The third counterclaim for tortious interference with a business relationship also fails to state a cause of action. Tortious interference with business relations requires allegations that a third party would have entered into a contract or economic relationship with the plaintiff but for the defendant's wrongful conduct (Vigoda v. DCA Prods. Plus, 293 A.D.2d 265, 266 ; Murtha v. Kalhorn, 237 A.D.2d 496, 497 ). Conduct constituting tortious interference with business relations is, by definition, conduct directed, not at the plaintiff, but at the party with which the plaintiff has or seeks to have a relationship (Carvel Corp. v. Noonan, 3 NY3d 182, 192 ).

Tortious interference with prospective economic relations requires allegations that a third party would have entered into a contractual or economic relationship with the plaintiff but for the defendant's wrongful conduct ( Vigoda v DCA Prods. Plus, 293 AD2d 265, 266; Murtha v Kalhorn, 237 AD2d 496, 497). In order to recover damages in such a situation, the plaintiff is required to show that the defendant used wrongful means.

Where, as here, plaintiffs submit an expert's medical affidavit which demonstrates the objective tests administered as well as how those tests support a finding that Ms. Zito has suffered a serious injury, plaintiffs have met their burden of demonstrating an issue of fact which precludes summary judgment. Steuer v. DiDunna, 233 A.D.2d 494 (2nd Dep't 1996);Puma v. Player, 233 A.D.2d 308 (2nd Dep't 1996); Murtha v. Kalhorn, 237 A.D.2d 496 (2nd Dep't 1997). This is especially so when plaintiffs' expert sets forth the loss of degrees of Ms. Zito's range of motion.Steuer v. DiDunna, supra; Eng v. New Main Line Trading Corporation, 249 A.D.2d 359 (2nd Dep't 1998); Pareti v. Giglietta, 221 A.D.2d 607 (2nd Dep't 1995).