Manchester Partners Ralph Suozzo and Bill Staar recently extracted our client from a lawsuit via a stipulation of dismissal in exchange for no money.  The plaintiff had fallen while exiting a beauty parlor, resulting in a broken nose, lost teeth, and other substantial facial injuries.  She alleged that a defectively-designed and/or defectively-constructed shallow concrete ramp leading from the exit had caused the fall.  We filed a motion for summary judgment, arguing (1) that the plaintiff testified at deposition that she had no specific memory of stepping on the ramp as she exited the building and (2) that the plaintiff had failed to disclose an expert who would opine that any aspect of the ramp violated local building code or otherwise was defective.  Upon receipt of the motion, the plaintiff dismissed her claim.