223, 228 (N.D.N.Y.1999). In terms of the level of skill that it required, Eisenberg’s moving work was not analogous to any of these jobs. Indeed, in this case White and Ewing all but offered Eisenberg a job without first asking her about moving-related work that she had done in the past, or about relevant skills that she might have developed over the years. See ante at 112-13. That White seemed to view Eisenberg as qualified for the job solely on the basis of her football and carpentry abilities, see ante at id., only emphasizes the point: While simple moving of the sort Eisenberg performed certainly requires skills — strength, for example, and agility— it does not demand specialized skills of the sort typically acquired through experience and/or education. See Aymes, 980 F.2d at 862 (<HOLDING>). As to the third and fourth factors, the
holding that if the putative employee has the discretion to adopt the means and methods he wishes to accomplish the required work he is an independent contractor holding that an employees injury while on college grounds to report for first day of work before he reached either the administration building where he was to complete payroll forms or the athletic field house where he was to do the work was an injury suffered in the course of the employment holding that the level of skill involved in a computer programmers work suggested that he was an independent contractor because his programming demanded that he use skills developed while a graduate student  and through his work experience holding that defendant was not resident of his mothers household even though his drivers license listed his mothers address and he received mail there because he expressed a belief that his residence was in a different location than his mothers home he rented and occupied his own residence and he testified that he was only living with his mother after expiration of his lease until he could find another place to live holding that duty to ensure that independent contractor performs its work in safe manner arises if the general contractor retains some control over the manner in which the independent contractor performs its work