Partner Cheryl Fuchs and associate Alicia Sklan obtained pre-discovery summary judgment in a Bronx County Labor Law case. In Fernando v. 210 East 15th Street et. al., the plaintiff fell from a scaffold located on the roof of a building owned by one of the defendants. Though our client installed a sidewalk bridge in front of the building, we moved to dismiss the complaint and all cross-claims on the ground that our client did not install any scaffolding on the roof of the building where plaintiff’s accident indisputably occurred. Rather than wait for these facts to be established through depositions, we were proactive and served a notice to admit on plaintiff as to where his accident occurred. Once plaintiff admitted that his accident occurred on the roof and not at the sidewalk level, we served a notice to admit on the defendant-general contractor who had hired our client to establish that the general contractor installed the scaffolding on the roof and not our client. As a result, we obtained a complete dismissal for our client without going through the lengthy discovery process.