Motion-Secondary: Pineda, Maynor Y. et al vs. Pro Con Incorporated et al

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COMMONWEALTH OF MASSACHUSETTS

MIDDLESEX, ss.

MAYNOR Y. PINEDA and OLGA
EXPERRANZA MARROQUIN GARCIA,
Plaintiffs

v.

PRO CON INCORPORATED and
ALLSTATE INTERIORS, INC.,
Defendants

NN

SUPERIOR COURT
C.A. No. 1481 CV 08863-J

JOINT PRE-TRIAL MEMORANDUM

r

Agreed Facts:

This matter arises out of an incident which occurred on June 20, 2014 whle the plaintiff
was working at a construction site known as Stone Place Apartments in Melrose, MA. The plaintiff
alleges he was injured when he fell at the construction site.

2. Plaintiff’s Statement of the Evidence:

The plaintiff, Maynor Pineda, expects the evidence at trial will show that on June 20,
2014 he was employed by Campos Drywall to perform work at a construction project located at

the Stone Place Apartments in Melrose, MA.

Incorporated (“Pro Con”) was the construction
will establish that defendant, Allstate Interiors,
complete the metal stud, insulation and drywall

Allstate, in turn, hired Ezequiel Campos,
the project. Maynor Pineda was a carpenter/labo:
Place Apartments project.

'e evidence will show that defendant, Pro Con
anager for the project. Further, the evidence

c. (“Allstate”), contracted with Pro Con to

ork under a contract dated November 16, 2011.

d/b/a Campos Drywall, as its subcontractor for
er for Campos Drywall working at the Stone

On June 20, 2014, Mr. Pineda, while in the course of his employment for Campos

Drywall, fell through a hole in the roof at the prot

ject when he stepped onto an unsecured

plywood hole cover which tilted under his weight. Photographs and other evidence clearly show

that at the time of the accident the plywood cover
on it to provide warning of the hazard.

did not have the word “HOLE” or “COVER”The jury will hear evidence that as the co:
responsible for overall safety on the jobsite. Thal
10.03 which provides, in pertinent part, as follo

struction manager for the Project, Pro Con was
duty is a non-delegable duty under 454 CMR
iS:

(1) Protection of health and safety af employees and others:

(a) All places where employe:

s are directed or permitted to perform

work of any kind in construction work or demolition shall be so
constructed, equipped, arranged, operated and conducted as to
provide reasonable and adequate protection to the lives, health and

safety of employees and o'

(b)

ihers.

Employers, owners, contractors, subcontractors, superintendents or

foremen in charge, and other persons obligated by law to adhere to
the requirements of 454 CMR 10.00 shall not direct, or permit an
employee to work under conditions which are not in compliance

with or which are prohibit

The above-mentioned regulations were de

on certain easily identifiable individuals or entiti
either would take the action required to maintain

ed by 454 CMR 10.00.

signed to impose responsibility for job safety
s or both so that those individuals or entities
ja reasonably safe working environment or take

 

clear, affirmative steps to delegate safety responsibility to others. On June 20, 2014, Mr. Pineda

fell through the opening in a roof because the op:
Section 1926.502 requires that holes in floors, ro.
meet the following requirements: “All covers sh

accidental displacement by the wind, equipment,
OSHA requires that “All covers shall be color co
“HOLE” or “COVER” to provide warning of the|

The duties and responsibilities imposed b
Con apply with equal force to Allstate under the
Drywall to work on the project. As such, Allstat
maintain a reasonably safe working environment
evidence will show that Allstate, like Pro Con, fa
the evidence will show that there was little, if an
Place Apartments project in July 2014.

The evidence will also show that at some’

ning did not have a secure hole cover. OSHA
fs, and other walking/working surfaces shall
1 be secured when installed so as to prevent
lor employees.” 1926.502(i)(3). Additionally,
ded or they shall be marked with the word
hazard. 1926.502(i)(4).

the above-mentioned regulations against Pro
facts of the instant case. Allstate hired Campos
e had a duty to take the actions required to

at the project. The plaintiff expects that the
iled to do so. Further, the plaintiff expects that
, safety training and job oversight on the Stone

 

point prior to Mr. Pineda’s accident there was a

piece of plywood which had been secured with screws to cover the hole in the roof. This
plywood floor cover had no markings on it to provide warning of the hazard posed by the floor
opening. Photographs taken immediately following Mr. Pineda’s accident by Pro Con
supervisors document this fact. Sometime shortly after Mr. Pineda’s accident, Pro Con

instructed its onsite carpenter, Paul Doyle, to wri!

N.

te the word “HOLE” on the cover.witnesses in the case that the subject floor
lby which subcontractors brought equipment to

There will also be testimony from several
opening was being used at the jobsite as a means
the roof from the floor beneath the roof.

The evidence at trial will also show that Pro Con and Allstate recognized its duty to
provide a safe worksite for workers at the Project In Pro Con’s contract with Allstate for work
at the Stone Place Apartments, numerous provisions of the contract deal specifically with safety.
In a section entitled “Safety” the following language appears:

he Site. It is the subcontractor’s
ons in the performance of his work and
its employees...Subcontractor shall

SHA safety rules and regulations while

Safety is to be given first priority on t
responsibility to maintain safe conditi
to provide ongoing safety training for
understand, practice and promote all
on the Project site.

 

Moreover, the specific hazard posed by the floor opening on the roof of the Connector
section of the Project was a hazard that was recognized by Pro Con prior to Mr. Pineda’s
accident. One of Pro Con’s carpenters had built the wooden frame for the floor opening and,
presumably, fastened the plywood over the opening using screws in an effort to secure the
plywood. Even though the carpenter knew the pliywood was covering a hole, the carpenter failed
to mark the plywood with lettering, required by OSHA, indicating that the plywood was covering
a hole.

The jury will also hear evidence that Pro Con had engaged the services of Contractor’s
Risk Management, Inc. to perform project worksite safety inspections. On June 19, 2014, one
such inspection was performed of the Stone Place project by Rich LeVinus of Contractor’s Risk
Management. Mr. LeVinus found that there wasja floor hole not adequately covered or labeled.
He also found that there were many 4” core holes on multiple floors of the Connector which
were not covered. Mr. LeVinus also found that there was an opening approximately 2.5 feet
square covered with “only a loose piece of decking not marked or secured”. The jury will hear
testimony from Mr. LeVinus that his overall con¢lusion- the day before Mr. Pineda’s accident-
was that on-site supervision at the Stone Place Tie project needed improvement.

The evidence will show that on June 20, 2014, Maynor Pineda (d.0.b. 5/4/1981) was a
healthy 33-year-old man who was working full- time as a carpenter/laborer for his employer,
Campos Drywall. When Mr. Pineda stepped on the unsecured hole cover he fell through the
opening in the roof and landed approximately 16/feet on the floor below the roof of the building.
Upon arrival at Massachusetts General Hospital (“©MGH”) Mr. Pineda complained of severe back
pain, headache, neck pain, right arm pain, pain in his left rib cage. He vomited in the Emergency
Room. Given the nature of his fall and his complaints, doctors were concerned that Mr. Pineda
had lost consciousness in the fall. Mr. Pineda was admitted to the hospital due to a significant
concern that he may have sustained an unstable spine injury with potential for permanent

neurological disability. Severe focal tenderness
pathology, with potential for progression and p
immediately ordered an MRI of his neck.

as identified consistent with acute spinal
anent neurological disability. DoctorsDoctors also ordered cervical spine immobilization plus imaging of Mr. Pineda’s spine to

identify any acute spinal pathology. An MRI of

. Pineda’s cervical spine did not show any

evident abnormality of his cervical spine. However, an MRI of Mr. Pineda’s right wrist showed

a distal radial fracture.

Mr. Pineda also complained of dizziness,
pelvis, thoracic and lumbar spine. A CT scan of
of abdominal trauma. Additionally, a CT scan w:
no evidence of acute intracranial hemorrhage.

chest pain as well as pain in his abdomen,
his abdomen and pelvis did not detect evidence
as ordered of Mr. Pineda’s head which showed

Mr. Pineda was discharged from MGH on June 21, 2014 with a cervical collar and a
splint on his right wrist. He was given prescriptions for pain and the spasms in his cervical spine

and told to follow up with the Orthopedic Depart

Thereafter, Mr. Pineda came under the cai
extremity specialist. On November 20, 2014, Mr,
which showed a partial tear in the scapholunate li

ment at MGH.

e of Hillel Skoff, M.D., a hand and upper
Pineda underwent a right wrist arthrogram
igament. The test was done in conjunction with

an MRI of Mr. Pineda’s right wrist. Based on the findings of these diagnostic tests, Dr. Skoff

recommended surgical reconstruction of the scap

On December 22, 2014, Dr. Skoff operate

holunate ligament.

id on Mr. Pineda’s right wrist. Dr. Skoff

reconstructed the scapholunate ligament. Mr. Pineda continued to treat with Dr. Skoff following
the surgery. X-rays taken of Mr. Pineda’s right wrist on July 2, 2015 showed that there was still
a3 millimeter gap between the scaphoid and lunate, which was an improvement. However,

Dr. Skoff did not believe that Mr. Pineda was capable of returning to work as a carpenter/laborer
unless his grip strength improved.

 

Since the accident Mr. Pineda has suffered with intractable chronic post-traumatic
headache, along with the pain he was experiencing in his cervical, thoracic and lumbar spine. He
came under the care of Vladan Milosavljevic, M.D. Dr. Milosavljevic recommended that Mr.
Pineda undergo trigger point injections into his lumbar area. He also recommended cognitive
and physical therapy as well as various medications including Topamax and Neurontin. Mr.
Pineda treated with Dr. Milosavljevic from October 23, 2014 through June 20, 2016. During that
time, Mr. Pineda failed to progress in any signifigant manner.

Mr. Pineda also has sought treatment with Robert C. Cantu, M.D. at the Cantu
Concussion Center located at Emerson Hospital. |Mr. Pineda first went to the Cantu Center in
January, 2016. At that time, Mr. Pineda presented complained of headache, nausea, neck pain,
back pain, dizziness with vertigo, blurred, foggy and double vision, significant cognitive
difficulties, fatigue, sleep disturbance with insomnia and early awakening, anxiety, depression,
as well as light and sound sensitivity. Doctors at|the Cantu Concussion Center noted that Mr.
Pineda’s neurological symptoms are worse whenjhe has an increase in cognitive and physical
stimulation, and they improve with decreased stimulation. The medical evidence will show that
Mr. Pineda has undergone cognitive rehabilitatiot n, physical therapy and occupational therapy at
the Cantu Concussion Center with a diagnosis ofipost-concussion syndrome.Mr. Pineda will also testify at trial that sin
memory and concentration. Medical evidence fr
Mr. Pineda was found to have decreased stability]
turning, and with head movements.

At the time of his accident in June, 2014,
laborer for Campos Drywall. Mr. Pineda is right
language.

As of February 25, 2016, Mr. Pineda was
noted above. Mr. Pineda was seen by a vocationa
CCM. In her report dated June 20, 2016, Ms. Sin
as a laborer since he was 14 years old. He has w
landscaping and laundry. Ms. Shugars saw Mr. F;
his cognitive therapy. She noted that Mr. Pineda
depression and generalized anxiety disorder are s'
June 20, 2014. She noted that Mr. Pineda has lim
employment, functional limitations related to his
from working his former occupation. Ms. Shugat
sustained in his June 20, 2014 accident eliminate
be available to him considering his vocational pr

ce the accident he has decreased short-term
m the Cantu Concussion Center will show that
with balance testing, dizziness when walking,

Mr. Pineda was earning $18.00 per hour as a
hand dominant and Spanish is his primary

istill having the same neurologic symptoms as
1 consultant, Sarah L. Shugars, MS, CRC,
hears noted that Mr. Pineda had been working
rked in the construction field as well as
‘ineda after he had his right wrist surgery and
s chronic headaches, cognitive impairment,
econdary to the injuries he sustained on

‘ited transferable skills and barriers to

June 20, 2014 accident, which preclude him

rs concludes that the injuries that Mr. Pineda
lany meaningful employment options that would
file, education, work history and training.

Defendant, Pro Con Incorporated’s, Statement of the Evidence:

The Defendant, Pro Con Incorporated, (“R
following:

Pro Con was the construction manager for
Melrose, MA. The project involved the renovatio)
of a connector building between them. Pro Con s'
one to two assistant superintendents. The Pro C.

ro Con”) expects the evidence will show the

the construction of Stone Place Apartments in

n of two former mill buildings and construction

‘affed the project with a fulltime supervisor and
superintendent and his assistant(s) made

‘on
regular daily inspections of all work areas to monitor the status of the work. Pro Con’s

inspections included reviewing the safety aspects
applicable OSHA regulations and Pro Con’s own|
management at the site, Pro Con also contracted

of New Hampshire, which performed bi-weekly s

of the work and enforcing compliance with
safety policies. As part of its safety

ith an outside construction safety firm, CRM
afety inspections.

The work on the project involved multiple trades and Pro Con subcontracted with
numerous subcontractors, including Allstate Inteyiors, Inc. (“Allstate”). Allstate’s work included
metal stud, insulation and drywall work. The subcontract placed significant safety

responsibilities on Allstate for the performance o:
subcontract also required Allstate to indemnify P.

its work and that of its subcontractors. The
‘o Con for all injuries arising out of Allstate’s

work and to obtain liability insurance covering Po Con as an additional insured.The Plaintiff was injured during the cow
a subcontractor retained by Allstate. At the time
up their construction materials and removing thei
building. They were the only individuals workin
accident. While performing that work, the Plainti
which had been covered with plywood.

e of his work as a laborer for Campos Drywall,
f his injury, he and a co-worker were cleaning
tools from the flat roof on top of the connector
in that area for a couple of hours prior to the
negligently fell through a floor opening

Pro Con contends that negligence on the part of the plaintiff and / or his co-worker was
the primary cause of the accident. In the event the plaintiff prevails on his claim against Pro Con,

Pro Con contends that it is entitled to be indemni:

Defendant also contends that the Plaintiff,
his usual employment.

fied by Allstate and / or its liability insurer.

has recovered from his injury and can perform

Defendant, Allstate Interior Inc.’s, Statement of the Evidence:

 

The Defendant Allstate Interiors (“Allstate”) will demonstrate that it acted as a reasonable

subcontractor in the performance of its work.
sustained by the plaintiff were not caused by a n¢
its officers, board members, agents or representa!
and extent of the plaintiff's claimed injuries.
show that the injuries sustained by the plaintiff
including the negligence of the plaintiff himself.

3. Agreed Description of the Case:

This matter arises out out of an alleged

The Defendant will establish that the injuries
gligent act or omission on its part or that of any
ives. Further, the Defendant contests the nature
‘oreover, the Defendant expects the evidence to
ere caused by the negligence of other parties,

cident which occurred on June 20, 2012 at a

construction site in Melrose, MA. The Plaintiff claims that as a result of the that incident he

sustained bodily injuries and damages. The Defe
incident and dispute the nature, extent and causal
by the plaintiff.

4, Significant Legal Issues:

dants denies any negligence with respect to the
lationship of the injuries and damages claimed

 

The plaintiff will seek though motions in

imine to redact the name “Humberto Campos”,

“Umberto Campos” and/or “Umberto” from all accident reports, accident investigations, witness
statements, medical records and medical reports, and to exclude at trial any reference to the name

“Humberto Campos”, “Umberto Campos” and/or!
Closing Arguments or in the examination or cros:

“Umberto” in either Opening Statements,

The plaintiff maintains that immediately following his accident, unbeknownst to him, his
employer provided the name “Humbeto Campos”, “Umberto Campos” or “Umberto” instead of

his actual name, Maynor Y. Pineda. These motio:

aca of the plaintiff or any witness.

ns in limine will be based upon the legalargument that introduction of such evidence has no probative value and will be so prejudicial as

to prevent the plaintiff from receiving a fair trial.

The Defendant Pro Con contends that plaintiff Maynor Pineda is a foreign national, not

legally authorized to work in the United States.

ccordingly, he is not entitled to future lost

earnings in the United States. If he is entitled to make a claim for lost earnings, it must be
measured by the earning standards of his own country.

The Defendant, Allstate, will oppose the Plaintiff's Motions in limine to remove
reference to the names “Umberto Campos”, “Humberto Campos” and “Umberto” from the

relevant documents in this case as there remains
decided by the jury. In addition, Allstate joins Pi
not entitled to future lost earnings as set out abo

ve.

crucial issue of identification that must be
Con in its contention that Maynor Pineda is
Moreover, the Plaintiff has failed to provide

any admissible evidence of his alleged lost earning or future lost earnings capacity. Specifically,

the Plaintiff has failed to produce any federal tax
R. Civ. P. 34.

Plaintiff's Witnesses:

Plaintiff, Maynor Y. Pineda, 4 Broad
Rich LeVinus, Contractor’s Risk M

David Raiche, Pro Con,
Gary M. Bragg, Pro Con, Inc., 31 Ad.

mo ae op

Robert “Bob” Beauchemin, Pro Con,
Hampshire;
Lance Bennett, Pro Con, Inc, 1359 Ha
Charles Rotrondi, Pro Con, Inc., 205 }
Steve, Adams, Pro Con, Inc., 25 Fren:
Rich Lambert, Pro Con, Inc, 1359 Hor
Victor Davis, Allstate Interior’s Inc. (.
Fred Soward, CEO, Allstate Interior’s|
. Jacob Raposa, 374 S. Precinct Street,
David Dam, 585 Freeport Street, Dora
Keeper of Records, Pro Con, Inc., 135
Keeper of Records, Allstate Interior’s
Keeper of Records, Contractor’s Risk
Keeper of Records, Massachusetts Ger

Keeper of Records, Beth Israel Deaco:
Keeper of Records, Vladan Milosavlje
Keeper of Records, Cantu Concussion

SEP YR OVO Rg or Boe

The Plaintiff reserves the right to call any
though each were fully listed herein, and adopts

Inc., 1359 Hob

Keeper of Records, Hillel Skoff, M.D!

returns or W-2s as requested pursuant to Mass.

ay Court, Lawrence, MA;

gement; Concord, New Hampshire;

ksett Road, Hooksett, New Hampshire;
s Road, Framingham, MA;

Louis Stamatelos, Pro Con, Inc., 731 High Street, Candia, New Hampshire;

nc., 45 South Road, Deerfieled, New

oksett Road, Hooksett, New Hampshire;
‘erry Street, Unit 210, Everett, MA;
h King Highway, Erving, MA;
sett Road, Hooksett, New Hampshire;
listate Foreman);
Inc., 1195 Route 208, Monroe, New York;
Taunton, MA;
ester, MA;
9 Hooksett Road, Hooksett, New Hampshire;
iInc., 1195 Route 208, Monroe, New York;
iManagement, Concord, New Hampshire;
neral Hospital, Boston, MA;
, Brookline, MA;
ness Hospital, Brookline, MA
vic, M.D., Lawrence, MA;
Center, Emerson Hospital, Concord, MA

of the witnesses identified by the Defendants as
and incorporates by reference the Defendants’witness lists. The Plaintiff further reserves the rig}
to call any rebuttal witnesses as may become nect

Defendant, Pro Con Incorporated’s, Wi

Rich LeVinus, Contractor’s Risk Man;
. David Raiche, Pro Con, Inc., 1359 Ho}

Louis Stamatelos, Pro Con, Inc., 731 F

Fred Soward, CEO, Allstate Interior’s
Jacob Raposa, 374 S. Precinct Street,
Davis Dam, 585 Freeport Street, Dorc]
Luis Enrique Becerra Sanchez
Anthony Sylvia

. Daniel Timmons

James Leahy

m. Steve Adams

n. Ezequiel Campos

o. Umberto Campos

crore me ae gp

t to amend and supplement this witness list, and

essary.
itnesses:
agement; Concord, New Hampshire;

oksett Road, Hooksett, New Hampshire;
Gary M. Bragg, Pro Con, Inc., 31 Adams Road, Framingham, MA;

igh Street, Candia, New Hampshire;

Victor Davis, Allstate Interior’s Inc. (Allstate Foreman);

Inc., 1195 Route 208, Monroe, New York;

Taunton, MA;
hester, MA;

Defendant Pro Con reserves the right to call each and every witness listed by every other

party.

Defendant Pro Con reserves the right to call impeachment and / or rebuttal witnesses.

Defendant Pro Con reserves the right to c
been previously disclosed, in the event the Plainti

unter designate fact witnesses who have not
iff is permitted to do so.

Defendant, Allstate Interior Inc.’s, Witnesses:

 

The defendant Allstate incorporates by reference any and all witnesses (lay or expert)

listed by the Plaintiff or the Defendant Pro Con in

this case.

Further, the Defendant Allstate lists the following additional witnesses:

a. Keeper of Records, Cataldo Ambulance Service, Somerville, MA
b. Victoria Sacco, EMT Paramedic, Cataldo Ambulance Service, Somerville, MA
c. Odimar Batista, EMT Paramedic, Catdldo Ambulance Service, Somerville, MA

 

In addition, Allstate reserves the right to call any person with knowledge of admissible

facts discovered prior to or during trial, and rebut

tt
any witnesses identified. The defendant Allstate

of any deposition taken in the instant action of a1

al witnesses if any, and to refrain from calling
eserves the right to read into evidence portions
witness who is unavailable for trial, insofar as

ny
permitted by Massachusetts’ law and the on ofan wi Rules of Civil Procedure.Allstate reserves the right to call impeachy

Allstate reserves the right to designate addition4
event the Plaintiff is permitted to do so.

Plaintiff’s Expert Witnesses:

Sara L. Shugars, MS, CRC, CCM
Vocational Diagnostics, Inc.
Bourne, MA

Vocational Consultant,

ment and or rebuttal witnesses.

1 lay witnesses not previously disclosed in the

The June 20, 2014 Report of Sara L. Shugars has been provided to defense counsel.

Additionally, the plaintiff will submit medical records, reports and bills pursuant to Mass.

G. L. ch. 233, Section 79 G.

The plaintiff reserves the right to supplem

‘ent this list prior to the trial of this matter.

Defendant, Pro Con Incorporated’s, Expert Witnesses:

Defendant Pro Con reserves the right to ¢
the Plaintiff by an orthopedic and / or neurologic
exams seasonably in advance of trial.

Defendant Pro Con reserves its rights und

ionduct M.R.Civ.P. 35 medical examinations of
\doctor(s) and to disclose the results of any such

er Mass. G. L. ch. 233, sec. 79G to conduct

cross-examination of any medical experts whose opinions are offered via certification of records,
either by subpoenaing such experts to trial or by conducting their audio-visual depositions in.

advance of trial.

Defendant Pro Con reserves the right to count

been previously disclosed, in the event the Plainti:

Defendant, Allstate Interior Inc.’s, Exp

Allstate reserves its rights under Mass. G.
examination of any medical experts whose opini

10)

er designate expert witnesses who have not
ffs are permitted to do so.

ert Witnesses:

L, ch. 233, sec. 79G to conduct cross-
s are offered via certification of records, either

f

by subpoenaing such experts to trial or by conducting their audio-visual depositions in advance

of trial. Moreover, Allstate reserves the right to ¢

all all medical, nursing and other health care

‘istered relevant medical treatment to the

professional providers whose names appear in the relevant medical records, including the keeper

of records, of any medical provider that has admii
Plaintiff.Further, Allstate reserves the right to designate expert witnesses who have not been previously
disclosed, in the event the Plaintiffs are permitted to do so.

With the agreement of Plaintiffs counsel, Allstate reserves the right to conduct Independent
Medical Examinations Pursuant to Mass R. Civ P. Rule 35, with respect to both the alleged
orthopedic and neurological injuries and to supplement the expert witness list accordingly.

7. Length of Trial:

4 to 5 days

8. Itemization of Special Damages

Medical bills to date total $50,333.45.
Lost wages to date amount to $112,320.00
Future impairment of earning capacity equals $1,123,200 to age 66 (without reducing to
present value or factoring in cost of living adjustments).

9. Certification of Counsel:

Counsel have conferred and discussed submitting the case to Mediation. No decision has
been made to date regarding Mediation.

Respectfully submitted,
The Plaintiff, Defendant,
MAYNOR Y. PINEDA PRO CON, INCORPORATED
By his Attorneys, By its Attorneys,

Brain M. Cullen, Esq., BBO# 347427

Law Offices of Steven B. Stein

 

Wellesley, MA 02481 Two Financial Center
(781) 263-9400 60 South Street, Suite 1000
reafarelli@sullivanllp.com ‘Boston, MA 02111-2759

(617) 772-2800
bcullen@travelers.comDated: August 2, 2017

11

Defendant,
ALLSTATE INTERIORS, INC.
By its Attorneys,

   

Christopher J Bulger¢ sq., BBO# 634589
cbulger@BSCtrialattorneys.com

Boyle, Shaughnessy, P.C.

695 Atlantic Avenue, 11", Floor

Boston, MA 02111

(617) 451-2000