[brief] Defendant-Respondent [...]  (“[...]”) submits this brief in opposition to Plaintiff-Appellant [...]’s (“Plaintiff”) appeal of the June 22, 2018, order granting [...]’s motion for summary judgment dismissing Plaintiff’s claims with prejudice.  The trial court concluded that no reasonable trier of fact could find that [...] had committed an intentional wrong.  This Court should affirm the trial court’s Order because Plaintiff failed to adduce evidence establishing that [...] committed an intentional wrong that would be sufficient to overcome the immunity provided by the New Jersey Workers’ Compensation Act (the “Act”), N.J.S.A. 34:15-8.  This lawsuit arose out of a highway construction accident that resulted in the death of [...] (“[...]”), a milling foreman employed by [...].  Plaintiff, [...]’s widow, brought suit both individually and on behalf of her deceased husband as executrix of his estate.  Plaintiff alleged that [...]’s actions and/or omissions were a proximate cause of the accident and [...]’s injuries.  As [...]’s employer, however, [...] is immune from liability under the Workers’ Compensation Act, subject only to the very limited exception for “intentional wrongs,” which can only be satisfied by a showing that (a) the employer knew that its actions were substantially certain to result in injury or death, and (b) the injury was more than a fact of life of industrial employment.  Through her experts, Plaintiff set forth a number of liability theories against [...] in an effort to overcome the Workers’ Compensation bar.  Despite the Monday-morning quarterbacking of Plaintiff’s experts, there was simply no evidence developed in discovery to support a finding that [...] knew that its actions were substantially certain to result in [...]’s accident, injury, or death.  Indeed, not even [...] — a project foreman who was known to have the utmost concern over safety and who was not shy about raising safety concerns with his employer — complained about or sought to correct any of the alleged safety violations identified by Plaintiff’s experts.  Moreover, and regardless of [...]’s alleged actions and inactions, Plaintiff’s claims herein still fail because the context and circumstances of Mr. [...]’s injury were not more than a fact of life of industrial employment.  [...] was injured when he was struck by a moving vehicle in an active road construction work zone.  There is no affirmative act or additional precaution that [...] could have undertaken that would have eliminated the need to have both employees and moving vehicles in that work zone on the night of the accident.  Although serious injury and death is thankfully not a frequent consequence of construction work, there is no question that the danger of being struck by a vehicle is a real and well-known risk in the industry.  In her deposition, Plaintiff herself acknowledged that her husband had a dangerous job.  Plaintiff’s claims were correctly dismissed by the trial court because, even when viewing the facts in the light most favorable to Plaintiff, none of the documents or testimony adduced demonstrated the knowledge of virtual certainty of severe injury or death required to overcome the Workers’ Compensation immunity or that the circumstances of [...]’s injury were plainly beyond anything that the Legislature intended the Workers’ Compensation Act to immunize.  Accordingly, the trial court properly granted summary judgment in favor of [...], and this Court should affirm that ruling.