could perform similar work for other companies. Thus, in the Court’s view, the manner and means factor weighs in favor of finding that the Plaintiff was an independent contractor. b.Skill Required The Plaintiff admits that there is a certain level of skill needed to perform the work he does. The Plaintiff also acknowledges that, for type of work he does, he must have a commercial driver’s license. To obtain this license, the Plaintiff had to participate in a special driving course and passing a test. Although the Court does not deem the skill required for the Plaintiffs work to be unusually high, it nevertheless requires training and calls for the exercise of independent judgment. See, e.g., Wadler v. E. College Ath. Conf., No. 00 Civ. 5671(JSM), 2003 WL 21961119, at *3 (S.D.N.Y.2003) (<HOLDING>). Thus, this factor weighs in favor of finding
holding that a baseball umpire is a skilled worker whose job performance requires training and the exercise of independent judgment holding that statements did not stigmatize employee because they concerned competency and job performance holding that ems training lieutenants position met criteria because the lieutenants developed coordinated implemented and conducted ems training programs  prepared lesson plans and training aids supervised delivery of training and tests and evaluated new equipment holding that controlling ingress and egress of worker and requiring that worker abide by rules of conduct within facility is insufficient to establish employment relationship  for title vii purposes holding employer discipline and written and verbal criticism of employees job performance not extreme and outrageous