Zupo v. CNA Insurance

On certification granted, 97 N.J. 584 (1984), we have reviewed the Appellate Division’s holding that “when a carrier has made [personal injury protection benefits] payments in connection with a compensable injury and is chargeable with knowledge at the time of its last payment that the injury will probably require future treatment, then the ‘two-year after *32payment’ provision of N.J.S.A. 39:6A-13.1 will not bar an action brought within a reasonable time after rejection of a prompt claim for payment of additional medical expenses for such treatment.” Zupo v. CNA Ins. Co., 193 N.J.Super. 374,…