Preview
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RKL/pd #15128
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
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TINY THOMAS and BIJU JOSE,
Plaintiffs, DEFENDANTS DORCE
AND GALEA OPPOSITION
-against- PLAINTIFFS'
TO MOTION
TO SET ASIDE THE JURY
MATTHEW A. COHEN, M.D., KETSIA DORCE, M.D., VERDICT
CRISTINA M. GALEA, M.D., NORTH AMERICAN
PARTNERS IN ANESTHESIA and NORTH SHORE-
Return Date: 10/16/19
LONG ISLAND HEALTH SYSTEM, NORTH SHORE
UNIVERSITY HOSPITAL, Honorable Allan B. Weiss
IAS Part 2
Defendants.
-------------------------------------------------- x
ROBERT K. LAPPING, an attorney admitted to practice before the Courts of the
State, affirms the following to be true under the penalties of perjury:
1. I am member of KERLEY, WALSH, MATERA & CINQUEMANI, P.C.,
attorneys for defendants, KETSIA DORCE, M.D., CHRISTINA M. GALEA, M.D, and NORTH
AMERICAN PARTNERS IN ANESTHESIA, and was Trial Counsel to those defendants
throughout the jury selection and Trial of this matter from July 1 through July 30, 2019. I submit
this opposition to plaintiff's Motion to set aside the verdict based upon attempted impeachment of
verdict.1
the
2. It iswell established that jurors may not impeach their own verdict. Bedeli
v. Hornick, 245 A.D.2d 538, 666 N.Y.S.2d 498 (2d Dep't 1997); Gabrielle G. v. White Plaim
I
Due to the fact that plaintiff's counsel will not be able to participate in this motion practice
after October 16,2019 pursuant to Mtr. ofLisabeth, Docket No. 2017 11266 dated September 18
2019, the return date of this motion must not be adjourned.
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City Sch. Dist., 106 A.D.3d 776, 964 N.Y.S.2d 603 (2d Dep't 2013). It is also well settled that
absent exceptional circumstances, a juror's affidavit may not be used to attack a jury verdict.
Richards v. Forest City Enters., 272 A.D.2d 462,708 N.Y.S.2d 320 (2d Dep't 2000). The Affidavit
of juror #6, Diane McEvaddy, which plaintiff relies upon in support of the motion seeking to set
aside the jury's verdict based on juror misconduct, contains accusations and surmises, but no facts
upon which this Court can rely on to set aside the verdict and fails to demonstrate exceptional
circumstances. I examine these in detail, as set forth below.
3. Ms. McEvaddy, who sat behind juror #1, Mr. Isaac Emokpae, alleges that
to" "invariably"
he "seemed have slept through half the Trial, missing essential testimony. The
Court may recall all counsel bringing up an episode of Mr. Emokpae's apparent sleepiness on Trial
day#2 when Dr. Galea was on the witness stand. No record was made of this. The Court thereafter
kept Mr. Emokpae under close watch, and found no reason to revisit the issue or remove him
during the remaining eight days of the Trial.
4. Ms. McEvaddy alleges that Mr. Emokpae was functionally illiterate. She
jurors'
states "I'm fairly certain that he didn't understand". While I did not save my copies of the
questionnaires, my notes from jury selection reflect the following: Mr. Emokpae was 67 years
old, married with adult children; he is from Nigeria: holds an MBA, and is a Supervisor of
Investigations for the New York City Department of Homeless Services. Mr. Emokpae has a very
deep voice, and his accent from his native Nigeria made him less easy to understand than other
jurors born here. Ms. McEvaddy's allegation that a supervisor at a New York City Department
with an MBA was functionally illiterate seems contrived, but at best itis evident that she mistook
Mr. Emokpae's heavy accent for illiteracy.
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5. Ms. McEvaddy's statement in the first sentence of paragraph 4 requires
analysis in detail. She states that itwas "apparent that Mr. Emokpae felt a highly inappropriate
racial affinity for Dr. Dorce". Since an allegation of racial bias is raised, itrequires an elucidation
of the racial mix of the parties and the jury. Both plaintiffs, as well as their family members who
testified, are naturalized US citizens who emigrated from India. Defendant Dr. Dorce is a black
woman who was born in the United States but raised in the Caribbean. Defendant Dr. Galea is a
white woman who was born, raised and educated in Romania. Defendant Dr. Cohen is a white
man who was born and raised in the United States. Juror #1, Mr. Emokpae is a black man from
Nigeria. All other jurors and alternates have spent their entire lives in the United States. All
other jurors were white, with the exception of juror #5, Daniel McAulay, a black man.
6. Ms. McEvaddy accuses Mr. Emokpae of racial affinity for Dr. Dorce, but
gives the Court no examples of this upon which to rely. Prior cases which seriously considered a
racial bias issue as invalidating a jury's verdict contain statements of the allegedly biased juror
Sicilian"
such as "I wouldn't believe a (McHugh v._Jones, 258 App Div 111, 16 N.Y.S.2d 332 (2d
out"
Dep't 1939);"we as blacks should not allow whitey to win (People v. Rukaj, 123 A.D.2d 277,
(1"
506 N.Y.S.2d 677 Dep't 1986).
7. Ms. McEvaddy alleges that Mr. Emokpae's racial affinity for Dr. Dorce
"foreclosed any reason or thoughtful consideration of the issues against any of the defendants".
How this black juror's allegedly racial affinity for the black defendant Dr. Dorce foreclosed
consideration of the issues against any of the defendants, including a white defendant born here
and a white defendant born in Romania, remains unsaid and, frankly, unfathomable. Nonetheless,
this allegedly biased juror's voting pattern should be closely scrutinized by the Court. Juror #1,
Mr. Emokpae, voted with all five other jurors to exonerate Dr. Cohen on his departure, Question
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1A. This juror voted with four other jurors (the dissenting juror was #2), to find that Dr. Dorce,
for whom he had an allegedly racial bias, departed from the standard of care in Question 2A. This
allegedly biased juror then voted with all five other jurors, including the juror claiming that he was
racially biased, in exonerating Dr. Dorce on the issue of causation in Question 2B. Please note:
Ms. McEvaddy claims that Mr. Emokpae's racial bias resulted in an injustice, but she and Mr.
Emokpae voted identically to hold Dr. Dorce accountable for a departure but to exonerate her on
the issue of causation. It is,at best, disingenuous of Ms. McEvaddy to claim any injustice when
"biased"
she voted identically to the juror. Returning to Mr. Emokpae, he voted with four other
jurors (juror #2 dissented) in finding that Dr. Galea departed from the standard of care in Question
3A, and voted with four other jurors (Ms. McEvaddy dissenting) in exonerating Dr. Galea on the
issue of causation. How racial biases can be inferred from these facts defies logic. Itis fascinating
that juror #1 Mr. Emokpae, a black man, is accused by Ms. McEvaddy of racial bias, when his
vote on allquestions was the same as that of the other black male juror, #5 Mr. McAulay, who is
not accused. A copy of the Verdict Sheet is annexed as Exhibit A.
8. The law is well settled that jurors may not ordinarily impeach their own
verdict. Moisakis v. Allied Bldg. Products Corp., 265 A.D.2d 457, 697 N.Y.S.2d 100 (2d Dep't
1999). This principle is subject to two well-known exceptions. First, where an error is made in
reporting the verdict, the trialjudge may upon the unanimous affidavits or statements of the jurors,
correct the judgment to conform to the actual verdict. Second, where the record demonstrates
substantial confusion among the jurors in reaching a verdict, the court must direct a new trial to
prevent a miscarriage of justice to the litigants. Porter v. Milhorat, 26 A.D. 3d 424, 424, 809
N.Y.S.2d 210 (2d Dep't 2006). Neither of these situations exists here. There is no evidence that
the verdict was reported incorrectly or that there was substantial confusion among the jurors in
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reaching a verdict and therefore there is no reason to set aside the verdict. Bedell v. Hornick, 245
A.D.2d 538, 666 N.Y.S.2d 498 (2d Dep't 1997).
9. Ms. McEvaddy clearly wanted a different result. This is why we have a
rule permitting a verdict by five of six jurors. Her statement in paragraph 6 evinces a clearly
wrong idea of the law. She says "it is my strong belief, had the jury been polled as to whether
Ms. Thomas was wronged by the anesthesiologists and therefore deserving of compensation, the
affirmative."
answer would have easily been returned 5-1 in the This is not the law. The law
requires both departure and causation, and the Court carefully crafted the questions in the juror
questionnaire accordingly. Dr. Dorce, who is allegedly the beneficiary of racial biases, was
exonerated by all jurors on the issue of a causation, including Ms. McEvaddy, the impeaching
juror.
10. Ms. McEvaddy accuses Mr. Emokpae, and juror #2 Ms. Paulino, of not
engaging in conversations. There is no rule which requires each juror to verbally state his or her
grounds for his or her opinion on a specific question that has gone to the jury. The jury was told
that "you should not surrender conscientious convictions of what the truth is". Clearly, juror #6
Ms. McEvaddy, was the outlier on the issue of holding Dr. Galea liable, just as clearly juror #2,
Ms. Paulino, was the outlier on not holding Dr. Galea liable.
11. The accusations by Ms. McEvaddy do not rise to the level of requiring the
extraordinary step of summoning all six jurors back for further inquiry by the Court, which would
occur three months after the verdict was rendered, nor do they raise exceptional circumstances to
set aside the jury's verdict. There has been no claim that the jury's verdict was against the weight
of the credible evidence, and, indeed, itis supported by the evidence.
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circumstances," juror'
12. Absent "exceptional the court may not use post-trial
affidavits to explore the jury's deliberative process and impeach the jury's verdict. Richards v.
Forest City Enters., 272 A.D.2d 462, 463, 708 N.Y.S.2d 320 (2d Dep't 2000); Careccia v.
Enstrom, 212 A.D.2d 658,659,622 N.Y.S.2d 770 (2d Dep't 1995); Kaufman v. Lilly & Co., 65
N.Y.2d 449, 460, 492 N.Y.S.2d 584, 482 N.E.2d 63 (1985). Exceptional circumstances include
outside influence,Alfordv.Sventek, 53 N.Y.2d 743, 744, 439 N.Y.S.2d 339, 421 N.E.2d 831(1981)
and inherent defects, pervasive confusion, or ambiguity in the verdict, apparent from the verdict
itself or elsewhere in the trial record. Moisakis, 265 LA.D. 2d at 458. Bedell v. Hornick, supra.
verdicts' "chaos"
This rule enhances stability, avoids judicial from post-trial harassment of jurors,
respects their option to keep their deliberations confidential, and promotes freer discussion in
deliberations. Russo v. Jess R. Rifkin, D.D.S., P.C., 113 A.D.2d 570, 575, 497 N.Y.S.2d 41 (2d
Dep't 1985).
13. InCarecciav. Enstrom, 212 A.D.2d at 658, the Court rejected the plaintiff's
contention that the verdict should have been set aside because the only juror to vote against the
County on the issue of proximate cause alleged that there was juror misconduct claiming that one
of the jurors visited the scene of the accident. The case involved personal injuries sustained by the
plaintiff motorcycle driver when he collided with an automobile driven by the defendant. The
Court stated, that absent exceptional circumstances a juror's testimony on affidavit may not be
used to attack the jury verdict. Careccia, 212 A.D.2d at 659.
14. In Gabrielle G. v. White Plains City Sch. Dist., 106 A.D.3d 776, 964
N.Y.S.2d 603 (2d Dep't 2013), itwas held that the Supreme Court properly denied the plaintiff's
motion for an evidentiary hearing and for a new trial. The alleged juror misconduct arose from
deliberations being commenced with the alternate jurors over lunch and upon claims that the jurors
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misunderstood the charge on the standard of negligence. The plaintiff's argument was supported
by affidavits from two alternate jurors and the affirmation of plaintiff's attorney stating his post
trial conversations with the jurors. According to the Appellate Division, the plaintiffs failed to
influence"
establish that the allegations ofjuror irregularities rose to the level of "improper or that
a party's substantial right was prejudiced. Gabrielle, 106 A.D.3d at 777.
15. In Lam v. Cheng, cited by plaintiff's counsel, a defamation and intentional
infliction of emotional distress case, the plaintiff's counsel argued that the verdict should be set
aside for juror misconduct based upon racial bias. The plaintiff contended that four jurors, three
female African American women and one Latina woman repeatedly called the white male jury
bitch"
foreman, names such as "asshole, "son of a and "white man". The four jurors were openly
hostile to him motivated by racial animus stating that the white juror was conspiring with the
plaintiff's white male attorney. The four jurors claimed that there was a homosexual encounter
plaintiffs'
between the white juror and white male attorney. An African American male juror
confirmed the white jury foreman's statement of the alleged bias. The Civil Court in NY County
set aside the jury verdict which was affirmed by the Appellate Term. Plaintiff's counsel failsto
set forth that the case was addressed on appeal to the Appellate Division, First Department. The
Appellate Division, First Department reversed and adopted the opinion of the Appellate Term
Dissent. Lam v. Cheng, 2001 NY Slip Op 40701111(U), affirmed 196 Misc.2d 538 (App. Term
(1st jurors'
2003), reversed 5 A.D.3d 290 Dep't 2004). The opinion of the Dissent states that the
blunderbuss affidavits which were handcrafted by the attomeys should not have been allowed to
impeach the jury verdict since there was no outside influence shown that affected the result, only
speculation. Lam, 196 Misc.2d at 550. The Dissent further stated that the trash talk did not reflect
a racial bias nor did itaffect the verdict. Lam, 196 Misc.2d at 553. In the same manner in this
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case, there is no outside influence, only the speculation of Ms. McEvaddy which is not sufficient
to set aside the jury verdict.
16. There is strong public policy not to impeach a jury's verdict. For example,
it was found to be insufficient to impeach a verdict where a juror alleges that she had been
threatened by the foreman who repeatedly shouted and screamed obscenities and even threatened
to throw the juror out the window, where the jurors discussed the case prior to the conclusion of
the trial and that other jurors were predisposed to find the defendant guilty. People v. Redd, 164
(13t
A.D.2d 34, 35-36, 561 N.Y.S.2d 439 Dep't 1990). In People v. Maddox, 139 A.D.2d 597, 598,
527 N.Y.S.89 (2d Dep't 1988), ly denied 72 N.Y.2d 862, 532 N.Y.S.2d 512 (1988), allegations of
personal attacks, harassment and intimidation by a fellow juror resulting in complaining juror
capitulating to a verdict was insufficient to impeach the verdict.
17. Plaintiff cites LaChapelle v. McLoughlin, 68 A.D.3d 824,891 N.Y.S.2d 428
(2d Dep't 2019). In LaChapelle, the Second Department affirmed that the Supreme Court's denial
of the plaintiff's motion alleging juror misconduct. The interaction between the juror and the
respondent's attorney in the parking lot concerning a jump start to her car did not require a new
trial in the "interests of justice". There was no evidence that substantial justice had not been done
as a result of juror misconduct.
18. Plaintiff's reliance on Anthony v. Schofield, 266 A.D.905, 42 N.Y.S.2d 784
(4th
Dep't 1943) is unavailing. The 1943 case reflects that the juror was biased toward the plaintiff
and was a convicted felon which he failed to disclose. In the interests of justice, the new trial was
granted. Contrary to plaintiff's argument, itwas not the juror's attitude that resulted in setting aside
the verdict, but itwould appear to be his undisclosed felony conviction which prohibited him from
serving on the jury pursuant to Judiciary Law.
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19. Plaintiff's reliance on the 1956 Supreme Court, New York County case
Sheehan v. Doyle, 152 N.Y.S.2d 931 (S.Ct. NY Co. 1956) is equally unavailing. In Sheehan, the
juror did not disclose a claim for personal injuries that he settled without bringing suit, in response
to a direct question as to whether he had ever made a claim or instituted a lawsuit for personal
injuries. To the contrary in this matter, juror McEvaddy erroneously speculates that Mr. Emokpae
did not have functional literacy in English, despite being a supervisor of investigations for the New
York City Department of Homeless Services with an MBA. She further speculates that there was
some racial favoritism to Dr. Dorce by Mr. Emokpae which is neither factually supported nor did
itaffect the verdict as to Dr. Dorce.
20. Plaintiff's counsel also misstates the People v. Karen, 34 Misc. 3d 1239(a)
(Co Ct. Sullivan Co. 2012) case. The People v. Karen case did not determine that there was jury
misconduct at trial based on a female juror who claimed to have her mind made up regarding the
guilt of the defendant and a 19 year old juror who was coerced by two other jurors by threatening
to tellthe Judge and the young juror's employer, that he was seen drinking at the hotel bar. In fact,
the trial court rejected the defendant's motion to set aside the murder conviction based on juror
misconduct. The defendant then appealed the convictions to the Third Department where his
convictions were affirmed and leave was denied by the Court of Appeals. People v. Karen, 17
A.D.3d 865, 793 N.Y.S.2d 273 (3d Dep't 2005) lv denied, 5 N.Y.3d 764, 801 N.Y.S.2d 259, 834
N.E.2d 1269 (2005). A Writ of Habeas Corpus in the United States District Court, Southern
District, which raised the same issues was also denied. The defendant moved again for the same
relief on the theory of improper jury conduct now adding that the 19 year old juror was fired from
his job and the witness from the hearing on juror misconduct was subsequently convicted of a
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felony. The Court again denied the motion to overturn the conviction based on alleged juror
misconduct.
21. Although plaintiff's reading of People v. Karen is obviously erroneous,
plaintiff claims that the facts in this matter are not as obvious as those in People v. Karen, and
further claims they are more harmful than those in People v. Karen. What plaintiff fails to
recognize is that the statements of Ms. McEvaddy are not facts, but rather are speculation and
allegations. Mr. Emokpae must not be illiterate if he has his MBA. While Ms. McEvaddy claims
that she had to translate the jury questionnaire to Mr. Emokpae, the best she could do was to
certain"
speculate that she is "fairly that he did not understand. She provides no factual basis for
her opinion about Mr. Emokpae's understanding of her explanation. While, Ms. McEvaddy
criticizes juror #2, Ms. Paulino, who allegedly chose not to discuss the issues, the Court of Appeals
recognizes that the decision not to discuss isjust a part ofjury deliberations. The Court of Appeals
has stated in People v. De Lucia, 20 N.Y.2d 275, 278, 282 N.Y.S.2d 526, 229 N.E.2d 211 (1967)
in examining the common law rule with respect to jurors impeaching their own verdict:
The policy reason for the present rule is of course, that we do not
wish to encourage the post trial harassing of jurors for statements
which might render their verdicts questionable. With regard to jury
room deliberations, scarcely any verdict might remain unassailable,
if such statements were admissible. Common experience indicates
that at times articulate jurors may intimidate the inarticulate, the
aggressive may unduly influence the docile. Some jurors may
in"
"throw when deliberations have reached an impasse. Others
may attempt to compromise. Permitting jurors to testify regarding
such occurrences would create chaos.
22. It is clear that Ms. McEvaddy's accusations of racial bias and illiteracy
against Mr. Emokpae would harass anyone and particularly Mr. Emokpae, a juror who was simply
performing his civic duty as required. The same holds true for Ms. McEvaddy's accusations
against Ms. Paulino, whose nature was such that she did not engage in conversations with the other
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jurors, is simply jury room deliberations that the Court of Appeals has confirmed that jurors should
not be permitted to testify to such occurrences in the jury room.
23. Plaintiff's counsel acknowledges that summoning the jurors back to Court
extraordinary"
for in camera examinations in this instance "may be however, claims that itwould
not be inappropriate. It is respectfully submitted that in light of the foregoing, that plaintiff has
not shown the exceptional circumstances of outside influences, inherent defects, pervasive
confusion or ambiguity in the verdict to impeach the jury's verdict. Consequently, the use of a
improper."
post-discharge juror affidavit to attack the verdict is "patently Richards, 272 A.D.2d
at 463. Instead, such inquiry would result in post-trial harassment of the jurors which should not
be permitted.
WHEREFORE, it is respectfully submitted that the plaintiff's motion seeking an
Order pursuant to CPLR 4404(a) setting aside the jury's verdict based upon juror misconduct must
be denied in its entirety.
Dated: Seaford, New York
September 27, 2019
BERT K.LAP
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
------------------ ------------------------------------- X Index No.: 708417/2016
TINY THOMAS and BIJU JOSE,
Plaintiffs, CERTIFICATION
PURSUANT TO NYCRR
-against-
SECTION 130-1.1A
MATTHEW A. COHEN, M.D., KETSIA DORCE, M.D., Return Date 10/16/19
CRISTINA M. GALEA, M.D., NORTH AMERICAN
PARTNERS IN ANESTHESIA and NORTH SHORE-
Honorable Allan B. Weiss,
LONG ISLAND HEALTH SYSTEM, NORTH SHORE IAS Part 2
UNIVERSITY HOSPITAL,
Defendants.
---------------¬------------------------------ ------ -------- X
S I R S:
The undersigned hereby certifies that, to the best of my knowledge, information and belief,
formed after an inquiry reasonable under the circumstances, the presentation of the following
paper(s):
PLAINTIFFS'
DEFENDANTS DORCE AND GALEA OPPOSITION TO MOTION
TO SET ASIDE THE JURY VERDICT
is not frivolous as defined in subsection (c) of Section 130-1.1(c).
Dated: Seaford, New York
September 27, 2019
Yours, e .,
KE ,WALS
BÉRT K. J/A
Attorneys for.De nd t
KETSIA DO E, M ., HRI TINA M. GALEA, M.D,
and NORTH AMERICAN P TNERS IN ANESTHESIA
2174 Jackson Avenue
Seaford, NY 11783
(516) 409-6200
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TO:
LAW OFFICES OF JEFFREY S. LISABETH
Attorneys for Plaintiffs
114 Old Country Road, Suite 460
Mineola, NY 11501
(516) 877-1233
AARONSON, RAPPAPORT, FEINSTEIN
& DEUTSCH, LLP
Attorneys for Defendants
MATTHEW A. COHEN, M.D., NORTH SHORE-LONG ISLAND HEALTH SYSTEM and
NORTH SHORE UNIVERSITY HOSPITAL
600 3rd Avenue
New York, NY 10016
(212) 593-6700
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