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Swinton v. Kamiyama, 147 A.D.3d 803 (2d Dept 2017)

Co-Defendant was the middle vehicle in a 3 vehicle rear-end chain accident.  Co-Defendant moved for summary judgment, which was denied by the lower court.  The Appellate Division affirmed, noting that there were questions of fact (i.e., order of impacts), as to whether the middle vehicle contributed to the proximate causation of this accident.

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