Plaintiff sued the Firm’s client, a grocery store chain with locations throughout the Northeast, in New York Supreme Court. Plaintiff claimed she fell due to a sticky substance on the floor and, as a result, sustained serious injuries, including fractured humerus and tibia with lengthy rehabilitation. Plaintiff’s statements to her medical providers indicated that plaintiff did not fall due to a substance, as alleged, but instead leaned on cardboard display that tipped over. After discovery, we moved for summary judgment, arguing that even if plaintiff fell due to a sticky substance, the client did not create the condition and was not on notice of it. We submitted an affidavit from the client’s former employee stating that when he inspected the area before the accident, it was clean. Though plaintiff attempted to submit an opposing affidavit from her daughter that the substance was part of a recurring condition, we convinced the court to disregard the affidavit as a sham because it contradicted the daughter’s earlier deposition testimony. The court granted the motion, dismissing plaintiff’s lawsuit in its entirety.