Obtained summary judgment, in advance of any depositions, on behalf of a scaffold erection contractor in a personal injury action with a low seven-figure exposure. The case was filed in New York County by a construction worker who fell from our client’s scaffolding. Based on affidavits, photographs, email messages and other documentation, the defense established that the scaffolding was properly erected, that it had been altered by unidentified third parties, and that, although the scaffold contractor was aware of the hazard posed by the alterations, it had no duty to repair the scaffolding absent a change order from the general contractor, which was not forthcoming. To obtain summary judgment, the defense established that their motion was not premature because depositions would not lead to evidence sufficient to overcome our client’s prima facie entitlement to that relief.