Plaintiffs commenced the instant action for personal injuries arising out of a motor vehicle accident in which plaintiff Michael Schroeder was allegedly injured. Plaintiffs' bill of particulars alleged various back injuries, which were the subject of his deposition and independent medical examination (IME), both of which occurred in early 2002.
In August 2002, the injured plaintiff had surgery on his left shoulder and, in October 2002, plaintiffs served a supplemental...
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