Plaintiff was injured, according to his deposition testimony, when, during a rainstorm, he simply slipped and fell on a wet platform outside of defendant's hotel entrance where there were "puddles of water." Subsequently, in response to defendant's prima facie showing that it was entitled to summary judgment, plaintiff alleged for the first time that he slipped and fell due to structural defects in the platform. In support of this contention, he submitted an affidavit of...
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