Kevin Hulslander and Karen Felter obtained pre-deposition summary judgment and dismissal of complaint in a serious leg-off case against a local forklift distributor. Defendant relied on a creative Espinal defense to extinguish the negligence claims against the distributor. Supreme Court, Broome County agreed based on detailed factual submissions in support of defendant’s motion that it merely performed pre-delivery inspection of the subject forklift and minimal warranty work and that defendant did not create or exacerbate any dangerous condition alleged by plaintiff to have caused or contributed to his injuries.