Plaintiff Antonia Rodriguez fell on a sidewalk owned and maintained by the Parkchester group of defendants on October 27, 1986. In her deposition, plaintiff testified that after she fell, she saw sand and little stones at the edge of the sidewalk. Photographs of the site were used at depositions to identify the location. At a further deposition, Michael Daniels, employed by defendant Parkchester Apts. Co. as a maintenance foreman and responsible for the maintenance and repair...
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