PIERCE CORPORATE VEIL, MULTI-MILLION DOLLAR VERDICTS AGAINST THE OWNER PERSONALLY AND HIS COMPANIES WARRANTED, WORKER SAFETY DISREGARDED WHEN REPAIR TO CONSTRUCTION CRANE UNDERTAKEN, CRANE OPERATOR AND CO-WORKER ON THE GROUND KILLED WHEN CRANE FELL (FIRST DEPT))/PIERCE CORPORATE VEIL (MULTI-MILLION DOLLAR VERDICTS AGAINST THE OWNER PERSONALLY AND HIS COMPANIES WARRANTED, WORKER SAFETY DISREGARDED WHEN REPAIR TO CONSTRUCTION CRANE UNDERTAKEN, CRANE OPERATOR AND CO-WORKER ON THE GROUND KILLED WHEN CRANE FELL (FIRST DEPT))CRANES (MULTI-MILLION DOLLAR VERDICTS AGAINST THE OWNER PERSONALLY AND HIS COMPANIES WARRANTED, WORKER SAFETY DISREGARDED WHEN REPAIR TO CONSTRUCTION CRANE UNDERTAKEN, CRANE OPERATOR AND CO-WORKER ON THE GROUND KILLED WHEN CRANE FELL (FIRST DEPT))/LABOR LAW-CONSTRUCTION LAW  (MULTI-MILLION DOLLAR VERDICTS AGAINST THE OWNER PERSONALLY AND HIS COMPANIES WARRANTED, WORKER SAFETY DISREGARDED WHEN REPAIR TO CONSTRUCTION CRANE UNDERTAKEN, CRANE OPERATOR AND CO-WORKER ON THE GROUND KILLED WHEN CRANE FELL (FIRST DEPT))

IN THIS LABOR LAW 240 (1) ACTION, PLAINTIFF SLIPPED AND FELL FROM A GREASY RAMP HE CONSTRUCTED FROM PLANKS, THERE WAS A QUESTION OF FACT WHETHER PLAINTIFF’S CONDUCT WAS THE SOLE PROXIMATE CAUSE OF HIS INJURIES (CT APP).

The Court of Appeals, reversing the appellate division, determined there was a question of fact whether plaintiff’s own conduct was the sole proximate cause of his injuries. Plaintiff had constructed a ramp out of greasy planks to move from the roof to a scaffold. Plaintiff slipped and fell from the ramp:

We agree with the Appellate Division that the fall of … plaintiff was the result of an elevation-related risk for which Labor Law § 240 (1) provides protection. We further conclude, however, that there is a triable issue of fact whether plaintiff’s “own conduct, rather than any violation of Labor Law § 240 (1), was the sole proximate cause of the accident” … . Viewing the facts in the light most favorable to defendants, as we must … , we conclude that plaintiff’s foreman arguably provided conflicting accounts of whether plaintiff had “adequate safety devices available,” whether “he knew both that they were available and that he was expected to use them,” whether “he chose for no good reason not to do so,” and whether “had he not made that choice he would not have been injured” … . Valente v Lend Lease (US) Constr. LMB, Inc., 2017 NY Slip Op 06400, CtApp 9-5-17

LABOR LAW-CONSTRUCTION LAW (IN THIS LABOR LAW 240 (1) ACTION PLAINTIFF SLIPPED AND FELL FROM A GREASY RAMP HE CONSTRUCTED FROM PLANKS, THERE WAS A QUESTION OF FACT WHETHER PLAINTIFF’S CONDUCT WAS THE SOLE PROXIMATE CAUSE OF HIS INJURIES (CT APP))/SOLE PROXIMATE CAUSE (LABOR LAW-CONSTRUCTION LAW, IN THIS LABOR LAW 240 (1) ACTION PLAINTIFF SLIPPED AND FELL FROM A GREASY RAMP HE CONSTRUCTED FROM PLANKS, THERE WAS A QUESTION OF FACT WHETHER PLAINTIFF’S CONDUCT WAS THE SOLE PROXIMATE CAUSE OF HIS INJURIES (CT APP))

QUESTION OF FACT WHETHER PLAINTIFF’S ACTIONS CONSTITUTED THE SOLE PROXIMATE CAUSE OF HIS INJURIES IN THIS LABOR LAW 240(1) ACTION (SECOND DEPT).

The Second Department determined there was a question of fact whether plaintiff’s actions constituted the sole proximate cause of his injuries in this Labor Law 240(1) action. Plaintiff fell after he had stacked two Baker scaffolds and a closed a-frame ladder on top of one another to install sheetrock:

… [T]he defendant raised a triable issue of fact as to whether pipe scaffolds, which were available to the plaintiff, constituted adequate protection for the work that the plaintiff was performing and, if so, whether the plaintiff, based on his training, prior practice, and common sense, knew or should have known to use pipe scaffolds instead of Baker scaffolds … . The defendant also raised a triable issue of fact as to whether the scaffolds alone were adequate for the job, thereby negating any need for the plaintiff to place a closed ladder on top of the scaffolds … . Therefore, the defendant submitted evidence that would permit a jury to find that “the plaintiff had adequate safety devices available; that he knew both that they were available and that he was expected to use them; that he chose for no good reason not to do so; and that had he not made that choice he would not have been injured” … . Nalvarte v Long Is. Univ., 2017 NY Slip Op 06183, Second Dept 8-16-17

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LABOR LAW-CONSTRUCTION LAW (QUESTION OF FACT WHETHER PLAINTIFF’S ACTIONS CONSTITUTED THE SOLE PROXIMATE CAUSE OF HIS INJURIES IN THIS LABOR LAW 240(1) ACTION (SECOND DEPT))/SOLE PROXIMATE CASE (LABOR LAW-CONSTRUCTION LAW, QUESTION OF FACT WHETHER PLAINTIFF’S ACTIONS CONSTITUTED THE SOLE PROXIMATE CAUSE OF HIS INJURIES IN THIS LABOR LAW 240(1) ACTION (SECOND DEPT))

PLAINTIFF’S STEPPING ON AN UNSECURED PLANK HE HAD JUST PLACED, RATHER THAN AN AVAILABLE SECURED PLANK, CONSTITUTED THE SOLE PROXIMATE CAUSE OF HIS FALL, DEFENDANTS’ PROPERLY GRANTED SUMMARY JUDGMENT ON THE LABOR LAW 240(1) CAUSE OF ACTION (SECOND DEPT).

The Second Department determined defendants were entitled to summary judgment dismissing plaintiff’s Labor Law 240(1) cause of action. Plaintiff was constructing a scaffold floor by laying planks. He fell when he stepped on an unsecured plank he had just put down, instead of an available secured plank. Therefore plaintiff’s action was the sole proximate cause of his fall:

To succeed on a cause of action alleging a violation of Labor Law § 240(1), a plaintiff must demonstrate that there was a violation of the statute and that the violation was a proximate cause of the accident … . Where the plaintiff is the sole proximate cause of his or her own injuries, there can be no recovery under Labor Law § 240(1)… . Here, the defendants established their prima facie entitlement to judgment as a matter of law dismissing the Labor Law § 240(1) cause of action by demonstrating that the plaintiff was the sole proximate cause of the accident that caused his alleged injuries, since he chose to step upon an unsecured plank that he had just seconds before placed on a narrow steel beam, rather than standing upon the secured planking available to him, which he had used in the minutes leading up to the accident. Melendez v 778 Park Ave. Bldg. Corp., 2017 NY Slip Op 06175, Second Dept 8-16-17

LABOR LAW-CONSTRUCTION LAW (SOLE PROXIMATE CAUSE, PLAINTIFF’S STEPPING ON AN UNSECURED PLANK HE HAD JUST PLACED, RATHER THAN AN AVAILABLE SECURED PLANK, CONSTITUTED THE SOLE PROXIMATE CAUSE OF HIS FALL, DEFENDANTS’ PROPERLY GRANTED SUMMARY JUDGMENT ON THE LABOR LAW 240(1) CAUSE OF ACTION (SECOND DEPT))/SOLE PROXIMATE CAUSE (LABOR LAW-CONSTRUCTION LAW, PLAINTIFF’S STEPPING ON AN UNSECURED PLANK HE HAD JUST PLACED, RATHER THAN AN AVAILABLE SECURED PLANK, CONSTITUTED THE SOLE PROXIMATE CAUSE OF HIS FALL, DEFENDANTS’ PROPERLY GRANTED SUMMARY JUDGMENT ON THE LABOR LAW 240(1) CAUSE OF ACTION (SECOND DEPT))

CONSTRUCTION MANAGER DID NOT EXERCISE SUFFICIENT CONTROL TO BE LIABLE UNDER LABOR LAW 240(1) (SECOND DEPT).

The Second Department determined plaintiff’s Labor Law 240(1) cause of action against the construction manager was properly dismissed. Plaintiff fell from a ten-foot-high stack of blasting mats. The construction manager demonstrated it did not exercise supervisory control over plaintiff’s work or site safety:

A construction manager of a work site is generally not responsible for injuries under Labor Law § 200, § 240(1), or § 241(6) unless it functions as an agent of the property owner or general contractor in circumstances where it has the ability to control the activity which brought about the injury …  “A party is deemed to be an agent of an owner or general contractor under the Labor Law when it has supervisory control and authority over the work being done where a plaintiff is injured”… . An agent’s liability is limited “to those areas and activities within the scope of the work delegated or, in other words, to the particular agency created” … .

Here, the construction management services contract … provided that the defendants were responsible for coordinating the work relating to the … project, namely liaising with contractors to ensure that the project was completed in accordance with cost, time, safety, and quality control requirements and reporting … . However, the contract did not confer upon the defendants the authority to control the methods used by the contractors, including the plaintiff’s employer, to complete their work. The defendants were authorized only to review and monitor safety programs and requirements and make recommendations, provide direction to contractors regarding corrective action to be taken if an unsafe condition was detected, and stop work only in the event of an emergency. The parties’ deposition testimony also demonstrated that the defendants did not have control or a supervisory role over the plaintiff’s day-to-day work and that they did not assume responsibility for the manner in which that work was conducted. Lamar v Hill Intl., Inc., 2017 NY Slip Op 06167, Second Dept 8-16-17

 

LABOR LAW-CONSTRUCTION LAW (CONSTRUCTION MANAGER DID NOT EXERCISE SUFFICIENT CONTROL TO BE LIABLE UNDER LABOR LAW 240(1) (SECOND DEPT))CONSTRUCTION MANAGER (LABOR LAW-CONSTRUCTION LAW, CONSTRUCTION MANAGER DID NOT EXERCISE SUFFICIENT CONTROL TO BE LIABLE UNDER LABOR LAW 240(1) (SECOND DEPT))

LABOR LAW 240(1) NOT APPLICABLE TO INJURY FROM A PORTION OF A FENCE WHICH FELL ON PLAINTIFF (SECOND DEPT).

The Second Department determined defendant property owner was entitled to summary judgment dismissing the Labor Law 240(1) cause of action. Plaintiff alleged a portion of a plywood fence around the work site fell on him. The “falling object” provisions of the Labor Law 240(1) did not apply:

To prevail on a cause of action pursuant to section 240(1) in a ” falling object’ case, the injured worker must demonstrate the existence of a hazard contemplated under that statute and the failure to use, or the inadequacy of, a safety device of the kind enumerated therein'”… . This requires a showing that at the time the object fell, it either was being hoisted or secured, or required securing for the purposes of the undertaking … . Labor Law § 240(1) “does not automatically apply simply because an object fell and injured a worker” … . In support of their cross motion, the defendants made a prima facie showing of their entitlement to summary judgment dismissing the Labor Law § 240(1) cause of action by demonstrating that the plywood fence was not an object being hoisted or that required securing for the purpose of the undertaking, and that it did not fall because of the absence or inadequacy of an enumerated safety device … . Berman-Rey v Gomez, 2017 NY Slip Op 06151, 2nd Dept 8-16-17

LABOR LAW-CONSTRUCTION LAW (LABOR LAW 240(1) NOT APPLICABLE TO INJURY FROM A PORTION OF A FENCE WHICH FELL ON PLAINTIFF (SECOND DEPT))/FALLING OBJECTS (LABOR LAW-CONSTRUCTION LAW, LABOR LAW 240(1) NOT APPLICABLE TO INJURY FROM A PORTION OF A FENCE WHICH FELL ON PLAINTIFF (SECOND DEPT))

LABOR LAW 200 CAUSE OF ACTION SHOULD NOT HAVE BEEN DISMISSED, QUESTION OF FACT WHETHER DEFENDANT EXERCISED SUFFICIENT CONTROL OVER THE MEANS AND METHODS OF PLAINTIFF’S WORK (SECOND DEPT).

The Second Department, reversing Supreme Court, determined plaintiff’s Labor Law 200 cause of action should not have been dismissed as there was a question of fact whether defendant (Plaza) had the authority to control the means and methods of plaintiff’s work at the site. The scaffold on which plaintiff was standing tipped when a wheel went into a space in the floor created by the removal of a tile by an electrical contractor who was installing wiring beneath the floor:

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Where, as here, a claim arises out of the means and methods of the work, a defendant may be held liable for common-law negligence or a violation of Labor Law § 200 “only if he or she had the authority to supervise or control the performance of the work'” … . “A defendant has the authority to supervise or control the work for purposes of Labor Law § 200 when that defendant bears the responsibility for the manner in which the work is performed” … .

Here, the defendants failed to establish, prima facie, that Plaza did not have the authority to exercise supervision and control over the subject work. The defendants’ submissions demonstrated that Plaza, as the construction manager, had a project superintendent at the work site on a daily basis who was responsible for job coordination and safety supervision. Plaza had the authority to stop work if a particular activity or condition was unsafe, and to regulate which workers and equipment were allowed in particular areas of the work site. Moreover, Plaza’s project superintendent held weekly meetings with every subcontractor. Although the superintendent testified at his deposition that he gave directions to the subcontractors’ supervisors, rather than to the workers themselves, he could tell a supervisor to immediately relay a safety-related instruction to a worker at any given time. Under these circumstances, the defendants’ submissions failed to eliminate all triable issues of fact as to whether Plaza was acting as the general contractor and had the authority to supervise and control the manner in which the plaintiff performed his work … . Caban v Plaza Constr. Corp., 2017 NY Slip Op 05931, Second Dept 8-2-17

 

LABOR LAW-CONSTRUCTION LAW (LABOR LAW 200 CAUSE OF ACTION SHOULD NOT HAVE BEEN DISMISSED, QUESTION OF FACT WHETHER DEFENDANT EXERCISED SUFFICIENT CONTROL OVER THE MEANS AND METHODS OF PLAINTIFF’S WORK (SECOND DEPT))/MEANS AND METHODS OF WORK (LABOR LAW-CONSTRUCTION LAW, LABOR LAW 200 CAUSE OF ACTION SHOULD NOT HAVE BEEN DISMISSED, QUESTION OF FACT WHETHER DEFENDANT EXERCISED SUFFICIENT CONTROL OVER THE MEANS AND METHODS OF PLAINTIFF’S WORK (SECOND DEPT))

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