Coming on the heels of the New York Court of Appeals’ recent decision in Parker v. Mobil Oil Corp., the Appellate Division, Second Department held in Edelson v. Placeway Constr. Co. that the plaintiff’s expert’s affidavit was speculative regarding causation of the plaintiff’s injuries. The plaintiff alleged injuries from a toxic chemical exposure to the chemical Lustran. The Court held that a plaintiff alleging injuries from a toxic chemical exposure must provide objective evidence that the exposure caused the injury, and the plaintiffs’ expert’s affidavit merely asserted in conclusory fashion that Edelson’s symptoms were the result of her exposure to the chemical. No objective tests were administered to diagnose or treat Edelson. As such, the Court held that the plaintiff failed to raise a triable issue of fact to defeat the defendants’ summary judgment motion.