Brandon successfully prevailed on a motion for summary judgment on the verbal threshold dismissing all claims against his clients in a multi-defendant, multi-accident Hudson County, New Jersey automobile action. Plaintiff claimed injuries following two separate motor vehicle accidents involving different defendants. Brandon represented the owner and driver of the vehicle involved in the subsequent accident, arguing Plaintiff did not meet his proofs in establishing a permanent injury and/or exacerbation sufficient to allow Plaintiff to vault the verbal threshold in the subsequent accident. Plaintiff argued the records and expert reports raised factual issues evidencing Plaintiff injured his left wrist and neck in both accidents, and a jury should determine if his injuries would breach the verbal threshold. Brandon successfully argued Plaintiff (1) failed to provide the AICRA required certification of permanency, (2) failed to provide a comparative analysis regarding Plaintiff’s pre-existing injuries and any injury allegedly exacerbated in the subject accident, and (3) Plaintiff’s medical records and testimony proved he did not sustain injuries that would overcome the verbal threshold.