FILED: NEW YORK COUNTY CLERK 05/21/ :43 PM INDEX NO /2016

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1 FILED : NEW YORK COUNTY CLERK 10 / : 18 PM) NYSCEF NYSCEF DOC. DOC. 10/13/2017 NO. NO RECEIVED NYSCEF: 05/21/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK TYRONE McGANN and MARY McGANN, Index No.: /2016 Plaintiff, 3 -against- SKYLIFT CONTRACTOR CORP., SKYLIFT MASTER RIGGERS CORP., ASRR CONSTRUCTION, LLC, THE SAPIR GROUP, LLC and MADISON AVENUE LLC, Defendants. SKYLIFT CONTRACTOR CORP. and SKYLIFT MASTER RIGGERS CORP., Third-Party Plaintiffs, V. MARINE & INDUSTRIAL SUPPLY COMPANY, INC., d/b/a MARINE & INDUSTRIAL TESTING SOLUTIONS; MARINE & INDUSTRIAL TESTING SOLUTIONS; HANES SUPPLY, INC., as successor-by-merger to and/or d/b/a PAUL'S WIRE ROPE & SLING; and PAUL'S WIRE ROPE & SLING, Third-Party Defendants. TO THE ABOVE-NAMED THIRD-PARTY DEFENDANTS: YOU ARE SUMMONED to answer the third-party complaint in this action and to serve a copy of your answer on the third-party plaintiffs' and the plaintiffs' attorneys within twenty (20) days after service of this summons, exclusive of the day of service (or within thirty (30) days after the service is complete if the summons and complaint are not personally delivered to you within the State ofnew York); and [continued on next page] 1 1 of 20

2 FILED : NEW YORK COUNTY CLERK 10 / : 18 PM) NYSCEF DOC. NO RECEIVED NYSCEF: : 05/21/ /13/2017 in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the third-party complaint. Dated: New York, New York October 12, 2017 KAUFMAN DOLOWICH & VOLUCK, LLP Attorneys for Defendants/Third-Party Plaintiffs Skylift Contractor Corp. and Skyhft Master Riggers Corp. By: Sco. lûiller 20th 40 Exchange Place, FlOOr New York, New York (212) To: MARINE & INDUSTRIAL SUPPLY COMPANY, INC. 150 Virginia Street Mobile, Alabama MARINE & INDUSTRIAL TESTING SOLUTIONS % Marine & Industrial Supply Company, Inc. 150 Virginia Street Mobile, Alabama HANES SUPPLY, INC. 55 James E Casey Drive Buffalo, New York PAUL'S WIRE ROPE & SLING % Hanes Supply, Inc. 55 James E Casey Drive Buffalo, New York , v of 20

3 FILED: NEW YORK COUNTY CLERK 10/13/ :18 PM NYSCEF DOC. DOC. NO. NO RECEIVED NYSCEF: 10/13/ /21/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK x TYRONE McGANN and MARY McGANN, Plaintiff/Petitioner, - against - Index No /2016 SKYLIFT CONTRACTOR CORP., et al x Defendant/Respondent. NOTICE OF COMMENCEMENT OF ACTION SUBJECT TO MANDATORY ELECTRONIC FILING PLEASE TAKE NOTICE that the matter captioned above has been commenced as an electronically filed case in the New York State Courts Electronic Filing System ("NYSCEF") as required by CPLR 2111 and Uniform Rule bb (mandatory electronic filing). This notice is being served as required by that rule. NYSCEF is designed for the electronic filing of documents with the County Clerk and the court and for the electronic service of those documents, court documents, and court notices upon counsel and unrepresented litigants who have consented to electronic filing. Electronic filing offers significant benefits for attorneys and litigants, permitting papers to be filed with the County Clerk and the court and served on other parties simply, conveniently, and quickly. NYSCEF case documents are filed with the County Clerk and the court by filing on the NYSCEF Website, which can be done at any time of the day or night on any day of the week. The documents are served automatically on all consenting e-filers as soon as the document is uploaded to the website, which sends out an immediate notification of the filing. The NYSCEF System charges no fees for filing, serving, or viewing the electronic case record, nor does it charge any fees to print any filed documents. Normal filing fees must be paid, but this can be done on-line. Parties represented by an attorney: An attorney representing a party who is served with this notice must either: 1) immediately record his or her representation within the e-filed matter on the NYSCEF site; or 2) file the Notice of Opt-Out form with the clerk of the court where this action is pending. Exemptions from mandatory e-filing are limited to attorneys who certify in good faith that they lack the computer hardware and/or scanner and/or internet connection or that they lack (along with all employees subject to their direction) the operational knowledge to comply with e-filing requirements. [Section bb(e)] Parties not represented by an attorney: Unrepresented litigants are exempt from e- filing. They can serve and file documents in paper form and must be served with documents in paper form. However, an unrepresented litigant may participate in e-filing. Page 1 of 2 EFM-1 3 of 20

4 FILED: NEW YORK COUNTY CLERK 10/13/ :18 PM NYSCEF DOC. NO RECEIVED NYSCEF: 10/13/ /21/2018 For information on how to participate in e-filing, unrepresented litigants should contact the appropriate clerk in the court where the action was filed or visit Unrepresented litigants also are encouraged to visit or contact the Help Center in the court where the action was filed. An unrepresented litigant who consents to e-filing may cease participation at any time. However, the other parties may continue to e-file their court documents in the case. For additional information about electronic filing and to create a NYSCEF account, visit the NYSCEF website at or contact the NYSCEF Resource Center (phone: ; efile@nycourts.gov). Dated: october 12, Exchange Place, 20th Floor Signature Address Scott E. Miller New York, New York Name Kaufman Dolowich 8 Voluck, LLP (212) Firm Name Phone smiller@kdvlaw.com --o. Third-Party Defendants Named Above 9/3/15 Index # Page 2 of 2 EFM-1 4 of 20

5 FILED : NEW YORK COUNTY CLERK 10 / : 18 PM) NYSCEF DOC. NO. NO RECEIVED NYSCEF: 10/13/ /21/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK TYRONE McGANN and MARY McGANN, Index No.: /2016 Plaintiffs, Third-Party Complaint -against- SKYLIFT CONTRACTOR CORP., SKYLIFT MASTER RIGGERS CORP., ASRR CONSTRUCTION, LLC, THE SAPIR GROUP, LLC and MADISON AVENUE LLC, Defendants. SKYLIFT CONTRACTOR CORP. and SKYLIFT MASTER IUGGERS CORP., Third-Party Plaintiff, v. MARINE & INDUSTRIAL SUPPLY COMPANY, INC., d/b/a MARINE & INDUSTRIAL TESTING SOLUTIONS; MARINE & INDUSTRIAL TESTING SOLUTIONS; HANES SUPPLY, INC., PAUL' as successor-by-merger to and/or d/b/a PAUL'S WIRE ROPE & SLING; and PAUL'S WIRE ROPE & SLING, Third-Party Defendants. Defendants/third-party plaintiffs Skylift Contractor Corp. and Skylift Master Riggers Corp. (separately and together, "Skylift"), by their attorneys Kaufman Dolowich & Voluck, LLP, as and for their third-party complaint, allege as follows, all upon information and belief: The Parties 1. At all times relevant hereto, Skylift were and still are corporations organized and existing under the laws of the State of New York. 2. At all times relevant hereto, third-party defendant Marine & Industrial Supply 1 5 of 20

6 F ILED : NEW YORK COUNTY CLERK 10 /13 / : 18 PM NYSCEF DOC. NO RECEIVED NYSCEF: 10/13/ /21/2018 Company ("M&ISC") was and still is a corporation organized and existing under the laws of the State of Alabama. 3. At all times relevant hereto, M&ISC did and continues to do business under the name Marine & Industrial Testing Solutions. 4. At all times relevant hereto, third-party defendant Marine & Industrial Testing Solutions ("M&ITS") was and still is a corporation or other business entity organized and existing under the laws of the State of Alabama. 5. At all times relevant hereto, third-party defendant Hanes Supply, Inc. ("Hanes") was and still is a corporation organized and existing under the laws of the State of New York. 6. At all times relevant hereto, third-party defendant Paul's Wire Rope & Sling ("Paul's") was a corporation organized and existing under the laws of the State of Connecticut. 7. On or about January 2, 2013, Hanes acquired the shares or equity in Paul's and became the successor-by-merger to the liabilities of Paul's. 8. On or about January 2, 2013, Paul's became an unincorporated division of Hanes and/or Hanes did business under the name Paul's Wire Rope & Sling. Jurisdiction 9. M&ISC regularly does business in the State of New York. 10. M&ISC derives substantial revenue from products used in the State of New York, or derives substantial revenue from interstate or international commerce, and expected or should reasonably have expected its tortious acts to have consequences in the State of New York. 11. M&ITS regularly does business in the State of New York. 12. M&ITS derives substantial revenue from products used in the State of New York, or derives substantial revenue from interstate or international commerce, and expected or should 2 6 of 20

7 F ILED : NEW YORK COUNTY CLERK 10 /13 / : 18 PM NYSCEF DOC. NO RECEIVED NYSCEF: 10/13/ /21/2018 reasonably have expected its tortious acts to have consequences in the State of New York. 13. Prior to January 2, 2013, Paul's derived substantial revenue from products used in the State of New York, or derived substantial revenue from interstate or international commerce, and expected or should reasonably have expected its tortious acts to have consequences in the State of New York. The Main Action 14. Plaintiffs Tyrone McGann and Mary McGann commenced the main action in the Supreme Court of the State of New York against Skylift and other defendants for personal injuries allegedly sustained by Tyrone McGann. A copy of plaintiffs' summons and complaint in the main action is annexed hereto as Exhibit A. (The action was commenced in Kings County but transferred to New York County). 15. Plaintiffs allege in that complaint that such damages were sustained when a chiller unit that Skylift and other defendants were hoisting into the building at 261 Madison Avenue, "Building" New York, New York (the "Building"), fell from the 30th floor, 16. Other defendants in the main action have or may assert cross-claims against Skylift in the main action. 17. That chiller unit fell when a sling used to rig the unit failed. 18. In their answer to the complaint, Skylift affirmatively allege that, if any injuries were sustained by the plaintiffs, such damages were caused by the negligence and culpable conduct of third-parties over whom Skylift had neither control nor responsibility. A copy of Skylift's answer is annexed hereto as Exhibit B. Product Liability Facts 19. That sling was designed, manufactured and placed into the stream of commerce 3 7 of 20

8 FILED : NEW YORK COUNTY CLERK 10 / : 18 PM) NYSCEF DOC. NO RECEIVED NYSCEF: 05/21/ /13/2017 by M&ISC. 20. That sling was designed, manufactured and placed into the stream of commerce by M&ITS. 21. That sling was distributed by Hanes. 22. That sling was distributed by Paul's. 23. M&ISC expressly and impliedly warranted and represented that the sling was suitable for rigging operations such as the one engaged in by Skylift, and was suitable for use with loads weighing greatly in excess of the chiller unit. 24. M&IST expressly and impliedly warranted and represented that the sling was suitable for rigging operations such as the one engaged in by Skylift, and was suitable for use with loads weighing greatly in excess of the chiller unit. 25. Hanes expressly and impliedly warranted and represented that the sling was suitable for rigging operations such as the one engaged in by Skylift, and was suitable for use with loads weighing greatly in excess of the chiller unit. 26. Paul's expressly and impliedly warranted and represented that the sling was suitable for rigging operations such as the one engaged in by Skylift, and was suitable for use with loads weighing greatly in excess of the chiller unit. 27. Skylift relied on those warranties and representations when using the sling to rig the chiller unit. 28. However, due to a design defect, the sling was not suitable for use with loads of the weight of the chiller unit. 29. However, due to a manufacturing defect, the sling was not suitable for use with loads of the weight of the chiller unit. 4 8 of 20

9 F ILED : NEW YORK COUNTY CLERK 10 / : 18 PM NYSCEF DOC. NO RECEIVED NYSCEF: 10/13/ /21/ However, due to the negligence of M&ITS in designing and manufacturing the sling, the sling was not suitable for use with loads of the weight of the chiller unit. 31. The accident referred to in the plaintiffs' complaint was caused by the breach of warranties and misrepresentations, negligence, defective design and/or defective manufacture and other culpable conduct of M&ISC, which is strictly liable therefore. 32. The accident referred to in the plaintiffs' complaint was caused by the breach of warranties and misrepresentations, negligence, defective design and/or defective manufacture and other culpable conduct of M&IST, which is strictly liable therefore. 33. The accident referred to in the plaintiffs' complaint was caused by the breach of warranties and misrepresentations, negligence, defective design and/or defective manufacture and other culpable conduct of Hanes, which is strictly liable therefore. 34. The accident referred to in the plaintiffs' complaint was caused by the breach of warranties and misrepresentations, negligence, defective design and/or defective manufacture and other culpable conduct of Paul's, which is strictly liable therefore. First Cause of Action Against All Third-Party Defendants (for Apportionment) 35. Skylift repeats and realleges, with the same force and effect as though fully set forth herein, every allegation contained in paragraphs "1" through "34" of this third-party complaint. 36. If the plaintiffs sustained the injuries and damages in the manner and at the time and place alleged, and if it is found that Skylift is liable to plaintiffs herein, all of which is specifically denied, then Skylift, on the basis of apportionment of responsibility for the alleged occurrence, is entitled to contribution from all third-party defendants to pay for all or part of any 5 9 of 20

10 FILED : NEW YORK COUNTY CLERK 10 / : 18 PM NYSCEF DOC. NO RECEIVED NYSCEF: 10/13/ /21/2018 verdict or judgment that plaintiff may recover against Skylift proportionate to each party's actual negligence or culpable conduct. Second Cause of Action Against All Third-Party Defendants (Contractual and Common Law Indemnification and Contribution) 37. Skylift repeats and realleges, with the same force and effect as though fully set forth herein, every allegation contained in paragraphs "1" through "36" of this third-party complaint. 38. If the plaintiffs sustained the damages in the manner and at the time and place alleged, and if it is found that Skylift is liable to plaintiffs herein, all of which is specifically denied, then Skylift is entitled to contractual and/or common law indemnification and/or contribution from any judgment or verdict rendered against it from all third-party defendants. WHEREFORE, Defendants/third-party plaintiffs Skylift Contractor Corp. and Skylift Master Riggers Corp., on the basis of apportionment of responsibility, common-law indemnification, contractual indemnification and/or contribution, demands judgment against third-party defendants Marine & Industrial Supply Company, Inc., Marine & Industrial Testing Solutions, Hanes Supply, Inc. and Paul's Wire Rope & Sling for all or part of any verdict or judgment against Skylift, together with the costs and disbursements of this action, and for such other and further relief as the Court may deem just and proper. Dated: New York, New York October 12, 2017 KAUFMAN DOLOWICH & VOLUCK, LLP Attorneys for Defendants/Third-Party Plaintiffs Skylift Contractor Corp. and Skylift Master Riggers Corp. By: Scottfl iller 6 10 of 20

11 INDEX NO /2 O16 FILED : NEW YORK COUNTY CLERK 10 / : 18 PM) NYSCEF DOC. NO RECEIVED NYSCEF: 05/21/ /13/ Exchange Place, 20* 20 Floor New York, New York (212) , v of 20

12 FILED: NEW YORK COUNTY CLERK 10/13/ :18 PM) NYSCEF DOC. NO RECEIVED NYSCEF: 05/21/ /13/2017 EXHIBIT A 12 of 20

13 F ILED : NEW YORK COUNTY CLERK 10/13 / : 18 PM NYdEiELER:. NYSCEF DOC. FoINGS NO. 58 COUNTY CLERK 06/10/ :50 AM RECEIVED NYSCEF: F 50p 05/21/2018 f 7 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/10/2016 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS TYRONE McGANN and MARY McGANN, X Plaintiff, SUMMONS -against- SKYLIFT CONTRACTOR CORP., SKYLIFT MASTER RIGGERS CORP., ASRR CONSTRUCTION, LLC, THE SAPIR GROUP, LLC and MADISON AVENUE, LLC, Defendants. ==X Plaintiffs designate Kings County as the place of trial based on Defendants' residence. To the above named Defendants: YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a copy of your Answer, or, if the Complaint is not served with this Summons, to serve a Notice of Appearance on the Plaintiff's Attorneys within 20 days after the service of this Summons, exclusive of the day of service (or within 30 days after the service is complete if this Summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded herein. Dated: June 9, 2016 Defendants' Uniondale, New York --> Addresses: / Law Office of Tho.as Tangney, By: Neil Flynn 405 RXR Plaza, Suite 405 Uniondale, New York Esq. Skylift Master Riggers Corp. ASRR Construction, LLC 170 Franklin Street The Sapir Group, LLC Brooklyn, New York Madison Avenue, LLC 261 Madison Avenue Skylift Contractor Corp. New York, New York Greenpoint Avenue Brooklyn, New York of 2 13 of 20

14 FILED: NEW YORK COUNTY CLERK 10/13/ :18 PM) NYSCEF DOC. NO RECEIVED NYSCEF: 05/21/ /13/ of 2 14 of 20

15 F ILED : NEW YORK COUNTY CLERK 10 / : 18 PM NYSCEF fll3lb. DOC. IfoINGS NO. 58 COUNTY CLERK 06/10/ :50 AM RECEIVED NYSCEF: F 05/21/2018 5É 7 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/10/2016 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS TYRONE McGANN and MARY McGANN, X Plaintiff, COMPLAINT -against- SKYLIFT CONTRACTOR CORP., SKYLIFT MASTER RIGGERS CORP., ASRR CONSTRUCTION, LLC, THE SAPIR GROUP, LLC and MADISON AVENUE, LLC, Defendants. --X Plaintiffs complain of Defendants as follows: 1. Skylift Contractor Corp. is a resident of Kings County, New York, 2. At all relevant times, Skylift Contractor Corp. was a domestic business corporation. 3. At all relevant times Skylift Master Riggers Corp. was a domestic business corporation. 4. At all relevant times, ASRR Construction, LLC was a domestic limited liability company authorized to do business in the State of New York. 5. At all relevant times, The Sapir Group, LLC was a foreign limited liability company authorized to do business in the State of New York. 6. At all relevant times, Madison Avenue, LLC was a foreign limited liability company authorized to do business in the State of New York. 7. At all relevant times, The Sapir Group, LLC owned the premises known as and located at 261 Madison Avenue, New York, New York (the premises). 8. At all relevant times, Madison Avenue, LLC owned the premises. 9. At all relevant times a construction, renovation, demolition and/or alteration work was underway at the premises. 1 of 6 15 of 20

16 FILED : NEW YORK COUNTY CLERK 10 / : 18 PM) NYSCEF DOC. NO RECEIVED NYSCEF: 05/21/ /13/ At all relevant times, ASRR Construction, LLC was the general contractor for the aforementioned work. 11. At all relevant times, ASRR Construction, LLC controlled and/or directed the aforementioned work. 12. At all relevant times, ASRR Construction, LLC contracted with Skylift Contractor Corp. to perform work at the premises. 13. At all relevant times, The Sapir Group, LLC contracted with Skylift Contractor Corp. to perform work at the premises. 14. At all relevant times, Madison Avenue, LLC contracted with Skylift Contractor Corp. to perform work at the premises. 15. At all relevant times, ASRR Construction, LLC contracted with Skylift Master Riggers Corp. to perform work at the premises. 16. At all relevant times, The Sapir Group, LLC contracted with Skylift Master Riggers Corp. to perform work at the premises. 17. At all relevant times, Madison Avenue, LLC contracted with Skylift Master Riggers Corp. to perform work at the premises. 18. At all relevant times, Skylift Contractor Corp. contracted with Skylift Master Riggers Corp. to perform work at the premises. 19. At all relevant times, Skylift Master Riggers Corp. contracted with Skylift Contractor Corp. to perform work at the premises. 20. At all relevant times, Skylift Contractor Corp. was a sub-contractor performing work at the premises. 21. At all relevant times, Skylift Master Riggers Corp. was a sub-contractor performing work 2 of 6 16 of 20

17 FILED : NEW YORK COUNTY CLERK 10 /13 / : 18 PM) NYSCEF DOC. NO RECEIVED NYSCEF: 10/13/ /21/2018 at the premises. 22. At all relevant times, ASRR Construction, LLC controlled Skylift Contractor Corp.'s work. 23. At all relevant times, ASRR Construction, LLC controlled Skylift Master Riggers Corp.'s work. 24. At all relevant times, Skylift Contractor Corp. controlled Skylift Master Riggers Corp.'s work. 25. At all relevant times, Skylift Master Riggers Corp. controlled Skylift Contractor Corp.'s work. 26. At all relevant times, The Sapir Group, LLC controlled Skylift Master Riggers Corp.'s work. 27. At all relevant times, The Sapir Group, LLC controlled Skylift Contractor Corp.'s work. 28. At all relevant times, Madison Avenue, LLC controlled Skylift Master Riggers Corp.'s work. 29. At all relevant times, Madison Avenue, LLC controlled Skylift Contractor Corp.'s work. 30. At all relevant times, Tyrone McGann was working on the project. AS AND FOR A FIRST CAUSE OF ACTION 31. Plaintiffs repeat all allegations. 32. At all relevant times, Defendants were negligent with regard to the ownership, operation, management, construction, maintenance, supervision and/or control of the premises. 33. At all relevant times, Defendants were negligent with regard to the operation, management, supervision and/or control of the work being performed at the premises. 3 of 6 17 of 20

18 FILED : NEW YORK COUNTY CLERK 10 /13 / : 18 PM) NYSCEF DOC. NO RECEIVED NYSCEF: 10/13/ /21/ At all relevant times, Defendants created and/or allowed to exist, a dangerous, hazardous and/or otherwise defective condition at the premises. 35. On May 31, 2015 Tyrone McGann was injured as a result of the aforementioned negligence. 36. Tyrone Megann's injuries were caused solely and wholly by Defendants' negligence. 37. This action falls within one or more of the exceptions set forth in Article 16 of the New York Civil Practice Law and Rules. 38. Plaintiffs' damages exceed the jurisdictional limits of all lower courts. AS AND FOR A SECOND CAUSE OF ACTION 39. Plaintiffs repeat all allegations. 40. At all relevant times, Skylift Contractor Corp. violated New York Labor Law At all relevant times, Skylift Master Riggers Corp. violated New York Labor Law At all relevant times, ASRR Construction, LLC violated New York Labor Law At all relevant times, The Sapir Group, LLC violated New York Labor Law At all relevant times, Madison Avenue, LLC violated New York Labor Law At all relevant times, Skylift Contractor Corp. violated one or more sections of the NYCRR. 46. At all relevant times, Skylift Master Riggers Corp. violated one or more sections of the NYCRR. 47. At all relevant times, ASRR Construction, LLC violated one or more sections of the NYCRR. 48. At all relevant times, The Sapir Group, LLC violated one or more sections of the 4 of 6 18 of 20

19 FILED : NEW YORK COUNTY CLERK 10 / : 18 PM) NYSCEF DOC. NO RECEIVED NYSCEF: 05/21/ /13/2017 NYCRR. 49. At all relevant times, Madison Avenue, LLC violated one or more sections of the NYCRR. 50. On May 31, 2015 Tyrone McGann was injured as a result of the aforementioned violation(s). AS AND FOR A THIRD CAUSE OF ACTION 51. Plaintiffs repeat all allegations. 52. At all relevant times, Skylift Contractor Corp. violated New York Labor Law 240(1). 53. At all relevant times, Skylift Master Riggers Corp. violated New York Labor Law 240(1). 54. At all relevant times, ASRR Construction, LLC violated New York Labor Law 240(1). 55. At all relevant times, The Sapir Group, LLC violated New York Labor Law 240(1). 56. At all relevant times, Madison Avenue, LLC violated New York Labor Law 240(1). AS AND FOR A FOURTH CAUSE OF ACTION 57. Plaintiffs repeat all allegations. 58. At all relevant times, Skylift Contractor Corp. violated New York Labor Law At all relevant times, Skylift Master Riggers Corp. violated New York Labor Law At all relevant times, ASRR Construction, LLC violated New York Labor Law At all relevant times, The Sapir Group, LLC violated New York Labor Law At all relevant times, Madison Avenue, LLC violated New York Labor Law of 6 19 of 20

20 FILED : NEW YORK COUNTY CLERK 10 / : 18 PM) NYSCEF DOC. NO RECEIVED NYSCEF: 05/21/ /13/2017 AS AND FOR A FIFTH CAUSE OF ACTION 63. Plaintiffs repeat all allegations. 64. At all relevant times, Mary McGann was married to Tyrone McGann. 65. As a result of the injuries sustained by Tyrone McGann, Mary McGann suffered a loss of her husband's consortium, society and affection and been otherwise damaged. Plaintiff demands judgment against Defendants on each of the foregoing causes of action with costs and disbursements. Dated: June 1, 2016 Uniondale, New York Law Office of Thorpds Tangney, Esq. By: Neil Flynn ' 405 RXR Plaza, Suite 405 Uniondale, New York of 6 20 of 20