A treating physician’s certificate, in compliance with N.J.S.A. 39:6A-8(a), is not by itself sufficient to satisfy the “verbal threshold” (now the “limitation on lawsuit option”) so as to warrant a jury trial based on a complaint for noneconomic losses in a case which plaintiff claims to have suffered a “permanent” injury. The summary judgment model of Oswin v. Shaw, 129 N.J. 290 (1992), survives the adoption of the Automobile Insurance Cost Reduction Act of 1998 in such cases.
Associate Editor: Ernest Fantini
