FILED: NEW YORK COUNTY CLERK 11/13/ :06 PM INDEX NO /2015 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 11/13/2015

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1 FILED: NEW YORK COUNTY CLERK 11/13/ :06 PM INDEX NO /2015 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 11/13/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK NICKOL SOUTHERLAND, Plaintiff, -against- PHOENIX CONSTRUCTORS JV; FLUOS ENTERPRISES, INC.; SLATTERY SKANSKA, INC.; SKANSKA USA CIVIL NORTHEAST, INC.; BOVIS LEND LEASE LMB, INC.; GRANITE CONSTRUCTION NORTHEAST INC.; KENNETH PRIMIANO; JOE DEROSA; and, DUDLEY EISSER, Index No.: /2015 ANSWER Defendants. Defendants, PHOENIX CONSTRUCTORS JV ("Phoenix"), SLATTERY SKANSKA, INC. ("Slattery") and SKANSKA USA CIVIL NORTHEAST INC. ("Skanska")(collectively referred to herein as "Defendants") by and through their undersigned counsel, hereby respond to the allegations in Plaintiff's Complaint ("Complaint") as follows: AS TO "INTRODUCTION" 1. Defendants admit that Plaintiff purports to bring this action pursuant to the statutes and regulations cited in paragraph 1 of the Complaint, but deny that Plaintiff has stated a cause of action. 2. Defendants deny the allegations contained in paragraph 2 of the Complaint except admit that Plaintiff previously worked at the World Trade Center site in lower Manhattan as a laborer.

2 AS TO "THE PARTIES AND VENUE" 3. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 3 of the 4. Defendants deny the allegations contained in paragraph 4 of the Complaint, except admit that Phoenix Constructors JV is a joint venture consisting of Defendants Fluor Enterprises, Inc., Slattery, Bovis Lend Lease LMB, Inc. (n/k/a Lend Lease (US) Construction LMB Inc.) and Granite Halmar Construction Company, Inc. that has performed construction work at the World Trade Center site. 5. Defendants deny the allegations contained in paragraph 5 of the Complaint except admit that Defendant Phoenix's principal place of business was in New York County. 6. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of whether Defendant Fluor "is one of the world's largest publicly traded engineering, procurement, construction, maintenance, and project management companies." Defendant Phoenix admits the remaining allegations contained in paragraph 6 of the Complaint and Defendants Slattery and Skanska lack knowledge or information sufficient to form a belief as to the truth or falsity of the remaining allegations contained in paragraph 6 of the 7. Defendants deny the allegations contained in paragraph 7 of the Complaint except admit that the company which previously operated as "Slattery Skanska, Inc." is now known as "Skanska USA Civil Northeast, Inc." with a principal place of business in Queens County. 8. Defendants lack knowledge or infoimation sufficient to form a belief as to the truth or falsity of whether Skanska USA Civil Northeast, Inc. is "one of the largest domestic construction and development companies" and admit that Skanska USA Civil Northeast, Inc. is 2

3 incorporated in the State of New York and a wholly owned subsidiary of Skanska USA Civil, Inc. with a principal place of business in Queens County, New York. 9. Defendant Phoenix admits the allegations contained in paragraph 9 of the Complaint, except to note that Bovis Lend Lease LMB, Inc. is now known as Lend Lease (US) Construction LMB Inc. Defendants Slattery and Skanska lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 9 of the 10. Defendant Phoenix admits the allegations contained in paragraph 10 of the Defendants Slattery and Skanska lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 10 of the 11. No response is required because paragraph 11 does not contain any factual allegation. 12. Defendants deny the allegations contained in paragraph 12 of the Complaint, except admit Kenneth Primiano worked for Defendant Phoenix at the World Trade Center site as a labor foreman with supervisory authority over Plaintiff. 13. Defendants deny the allegations contained in paragraph 13 of the Complaint, except admit Joseph DeRosa worked for Defendant Phoenix at the World Trade Center site as a labor foreman with supervisory authority over Plaintiff. 14. Defendants deny the allegations contained in paragraph 14 of the Complaint, except admit Dudley Eisser worked for Skanska at the World Trade Center site as Superintendent with supervisory authority over Plaintiff. 15. No response is required because paragraph 15 does not contain any factual allegation. 3

4 16. Defendant Phoenix admits it is a resident of New York County. Defendants Slattery and Skanska lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 16 of the ' AS TO "FACTS RELEVANT TO ALL CLAIMS" 17. Defendants deny the allegations contained in paragraph 17 of the Complaint, except admit Plaintiff worked as a laborer at the World Trade Center site from in or around June 2006 through December 2008 when she was selected for layoff. 18. Defendants lack knowledge or information sufficient to foit n a belief as to the truth or falsity of the allegations contained in paragraph 18 of the 19. Defendants deny the allegations contained in paragraph 19 of the Complaint, except admit Plaintiff worked at Gate 3 at the World Trade Center site at some point during the term of her former employment with Defendant Phoenix. 20. Defendants deny the allegations contained in paragraph 20 of the 21. Defendants deny the allegations contained in paragraph 21 of the Complaint, except admit overtime hours were available at Gate 3 of the World Trade Center site. 22. Defendants deny the allegations contained in paragraph 22 of the 23. Defendants deny the allegations contained in paragraph 23 of the 24. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 24 of the 25. Defendants deny the allegations contained in paragraph 25 of the 4

5 26. Defendants lack knowledge or infoiivation sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 26 of the 27. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 27 of the 28. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 28 of the 29. Defendants deny the allegations contained in paragraph 29 of the Complaint, except admit laborers were constantly added to the World Trade Center site on an as needed basis. 30. Defendants deny the allegations contained in paragraph 30 of the Complaint, except admit Joseph Derosa and Giovanni Santillo commenced work at the World Trade Center site in or around Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 31 of the 32. Defendants admit the allegations contained in paragraph 32 of the 33. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 33 of the 34. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 34 of the 35. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 35 of the 36. Defendants lack knowledge or infoimation sufficient to foiiu a belief as to the truth or falsity of the allegations contained in paragraph 36 of the 5

6 37. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 37 of the 38. Defendants lack knowledge or infolmation sufficient to fotiii a belief as to the truth or falsity of the allegations contained in paragraph 38 of the 39. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 39 of the 40. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 40 of the 41. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 41 of the 42. Defendants lack knowledge or infotmation sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 42 of the 43. Defendants deny the allegations contained in paragraph 43 of the Complaint except admit Kenneth Primiano, Joseph DeRosa and Dudley Eisser, at various times during their employment with Defendant Phoenix, used the same two-way radio system as Plaintiff and Giovanni Santillo. 44. Defendants lack knowledge or infonnation sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 44 of the 45. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 45 of the 46. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 46 of the 47. Defendants deny the allegations contained in paragraph 47 of the Complaint, except admit Plaintiff did contact Dudley Eisser regarding Giovanni Santillo. 6

7 48. Defendants deny the allegations contained in paragraph 48 of the Complaint, except admit Dudley Eisser conducted an investigation after his discussion with Plaintiff about Giovanni Santillo wherein he spoke with both Kenneth Primiano and Giovanni Santillo. 49. Defendants deny the allegations contained in paragraph 49 of the Complaint, except admit Plaintiff was transferred to the West Broadway staging area due to her personality conflicts with Giovanni Santillo. 50. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 50 of the Complaint, except admit Plaintiff did not need a two-way radio at the West Broadway location where she was reassigned. 51. Defendants lack knowledge or information sufficient to foul' a belief as to the truth or falsity of the allegations contained in paragraph 51 of the 52. Defendants deny the allegations contained in paragraph 52 of the Complaint, except admit Defendants did not move Giovanni Santillo, change his schedule or take away his radio. 53. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 53 of the 54. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 54 of the 55. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 55 of the 56. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 56 of the Complaint, except admit Plaintiff was moved to the Gate 2 ramp. 7

8 57. Defendants admit the allegations contained in paragraph 57 of the 58. Defendants deny the allegations contained in paragraph 58 of the 59. Defendants deny the allegations contained in paragraph 59 of the 60. Defendants lack knowledge or infonnation sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 60 of the 61. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 61 of the 62. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 62 of the 63. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 63 of the 64. Defendants lack knowledge or information sufficient to foul" a belief as to the truth or falsity of the allegations contained in paragraph 64 of the 65. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 65 of the Complaint, except admit Plaintiff was injured on the job in or around December Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 66 of the 67. Defendants lack knowledge or information sufficient to fot i a belief as to the truth or falsity of the allegations contained in paragraph 67 of the 8

9 68. Defendants deny Plaintiff was subjected to any discriminatory treatment and further lack knowledge or information sufficient to form a belief as to the truth or falsity of the remaining allegations contained in paragraph 68 of the 69. Defendants lack knowledge or information sufficient to fore a belief as to the truth or falsity of the allegations contained in paragraph 69 of the 70. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 70 of the 71. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 71 of the 72. Defendants lack knowledge or information sufficient to foi n a belief as to the truth or falsity of the allegations contained in paragraph 72 of the 73. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 73 of the 74. Defendants deny the allegations contained in paragraph 74 of the Complaint, except admit that at some point Plaintiff handed Dudley Eisser a doctor's note. 75. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 75 of the 76. Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 76 of the Complaint, except admit that Dudley Eisser advised Plaintiff of her selection for layoff. 77. Defendants lack knowledge or info' nation sufficient to fonn a belief as to the truth or falsity of the allegations contained in paragraph 77 of the 78. Defendants deny the allegations contained in paragraph 78 of the 9

10 AS TO "COUNT I HOSTILE WORK ENVIRONMENT IN VIOLATION OF NYSHRL AGAINST ALL CORPORATE DEFENDANTS" 79. Defendants repeat and reallege each and every response contained in paragraphs numbered 1 through 78, with the same force and effect as if more fully set forth herein. 80. Defendants deny the allegations contained in paragraph 80 of the 81. Defendants deny the allegations contained in paragraph 81 of the 82. Defendants deny the allegations contained in paragraph 82 of the AS TO "COUNT II AIDING AND ABETTING HOSTILE WORK IENVIROMENT OF NYSHRL AGAINST DEFENDANTS PRIMIANO AND EISSER" 83. Defendants repeat and reallege each and every response contained in paragraphs numbered 1 through 82, with the same force and effect as if more fully set forth herein. 84. Defendants deny the allegations contained in paragraph 84 of the Complaint as they pertain to Dudley Eisser and lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations as they pertain to Kenneth Primiano 85. Defendants deny the allegations contained in paragraph 85 of the Complaint as they pertain to Dudley Eisser and lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations as they pertain to Kenneth Primiano. AS TO "COUNT III HOSTILE WORK ENVIORMENT IN VIOLATION OF THE CITY LAW AGAINST ALL DEFENDANTS" 86. Defendants repeat and reallege each and every response contained in paragraphs numbered 1 through 85, with the same force and effect as if more fully set forth herein. 87. Defendants deny the allegations contained in paragraph 87 of the 10

11 88. Defendants deny the allegations contained in paragraph 88 of the 89. Defendants deny the allegations contained in paragraph 89 of the AS TO "COUNT IV AIDING AND ABETTING HOSTILE WORK ENVIRONMENT IN VIOLATION OF THE CITY LAW AGAINST DEFENDANTS PRIMIANO AND EISSER" 90. Defendants repeat and reallege each and every response contained in paragraphs numbered 1 through 89, with the same force and effect as if most fully set forth herein. 91. Defendants deny the allegations contained in paragraph 91 of the Complaint as they pertain to Dudley Eisser and lack knowledge or infonnation sufficient to form a belief as to the truth or falsity of the allegations as they pertain to Kenneth Primiano. 92. Defendants deny the allegations contained in paragraph 92 of the Complaint as they pertain to Dudley Eisser and lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations as they pertain to Kenneth Primiano. AS TO "COUNT V RETALIATION IN VIOLATION OF NYSHRL AGAINST ALL DEFENDANTS" 93. Defendants repeat and reallege each and every allegation contained in paragraphs numbered 1 through 92 with the same force and effect as if more fully set forth herein. 94. Paragraph 94 contains a legal conclusion to which no response is required. To the extent a response is required, Defendants deny any factual allegations contained in paragraph 94 of the 95. Defendants deny the allegations contained in paragraph 95 of the 96. Defendants deny the allegations contained in paragraph 96 of the 11

12 AS TO "COUNT VI RETALIATION IN VIOLATION OF THE CITY LAW AGAINST ALL DEFENDANTS" 97. Defendants repeat and reallege each and every response contained in paragraphs numbered 1 through 96, with the same force and effect as if more fully set forth herein. 98. Paragraph 98 contains a legal conclusion to which no response is required. To the extent a response a required, Defendants deny any factual allegations contained in paragraph 98 of the 99. Defendants deny the allegations contained in paragraph 99 of the 100. Defendants deny the allegations contained in paragraph 100 of the AS TO "COUNT VII RETALIATION IN VIOLATION OF NYSHRL AGAINST ALL CORPORATE DEFENDANTS" 101. Defendants repeat and reallege each and every response contained in paragraphs numbered 1 through 100, with the same force and effect as if more fully set forth herein Defendants deny the allegations contained in paragraph 102 of the 103. Defendants deny the allegations contained in paragraph 103 of the 104. Defendants deny the allegations contained in paragraph 104 of the 105. Defendants deny the allegations contained in paragraph 105 of the 12

13 AS TO "COUNT VIII FAILURE TO ACCOMMODATE IN VIOLATION OF NYSHRL AGAINST ALL CORPORATE DEFENDANTS" 106. Defendants repeat and reallege each and every response contained in paragraphs numbered 1 through 105, with the same force and effect as if more fully set forth herein Defendants lack knowledge or information sufficient to fouu a belief as to the truth or falsity of the allegations contained in paragraph 107 of the 108. Defendants deny the allegations contained in paragraph 108 of the 109. Defendants deny the allegations contained in paragraph 109 of the 110. Defendants deny the allegations contained in paragraph 110 of the AS TO "COUNT IX DISABILITY DISCRIMINATION IN VIOLATION OF THE CITY LAW AGAINST ALL CORPORATE DEFENDANTS" 111. Defendants repeat and reallege each and every response contained in paragraphs numbered 1 through 110, with the same force and effect as if more fully set forth herein Defendants lack knowledge or information sufficient to foul' a belief as to the truth or falsity of the allegations contained in paragraph 112 of the 113. Defendants deny the allegations contained in paragraph 113 of the 114. Defendants deny the allegations contained in paragraph 114 of the 13

14 115. Defendants deny the allegations contained in paragraph 115 of the AS TO "COUNT X DISABILITY DISCRIMINATION IN VIOLATION OF THE CITY LAW AGAINST ALL CORPORATE DEFENDANTS" 116. Defendants repeat and reallege each and every response contained in paragraphs numbered 1 through 115, with the same force and effect as if more fully set forth herein Defendants lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 117 of the 118. Defendants deny the allegations contained in paragraph 118 of the 119. Defendants deny the allegations contained in paragraph 119 of the 120. Defendants deny the allegations contained in paragraph 120 of the AS TO "COUNT XI NEGLIGENT HIRING, RETENTION AND SUPERVISION AGAINST ALL CORPORATE DEFENDANTS" 121. Withdrawn pursuant to Stipulation filed October 9, Withdrawn pursuant to Stipulation filed October 9, Withdrawn pursuant to Stipulation filed October 9, Withdrawn pursuant to Stipulation filed October 9, Withdrawn pursuant to Stipulation filed October 9, Withdrawn pursuant to Stipulation filed October 9, AS TO "JURY DEMAND" Defendants deny Plaintiff is entitled to a trial by jury for some or all claims. 14

15 AS TO "WHEREFORE CLAUSE" Defendants deny all statements and allegations contained therein, including any claim for relief set forth in the "Wherefore Clause." AFFIRMATIVE DEFENSES Without assuming the burden of proof as to any of the following defenses where the law does not impose such a burden on Defendants, Defendants assert the following defenses: AS AND FOR A FIRST AFFIRMATIVE DEFENSE Plaintiff's Complaint should be dismissed for failure to state a cause of action. AS AND FOR A SECOND AFFIRMATIVE DEFENSE The Complaint is barred, in whole or in part, because: (a) Defendants exercised reasonable care to prevent and correct promptly any discriminatory behavior, and (b) Plaintiff unreasonably failed to take advantage of any preventative or corrective opportunities provided by Defendants or to avoid harm otherwise. AS AND FOR A THIRD AFFIRMATIVE DEFENSE Any and all actions taken by Defendants with regard to Plaintiff's employment with Defendant Phoenix, or the terms and conditions thereof, were based upon legitimate, nondiscriminatory and non-retaliatory business reasons and would have been taken regardless of Plaintiff's gender, alleged disability or purported protected activity. AS AND FOR A FOURTH AFFIRMATIVE DEFENSE To the extent Plaintiff has failed to make diligent and good faith efforts to mitigate her damages, any relief awarded upon her claims in this action must be dismissed or reduced in whole or in part. AS AND FOR A FIFTH AFFIRMATIVE DEFENSE To the extent that Plaintiff engaged in conduct prior to or during her employment 15

16 with Defendant Phoenix which would have resulted in denial of employment or in her discharge had said acts or omissions been known to Defendants, any relief awarded to Plaintiff should be reduced, in whole or in part, due to Plaintiff having engaged in such misconduct, whenever discovered. AS AND FOR A SIXTH AFFIRMATIVE DEFENSE All claims should be dismissed to the extent that they are barred by the applicable statute of limitations and/or doctrine of laches. AS AND FOR AN SEVENTH AFFIRMATIVE DEFENSE At all times relevant hereto, Defendants acted in good faith and have not violated any rights which may be secured to Plaintiff under any state, local or other law, rule, regulation, code or guideline. AS AND FOR AN EIGHTH AFFIRMATIVE DEFENSE To the extent that Plaintiff's claims are compensable under the New York Workers' Compensation Law, those claims are barred by the exclusive remedy provision of said law. AS AND FOR A NINTH AFFIRMATIVE DEFENSE In the event it is concluded that a prohibited factor motivated any discriminatory act against Plaintiff, the same act(s) would have been taken even absent the alleged discriminatory motive and, as such, no relief or recovery should be awarded. AS AND FOR A TENTH AFFIRMATIVE DEFENSE Plaintiff's recovery of front or back pay or any other recovery should be reduced by any period of Plaintiff's inability or unavailability to work due to any alleged disability or other reasons. 16

17 AS AND FOR AN ELEVENTH AFFIRMATIVE DEFENSE Plaintiff's Complaint should be dismissed to the extent she is not disabled within the meaning of the New York City and/or New York State Human Rights Laws. AS AND FOR A TWELFTH AFFIRMATIVE DEFENSE Plaintiffs Complaint should be dismissed to the extent she failed to fulfill any jurisdictional prerequisites or exhaust her administrative remedies. AS AND FOR A THIRTEENTH AFFIRMATIVE DEFENSE Plaintiffs Complaint should be dismissed to the extent her claims are subject to arbitration. AS TO A FOURTEENTH AFFIRMATIVE DEFENSE Plaintiffs retaliation claims should be dismissed because Plaintiff did not engage in any protected activity known to Defendants. AS TO A FIFTEENTH AFFIRMATIVE DEFENSE Plaintiffs disability discrimination claims should be dismissed because Plaintiff never requested a reasonable accommodation. AS AND FOR A SIXTEENTH AFFIRMATIVE DEFENSE If any of the individually named defendants engaged in any of the conduct alleged in the Complaint, said conduct was taken outside the scope of their employment with Defendant Phoenix and not as an agent of Defendants. As such, any liability cannot be imputed to Defendants. AS AND FOR A SEVENTEENTH AFFIRMATIVE DEFENSE Plaintiffs claims are barred, in whole or in part, to the extent Plaintiff is not a qualified individual with a disability or otherwise could not perform the essential functions of her position with or without a reasonable accommodation. 17

18 AS AND FOR A EIGHTEENTH AFFIRMATIVE DEFENSE Plaintiff's claims are barred, in whole or part, because reasonable efforts were made to accommodate Plaintiff. AS AND FOR A NINETEENTH AFFIRMATIVE DEFENSE The Complaint, and each of the purported claims for relief alleged therein, is barred by the equitable doctrines of unclean hands and/or estoppel. SUPPLEMENT AFFIRMATIVE DEFENSES Defendants reserve the right to supplement these Affirmative Defenses as additional information becomes known through the course of discovery in this action or otherwise. WHEREFORE, Defendants request that the Court: 1. dismiss with prejudice Plaintiff's Complaint; 2. deny each and every demand, claim and prayer for relief contained in Plaintiff's Complaint; 3. award to Defendants reimbursement for the costs, attorneys' fees incurred in the defense of this case; and, 4. grant such other and further relief as the Court deems just and proper. Dated: Melville, New York November 13, 2015 Respectfully submitted, JACKSON LEWIS P.C. 58 South Service Road, Suite 250 Melville, New York (631) By: MA S. WENGER KIM ERLY N. DOBSON ATTORNEYS FOR DEFENDANTS 18

19 TO: DANIELA NANAU, ESQ. LAW OFFICES OF DANIELA NANAU, P.C Rutledge Avenue Glendale, New York ATTORNEYS FOR PLAINTIFF 19

20 STATE OF NEW YORK ) )ss.: COUNTY OF SUFFOLK ) AFFIDAVIT OF SERVICE The undersigned being duly sworn, deposes and says: Deponent is not a party to this action, is over 18 years of age and resides at Medford, New York. I hereby swear that on November 13, 2015, DEFENDANTS PHOENIX CONSTRUCTORS JV, SLATTERY SKANSKA, INC. and SKANSKA USA CIVIL NORTHEAST INC.'S ANSWER was electronically filed with the clerk of the Court and served in accordance with the New York State Courts Electronic Filing System Rules on Electronic Service upon the following parties and participants via First Class Mail and electronic mail: DANIELA NANAU, ESQ. LAW OFFICES OF DANIELA NANAU, P.C. Attorneys for Plaintiff Rutledge Avenue Glendale, New York dn@danielananau.corn Sworn to before me this h.3 t day of November, Luz A. Franco t_ c7ill. >)( Notary Public , v. 1 PAULL f 1 t DI MARCO Notary Public, State of New York No Qualified in Suffolk County -7 Commission Expires Nov. 02, 20

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