Fiorucci-Melosevich v Harris, 2018 NY Slip Op 07410 (2d Dept. 2018)
“In opposition, the plaintiff submitted, inter alia, the affirmation of a physician who stated that he measured the range of motion of the cervical and lumbar regions of the plaintiff’s spine at a recent examination and found significant restrictions. The plaintiff’s physician did not specify the objective test he used to measure the plaintiff’s range of motion.”
Always comes down to the objective tests that were performed, the listing and quantification of the same,