Wingate, Russotti, Shapiro, Moses & Halperin, LLP attorneys Kenneth Halperin and Noah Katz obtained a $2,400,000 recovery on behalf of a union carpenter who tripped and fell over plywood, which served as floor protection covering of the pre-existing marble floor. Ken and Noah showed through photographic evidence and testimony of the construction manager that the plywood was cut to accommodate a doorway under renovation and that the plywood was not flush with the floor surface, resulting in a tripping hazard. They also showed that the plywood could have been placed in a safer manner notwithstanding the positioning near the doorway. The plaintiff was working near the plywood when he tripped over the mid-leveled portion of the plywood, sustaining an injury to his ankle, which required arthroscopic surgery. Subsequently, as a result of his gait impairment, the plaintiff developed worsening back pain that required him to undergo a laminectomy and, as a consequence, he is unable to return to work in the foreseeable future due to his injuries. The defendants contended that the back injury was not related to the case and was a result of a pre-existing degenerative condition. The case settled approximately one year before trial for $2,400,000.