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John vs Jane

Verified Bill of ParticularsIndex 700123/2024Queens CountyMatter record
v6Fact review

Your confirmation is the only factual authority for this draft

Nothing was inferred. A value shown as missing was not stated in the source. Correct it, fill it, or mark it unavailable so the bill says so deliberately.

Needed before drafting (38)

  • date_purchasedThe date the index number was purchased/the summons and complaint filed (The Bill of Particulars caption and CPLR-compliant pleading header require the date the index number was purchased; it is nowhere in the source.)
  • partiesConfirmation of the full caption as filed — whether any additional defendants (e.g., a separate titled owner of the Nissan, a lessor, or an employer of the operator) are named, and the exact spelling/order of party names on the summons (The Bill of Particulars must be captioned identically to the filed pleading; the source gives only a narrative party list, not the filed caption. A separate vehicle owner or employer would also drive vicarious-liability allegations.)
  • parties[Chanequa Williams].pronounsConfirmation of defendant's pronouns (No pronoun is used for the defendant anywhere in the source; defaulting to they/them may misdescribe the party in narrative allegations.)
  • relationshipsConfirmation from the police report/DMV title records that Chanequa Williams both owned and operated the striking vehicle, and whether the vehicle was used with the owner's permission by anyone else (Ownership/permissive-use (VTL §388) is the basis for vicarious liability; the source states owner-and-operator only in a summary field, not from a title or police record.)
  • unplaced_source_content (pre-suit release)Instruction on how to treat the June 24, 2024 $500.00 Progressive release in light of continued litigation (A signed general release four days post-accident is a potentially case-dispositive defense and may affect what damages can be verified in a sworn Bill of Particulars.)
  • unplaced_source_content (Docs/Lit Merge prior-injury data)Verification whether the extensive prior-injury/pre-existing-condition list and the 10/16/18–11/7/18 confinement belong to this plaintiff or to a different case file (Both the injury list and the prior-history list in Docs/Lit Merge are flagged as possibly belonging to another file; using them would place false sworn statements in the pleading.)
  • accident.locationConfirmation of the exact accident location. The source describes the RFK Bridge 'at or near its intersection with 31st Street,' and the narrative refers to approaching an intersection; the precise roadway, direction of travel, and lane should be confirmed. (The Bill of Particulars must state the place of occurrence with specificity; a bridge roadway and a street intersection are not obviously the same location.)
  • liability_facts (statutory violations)Whether a police report (MV-104) exists and which VTL sections defendant is alleged to have violated (e.g., VTL §1129(a) following too closely). (The Bill of Particulars must specify statutes, ordinances and rules claimed to have been violated; none are stated in the source.)
  • liability_facts (direction of travel / vehicle positions)Direction of travel of both vehicles, number of lanes, speed, and whether any traffic control device governed the intersection. (Standard demanded particulars in an auto case; not stated anywhere in the source.)
  • liability_facts (release)Attorney determination on how to address the June 24, 2024 $500.00 Progressive release, and whether rescission/invalidity will be pleaded. (A signed general release four days post-accident is a potentially dispositive affirmative defense that affects the entire pleading strategy.)
  • noticeConfirmation that this is solely a motor-vehicle matter with no premises or Labor Law component. (Notice allegations are omitted on that basis; if any premises theory exists, notice particulars would be required.)
  • accident.mechanism_subtypesConfirmation whether the collision involved a chain-reaction with the vehicle ahead of plaintiff (the car that slowed) and whether additional parties should be named. (The narrative references a car in front of plaintiff; a multi-vehicle chain reaction would change the mechanism labels and potential defendants.)
  • injuriesA complete list of claimed injuries with body region, laterality, spinal levels, diagnoses, and imaging findings (with modality and date), and whether any injury aggravated a pre-existing condition. (The injury list is the core of the Bill of Particulars; without it no injury allegations can be pleaded, and aggravation of pre-existing conditions must be pleaded specifically.)
  • proceduresAll surgeries, injections and other procedures with exact dates as documented, plus performing provider and facility. (Procedures and their exact dates support the injury claim and damages; estimated dates in a sworn pleading are a defect and expose the client on cross-examination.)
  • providersNames and addresses of all treating providers (hospitals, physicians, physical therapy, chiropractic, radiology) and the dates of treatment for each. (Provider identities, addresses and treatment dates are expressly demanded in a New York Bill of Particulars and drive authorizations and records collection.)
  • permanencyA statement, supported by a treating or examining physician, as to which injuries are claimed to be permanent. (Permanency must be alleged to preserve future pain and suffering damages and to support a serious injury threshold claim in a motor vehicle case.)
  • future_careAny recommended future treatment, surgery, therapy or medication, and any cost estimates as stated by a provider. (Future care must be particularized to claim future medical expenses; costs cannot be computed or estimated by the drafter.)
  • serious_injury_factsUnderlying facts such as limitations in range of motion with measurements, inability to perform specific daily activities, days missed from work or usual activities, and any fracture, dismemberment or significant disfigurement. (In a New York motor vehicle case these underlying facts are required to support the Insurance Law 5102(d) threshold allegation; the statutory category is an attorney determination, not an extraction.)
  • unplaced_source_contentThe actual injuries/treatment narrative and attorney notes — the supplied source contained only the character "v" in both sections. (No factual extraction is possible from the material provided; the bill cannot be drafted until the substantive records or narrative are supplied.)
  • employment.employerName and address of plaintiff's employer at the time of the occurrence. (CPLR 3043(a)(7)-(8) requires identification of employment and lost earnings; the bill cannot allege a wage loss without the employer.)
  • employment.occupationPlaintiff's job title / nature of work. (Needed to particularize the claim of inability to perform work duties and to support any lost earnings claim.)
  • employment.wage_rateRate of pay with its period exactly as documented (e.g., per hour/week/year). (The wage rate is the arithmetic basis for the lost earnings claim; it must be pleaded as stated, not estimated.)
  • employment.additional_employersWhether plaintiff held concurrent employment, and if so each employer and rate. (A multi-employer wage claim must be itemized and computed separately for each employer.)
  • employment.out_of_work_from / out_of_work_toExact first and last dates out of work, and whether the absence is continuing. (Defines the compensable lost earnings period and whether future lost earnings are claimed.)
  • employment.claimed_lost_earningsThe total lost earnings figure claimed, as documented, or authorization to state "to be determined". (Totals may not be derived by the drafter; an unsupported total in a verified bill is a sworn misstatement.)
  • employment.student_statusIf plaintiff was a student, school name and time lost from school. (Lost schooling is a separate item of special damages under CPLR 3043(a)(8).)
  • confinementEach separate period of hospital, rehabilitation, bed and home confinement with facility names and inclusive dates/durations. (CPLR 3043(a)(6) requires the length of confinement to bed and home and to hospital to be pleaded separately.)
  • special_damagesItemized medical, hospital, ambulance, diagnostic, therapy and medication expenses with provider names and amounts, and whether paid or billed. (CPLR 3043(a)(9) requires itemization of special damages; unitemized items may be precluded at trial.)
  • collateral_sourcesAll no-fault, health insurance, Medicare/Medicaid and Workers' Compensation carriers, claim numbers, the benefit type actually paid, and amounts paid. (CPLR 4545 offsets turn on the specific benefit paid; omission risks an unanticipated post-verdict reduction and lien exposure.)
  • property_damageWhether property damage is claimed and in what amount. (Property damage is a separate item of special damages that must be pleaded to be recoverable.)
  • loss_of_services_claimantWhether a derivative claim is asserted and by whom. (A loss of services claim requires its own particulars and a named derivative plaintiff.)
  • unplaced_source_contentThe actual damages/confinement records and attorney notes; the material supplied consisted only of the character "v". (No portion of the Bill of Particulars can be drafted from the submitted material; the entire factual record is absent.)
  • items[].prior_injuryWhether plaintiff sustained any prior injuries, and if so the date, body region and description of each (The Bill of Particulars must respond to demands for prior injuries to the same body parts; an incomplete or omitted response invites preclusion motions and undermines credibility at trial.)
  • items[].prior_accidentWhether plaintiff was involved in any prior accidents (motor vehicle, work, slip/fall or otherwise), with dates and descriptions (Defendants routinely demand prior accident history; undisclosed prior accidents surfacing in records or IME reports damage the claim and can trigger sanctions.)
  • items[].subsequent_accidentWhether plaintiff has been involved in any accident or incident after the subject occurrence, with dates and descriptions (Subsequent accidents are the primary defense causation argument for apportioning or defeating damages; the pleading must be accurate on this point.)
  • items[].preexisting_conditionWhether plaintiff had any pre-existing medical conditions (degenerative, congenital, or otherwise) affecting the claimed body regions, with diagnoses and dates (Pre-existing conditions must be disclosed and reconciled with the injuries pleaded, particularly where degenerative findings appear on imaging.)
  • claims_aggravation_of_preexistingAttorney confirmation whether plaintiff claims aggravation/exacerbation of a pre-existing condition, supported by a treating provider's opinion (This flag must match the injury paragraph. Defaulted to false because the source states nothing supporting aggravation; asserting or denying it incorrectly produces a self-contradictory sworn statement.)
  • unplaced_source_contentThe actual prior/subsequent history narrative and attorney notes — the supplied fields each contain only the single character 'v' and convey no substantive information (No history facts can be extracted from a placeholder; the bill cannot be drafted or verified without the underlying source material.)
23 confirmed15 missing

38 facts extracted

Caption and parties1 to resolve

8 facts

  • caption › court

    Basis: "Supreme Court of the State of New York, County of Queens. Index No. 702930/2025." (Court & Index Number section)

  • caption › county

    Basis: "County of Queens"; accident also "County of Queens, State of New York"

  • caption › index number

    Basis: "Index No. 702930/2025"

  • caption › date purchased

    Basis: No index-number purchase/filing date appears anywhere in the source; only the index number and presiding justice are given.

  • caption › parties #0

    Basis: "Plaintiff: Sultan Karim, DOB: 01/16/1987, residing at 6520 Grand Central, Apt. 2B, Forest Hills, NY 11375." Pronouns evidenced by narrative: "the car in front of him slowing down" and "plaintiff was unable to pursue his usual duties".

  • caption › parties #1

    Basis: "Defendant: Chanequa Williams, residing at 1101 Bunting Street, Clinton, NC 28328."; "Role: Owner and operator of the vehicle that struck plaintiff's vehicle from the rear. Defendant is a North Carolina resident." No pronouns used for this party in the source.

  • caption › relationships #0

    Basis: "Role: Owner and operator of the vehicle that struck plaintiff's vehicle from the rear."

  • caption › relationships #1

    Basis: "the defendant Chanequa Williams's vehicle rear-ended the plaintiff's vehicle"

AccidentComplete

6 facts

  • accident › date

    Basis: "Date of accident: June 20, 2024, at approximately 10:50 AM."

  • accident › time

    Basis: "at approximately 10:50 AM"

  • accident › location

    Basis: "Location: Robert F. Kennedy (RFK) Bridge, at or near its intersection with 31st Street, County of Queens, State of New York."

  • accident › county of occurrence

    Basis: Location line: "County of Queens, State of New York"

  • accident › case type

    Basis: "the defendant Chanequa Williams's vehicle rear-ended the plaintiff's vehicle" — motor vehicle collision

  • accident › mechanism narrative

    Basis: "How It Happened" section, source [8]

Notice and condition2 to resolve

2 facts

  • notice › condition description

    Basis: Motor-vehicle matter; notice fields not applicable

  • notice › condition measurements

    Basis: Motor-vehicle matter; notice fields not applicable

Liability facts1 to resolve

11 facts

  • liability facts #0

    Basis: "As plaintiff Sultan Karim was approaching an intersection and slowed down due to the car in front of him slowing down"

  • liability facts #1

    Basis: "the defendant Chanequa Williams's vehicle rear-ended the plaintiff's vehicle"

  • liability facts #2

    Basis: "Role: Owner and operator of the vehicle that struck plaintiff's vehicle from the rear."

  • liability facts #3

    Basis: "The Complaint alleges the collision was caused solely by defendant's negligence, carelessness, and reckless disregard."

  • liability facts #4

    Basis: "Plaintiff was the restrained driver and did not go to a hospital that day."

  • liability facts #5

    Basis: "The airbags did not deploy and EMS did not arrive on scene."

  • liability facts #6

    Basis: "Plaintiff's vehicle was a 2021 Chevrolet; defendant's vehicle was a Nissan."

  • liability facts #7

    Basis: "Defendant was served via the Secretary of State pursuant to VTL §253 (non-resident motorist)."

  • liability facts #8

    Basis: "Pre-suit BI settlement: Plaintiff signed a release on June 24, 2024 ... for $500.00 with Progressive"

  • liability facts #9

    Basis: "Supreme Court of the State of New York, County of Queens. Index No. 702930/2025."

  • liability facts #10

    Basis: Source contains no reference to a police report or specific VTL violations

Injuries and treatment2 to resolve

2 facts

  • injuries › permanency

    Basis: Source content consists only of the character "v"; no statement regarding permanency.

  • injuries › future care

    Basis: Source content consists only of the character "v"; no statement regarding future care or treatment.

Damages9 to resolve

9 facts

  • damages › employment › employer

    Basis: Source contains only the single character "v"; no employer stated.

  • damages › employment › occupation

    Basis: Source contains only the single character "v"; no occupation stated.

  • damages › employment › wage rate

    Basis: Source contains only the single character "v"; no wage rate stated.

  • damages › employment › out of work from

    Basis: No dates of any kind appear in the source.

  • damages › employment › out of work to

    Basis: No dates of any kind appear in the source.

  • damages › employment › claimed lost earnings

    Basis: No amount stated; no total may be computed.

  • damages › employment › student status

    Basis: No reference to student status in the source.

  • damages › property damage

    Basis: No property damage claim stated in the source.

  • damages › loss of services claimant

    Basis: No derivative/loss of services claimant named in the source.

Confirmed 2 days ago. Any edit voids that confirmation.