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DocketDrafterJane Roe v. John Doe
Summary Judgment Motion · Created May 9, 2026 · Input Documents (11)
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PRELIMINARY STATEMENT
This affirmation is submitted in support of defendant John Doe’s motion, pursuant to CPLR 3212, for summary judgment dismissing the complaint of plaintiff Jane Roe on the ground that plaintiff did not sustain a “serious injury” within the meaning of Insurance Law § 5102(d) as a result of the motor vehicle accident of March 3, 2024.
STATEMENT OF FACTS
1.Plaintiff alleges in the bill of particulars that she sustained injuries to the cervical and lumbar spine. Defendant’s independent orthopedic examination, annexed as Exhibit G, records full range of motion and resolved sprains.
2.Plaintiff’s certified treatment records, annexed as Exhibit J (NYSCEF Doc. No. 27), reflect that treatment ceased approximately four months after the accident, with no documented explanation for the cessation.
ARGUMENT
3.A defendant moving for summary judgment on the issue of serious injury bears the initial burden of establishing, through competent medical evidence, that the plaintiff did not sustain a serious injury causally related to the accident. See Toure v. Avis Rent A Car Sys..
4.Defendant has met that burden. The affirmed report of Dr. Alan Pierce, annexed as Exhibit G, sets forth quantified range-of-motion findings compared against normal values and concludes that the claimed injuries are not causally related to the accident of March 3, 2024. An unexplained gap in treatment further severs any causal chain. See Pommells v. Perez.
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You pull up an old motion, swap the facts, and manually match 11 exhibits to 98 paragraphs. The case law stays the same; the dates, body parts, and exhibit letters change. The risk is not the wrong case. It is Exhibit “G” instead of Exhibit “H” on page 12.
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A threshold motion with a 10% chance of winning still drives settlements down the day it is filed. But across 200 cases, the borderline ones keep getting pushed to next week. The motions that don't get filed are not weaker cases. They are just further down the pile.
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One Wrong Exhibit Reference and the Motion Fails
Mapping 29 exhibits to 98 paragraphs, the risk is not legal error. It is the old plaintiff's name in paragraph 14. It is Exhibit “G” when you meant Exhibit “H.” It is a date on page 12 that came from the last case you copied from.
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Motion Types We Support
The same playbook approach applied to every motion type in motor vehicle tort defense.
5102(d) Threshold MSJ
Addresses every claimed body part, injury category, and the 90/180-day threshold. Matches IME findings to deposition testimony and medical records.
Graves Amendment MSJ
Maps the complaint and bill of particulars to your maintenance evidence. Flags gaps between what the plaintiff alleged and what your records cover.
Liability MSJ Opposition
Turns the plaintiff’s own submissions against them. Surfaces contradictions, VTL violations, and comparative fault admissions across deposition transcripts and police reports.
Motion to Compel Discovery
Full motion package with good faith affirmation under 22 NYCRR 202.7 and conditional order language under Gibbs v St. Barnabas.
From Our Research
Case Law Digest
Insurance Law §5102(d):
Serious Injury Threshold
Case Law Digest
30+ appellate decisions from 2025–2026 on the defendant’s prima facie burden, organized by the 12 issues that decide serious injury threshold motions.
Published
March 2026
Jurisdiction
New York
Coverage
Jan 2025 – Feb 2026
Case Law Digest
Insurance Law 5102(d): 30+ Appellate Decisions from 2025-2026
Every issue that decides serious injury threshold motions, organized by topic: prima facie burden, ROM thresholds, exacerbation, 90/180-day category, treatment gaps, and more. With key quotes and citations from each decision.
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Tommy Eberle, DocketDrafter Co-Founder and CEO