What is the effect of not having photographs or statements of eye witnesses on a motion for summary judgment?

I note in at least two cases obiter comments have been made with respect to the question of prejudice had photographs or statements of eye witnesses been available. In Kors v. City of Toronto, [2006] 25 M.P.L.R. (4th) 70 Lederman J. granted the City’s motion for summary judgment because there was no reasonable excuse for the plaintiff’s delay in providing notice and because the city was prejudiced in its defence. In dismissing the plaintiff’s claim, Lederman J. noted as follows, albeit obiter: “The lack of timely notice or other potential witnesses is particularly acute in this case since the plaintiff has no photographs of the condition of the area; has not provided any detailed description of the snow and ice problem that existed; and has no corroborating evidence from witnesses with respect to the alleged state of the snow and ice conditions at the location of his fall.”