In Curley v. Gateway Communications, Inc., 250 A.D.2d 888, 672 N.Y.S.2d 523 (3d Dep't 1998), the Plaintiff was delivering iron pipe to a construction site. There was no equipment to unload the truck and so a ramp was made with two pieces of wood against the flatbed truck. The plaintiff got on top of the pipes on the truck and when the entire load gave way, he was thrown to the ground and injured. The Court concluded the work exposed the plaintiff to the risk of falling from one elevation to another, and his injuries were proximately caused, as a matter of law, by the lack of any appropriate safety devices.