A settlement of more than $3.5 million was reached in Bronx County for a 36-year-old construction worker and Local 6A Cement & Concrete Workers Union member who fell approximately fifteen feet through an unmarked hole from the 16th to the 15th floor at a work cite in midtown Manhattan. As a result of the fall, the worker suffered a traumatic brain injury with psychological and cognitive deficits in addition to spinal, wrist and knee injuries which required surgical intervention. Notwithstanding blanket denials on all important issues by the general contractor and others , Gersowitz Libo & Korek was able to achieve a favorable result in our ongoing effort to protect the rights of construction workers in New York.