In Joseph v. Pitkin Carpet. Inc., 44 AD3d 462 (1st Dept 2007) the defendant made a prima facie showing that its snow removal efforts, while incomplete, did not exacerbate the condition of the sidewalk. In dismissing the complaint, the Appellate Division, First Department held, in language particularly applicable to the facts herein, that: In opposition [to defendant's motion for summary judgment], plaintiff, who offered only her attorney's affirmation in response to the motion, failed to raise a triable issue of fact. Plaintiffs claim that defendant's snow removal efforts made the condition of the sidewalk more hazardous is unsupported by any evidence, constitutes rank speculation and is insufficient to defeat defendant's motion for summary judgment. (Id., at 464.)