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Dump whatever the carrier sends you. DocketDrafter identifies the NF-10s, scheduling letters, denial forms, and transcripts, splits them into labeled exhibits, computes denial timelines bill by bill, and produces the affirmation in support with every factual assertion tied to a specific exhibit.
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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500 Pages In. One Motion Out.
Every Detail Has to Be Right.
The Carrier Sends a 500-Page PDF. Your Paralegal Sorts It by Hand.
Some carriers send organized files. Others send one PDF, hundreds of pages: duplicate NF-10s (one signed, two unsigned), bills from the wrong claimant, reprocessed EURs for the same date of service. Your staff spends an hour just figuring out which pages are which before the motion work even starts.
Upload Whatever They Give You. We Sort It.
- Reads the entire claim file, however it arrives
- Identifies NF-10s, scheduling letters, denial forms, and transcripts
- Splits them into labeled exhibits in your firm’s format
- Flags missing documents before you start drafting
The 30-Day Clock Does Not Care How Busy You Are
Every denial must land within 30 days of the final EUO no-show or completed verification. Miss one bill by one day and the defense is precluded, no matter how strong the rest of the proof is. With five bills on different verification chains, the timeline math is where mistakes hide.
Every Timeline Computed Before You File
- Computes the 30-day window for each bill from the final no-show or completed verification
- Flags any denial that may be untimely
- Every date references a specific exhibit letter
Same Structure. Different Dates. Every Single Case.
Each bill paragraph follows the same pattern: receipt date, verification dates, denial date, day count. You copy from an old motion and swap dates by hand. Three bills is fine. Ten bills on different verification chains is where you copy a date from the last case and do not catch it.
Bill-by-Bill Paragraphs From the Claim File
- Generates each bill paragraph from the uploaded documents
- Receipt dates, verification request dates, denial dates, and day counts
- No copy-paste, no leftover dates from the last case
Exhibit H When You Meant Exhibit G
Each bill gets its own denial, EOB, peer review, and verification requests packaged as a single exhibit. With five or more bills, the letters run A through K or beyond. One mismatched reference and the court cannot follow your proof.
Every Exhibit Reference Mapped Automatically
- Assigns exhibit letters and maps every paragraph reference to the right exhibit
- Court-formatted Word doc: caption, signature blocks, exhibit cover pages
- Fully editable
“Where Did You Get This Template From?”
Your staff finds an old motion that looks close enough and swaps the dates. But the fee schedule version is wrong, or the case law is from the wrong appellate department, or a paragraph from the last case is still in there. You catch it in review. You catch it every week.
One Playbook. Every Motion. Always Current.
- Selects the correct fee schedule version for the claim
- Correct appellate department case law and defense theory
- Update the playbook once; every future motion gets it automatically
Motion Types We Support
Every case citation is pre-vetted by attorneys. DocketDrafter does not do research. It applies known-good strategies to new facts.
No-Fault Summary Judgment
Full affirmation in support with defense theory selection, claims examiner affidavit language, and bill-by-bill breakdowns. EUO non-appearance, lack of medical necessity, 45-day late submission, or non-cooperation.
From Our Research
Case Law Digest
New York No-Fault:
Case Law Digest
50 decisions from 2025–2026 covering EUO non-appearance, timely denial, verification compliance, policy exhaustion, and 12 other topics that decide no-fault summary judgment motions.
Published
March 2026
Jurisdiction
New York
Coverage
Jan 2025 – Feb 2026
Case Law Digest
New York No-Fault: 50 Decisions from 2025-2026
EUO non-appearance, timely denial, verification compliance, policy exhaustion, Mallela, late claim submission, and more. Organized by topic with key holdings and citations from each decision.
Email tommy@docketdrafter.com for a copy
Tommy Eberle, DocketDrafter Co-Founder and CEO
Mallela After Mayzenberg: What Insurers Can and Cannot Deny Under 11 NYCRR 65-3.16(a)(12)
The Court of Appeals limited the Mallela defense in Mayzenberg, while the Appellate Term clarified how insurers can use verification requests for corporate records.
The Evidentiary Rules Shaping EUO Non-Appearance Motions
Recent Appellate Term decisions on proving mailing, non-appearance, and timely denial. Plus the departmental split on objective justification.