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The self-imposed ROM continuumSeptember 13, 2019

Mondesir v Ahmed, 2019 NY Slip Op 06489 (2d Dept. 2019)

“One of the defendants’ experts found significant limitations in the range of motion of the cervical region of the plaintiff’s spine and failed to adequately explain and substantiate, with competent medical evidence, his belief that the limitations were self-imposed (see Singleton v F & R Royal, Inc., 166 AD3d 837, 838; Rivas v Hill, 162 AD3d 809, 810-811; Miller v Ebrahim, 134 AD3d 915, 916; Mercado v Mendoza, 133 AD3d 833, 834; Miller v Bratsilova, 118 AD3d 761).”

How many times have we read the same thing: the ROM limitations are self-imposed.

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