Plaintiff sued the Firm’s municipal client in New York Supreme Court. Plaintiff claimed he fell due to a defective sidewalk and manhole. After discovery, we moved for summary judgement, arguing that plaintiff’s testimony established he fell on a privately owned sidewalk surrounding a municipal manhole, that there was no evidence of a defect with respect to the manhole or cover and that there was no prior written notice of any defect concerning the sidewalk or manhole. In opposition, plaintiff argued that his accident occurred due to the uneven condition between the sidewalk and manhole cover and that prior written notice was not required as the client had special use of the manhole. The court granted the motion, dismissing the complaint in its entirety.