Plaintiff, a New York resident, sued the Firm’s client, a national retailer, claiming she slipped and fell on liquid on the floor. Plaintiff claimed that as a result, she sustained serious injuries, including an arthroscopic shoulder surgery and subsequent total shoulder replacement. We removed the case to the United States District Court for the Eastern District of New York. After discovery, we moved for summary judgment, arguing the client did not create and was not on notice of the alleged puddle. We submitted an affidavit from the client’s former employee stating that when he inspected the area before the accident, it was clean and dry. The court granted the motion, dismissing plaintiff’s lawsuit in its entirety.