Appellate Division of the Supreme Court of the State of New York December 17, 2009 (Sone v. Qamar)

Defendant satisfied her initial burden of demonstrating, prima facie, that plaintiff did not sustain a serious injury as defined by Insurance Law § 5102 (d). Defendant submitted the affirmed report of a neurologist who found no neurological deficits and noted only a 20-degree limitation on flexion in plaintiffs lumbosacral spine.