[brief] Among other points, [...] and [...] explain that: - “PIP dispute resolution only applies to disputes over payment of medical expense benefits,” and the payment of medical expenses is not at issue on Plaintiffs’ claims for compensatory damages and other relief, NJb10-11; - the Legislature intended PIP ADR “to resolve expeditiously uncomplicated claims by an insured, an injured person, or a medical provider who has an assignment of benefits, related solely to payment of medical benefits stemming from single accidents, and not broad, complex, multi-defendant IFPA and RICO claims,” *id.* at 11; - the purpose of PIP ADR is to provide an expeditious procedure to resolve disputes about entitlement to payment while the IFPA’s purpose is to root out fraud, *id.* at 13; - “[a]n IFPA case does not constitute a dispute under N.J.S.A. 39:6A-5.1 because it is not a dispute ‘regarding the recovery of medical expense benefits. ’ (emphasis added).  Rather, it is a dispute about whether an entity has defrauded an insurance company,” *id.* at 14; • “the Legislature could not have intended IFPA claims to be subject to PIP arbitration because an insurance company who claims fraud cannot obtain any of the relief permitted by the IFPA in a PIP no-fault arbitration,” *ibid.*; • “[a] PIP arbitrator’s complete lack of authority to make mandatory damage awards and grant equitable relief plainly shows that the Legislature did not intend that IFPA and RICO claims be decided in a PIP arbitration,” *id.* at 17-18; • “the very limited discovery allowed in a PIP arbitration clearly shows that the Legislature never intended that broad, multi-defendant IFPA and RICO claims be arbitrated there,” *id.* at 18; • [...]’s regulations do not provide “parameters” for insurance-fraud cases, which “frequently involve many parties, complex schemes, and require large amounts of fact and financial discovery,” *id.* at 19; • “[t]hat neither the Commissioner’s regulations nor the court rules contemplated such complex disputes in PIP arbitration is a very significant indication that such arbitrations were never intended to cover IFPA or RICO claims,” *id.* at 20; • “[i]n a PIP arbitration, neither claim, nor party, aggregation is possible,” but “both the IFPA and RICO involve the aggregation of claims against multiple defendants who acted in concert, and the aggregation of similar claims, to establish ‘patterns’ of IFPA or racketeering violations,” id. at 20-21; • the rules adopted by [...], the organization that [...] designated to administer PIP ADR, “do not provide for the types of discovery that a party bringing (or defending) a large and complex case alleging IFPA violations would require to prove (or rebut) the allegations and penalties that are being sought,” id. at 22; • “the Third Circuit’s cursory and flawed analysis and holding in GEICO that an insurer’s affirmative IFPA claims are subject to PIP arbitration is simply wrong on numerous levels,” id. at 24; • “the Department cannot intervene in IFPA cases that are sent to PIP arbitration, since those proceedings do not contemplate intervenor action by the Department to enforce the IFPA,” id. at 27; and • “AICRA calls for more, not less, statewide fraud fighting capabilities.