Illness of Present History The patient is a 56 yrs year old lady.

!p t=Han, no syncope or órth pain , no emesis, no constipation no abdominal no dysphagia, Gl: No change in appetite, .

is a 57 yrs old lady who suffers from: Patient to a Motor Vehicle Accident Whiplash secondary Axial Back Pain Axial Neck Pain Cervical Facet Arthropathy Lumbar Facet Arthropathy Right knee pain - Spüñdylssis without mye!epathy

; without myelopathy or radiculanwhy, or radicG!Gpethy, cervical region) fumbar region) y Pain Mapp -ñéñt Plan - Discussed my philosophy - Continue Maloxicam - Acetarninophen 325 rng, 1-2 Tablets, PO, q4-6 hours.

(Total dose not to exceed 3 grams per day) practicefusion Free cloud based EHR a c a r 3 o 1 -r https·J/static.practicefusion.ccm!c:cc!

the additional following v. SANCHEZ, case

the Clerk's Based Office upon in this follows: resülved those set the filing date, Note of the Issue by DECEMBER assigned the by a Request

2019.These deadlines a preheagr 08, Justice in conference or other order.

Goals for the by SEPTEMBER general represent processing of this and type the of case are case should 06, 2018. goals.

Actual deadliñcs shall as be be As of the current date, the court has no record of a Note of Issue

Third: Deny/denies any knowledge or information sufficient to form a belief as to the truth of any of the allegations contained in the paragraph(s) of the Complaint designated as follows: 1, 2, 3, 5, 6, 7, 8 and 9.

Fifth: Deny/denies any knowledge or information sufficient to form a belief as to the truth of any of the allegations contained in the paragraph(s) of the Complaint designated as follows, and refers all questions of law to the Court: 15.

Eighth: Upon information and belief, some or all of the damages alleged in the plaintiff(s)’s Complaint is/are barred and/or subject to the qualification of the provision of § 4545 of the CPLR.

Ninth: If it is determined that the plaintiff(s) failed to use available seat belts, the defendant(s) plead(s) said fact in mitigation of damages.

Tenth: In the event that any person or entity liable or claimed to be liable for the injuries or damages alleged in this action has been given or may hereafter be given a release or covenant not to sue, the answering defendant(s) will be entitled to protection under New York General Obligations Law 15-108 and the corresponding reduction of any damages that may be determined to be due against the answering defendant(s).

the answering Statement defendant of acts the is as follows: and/or omissions constituting the negligence claimed against That collision said recklessness carelessness, maintenance operation, harm to individuals and carelessly traffic and operating control devices; street markings recklessly operating at and carelessly in ignoring under the caused result the was of, of the negligence and of his motor control and properly lawfully vehicle his motor in negligently thereat; existing his motor vehicle answering vehicle; the subject using subject the occasioned defendant in creating roadway; in failing traffic to obey failing control device a traffic circumstances and roadway; and through by in his ownership, an unreasonable in negligently to observe that controls, existed then and conditions reason of the risk of and and obey street signs in thereat; and there

including, a copy inter the alia, no-fault of the beneficiaries, file with the and dates executed duly amounts paid

Lawrence T. Yablon, being duly sworn, says: I am an attorney admitted to practice law before the courts of the State of New York and am a member of the firm

Plaintiff police is not incidêñt aware report, of any witnesses of which a copy on the subject to the is annexed occurrence, hereto.

set forth Plaintiff on the is not police in possession incidelit report, of any a copy adverse party of which statcñiciit is attached.