Granieri v. 500 Fifth Avenue Associates
The Supreme Court, Bronx County, granted plaintiffs' motion for summary judgment on the issue of liability pursuant to Labor Law § 240 (1). The court denied defendant 500 Fifth Avenue Associates' cross-motion to amend their answer to include Workers' Compensation as an exclusive remedy and for summary judgment dismissing the complaint. The denial was based on evidence that control and supervision over the plaintiff was exercised by Newmark Real Estate, Inc., the defendant's managing agent, refuting the claim that the plaintiff was a special employee of the defendant. The court also affirmed that Labor Law § 240 (1) imposes absolute liability on the owner for injuries due to a failure to provide proper equipment, and the plaintiff's possible culpable conduct regarding ladder placement would not defeat the claim. Additionally, the court found no error in refusing to reinstate the third affirmative defense given the two-year delay in serving the verification of the bill of particulars.