Range of motion measurements do not require an instrument

If you were injured due to someone else’s careless actions, we understand the challenges you may be facing. As a victim or a surviving family member, you could be dealing with the life-altering consequences of a serious accident.

Frias v Son Tien Liu, 2013 NY Slip Op 04736 (1st Dept. 2013)

From the world of 5102(d) land:

Defendants made a prima facie showing of their entitlement to judgment as a matter of law by submitting the affirmed reports of an orthopedic surgeon who examined the alleged injured body parts, listed the tests he performed and recorded range of motion measurements, expressed in numerical degrees and the corresponding normal values, and found no limitations (see Singer v Gae Limo Corp., 91 AD3d 526, 527 [1st Dept 2012]). The surgeon’s examination was sufficient, even though he did not use an instrument to measure the ranges of motion.

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