Appellate Division of the Supreme Court of the State of New York October 13, 2011 (Anderson v. Zapata)

Defendant’s orthopedist found no limitations of motion regarding plaintiff Rebecca Anderson. Although defendant’s neurologist found that she had limitations in 2010, there is no objective evidence to support a cervical injury (see Toure v Avis Rent A Car Sys., 98 NY2d 345, 353 [2002]).