Plaintiff alleged she tripped and fell over a deteriorated sidewalk flag. She filed suit against the Firm’s municipal client. Prior to depositions, we moved for summary judgment based upon lack of prior written notice. In opposition, plaintiff argued our motion was premature since depositions had not yet occurred. The Court granted our motion and held that that plaintiff failed to demonstrate an exception to the prior written notice rule, and any contention that our motion was premature was unpersuasive.