A person has “reason to know” when he or she “has information from which a person of reasonable intelligence or of the superior intelligence of the actor would infer that the fact in question exists, or that such person would govern

The key to this case is the excellent development of the circumstantial and attendant facts surrounding the access to the worksite, and its proximity to public access, together with the deposition of numerous construction employees and the safety literature/materials of the company contracted to perform the work.  It is an excellent read of the meticulous…