On January 22, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Hyacinth Reid,
and
County Of Nassau,
for Torts - Other Negligence (Premises Liability)
in the District Court of Nassau County.
Preview
FILED: NASSAU COUNTY CLERK 01/16/2023 01:32 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 01/16/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
________________..___________.____________-____________________Ç
HYACINTH RElD, Index No.: 600978/2019
Plaintiff, COUNTERSTATEMENT
-against- OF MATERIAL FACTS
COUNTY OF NASSAU,
Defendant.
________---____________________________________________________Ç
Plaintiff HYACINTH REID submits the following Counter-Statement of Material Facts in
opposition to defendant's motion for summary judgment, pursuant to New York Codes Rules and
Regulations Section 202.8-g:
1. Admitted.
2. Admitted.
3. Admitted.
"regularly"
4. Controverted to the extent plaintiff cleaned the subject location.
5. Admitted.
6. Controverted. The statement made by defendant refers to an allegation that is
subject to a finding of fact.
7. Controverted. The statement made by defendant refers to an allegation that is
subject to a finding of fact.
8. Controverted. The statement made by defendant refers to an allegation that is
subject to a finding of fact.
9. Controverted. The statement made by defendant refers to an allegation that is
subject to a finding of fact.
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FILED: NASSAU COUNTY CLERK 01/16/2023 01:32 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 01/16/2023
ADDITIONAL UNDISPUTED FACTS
10. It isunclear when defendant last inspected Room L88 prior to the subject accident.
[McKeon EBT at p. 14; 43-44].
11. Defendant was responsible for electric work within the Nassau County District
Courthouse located at 99 Main Street, Hempstead, New York. [McKeon EBT at p. 21].
12. Defendant did not have maintenance schedules or walkthroughs for light switches.
[McKeon EBT at p. 21].
13. The subject light switch was not OSHA compliant. [McKeon EBT at p. 26].
14. Regular inspections ofthe electrical outlets and light switches at the Nassau County
District Courthouse located at 99 Main Street, Hempstead, New York were not conducted.
[McKeon EBT at p. 41].
15. Plaintiffs hand touched an exposed wire charged with 277 volts of electricity.
[McKeon EBT at p. 47].
16. The light switch condition was in an open and visible condition. [McKeon EBT at
p. 47].
Dated: Mineola, New York
January 16, 2023
Yours etc.,
MONTEL NE & SIEGEL, PLLC.
JARA L. SIEGEL, ESQ.
Attorneys for Plaintiff
HYACINTH REID
1539 Franklin Avenue
Suite 300
Mineola, New York 11501
(516) 746-0002
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FILED: NASSAU COUNTY CLERK 01/16/2023 01:32 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 01/16/2023
To:
HON. THOMAS A. ADAMS
County Attorney of Nassau County
Attorneys for Defendant
COUNTY OF NASSAU
One West Street
Mineola, New York 1 1501
(516) 571-3076
3 of 3
Document Filed Date
January 16, 2023
Case Filing Date
January 22, 2019
Category
Torts - Other Negligence (Premises Liability)
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FILED: NASSAU COUNTY CLERK 01/16/2023 01:32 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 01/16/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ________________..___________.____________-____________________Ç HYACINTH RElD, Index No.: 600978/2019 Plaintiff, COUNTERSTATEMENT -against- OF MATERIAL FACTS COUNTY OF NASSAU, Defendant. ________---____________________________________________________Ç Plaintiff HYACINTH REID submits the following Counter-Statement of Material Facts in opposition to defendant's motion for summary judgment, pursuant to New York Codes Rules and Regulations Section 202.8-g: 1. Admitted. 2. Admitted. 3. Admitted. "regularly" 4. Controverted to the extent plaintiff cleaned the subject location. 5. Admitted. 6. Controverted. The statement made by defendant refers to an allegation that is subject to a finding of fact. 7. Controverted. The statement made by defendant refers to an allegation that is subject to a finding of fact. 8. Controverted. The statement made by defendant refers to an allegation that is subject to a finding of fact. 9. Controverted. The statement made by defendant refers to an allegation that is subject to a finding of fact. 1 of 3 FILED: NASSAU COUNTY CLERK 01/16/2023 01:32 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 01/16/2023 ADDITIONAL UNDISPUTED FACTS 10. It isunclear when defendant last inspected Room L88 prior to the subject accident. [McKeon EBT at p. 14; 43-44]. 11. Defendant was responsible for electric work within the Nassau County District Courthouse located at 99 Main Street, Hempstead, New York. [McKeon EBT at p. 21]. 12. Defendant did not have maintenance schedules or walkthroughs for light switches. [McKeon EBT at p. 21]. 13. The subject light switch was not OSHA compliant. [McKeon EBT at p. 26]. 14. Regular inspections ofthe electrical outlets and light switches at the Nassau County District Courthouse located at 99 Main Street, Hempstead, New York were not conducted. [McKeon EBT at p. 41]. 15. Plaintiffs hand touched an exposed wire charged with 277 volts of electricity. [McKeon EBT at p. 47]. 16. The light switch condition was in an open and visible condition. [McKeon EBT at p. 47]. Dated: Mineola, New York January 16, 2023 Yours etc., MONTEL NE & SIEGEL, PLLC. JARA L. SIEGEL, ESQ. Attorneys for Plaintiff HYACINTH REID 1539 Franklin Avenue Suite 300 Mineola, New York 11501 (516) 746-0002 2 of 3 FILED: NASSAU COUNTY CLERK 01/16/2023 01:32 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 01/16/2023 To: HON. THOMAS A. ADAMS County Attorney of Nassau County Attorneys for Defendant COUNTY OF NASSAU One West Street Mineola, New York 1 1501 (516) 571-3076 3 of 3