Order to Show Cause: Terrance Anthony Small v. Long Island Jewish Medical Center, North Shore - Long Island Jewish Health System, Inc., Northwell Health, Inc.

On July 07, 2016 a Order to Show Cause was filed involving a dispute between Terrance Anthony Small, and Long Island Jewish Medical Center, North Shore - Long Island Jewish Health System, Inc., Northwell Health, Inc., for Torts - Medical, Dental, or Podiatrist Malpractice in the District Court of Queens County.

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FILED: QUEENS COUNTY CLERK 06/28/2019 05:39 PM INDEX NO. 707979/2016
NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 06/28/2019

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
------------------------------------------------------------------X
TERRANCE ANTHONY SMALL,
Index No: 707979/2016E

Plaintiff,
AFFIRMATION IN
- against - OPPOSITION

LONG ISLAND JEWISH MEDICAL CENTER,

Defendants.
------------------------------------------------------------------X

I,CHRISTOPER R. DEAN, an attorney admitted to practice before the Courts of the State

of New York, affirm that the following statements are true under penalties of perjury:

1. I am associated with the law firm DELL & DEAN, PLLC, the attorneys for the Plaintiff

TERRANCE ANTHONY SMALL (hereinafter "Plaintiff") in the above captioned action,

and am familiar with the facts and circumstances as revealed by the file maintained in my

office.

2. I am respectfully submitting this Affirmation in Opposition to Defendant LONG ISLAND

JEWISH MEDICAL CENTER's (hereinafter "Defendant") application for an Order: (a)

Pursuant to CPLR § 3101 (d) striking this matter from the trial calendar and precluding

Plaintiff's expert testimony based on new theories of liability; (c) or in the alternative, that

Plaintiff be ordered to reveal the identity of his expert should the trial proceed; or (d) in the

interim pursuant to CPLR § 2201, staying the trial of this action for 60 days to allow

adequate time for Defendant to subpoena records for use at trial and complete additional

necessary discovery; and respectfully request an Order dismissing Defendant's motion in

its entirety and granting Plaintiff such other and further relief as this Honorable Court may

deem just and proper.

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PRELIMINARY STATEMENT

3. This is a medical malpractice action to recover damages for serious injuries sustained by

Plaintiff as the result of the Defendant's alleged failure in negligently placing a NAC IV in

Plaintiff's right arm. It is further claimed that Defendant failed to timely and properly

recognize compartment syndrome of Plaintiff's right hand and arm.

4. As a result of the abovementioned occurrence, Plaintiff sustained severe and permanent

injuries, including but not limited to: (a) acute compartment syndrome of right hand; (b)

myoneural ischemia; (c) microvascular compromise; and (d) muscle and nerve ischemia.

5. Defendant now moves to strike this matter from the trial calendar and preclude Plaintiff's

expert testimony based on new theories of liability.

6. Foremost, Defendant claims that Plaintiff has failed to provide the required authorizations

for trial,which include Arons authorizations.

7. Specifically, Defendant professes that, "it is inexcusable that one week before trialthat

Plaintiff has yet to serve trial authorizations in a medical malpractice case where his

fact."
medical condition is the central issue to be decided by the trier of

8. However, as evidenced below, Plaintiff has in fact complied with all discovery demands

and has supplied Defendant with numerous trial and Arons authorizations.

9. Moreover, it isevident that Defendant can no longer correlate any prejudice between the

time itreceived the disputed trial authorizations to the amount of time ithas left to prepare

for trial, as this action was deferred on this Honorable Court's active trial calendar until

September 23, 2019. As such, Defendant now has over three (3) months to properly process

"I."
alltrial and Arons authorizations. S_ee Exhibit

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10. Regarding Plaintiff's expert disclosure itself, as required by CPLR § 3101(d), Defendant

cites to two specific deficiencies in its moving papers, as justifications to why Plaintiff's

expert must be precluded.

defendant."
11. First, Defendant argues that, "Plaintiff is attempting an ambush of the This

"ambush"
Defendant claims is the result of Plaintiff untimely serving expert disclosure

three (3) days after the deadline imposed by this Honorable Court.

12. However, as referenced in Saldivar v. I.J. White Corp., an action decided by the Appellate

Division, Second Department, "CPLR 3101(d)(1)(i) does not require a party to respond to

a demand for expert witness information 'at any specific time nor does it mandate that a

party be precluded from proffering expert testimony merely because of noncompliance

statute,'
with the unless there is evidence of intentional or willful failure to disclose and a

party"
showing of prejudice by the opposing (Aversa v. Taubes, 194 A.D.2d 580, 582, 598

N.Y.S.2d 801, quoting Lillis v. D'Souza, 174 A.D.2d 976, 572 N.Y.S.2d 136; see Gayz v.

Kirby, 41 A.D.3d 782, 839 N.Y.S.2d 196).

13. Here, there is no evidence that the Plaintiff's service of 3101(d) prior to the trial was

willfully in violation of any Court Order. More importantly, Defendant was not prejudiced

by the Plaintiffs delay given that the Plaintiff had served the defendant the requested

subject matter, only three (3) days after this Honorable Courts Order. S_ee Saldivar v I.J.

White Corp., 46 AD3d 660, 661 [2d Dept 2007].

14. Likewise, any claimed prejudice to Defendant was ameliorated by this Honorable Court by

granting an adjournment of the trial until September 23, 2019.

15. As the Appellate Division, Second Department has generally recognized, "the statutory

scheme provides that, even where one party requests trial expert disclosure during

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discovery pursuant to CPLR 3101(d)(1)(i), a recipient party who does not respond to the

request until after the filing of the note of issue and certificate of readiness will not

testimony."
automatically be subject to preclusion of its expert's trial See Rivers v.

Birnbaum, 102 AD3d 26, 37 [2d Dept 2012].

16. Second, Defendant argues that Plaintiff's expert should be precluded, as it claims that the

disclosure is deficient and lacks essential material.

17. However, as reiterated in Thomas v. Alleyne, "Specifically, the last sentence of CPLR

3101(d)(1)(i) states, in part, "[i]n an action for medical, dental or podiatric malpractice, a

party, in responding to a request, may omit the names of medical, dental, or podiatric

experts but shall be required to disclose all other information concerning such experts

otherwise required by this paragraph (emphasis added). See Thomas v. Alleyne, 302

A.D.2d 36, 40, 752 N.Y.S.2d 362, 366 (2002).

18. As evidenced in Plaintiff's Expert Exchange Pursuant to CPLR 3101 (d),the qualifications

detail." "E."
of said Expert are stated in "reasonable See Exhibit

19. To the extent that there is any rule to the effect that a plaintiff in a medical malpractice

action, in responding to a demand that he or she describe his or her proposed expert's

qualifications, need not provide any data that would allow for relatively effortless

determination of such expert's identity, such rule is entirely the product of case law (see

Jasopersaud v. Tao Gyoun Rho, supra; see also Thompson v. Swaintek, 291 A.D.2d 884,

736 N.Y.S.2d 819; Morris v. Clements, 228 A.D.2d 990, 644 N.Y.S.2d 850; Yablon v.

Coburn, 219 A.D.2d 560, 631 N.Y.S.2d 351).

20. Accordingly, all outstanding discovery is complete. Further, Plaintiff's expert should not

be precluded, as Plaintiff's disclosure does in fact conform to CPLR § 3101(d).

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21. Based on the foregoing, Plaintiff respectfully requests, that this Honorable Court deny

Defendant's motion in itsentirety.

PRO_CEDURAL HISTORY

22. Plaintiff commenced this action by filing the Summons and Verified Complaint on July 7,

"A."
2016, a copy of which is annexed hereto as Exhibit

23. Issue was joined by Defendant by filing an Answer on August 15, 2016, a copy of which

"B."
is annexed hereto as Exhibit

24. Thereafter, on January 8, 2018, Plaintiff filed itsNote of Issue and Certificate of Readiness

for Trial. See copy of Plaintiff's Note of Issue and Certificate of Readiness, annexed hereto

"C."
as Exhibit

25. Plaintiff notes that the email exchange provided by Defendant in its moving papers,

inexplicably fails to provide the full email correspondence between Defendant and

response"
Plaintiff's counsel. To say that there was, "no to Defendant's request is a blatant

falsehood and misrepresentation made to this Honorable Court. As evidenced, Joseph

Muzio, Esq., provided an email response, which was only one (1) day after Defendant's

email request, dated April 26, 2019. See copy of email correspondence, annexed hereto as

"D."
Exhibit

26. Additionally, Defendant actually failed to respond to requests from Plaintiff's counsel,

including ignoring our correspondence asking for a, "copy of all LIJ records aside from the

admission in issue...these would include physch (Zucker) and apparently PT records which

feasible...thanks."
may be included in one set. We can use Dropbox if It is the Plaintiff

response"
that can truly say that there was actually "no from the Defendant. As such,

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Plaintiff was justified in its slight delay in in providing the below-mentioned expert

"D."
disclosure due to Defendants own non-compliance. See Exhibit

27. Moving to May 20, 2012, Plaintiff in fact provided itsExpert Exchange Pursuant to CPLR

§ 3101(d). Said expert is a physician duly licensed to practice medicine in the State of

New Hampshire and Massachusetts. See copy Plaintiff's Expert Exchange Pursuant to

"E."
CPLR § 3101 (d), armexed hereto as Exhibit

28. Three (3) days thereafter, on May 23, 2019, Defendant sent a letterto Plaintiff, which states

in part, "We are in receipt of plaintiff's response to the Demand for Expert Disclosure

pursuant to CPLR § 3101 (d), dated May 20, 2019. We hereby reject same as itis expressly

precluded pursuant to the court's order, directing that same be served by May 17, 2019.

We note that the May 17, 2019 date was an enlargement of the original court ordered

2019."
deadline of March 15, See copy of Defendant's correspondence regarding same,

"F."
annexed hereto as Exhibit

29. On June 11, 2019, Plaintiff served Defendant duly executed Arons authorizations for the

following medical providers: (a) Dr. Kambiz Jacob Cohen-Kashi; (b) Dr. Justin Yoon; (c)

Dr. Matthew Demauro; (d) Dr.Amrita Khokhar; and (e) Dr. Najma Ahmed. Moreover,

Plaintiff served duly executed trial authorization for the following providers: (a) Long

Island Jewish Medical Center; (b) Medicaid; (c) Emblem Health/HIP Health Plan; (d) Dr.

Najma Ahmed of Advantage Care Physicians; (e) Dr. Rohit Verma; and (f) Dr. Tiffany

"G."
Wu. See copy of Plaintiff's Response, annexed hereto as Exhibit

30. One day thereafter, on June 12, 2019, a So-Ordered Stipulation was agreed to by both

parties, where it was stipulated that, "Defendants OTSC is hereby adjourned to 7/10/10.

Plaintiff's Opposition is due on 6/26/19. The trial of this matter is hereby adjourned to

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days."
9/23/19. In addition, Plaintiff to provide trialAz for Dr. Cohen-Kashi within 10 See

"H."
copy of said Stipulation, annexed hereto as Exhibit

31. On June 13, 2019, Defendant sent a follow-up letter to Plaintiff requesting a trial

authorization for Dr. Kambiz Jacob Cohen-Kashi. In said correspondence, Defendant also

stated, "As to any subsequent treatment sought with any physicians, including but not

limited to orthopedist, Dr. Rohit Verma and hand surgeon, Dr. Tiffany Wu, we reject the

authorizations given to us and will oppose any attempt by you to introduce any evidence

of subsequent treatment pursuant to the prior orders hereto and your persistent lack of

compliance." "I."
See copy of Defendant's correspondence, annexed hereto as Exhibit

compliance"
32. In is worthy to note that Defendant cites to a "lack of only almost one month

a_gg Plaintiff provided itsExpert Disclosure. In addition, Plaintiff provided Duly executed

compliance."
Arson and trial authorizations two (2) days before said "lack of

33. In actuality, the only thing that is lacking is Defendants knowledge of the discovery in its

own possession.

34. As such, as a follow up to Defendant's request, on June 24, 2019, Plaintiff provided the

Plaintiffs'
trialauthorization to Dr. Cohen-Kashi. See copy of additional response, annexed

"J."
hereto as Exhibit

35. As evidenced, all discovery requested by Defendant, and claimed to be outstanding, has

been provided.

36. Based on the foregoing, Plaintiffs respectfully request, that this Honorable Court deny

Defendant's motion in itsentirety as Plaintiffs have complied with all Orders, and have not

acted willfully or contumaciously.

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ARGUMENT

L PLAINTIFF'S EXPERT SHOULD NOT BE PRECLUDED

37. At the outset, as discussed above, "[p]reclusion for failure to comply with CPLR 3101(d)

is improper 'unless there is evidence of intentional or willful failure to disclose and a

showing of prejudice'". (Gayz, supra, 41 AD3d 782, 839 N.Y.S.2d 196). (See also Cruz,

supra, 51 AD3d 963, 858 N.Y.S.2d 791)(same)). As a Trial Court reviewing Appellate

precedent stated in Einheber v. Bodenheimer, 12 Misc.3d 1177, 820 N.Y.S.2d 842 (Sup.

Ct., New York Cty. 2006):

Courts have made clear, ...,that "preclusion for failure to comply with

CPLR 3101(d) is improper unless there is evidence of intentional or willful
party."
failure to disclose and a showing of prejudice by the opposing
Shopsin v. Siben & Siben, 289 AD2d 220, 221, (2d Dept. 1991); see, Busse
(13t
v. Clark Equip. Co., 182 AD2d 525, 526 Dept. 1992)(denying
preclusion of expert testimony because moving party failed to show

prejudice); see also, Douglass v. St. Joseph's Hosp., 246 AD2d 695, 696

(3d Dept. 1998).

(3rd
(See also Citron v. Northern Dutchess Hosp., 198 AD2d 618, 603 N.Y.S.2d 639

1993)("Although the testimony deviated from the expert witness statement, defendant was

not deliberately deceived or misled by plaintiff's expert witness report")).

38. Defendants bear the initial burden of showing prejudice, and as shown above, that itis

impossible in the instant case. Further, defendants must show that plaintiff's expert

responses were "so inadequate or inconsistent with the expert[s'] testimony as to have been

misleading, or to have resulted in prejudice or surprise". (Rabinowitz v. Eliman, -AD3d-,

(2nd
-N.Y.S.2d-, 2008 WL 4682025 Dept. 2008)). (See also Gagliardotto v. Huntington

(2nd
Hosp., 25 AD3d 758, 808 N.Y.S.2d 430 Dept. 2006) (same); Andaloro v. Town of

(2nd
Ramapo, 242 AD2d 354, 661 N.Y.S.2d 285 Dept. 1997) (Same)).

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39. An expert witness response should not be found to be "so inadequate or inconsistent ...as

misleading"
to have been simply because the expert's testimony does not "precisely

formulation"
[follow] the of such response (Andaloro, ~su ra, 242 AD2d 354, 661 N.Y.S.2d

significance"
285), or because the testimony provides additional information of "collateral

Ib « ii i "f k

(2"
AD3d 920, 845 N.Y.S.2d 362 Dept. 2007)), or because the testimony provides a

conclusion"
"mere[] ...explanation to support the ultimate not contained in the response

(3'
(Oliver Chevrolet Inc. v. Mobil Oil Coro., 274 AD2d 782, 711 N.Y.S.2d 225 Dept.

2000)).

40. CPLR $3101(d)(1)(i) further states that:

Upon request, each party shall identify each person whom the party expects to call
as an expert witness at trialand shall disclose in reasonable detail the subject matter
on which each expert is expected to testify, the substance of the facts and opinions
on which each expert is expected to testify, the qualifications of each expert witness
and a summary of the grounds for each expert's opinion".

41. However, under this statute, a party is not required to provide the actual facts and opinions

which the expert is expected to testify. (See e.g., ~Kr ier v. Airweld, Inc., 176 AD2d 700,

(2"
574 N.Y.S.2d 790 Dept. 1991)). Moreover, itis improper for a party to demand facts

"substance"
and opinions in an expert witness demand. (Id.). The statute requires only the

of the facts and opinions underlying the expert's opinion. (Id.).

42. It has been made clear that the unwarranted preclusion of a party's expert witness(es)

results in reversible error and a new trial.(See e.g., Stevens v. Atwal, 30 AD3d 993, 817

N.Y.S.2d 469 (4 Dept. 2006); Maldonado v. Cotter, 256 AD2d 1073, 685 N.Y.S.2d 339

(4~
Dept. 1998)).

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43. Further, preclusion of a party's expert witness(es) based on expert responses and alleged

prejudice is unwarranted. In Rabinowitz, supra, -AD3d-, -N.Y.S.2d, 2008 WL 4582025,

the Appellate Division determined that preclusion of plaintiff s expert witness was

unwarranted. As recited in Rabinowitz, the plaintiff s expert disclosure did not indicate

that the expert would testify that defendant "improperly aligned the severed ends of

[plaintiff s] rectal sphincter muscle". However, the expert disclosure did state that the

"expert will opine that defendant utilized substandard technique with regard to the repair

of a third degree extension of a midline episiotomy". The Court held that plaintiff s expert

disclosure was "not so inadequate or inconsistent ...as to have been misleading, or to have

resulted in prejudice or surprise".

44. In Gaeliardotto, supra, 25 AD3d 758, 808 N.Y.S.2d 430, as recited by the Appellate

Division, defendant's expert disclosure did not indicate the expert would testify that "an

infant's rapid descent during the second stage of delivery could cause Erb's

palsy". However, the expert disclosure did state that the "expert would testify that

forces'
'maternal expulsive could cause Erb's palsy". Also, the expert disclosure stated

that the "expert could be 'expected to comment upon any and alltestimony adduced at trial

plaintiff"
by [the] (i.e.,two of plaintiff s witnesses offered opinions as to whether or not

descent"
"rapid could cause Erb's palsy). The Court held that defendant's expert

disclosure was "not so inadequate or inconsistent ...as to have been misleading, or to have

resulted in prejudice or surprise".

issues"
45. In Popkave, supra, 44 AD3d 920, 845 N.Y.S.2d 362, the "principal concerned the

presence and detection of breast cancer on mammography, and whether defendant

radiologist should have diagnosed the cancer. Defendant's expert witness testified to

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history"
"plaintiff s social and to "the causes of breast cancer in general", which were not

contained in defendant's expert disclosure. The Appellate Division determined that such

testimony "was of collateral significance or constituted general background information",

misleading"
and that defendant's expert disclosure was not so "inadequate or as to cause

prejudice or surprise to plaintiff.

(4th
46. In Miller v. Galler, 45 AD3d 1325, 846 N.Y.S.2d 493 Dept. 2007), the Appellate

Division rejected plaintiff's claim that defendant's expert disclosure failed to state that the

expert would testify as to "ongoing septic shock syndrome". The Appellate Division

determined that plaintiff "had sufficient notice of the expert's testimony that decedent

suffered from septic shock".

47. In Maldonado, supra, 256 AD2d 1073, 685 N.Y.S.2d 339, defendants claimed prejudice

and surprise by the plaintiff's failure to state in the expert disclosure "the theory of

continuous electronic monitoring". The Appellate Division rejected the claim, as

plaintiff's expert disclosure stated such departures as failing "to monitor the infant after

room"
removing him from the operating and failing "to appreciate changes in [his]

respiratory rate and to properly access, monitor and respond to those changes".

(2nd
48. In Suhr v. Long Beach Med. Ctr., 35 AD3d 440, 825 N.Y.S.2d 252 Dept. 2006),

plaintiff contended that defendant's expert witness testified beyond the scope of the expert

disclosure. The Appellate Division disagreed, based on such statements in defendant's

expert disclosure showing that the expert would testify regarding "the mechanics of

plaintiff's claimed injury", and "the probable cause(s) of plaintiff's claimed injuries and

whether that said injury was caused by any alleged deviation of standard of care by

defendants".

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(2nd
49. In Casimir v. Bar-Zvi, 36 AD3d 578, 828 N.Y.S.2d 175 Dept. 2007), plaintiff claimed

that defendant's expert disclosure failed to state that the expert would testify regarding "the

use of various dissection techniques". The Appellate Division rejected the claim, stating

that defendant's expert disclosure stated that the expert "would testify based on facts and

circumstances other witnesses presented at trial".

50. In Oliver Chevrolet Inc., supra, 274 AD2d 782, 711 N.Y.S.2d 225, defendant's expert

fuel"
disclosure failed to state that the expert witness would testify as to "aviation found

on the subject properly. The Appellate Division determined that the reference to "aviation

fuel"
was a "mere ...explanation to support the ultimate conclusion", and as such the

inconsistent" "misleading"
disclosure was not "so or as to warrant preclusion of testimony

or reversal.

51. Accordingly, every statement testified to by plaintiff's experts to date is proper,

appropriate and in compliance with statutory requirements. Any preclusion under these

specific circumstances is seemingly contrary to prevailing case law.

CONCLUSION

52. Based on the foregoing, Plaintiff respectfully requests that this Honorable Court deny

Defendant's motion in itsentirety as there is no outstanding discovery.

WHEREFORE, the Plaintiff respectfully requests that the Court issues an Order denying

Defendant's motion in its entirety and grant Plaintiff such other and further relief as this

Honorable Court may deem just and proper.

Dated: Garden City, New York 7
June 27, 2019

PHER R. DEAN

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TO:

Archana Sundar, Esq.
GORDON & SILBER, P.C.

Attorney for Defendant(s)
LONG ISLAND JEWISH
MEDICAL CENTER
355 Lexington Avenue, 7th Floor

New York, NY 10017

(212) 834-0600

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Case Info

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Joseph Esposito Track Judge’s New Case

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Document Filed Date

June 28, 2019

Case Filing Date

July 07, 2016

County

Parties

ADELSON, DAWN ALANE Attorney for the Defendants
BENVENUTO, THOMAS J Attorney for the Defendants
BURKE, YANIQUE LATOYA Attorney for the Defendants
DELL, JOSEPH GERARD Attorney for the Plaintiff
KOWELL, ELIZABETH ANN Attorney for the Defendants
Long Island Jewish Medical Center Defendant
MUNDACA, FRANCISCO EGBERT Attorney for the Defendants
North Shore - Long Island Jewish Health System, Inc. Defendant
Northwell Health, Inc. Defendant
Terrance Anthony Small Plaintiff
JOSEPH MUZIO Attorney
ARCHANA SUNDAR Attorneys for Defendants
ROBERT JORDAN Attorney

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Order to Show Cause: Terrance Anthony Small v. Long Island Jewish Medical Center, North Shore - Long Island Jewish Health System, Inc., Northwell Health, Inc.

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