Gonzalez v. New Jersey Property-Liability Insurance Guaranty Association, A-1298-07T2; Appellate Division; opinion by Alvarez, J.A.D.; decided and approved for publication March 25, 2010. Before Judges Lisa, Baxter, and Alvarez. On appeal from the Law Division, Hudson County, L-3627-07. DDS No. 23-2-7264 [24 pp.]

In this appeal, the Appellate Division considers the validity of the National Arbitration Forum’s (NAF) Rule 4 (now known as Rule 9). The rule requires a person injured in an automobile accident to demonstrate “immediate and irreparable loss or damage” when seeking emergent medical services disputed by a personal injury protection (PIP) insurer.