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When Your Own IME Doctor Kills Your Motion
February 26, 2026

When Your Own IME Doctor Kills Your Motion

Three patterns from recent New York appellate and trial court decisions show how defense IME reports undermine serious injury motions under Insurance Law 5102(d): contradictory findings, the 20% ROM line, and non-standard norms.

Tommy EberleTommy Eberle
The Movant's Own Evidence Problem: NY Motor Vehicle Liability MSJ Failures
February 24, 2026

The Movant's Own Evidence Problem: NY Motor Vehicle Liability MSJ Failures

Tommy EberleTommy Eberle
Same Defendant, Same Crash, Two Different Outcomes: What Graves Amendment Motions Live and Die On
February 20, 2026

Same Defendant, Same Crash, Two Different Outcomes: What Graves Amendment Motions Live and Die On

Tommy EberleTommy Eberle
The #1 Reason Serious Injury MSJs Get Reversed
February 18, 2026

The #1 Reason Serious Injury MSJs Get Reversed

Tommy EberleTommy Eberle
7 CPLR 4518 Attacks That Defeated MCA Summary Judgment in 2024
February 4, 2026

7 CPLR 4518 Attacks That Defeated MCA Summary Judgment in 2024

Tommy EberleTommy Eberle
What We Learned Researching Motions to Vacate in MCA Cases
January 23, 2026

What We Learned Researching Motions to Vacate in MCA Cases

Tommy EberleTommy Eberle
Chain of Title Evidence in NY Debt Buyer Summary Judgment Motions
January 20, 2026

Chain of Title Evidence in NY Debt Buyer Summary Judgment Motions

Tommy EberleTommy Eberle
What 7 NY Appellate Decisions Tell Us About MCA Usury Defense in 2024-2025
January 7, 2026

What 7 NY Appellate Decisions Tell Us About MCA Usury Defense in 2024-2025

Tommy EberleTommy Eberle
What NY Debt Buyer Cases Reveal: Evidentiary Gaps and Procedural Pitfalls (2023-2025)
January 6, 2026

What NY Debt Buyer Cases Reveal: Evidentiary Gaps and Procedural Pitfalls (2023-2025)

Tommy EberleTommy Eberle
December 2, 2025

How to Format Attorney Signature Blocks in Answers Perfectly in Word Every Time

Tommy EberleTommy Eberle
December 1, 2025

How to Draft Consumer Debt Answers Faster by Using Styles in Microsoft Word

Tommy EberleTommy Eberle
November 26, 2025

How to Find Consumer Debt Dockets in New York State

Tommy EberleTommy Eberle
November 26, 2025

How to Keep the Attorney Signature Block on a Single Page in Microsoft Word

Tommy EberleTommy Eberle

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