FILED: NEW YORK COUNTY CLERK 10/29/ :02 PM INDEX NO /2017 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 10/29/2018 EXHIBIT "B"

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1 EXHIBIT "B"

2 NYSCEF. DOC. NO. 73. RECEIVED NYSCEF: 10/29/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X JAMES A. GIBSON, JR., Index No.: /2017 Plaintiff, - against - ANSWER TO VERIFIED LIC DEVELOPMENT OWNER, L.P., COMPLAINT LIC DEVELOPMENT, L.P. TURNER CONSTRUCTION COMPANY, Defendants X Defendants, LIC DEVELOPMENT OWNER, L.P. i/s/h/a LIC DEVELOPMENT OWNER, L.P. LIC DEVELOPMENT, L.P. ("LIC"), TURNER CONSTRUCTION COMPANY ("TURNER") (collectively "Defendants" or "Answering Defendants"), by their attorneys, CULLEN AND DYKMAN LLP, as for their Verified Answer to the Verified Complaint, allege, upon information belief, as follows: AS AND FOR AN ANSWER TO THE FIRST CAUSE OF ACTION FIRST: LIC denies knowledge or information sufficient to form a belief as to the truth to the allegations contained in paragraphs "1" "3" of Plaintiff's Verified Complaint. TURNER denies knowledge or information sufficient to form a belief as to the truth to the allegations contained in paragraphs "1" "3" of Plaintiff's Verified Complaint. SECOND: LIC denies each every allegation contained in paragraph "2" of the Plaintiff's Verified Complaint, except admits that it was still is a foreign limited partnership authorized to do business in the State of New York. TURNER denies knowledge or information sufficient to form a belief as to the truth to the allegations contained in paragraph "2" of Plaintiff's Verified Complaint. ( DOC}

3 THIRD: LIC denies knowledge or information sufficient to form a belief as to the truth to the allegations contained in paragraph "4" of Plaintiff's Verified Complaint. TURNER denies each every allegation contained in paragraph "4" of the Plaintiff's Verified Complaint, except admits that it was still is a domestic business corporation organized in existence under by virtue of the laws of the State of New York. FOURTH: LIC denies each every allegation contained in paragraph "5" of the Plaintiff's Verified Complaint, except admits that it had an ownership interest in the property located at Jackson Avenue, Long Isl City, New York (the "Premises"). TURNER denies knowledge or information sufficient to form a belief as to the truth to the allegations contained in paragraph "5" of Plaintiff's Verified Complaint. FIFTH: LIC denies each every allegation contained in paragraphs "6", "7", "8", "9", "10", "11", "12", "14" "15" of the Plaintiff's Verified Complaint. TURNER denies knowledge or information sufficient to form a belief as to the truth to the allegations contained in paragraphs "6", "7", "8", "9", "10", "11", "12", "14" "15" of Plaintiff's Verified Complaint. SIXTH: LIC denies each every allegation contained in paragraphs "13" "16" of the Plaintiff's Verified Complaint except admits that it agreed for certain work to be performed, limited in scope duration, at the Premises refers all questions of law to the Court for determination. TURNER denies knowledge or information sufficient to form a belief as to the truth to the allegations contained in paragraphs "13" "16" of Plaintiff's Verified Complaint refers all questions of law to the Court for determination. SEVENTH: LIC denies knowledge or information sufficient to form a belief as to the truth to the allegations contained in paragraphs "17", "18", "19", "20", "21", "22", ( DOC}

4 "23", "24", "25", "26", "27" "28" of Plaintiff's Verified Complaint. TURNER denies knowledge or information sufficient to form a belief as to the truth to the allegations contained in paragraphs "17", "18", "19", "20", "21", "22", "23", "24", "25", "26", "27" "28" of Plaintiff's Verified Complaint. EIGHTH: LIC denies knowledge or information sufficient to form a belief as to the truth to the allegations contained in paragraph "29" of Plaintiff's Verified Complaint. TURNER denies each every allegation contained in paragraph "29" of the Plaintiff's Verified Complaint. NINTH: LIC denies knowledge or information sufficient to form a belief as to the truth to the allegations contained in paragraphs "30", "31", "32", "33" "36" of Plaintiff's Verified Complaint refers all questions of law to the Court for determination. TURNER denies each every allegation contained in paragraphs "30", "31", "32", "33" "36" of the Plaintiff's Verified Complaint, except admits that it agreed to perform certain work, limited in scope duration, at the Premises refers all questions of law to the Court for determination. TENTH: LIC denies knowledge or information sufficient to form a belief as to the truth to the allegations contained in paragraphs "34", "35" "39" of Plaintiff's Verified Complaint. TURNER denies each every allegation contained in paragraphs "34", "35" "39" of the Plaintiff's Verified Complaint. ELEVENTH: LIC denies knowledge or information sufficient to form a belief as to the truth to the allegations contained in paragraphs "37", "38" "40" of Plaintiff's Verified Complaint refers all questions of law to the Court for determination. TURNER denies each every allegation contained in paragraphs "37", "38" "40" of the Plaintiff's ( DOC)

5 Verified Complaint, except admits that it contracted with subcontractors for work to be performed at the Premises refers all questions of law to the Court for determination. TWELFTH: LIC denies each every allegation contained in paragraphs "41", "42", "43" "45" of Plaintiff's Verified Complaint. TURNER denies each every allegation contained in paragraphs "41", "42", "43" "45" of Plaintiff's Verified Complaint. THIRTEENTH: LIC denies each every allegation contained in paragraph "44" of Plaintiff's Verified Coraplaint refers all questions of law to the Court for determination. TURNER denies each every allegation contained in paragraph "44" of Plaintiff's Verified Complaint refers all questions of law to the Court for determination. AS AND FOR AN ANSWER TO THE SECOND CAUSE OF ACTION FOURTEENTH: With respect to the reallegations coñtaiñêd in paragraph "46" of the Verified Complaint, Defendants repeat, reiterate reallege each every above denial other response to the allegations contained in paragraphs "1" to "45" of Plaintiff's Verified Complaint as if fully set forth herein. FIFTEENTH: LIC denies each every allegation contained in paragraph "47" of Plaintiff's Verified Complaint refers all questions of law to the Court for determination. TURNER denies each every allegation contained in paragraph "47" of Plaintiff's Verified Complaint refers all questions of law to the Court for determination. SIXTEENTH: LIC denies each every allegation contained in paragraph "48" of Plaintiff's Verified Complaint TURNER denies each every allegation contained in paragraph "48" of Plaintiff's Verified Complaint. (003)3291DOC}

6 NYSCEF DOC. NO RECEIVED NYSCEF:. 10/29/2018 AS A_ND FOR AN ANSWER TO THE THIRD CAUSE OF ACTION SEVENTEENTH: With respect to the reallegations contained in paragraph "49" of the Verified Complaint3 Defendants repeat, reiterate reallege each every above denial other response to the allegations contained in paragraphs "1" to "48" of Plaintiff's Verified Complaint as if fully set forth herein. EIGHTEENTH: LIC denies each every allegation contained in paragraph "50" of Plaintiff's Verified Complaint refers all questions of law to the Court for determination. TURNER denies each every allegation contained in paragraph "50" of Plaintiff's Verified Complaint refers all questions of law to the Court for determiñation. NINETEENTH: LIC denies each every allegation contained in paragraph "51" of Plaintiff's Verified Complaiñt. TURNER denies each every allegation contained in paragraph "51" of Plaintiff's Verified Complaint. AS AND FOR AN ANSWER TO THE FOURTH CAUSE OF ACTION TWENTIETH: With respect to the reallegations contained in paragraph "52" of the Verified Complaint, Defendants repeat, reiterate reallege each every above denial other response to the allegations contained in paragraphs "1" to "51" of Plaintiff's Verified Complaint as if fully set forth herein. TWENTY-FIRST: LIC denies each every allegation contained in paragraph "53" of Plaintiff's Verified Complaint refers all questions of law to the Court for determination. TURNER denies each every allegation contained in paragraph "53" of Plaintiff's Verified Complaint refers all questions of law to the Court for determination. ( DOC}

7 TWENTY-SECOND: LIC denies each every allegation contained in paragraph "54" of Plaintiff's Verified Complaint. TURNER denies each every allegation contaiñed in paragraph "54" of Plaintiff's Verified Complaint. AS AND FOR A FIRST AFFIRMATIVE DEFENSE TWENTY-THIRD: Whatever injuries /or damages Plaintiff may have sustained at the time place mentioned in Plaintiff's Verified Complaint /or as a result of the occurrence alleged in Plaintiff's Verified Complaint, all of which are denied by the Answering Defender-ts were caused in whole or in part by the culpable conduct of Plaintiff. The amount of dainages recovered, if any, shall therefore be diminished in the proportion which is culpable conduct, attributable to Plaintiff, bears to the culpable conduct which caused said injuries. AS AND FOR A SECOND AFFIRMATIVE DEFENSE TWENTY-FOURTH: Each risk danger of loss or damage connected with the situation alleged in Plaintiff's Verified Compkint were at the time place mentioned obvious apparent were known by Plaintiff voluntarily assumed by Plaintiff. AS AND FOR A THIRD AFFIRMATIVE DEFENSE TWENTY-FIFTH: The injuries damages alleged were caused by the culpable conduct of some third person or persons over whom the Answering Defendants neither had nor exercised control. AS AND FOR A FOURTH AFFIRMATIVE DEFENSE TWENTY-SIXTH: The liability of the Answering Defendants is limited by the provisions of Article 16 of the Civil Practice Law Rules. [ DOC]

8 AS AND FOR A FIFTH AFFIRMATIVE DEFENSE TWENTY-SEVENTH: Plaintiff failed to mitigate Plaintiff s damages, AS AND FOR A SIXTH AFFIRMATIVE DEFENSE TWENTY-EIGHTH: Any verdict, judgemeñt or decision that might be obtained by Plaintiff against the Answering Defendants shall be reduced by the amount of any collateral source payments received by Plaintiff pursuant to CPLR 4545(c), as determined by the Court. AS AND FOR A SEVENTH AFFIRMATIVE DEFENSE TWENTY-NINTH: The negligence of those responsible for the accident or the occurrence alleged in Plaintiff s Verified Complaint constituted a separate, independent, superseding, intervening culpable act or acts which constitute the sole proximate cause of the accident or occurrence alleged. AS AND FOR AN EIGHTH AFFIRMATIVE DEFENSE THIRTIETH: Plaintiff was the sole proximate cause of any injuries /or damages Plaintiff may have sustained at the time place mentioned in Plaintiff s Verified Complaint /or as a result of the occurrence alleged in Plaintiff s Verified Complaiñt, all of which are denied by Answering Defendants. AS AND FOR A NINTH AFFIRMATIVE DEFENSE THIRTY-FIRST: To the extent that Plaintiff asserts claims against Answering Defendants arising under Section 241(6) of the New York Labor Law, such claims must be dismissed because no applicable rules or regulations were violated by Answering Defendants. AS AND FOR A TENTH AFFIRMATIVE DEFENSE THIRTY-SECOND: Plaintiff s claims are barred by assumption of risk. ( DOCJ

9 .... FILED: NEW YORK COUNTY CLERK 10/29/ :02 PM INDEX NO /2017 NYSCEF. DOC. NO RECEIVED. NYSCEF:. 10/29/2018 AS AND FOR AN ELEVENTH AFFIRMATIVE DEFENSE THIRTY-THIRD: Where Plaintiff disregarded warnings, safety measures training, insofar as Plaintiff was a recalcitrant worker whose conduct caused /or contributed to the alleged damages or injuries, Plaintiff's recoverable damages must be reduced in proportion to which the culpable conduct, attributable to Plaintiff, bears to the culpable conduct which caused said injuries. AS AND FOR A TWELFTH AFFIRMATIVE DEFENSE THIRTY-FOURTH: Plaintiff failed to take reasonable /or adequate steps precautions for his own safety. AS AND FOR A THIRTEENTH AFFIRMATIVE DEFENSE THIRTY-FIFTH: Plaintiffs speculative, uncertain /or contingent damages have not accrued are not recoverable. AS AND FOR A FOURTEENTH AFFIRMATIVE DEFENSE THIRTY-SIXTH: The alleged injuries /or damages complaiñed of were not proximately caused by any negligence or culpable conduct on the part of Answering Defendants, its agents or employees /or predated the accident alleged in Plaintiff's Verified Complaint. AS AND FOR A FIFTEENTH AFFIRMATIVE DEFENSE THIRTY-SEVENTH:Plaintiffs claims against Answering Defendants must be dismissed because no applicable statutes, laws, rules or regulations were violated by Answering Defendants. AS AND FOR A SIXTEENTH AFFIRMATIVE DEFENSE THIRTY-EIGHTH: Pursuant to Section 1411 of the New York Civil Practice Law Rules, the amount of damages, if any, recoverable by Plaintiff must be diminished in ( DOC)

10 the proportion to which the allegedly injured Plaintiff's negligence, assumption of risk /or other culpable conduct bears to the overall culpable conduct that caused the damages. AS AND FOR A SEVENTEENTH AFFIRMATIVE DEFENSE THIRTY-NINTH: The Answering Defendants are not liable to the Plaintiff to the extent that the Answering Defendants did not have sufficient control over the allegedly injury-producing work. AS AND FOR AN ElGHTEENTH AFFIRMATIVE DEFENSE FORTIETH: Answering Defendants are not liable to the Plaintiff to the extent that Defendants did not have sufficient control over the allegedly injury-producing work. AS AND FOR A NINETEENTH AFFIRMATIVE DEFENSE FORTY-FIRST: To the extent Plaintiff asserts claims that are inconsistent /or contradict each other, such claims are barred. AS AND FOR A TWENTIETH AFFIRMATIVE DEFENSE FORTY-SECOND: Answering Defenderts did not create any defect or unsafe condition on the property at issue. AS AND FOR A TWENTY-FIRST AFFIRMATIVE DEFENSE FORTY-THIRD: Answering Defendants did not have actual notice or constructive notice of any defect /or unsafe condition on the property at issue. AS AND FOR A TWENTY-SECOND A.FFIRMATIVE DEFENSE FORTY-FOURTH: To the extent Answering Defendants are found to have actual or constructive notice of any defect or unsafe condition on the property at issue, Answering Defendants did not have the opportunity prior to the time of Plaintiff's claimed ( DOC}

11 injury to remediate or ameliorate any such defect /or unsafe condition on the property at issue before Plaintiff's claimed injuries occurred. AS AND FOR A TWENTY-THIRD AFFIRMATIVE DEFENSE FORTY-FIFTH: To the extent Plaintiff was hired to mitigate, remediate /or eliminate the same hazard that Plaintiff claims caused the alleged injuries, Plaintiff cannot recover from the injuries caused by the same hazard. AS AND FOR A TWENTY-FOURTH AFFIRMATIVE DEFENSE FORTY-SIXTH: Any recovery by Plaintiff for the injuries alleged is barred in whole or in part by the allegedly injured Plaintiff's failure to use appropriate safety devices made available to him.. AS AND FOR A TWENTY-FIFTH AFFIRMATIVE DEFENSE FORTY-SEVENTH: At all times during the conduct of their operations, the agents, servants, /or employees of Answering Defendants used proper methods in the conduct of their operations, in conformity with the available scientific industrial knowledge. AS AND FOR A TWENTY-SIXTH AFFIRMATIVE DEFENSE FORTY-EIGHTH: To the extent that Plaintiff asserts claims against the Answering Defendants arising under Section 241(6) of the New York Labor Law, such claims must be dismissed because any alleged violations of any regulations set forth in the Verified Complaint did not proximately cause the injuries alleged by Plaintiff. AS AND FOR A TWENTY-SEVENTH AFFIRMATIVE DEFENSE FORTY-NINTH: Answering Defendants did not direct or control the site, the work, safety or personal protective equipment ("PPE") for Plaintiff. Answering Defendants ( DOC)

12 NYSCEF DOC. NO RECEIVED NYSCEF:. 10/29/2018 did not possess the authority to direct, supervise or control the activity that resulted in Plaintiff's alleged injury. Answering Defeñdañts did not control the manner or methods by which Plaintiff performed his work. AS AND FOR A TWENTY-EIGHTH AFFIRMATIVE DEFENSE FIFTIETH: Answering Defeñdañts have at all times acted in good faith, reasonably, with due care in a prudent manner, in accordance with all applicable laws. AS AND FOR A T_WENTY-NINTH AFFIRMATIVE DEFENSE FIFTY-FIRST: Plaintiff's claims are barred, in whole or in part, because Answering Defendants did not owe any legal duty to Plaintiff, or if they owed a legal duty to Plaintiff, they did not breach that duty. AS AND FOR A THIRTIETH AFFIRMATIVE DEFENSE FIFTY-SECOND: To the extent that Plaintiff was not directly employed by Answering Defendants, Plaintiff was not under Answering Defendants' supervision, direction or control. AS AND FOR A THIRTY-FIRST AFFIRMATIVE DEFENSE FIFTY-THIRD: To the extent that Plaintiff asserts claims against Answering Defendants arising under Section 200 of the New York Labor Law, such claims must be dismissed because Answering Defendants did not owe any duty to the allegedly injured Plaintiff. ( DOC)

13 AS AND FOR A THIRTY-SECOND AFFIRMATIVE DEFENSE FIFTY-FOURTH: To the extent that Plaintiff asserts claims against Answering Defendants arising under Section 240 of the New York Labor Law, such claims must be dismissed because Answering Defendants did not exercise supervision control over the activities alleged to have caused Plaintiff's injuries. AS AND FOR A THIRTY-THIRD AFFIRMATIVE DEFENSE FIFTY-FIFTH: To the extent that Plaintiff asserts claims against Answering Defendants under Section 241 of the New York Labor Law, such claims must be dismissed because no action or inaction on Answering Defendants' part was or could be the proximate cause of the injuries alleged by Plaintiff. AS AND FOR A THIRTY-FOURTH AFFIRMATIVE DEFENSIC FIFTY-SIXTH: That pursuant to 1401 of the CPLR, the Answering Defendants are entitled to a General Obligations Law set-off to the extent that a release or a covenant not to sue or not to enforce a judgcmcñt was given to one or more persons liable, or claimed to be liable, for the plaintiff's alleged injury, the Answering Defendants are entitled to a reduction of the claim by the plaintiff/releaser against other tortfeasors to the extent of any amount stipulated by or in the release or the covenant, or in the amount of the consideration paid for it, or in the amount of the released tortfeasor's equitable share of the damage, whichever is greater. AS AND FOR A THIRTY-FIFTH AFFIRMATIVE DEFENSE FIFTY-SEVENTH: Service of the Summons Complaint in this matter was not accomplished in the proper designated manner set forth in the Civil Practice Law {O DOC)

14 Rules therefore the Court has not obtained personal jurisdiction over these Answering Defendants. AS AND FOR A THIRTY-SIXTH AFFIRMATIVE DEFENSE FIFTY-EIGHTH: The Verified Complaint fails to state a cause of action. AS AND FOR A THIR_TY-SEVENTH AFFIRMATIVE DEFENSE FIFTY-NINTH: The claims alleged in the Verified Complaint are barred by the doctrine of res judicata. AS AND FQR A THIRTY-EIGHTH AFFIRMATIVE DEFENSE SIXTIETH: The claims alleged in the Verified Complaint are barred by the doctrine of collateral estoppel. SIXTY-FIRST: Añsweriñg Defendants give notice that they intend to rely upon any other defenses that may become available or appear during the discovery proceedings in this case hereby reserve their right to amend their Answer to assert any such defenses. WHEREFORE, Defendants LIC DEVELOPMENT OWNER, L.P., TURNER CONSTRUCTION COMPANY dem judgment dismissing the Plaintiff's Verified Complaint, together with the costs disbursements of this action such other further relief as the court deems just proper. Dated: New York, New York April 28, 2017 (O DOC)

15 CtJLLEN A D DYKMAN LLP John arfing, Esq. rneys for Defendants LIC DEVELOPMENT OWNER, L.P. i/s/h/a LIC DEVELOPMENT OWNER, L.P. LIC DEVELOPMENT, L.P. TURNER CONSTRUCTION COMPANY 44 Wall Street New York, New York File #: TO: JASPER & JASPER Harvey M. Jasper, Esq. Attorneys for Plaintiff JAMES A. GIBSON, JR. 299 Broadway, Suite 1818 New York, New York ( l DOC)

16 ATTORNEY'S VERIFICATION JOHN SPARLING, an attorney duly admitted to practice in the Courts of the State of New York, hereby affirms the following to be true under the penalty of perjury: That I am a member of the firm of Cullen Dykman LLP, the attorneys for Defendant, LIC DEVELOPMENT OWNER, L.P., in the within action as such, I am fully familiar with the facts circumstances surrounding this matter based upon my review of the contents of the file maintained by this office. That I have read the foregoing VERIFIED ANSWER know the contents thereof; that the same is true to my knowledge except as to the matters therein stated to be alleged upon information belief,, as to those matters, I believe them to be true. That the reason this verification is made by your affirmant not by Defendant, LIC DEVELOPMENT OWNER, L.P., is that Defendant is a foreign limited partnership does not have offices within the county in which my office is maintained. That the grounds for your affirmant's belief as to all matters not stated upon my own knowledge are as follows: facts, investigations, reports, documents contained in Defendant's file maintained by your affirmant's office. Dated: New York, New York April 28, 2017 OHN PARLING, ESQ. ( DOC)

17 CORPORATE VERIFICATION STATE OF NEW YORK } COUNTY OF NEW YORK } } ss.: JOSEPH R. BYRNE, being duly sworn, states as follows: Deponent is the VP & Sr. Operations Manager of TURNER CONSTRUCTION COMPANY, a defendant in the within action. Deponent has read the foregoing Verified Answer to the Verified Complaint knows the contents thereof to be true based on deponent's own knowledge, except as to the matters stated to be alleged upon information belief, as to those matters, deponent believes them to be true. The grounds of deponent's belief as to all matters not stated upon deponent's knowledge are information contained in the files of TURNER CONSTRUCTION COMPANY /or conversations with its employees. J. BYRNE Sworn to before me this day of, 2017 Barbara J Razzo, ÂÂnx2d & g/ Notary Public- State of NewYork No, Notc ''Publ 01RA c.. Quallfledin SuffolkCounty MyCommlesion ExpiresJuly22,2017 { DOC)

18 .... SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X JAMES A. GlBSON, JR., Index No: /2017 Plaintiff, - against - SUBPOENA AD TESTIFICANDUM LIC DEVELOPMENT OWNER, L.P., AND DUCES TECUM LIC DEVELOPMENT, L.P. TURNER CONSTRUCTION COMPANY, X Defendants. To: James Gibson, Sr. C/O Gibson Complete Lscaping & Design 43 Stanton Blvd. Uniondale, NY GREETINGS: WE COMMAND YOU, that all business excuses being laid aside you appear attend before Cullen Dykman LLP, 44 Wall Street, 15th Floor, New York, New York 10005, on the 25th day qf September, 2018 at 10:00 A.M. at any adjourned date, to be examined under oath, upon oral questions, on all matters relevant to the above-captioned action. You are directed to bring with you at the aforesaid time place all work records, timesheets, payroll records, photographs any other documentation you possess pertaining to any work performed by James Gibson, Jr, for Gibson Complete Lscaping Service & Design from May 1, 2016 through present. PLEASE TAKE FURTHER NOTICE, that pursuant to of the Uniform Rules, all depositions will be videotaped by Reynolds Court Reporting Service, 1320 Breakwater Road, Mattituck, New York ( CX}

19 ..... Failure to comply with this Subpoena is punishable as contempt of court shall make you liable on whose behalf this Subpoena was issued for a penalty not to exceed fifty dollars all darnages sustained by reason of your failure to comply. Please contact Jennessy Rivern, Esq, at orior to the date herein to schedule the deposition. Dated: New York, New York August 23, 2018 CULLEN DYKMAN LLP Jennessy Alivera, Esq. Attorneys for Defendants LIC DEVELOPMENT OWNER, L.P. i/s/h/a LIC DEVELOPMENT OWNER, L.P. LIC DEVELOPMENT, L.P. TURNER CONSTRUCTION COMPANY 150' 44 Wall Street, Floor New York, New York File #: { ,DOCX)

20 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X JAMES A. GIBSON, JR., Index No: /2017 Plaintiff, - against - NOTICE TO TAKE DEPOSITION OF LIC DEVELOPMENT OWNER, L.P., NON-PARTY WITNESS LIC DEVELOPMENT, L.P. TURNER CONSTRUCTION COMPANY, Defendants..._..._ X C O U N S E L: PLEASE TAKE NOTICE, that pursuant to Article 3 1 of the Civil Practice Law Rules ("CPLR"), the testimony, upon oral examination, of a knowledgeable witness, James Gibson, Sr. on behalf of Gibson Complete Lscaping & Design will be taken before a Notary Public who is not an attorney or ernployee of an attorney, or any party or prospective party herein, is not a person who would be disqualified to act as a juror because of interest, or because of consanguinity or affmity to any party herein, at the offices of Cullen Dykman LLP located at 44 Wall Street, 15th Floor, New York, New York 10005, commencing on September 25, 2018 at 10:00 a.m., or any recesses or adjourned date thereafter continuing day-to-day until complete. The subject matter of the examination will be as to all evidence material necessary to the prosecution defense of this action. Dated: New York, New York August 23, 2018 CULLEN AND DYKMAN LLP Jennessy ivera, Esq. Attorneys for Defendants LIC DEVELOPMENT OWNER, L.P. i/s/h/a LIC DEVELOPMENT OWNER, L,P. LIC DEVELOPMENT, L.P. TURNER ( ,DOCX)

21 ..... CONSTRUCTION COMPANY 15* 44 Wall Street, Floor New York, New York File #: TO: GROVER & FENSTERSTOCK P.C. Attorneys for Plaintiff 750 Third Avenue, Suite 900 New York, NY ( , DOCXJ

22 .... SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X JAMES A. OlBSON, JR., Index No: /2017 Plaintiff, - against - SUBPOENA AD TESTIFICANDUM LIC DEVELOPMENT OWNER, L.P., AND DUCES TECUM LIC DEVELOPMENT, L.P. TURNER CONSTRUCTION COMPANY, Defendants X To: James Gibson, Sr. C/O Gibson Complete Lscaping & Design 43 Stanton Blvd. Uniondale, NY GREETINGS: WE COMMAND YOU, that all business excuses being laid aside you appear attend before Cullen Dykman LLP, 44 Wall Street, 15th Floor, New York, New York 10005, on the 25th day of September, 2018 at 10:00 A.M. at any adjourned date, to be examined under oath, upon oral questions, on all matters relevant to the above-captioned action. You are directed to bring with you at the aforesaid time place all work records, timesheets, payroll records, photographs any other documentation you possess pertaining to any work performed by James Gibson, Jr, for Gibson Complete Lscaping Service Be Design from May 1, 2016 through present. PLEASE TAKE FURTHER NOTICE, that pursuant to of the Uniform Rules, depositions will be videotaped by Reynolds Court Reporting Service, 1320 Breakwater Road, Mattituck, New York ( ,DOCX)

23 . FILED: NEW YORK COUNTY CLERK 10/29/ :02 PM INDEX NO /2017 Failure to comply with this Subpoena is punishable as contempt of court shall make you liable on whose behalf this Subpoeña was issued for a penalty not to exceed fifty dollars all damages sustained by reason of your failure to comply. Please contact Jennessy Rivera, Esq. at prior to the date herein to schedule the deposition. Dated: New York, New York August 23, 2018 CULLEN DYKMAN LLP Jennessy A ivera, Esq. Attorneys for Defendants LIC DEVELOPMENT OWNER, L.P. i/s/h/a LIC DEVELOPMENT OWNER, L.P. LIC DEVELOPMENT, L.P, TURNER CONSTRUCTION COMPANY 15th 44 Wall Street, Floor New York, New York File #: ( DOCM)

24 AFFIDAVIT OF SERVICE STATE OF NEW YORK ) COUNTY OF NEW YORK ) : ss.: SUZETTE D. JEUDY, being duly swom, deposes says that I am not a party to this action, am over the age of eighteen reside in Kings County, New York. 23rd That on the day of August 2018 I served the within NOTICE TO TAKE NON PARTY DEPOSITION, by first-class mail, postage prepaid upon: GROVER & FENSTERS.TOCK P.C. Attorneys for Plaintiff by depositing a true copy thereof in a properly sealed wrapper at a post office depository under the exclusive eare custody of the United States Postal Service within the State of New York, addressed as follows: OROVER & FENSTERSTOCK P.C. 750 Third Avenue, Suite 900 New York, NY that being the address designated by them for that purpose upon the latest papers served by them in this action. SUZETTE D, JEUDY Sworn to before me this 23"d day of August 2018 TUSHNOVA- AN2HELlKA Commissioner f ity of NewYork NOTARY PUBLIC Cat. Filed In NewYork Coun Commission Expires on

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