In Putnam Rolling Ladder Co., Inc. v. Manufacturers Hanover Trust Co., 74 N.Y.2d 340 [1989] the Court of Appeals held that the evidence was sufficient to show that the bank's inspection procedures "were so superficial as to offer no realistic opportunity to detect forged checks" (Putnam Rolling at 346). The evidence submitted at trial was that using the identical, routine procedures for check review there were five facially defective checks paid by the Bank. In Putnam Rolling Ladder there was some evidence presented by the customer to establish lack of ordinary care on the part of the bank in paying the items.