Motion to Be Relieved or Withdraw as Counsel in Shelley A. Mcmindes-Wojdan, As Administratrix Of The Estate Of, Timothy Wojdan v. Erie County Medical Center Corporation, William Dice M.D., Andrew J. Eckert M.D., Tatiana V. Boyko M.D., Charles Wiles M.D.| Trellis.Law

On July 06, 2015 a Motion-Secondary was filed involving a dispute between Shelley A. Mcmindes-Wojdan, As Administratrix Of The Estate Of, Timothy Wojdan, and Andrew J. Eckert M.D., Charles Wiles M.D., Erie County Medical Center Corporation, Tatiana V. Boyko M.D., William Dice M.D., for Medical Malpractice in the District Court of Erie County.

Preview
FILED: ERIE COUNTY CLERK 05/07/2018 02:27 PM INDEX NO. 808140/2015
NYSCEF DOC. NO. 54 RECEIVED NYSCEF: 05/07/2018

STATE OF NEW YORK
SUPREME COURT : COUNTY OF ERIE

TIMOTHY WOJDAN

Plaintiff AFFIDAVIT
-vs-

ERIE COUNTY MEDICAL CENTER CORPORATION
WILLIAM DICE, M.D. Hon. Frederick J. Marshall, JSC
ANDREW J. ECKERT, M.D. Index No.: 808140/2015
TATIANA V. BOYKO, M.D.
CHARLES WILES, M.D.

Defendants

STATE OF NEW YORK )
COUNTY OF ERIE ) ss:
CITY OF BUFFALO )

Kait R. Miceli, Esq., being duly sworn, deposes and says:

I. That I am an attorney at law duly licensed to practice in the State ofNew York and

am associated with the law firm ofROACH, BROWN, MCCARTHY & GRUBER, P.C., attorneys

for defendants ERIE COUNTY MEDICAL CENTER CORPORATION, ANDREW J. ECKERT,
.

"Defendants" above-
M.D., and TATIANA V. BOYKO, M.D. (hereinafter, together, "Defendants") in the

captioned matter. As such, I am fully familiar with the facts and proceedings herein.

2. This affidavit and the exhibits attached hereto are respectfully submitted on behalf

of the Defendants: (a) in opposition to the plaintiff's motion for a protective order precluding the

Defendants and their co-defendants from completing the non-party deposition of the plaintiff's

Defendants' cross-
wife, Shelley McMindes-Wojdan ("Mrs. Wojdan"); and (b) in support of the

motion for an order of the Court compelling (i)Mrs. Wojdan to appear for the completion of her

deposition and (ii)the plaintiff to provide his responses to outstanding discovery responses.

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3. Your deponent has read and is familiar with the Attorney Affirmation of Florina

Alshiler, Esq., dated April 26, 2018 filed on behalf of Defendant Charles Wiles, M.D., as well as

Exhibits A-F filed therewith, and hereby incorporates herein those exhibits as well as the

arguments set forth therein submitted in opposition to the plaintiff's motion for a protective order

Defendants'
and in support of the application for affirmative relief.

4. It is noted, as an initial matter, that Attorney Steven M. Cohen, counsel for the

plaintiff, has been retained by and represented Mrs. Wojdan through the course of her deposition.

5. It is further noted that while Mr. Cohen accuses defense counsel of being

unprepared and wasting time in conducting this witness's deposition, it is he who failed to

Defendants'
adequately respond to the demands for statements; and he who failed prepare his

client to be forthcoming and to provide all her documentation/audio/video recordings relevant to

this action prior to the commencement of her deposition so that the deposition could be

manner.1
accomplished in an efficient

t
6. Hundreds of pages of documents and hours of audio recordings have been provided

in piecemeal fashion from this witness, at times produced during the actual course of her

deposition, and itis hardly appropriate for plaintiff's counsel orhis client to now complain about

the protracted nature of the deposition. Mr. Cohen's characterization of the course of discovery is,

at best, misleading and should be rejected by the Court, as established more fully below. I

1 At the commencement of Mrs. Wojdan's deposition Mr. Cohen even indicated his intention to add her as
deposition.1
a plaintiffto the action, so it begs the question of why he had not prepared his client for her
(Please see Exhibit E atpp. 23-24).

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PROCEDURAL POSTURE
DEPOSITION'
AND MRS. WOJDAN'S DEPOSITION

7. After being granted leave to file a late notice of claim, the plaintiff served a notice

of claim for alleged medical malpractice as against ECMCC, a copy of which is attached hereto as

Exhibit A. The plaintiff thereafter commenced the instant action as against, inter alia, ECMCC

and two resident physicians working there in May of 2014, at the time in question, Drs. Eckert and

Boyko. A copy of the plaintiff's summons and complaint is attached hereto as Exhibit B.

8. ECMCC and Drs. Eckert and Boyko joined issue with the service of their answers,

copies of which are attached as Exhibit C. Also attached as part of Exhibit C isthe notice for the

production of statements, which these Defendants served upon counsel for the plaintiff with their

Defendants'
respective answers. In response to these demands for a bill of particulars, the plaintiff

served the billsof particulars attached hereto as Exhibit D.

9. The deposition of plaintiff Timothy Wojdan took place on January 3, 2017. (Please

see Exhibit B to the plaintiff's motion papers, which is fully incorporated herein as if attached

hereto).

10. Mr. Wojdan testified to being injured in a motor vehicle accident on May 6, 2014,

which resulted in him being brought to ECMCC for treatment of his injuries. He has no

recollection of the time at issue in this case when he was a patient at ECMCC following his motor

vehicle accident. Mr. Wojdan testified that he does not know what happened for the month

following his accident. (Plaintiff's Exhibit B at pp. 23-25, 36, 41-43, 48-50; see also plaintiff's

bills of particulars, Exhibit D).

11. Thus, during his deposition, Mr. Wojdan was unable to answer questions put to him

by defense counsel and plaintiff's counsel advised that Mrs. Wojdan would be better able to answer

the questions being put to Mr. Wojdan. (Exhibit B at p. 62). Importantly, Mrs. Wojdan was the

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plaintiff's health care proxy and his power of attorney at the time of the care and treatment at issue

was rendered, because at the time of his motor vehicle accident he was being (separately) treated

for rectal cancer. (Plaintiff's Exhibit B at pp. 23-25, 35-36, 43, 47, 49-51, 59-62, 83-84, 91-92).

Defendants' cross-
12. Notable for the purposes of the plaintiff's instant motion and the

motion is the fact that during the course of the plaintiff's deposition, his counsel represented that

he would produce Mrs. Wojdan as a witness. (Plaintiff's Exhibit B at p. 62).

Defendants' cross-
13. Also notable for the purposes of the plaintiff's motion and the

motion is the fact that counsel for Mrs. Wojdan did not demand that a subpoena be served in order

to take the deposition testimony or secure any relevant evidence which might be in Mrs. Wojdan's

possession. Despite this circumstance, counsel now argues that defense counsel somehow acted

improperly in taking Mrs. Wojdan's testimony without first having subpoenaed her after he

produced her for her deposition.

14. It iswell settled that "[p]arties to a civil dispute are free to chart their own litigation

course". Mitchell v New York Hosp., 61 NY2d 208, 214, (1984); Hasselback v 2055 Walden Ave.,

Inc., 139 AD3d 1385, 1387 (4th Dept. 2016); guilty v Cormier, 115 AD3d 1229, 1230 (4th Dept.

2014); see Hann v Black, 96 AD3d 1503, 1504 (4th Dept. 2012); Perez v Computer Directions

177 AD2d â€”
359-360 (1st Dept. 1991). Counsel for plaintiff and Mrs. Wojdan set
Group, Inc., 359,

the course of discovery concerning this witness and cannot now be heard to complain about it.

Hyundai Corp. v Republic of Iraq, 20 AD3d 56, 59 (1st Dept. 2005) ("[h]aving chosen to chart

their own procedural course, respondents cannot now be heard to complain that the destination to

liking"
which ithas led them is not to their liking").

15. The plaintiff also testified to Mrs. Wojdan having taken photographs of decubitus

ulcers he developed following the May 2014 motor vehicle accident that brought him to ECMCC,

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photographs which had not been produced by plaintiff's counsel. Defense counsel thus requested

that the photographs be provided. (Plaintiff's Exhibit B at pp. 63-65).

16. The plaintiff further testified that his wife kept calendars regarding his care and

treatment, and that she made certain cell phone recordings of her interactions with ECMCC

personnel regarding his care and treatment while he was a patient there. (Plaintiff's Exhibit B at

pp. 77-79).

17. Your deponent thus made a request, on the record, that plaintiff's counsel provide

the calendars and recordings. That was on 3, 2017. (Plaintiff's Exhibit B at p. 79). No
January

response from plaintiff's counsel was forthcoming.

March 9, 2017

18. Two months later, on March 9, 2017, Mrs. Wojdan's deposition was commenced.

client"
Plaintiff's counsel, Attorney Cohen, referred to Mrs. Wojdan as "my on therecord. (Please

see relevant portions of Volume I of Mrs. Wojdan's deposition, attached hereto as Exhibit E, at

pp. 26-28 ).

19. During this first day of her testimony, Mrs. Wojdan testified to writing notes

concerning the care and treatment being provided to the plaintiff; itwas at this time that defense

counsel first gained some idea of the extent of her notes - which she had been on an almost
making

daily basis for over three years, and continued taking them up through the day prior to the

commencement of her deposition. (Exhibit E at pp. 18-22).

20. Itis undisputed that Mr. Cohen represents Mrs. Wojdan and that his office had Mrs.

Wojdan's notes prior to producing her for her deposition. Mr. Cohen did not advise defense

counsel as to the existence of these notes prior to Mrs. Wojdan's deposition, with some of those

notes in his office's possession since at least 2014. (Exhibit E at pp. 22-24). Defense counsel

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thus requested copies of Mrs. Wojdan's notes and Mr. Cohen advised that he would take the

request under advisement and would not produce anything covered by attorney/client privilege.

21. Also on March 9, 2017, your deponent, on the record, noted Mrs. Wojdan's

reluctance to provide her notes about her husband's care and treatment and my concern about the

possibility of spoliation. (Exhibit E at p. 24). Counsel for co-defendant William Dice, M.D.,

noted for the record that the notes taken by Mrs. Wojdan were not taken for the purposes of

litigation and that defense counsel are thus entitled to them, a position concurred in by your

deponent. (Exhibit E at p. 25).

22. In response Mr. Cohen stated: "I understand your position and certainly you have

you'
Plaintiff's consent to adjourn this deposition with full rights to reconvene after you've had an

you."
opportunity to review the material that we turn over to (Exhibit E at p. 26). Shortly

thereafter the deposition was suspended for just that purpose. (Exhibit E at p. 29).

23. Prior to the second day of Mrs. Wojdan's testimony, on August 10, 2017, her

counsel delivered to defense counsel approximately 630 pages of notes and documents, including

3"
Mrs. Wojdan's handwritten "Tim's Accident Journal". (Please see "Exhibit attached to the

April 26, 2018 Affirmation of Florina Altshiler, Esq., which, for the sake of economy and ease of

reference is fully incorporated herein as if attached hereto).

August 10, 2017

24. When Mrs. Wojdan's deposition was continued that day Mr. Cohen re-confirmed

his status as Mrs. Wojdan's counsel, stating on the record that he was participating in the deposition

as Mrs. Wojdan's attorney pursuant to a signed retainer. (Please see relevant portions of Mrs.

Wojdan's second day of testimony, attached hereto as Exhibit F, at pp. 191-192). Mr. Cohen was

asked to provide a copy of the written retainer agreement between himself and Mrs. Wojdan for

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the purposes of this action, which, upon information and belief, he has yet to produce. (Exhibit F

at p. 192).

25. Moreover, contrary to the representations of plaintiff's counsel upon the instant

motion, it was established on that day that Mrs. Wojdan was subpoenaed to give testimony as a

non-party to this action, a fact not contradicted by Mr. Cohen at the deposition. (Please see Exhibit

F atp. 191),

26. It was also established on that day that the notes provided defense counsel did not

constitute all of Mrs. Wojdan's notes regarding the plaintiff's condition and his care and treatment

following the alleged malpractice in this case. (Exhibit F at p. 192). This, unfortunately, meant

another day of Mrs. Wojdan's deposition would be necessary.

t
August 11, 2017

27. Mrs. Wojdan's deposition was continued the next day, August 11, 2017. (Relevant

portions of the transcript for the deposition held that day are attached hereto as Exhibit G). Itwas

on that day Mrs. Wojdan first testified about audio tapes she had made with ECMCC personnel

"composed"
and to having her journal from "day one, May 6, 2014". (Exhibit G at p. 221-222).

It was also learned on this day that Mrs. Wojdan's sisters had also made audio recordings of

interactions with individuals associated with ECMCC. (Exhibit G at pp. 239-240).

28. Your deponent put on the record her request that any such recordings be preserved

and produced. Your deponent directly asked Mr. Cohen whether a subpoena would be necessary

in order to secure copies of the audio recordings and he responded that he would take "any

requests"
for the recordings under advisement. (Exhibit G at pp. 240-242). Mr. Cohen also asked

the court reporter transcribing the deposition to assemble a listof the discovery requests made by

defense counsel during the course of the deposition that day. (Exhibit G at p. 242; see also Exhibit

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G at p. 198). Mr. Cohen gave no indication that he expected his client and/or the

documents/recordings to be subpoenaed, as might be expected, given Mrs. Wojdan's exclusive,

detailed and intimate knowledge of the facts and circumstances at issue in this lawsuit.

29. At the time she was testifying on August 11, 2017, Mrs. Wojdan had with her an

iPad containing many hours of audio recordings consisting of, among other things, conversations

with people at ECMCC concerning the plaintiff's care which her counsel had not previously

provided. Because copies of the audio recordings were not previously provided, and Mrs. Wojdan

could not recall the substance of the recording or the identity of the people involved in those

recordings, the court reporter was asked to transcribe the audio as it was played from Mrs.

Wojdan's iPad. (Exhibit G at pp. 273-274). This, of course, made it a more cumbersome and

lengthy deposition.

30. Mr. Cohen made no objection to court reporter transcribing the audio recordings as

they were played. Indeed, Mr. Cohen went so far as to instruct Mrs. Wojdan: "Stop talking. Start

playing."
(Exhibit G at p. 322). Italso became clear that Mrs. Wojdan's notes regarding the

recorded conversations were at times not an accurate reflection of what was captured on the audio.

Mrs. Wojdan documented some of the recordings she made in her journal, some she did not.

(Exhibit G at pp. 366-371).

31. After going through a number of the audio recordings on Mrs. Wojdan's iPad, and

defense counsel asking follow up questions, the deposition was suspended in anticipation of Mrs.

Wojdan returning for another day of questioning. She was instructed to bring the iPad containing

the audio recordings to her continued deposition. In addition, as the testimony was concluding for

that day, Mr. Cohen provided a further set of notes concerning the plaintiff which Mrs. Wojdan

had made following the second day of Mrs. Wojdan's deposition. (Exhibit G at pp. 406-407).

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32. Mrs. Wojdan's deposition was then continued on September 28, 2017. Between

August 11, 2017 and that day, Mrs. Wojdan/plaintiff's counsel provided defense counsel with a

USB drive containing 26 audio recordings made by Mrs. Wojdan. (Please see the transcript from

Mrs. Wojdan's September 28, 2017 testimony, relevant portions of which are attached hereto as

Exhibit H, at p. 412).

September 28, 2017

33. According to Mrs. Wojdan's testimony on September 28, 2017, she provided

approximately 629 pages of documents to plaintiff's counsel which were then provided to defense

counsel (Exhibit H at pp. 434, 549). As to those 629 pages of documents, Mr. Cohen stated that

They'
day: "These are all of the paper documents that she has. They've been turned over to you. You

it."
are absolutely free to exhaustively go through and ask any questions about (Exhibit H at pp.

439-440) (emphasis added).

34. Itwas also on this day that your deponent learned for the firsttime that Mrs. Wojdan

had also taken videos atECMCC concerning the plaintiff's health and his care and treatment. Mrs.

Wojdan claimed during her testimony this day that she had forgotten about the videos when

previously asked to provide everything she had concerning the plaintiff's care and treatment and

relating to his claims in this action. Mrs. Wojdan was asked to preserve any such videos she might

have and Mr. Cohen was asked to provide copies of the same. (Exhibit H at pp. 457-458). All

counsel put statements on the record about the course of Mrs. W's deposition and further materials

to be produced by the witness in response to long standing demands made by the defendants.

(Exhibit H at pp. 457-461, 479-481, 485).

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35. At 4:15 p.m. on September 28, 2017, Mr. Cohen unilaterally ended Mrs. W's

deposition and defense counsel put their objections on the record. As of the date of this affidavit,

counsel for Dr. Dice has not even had a chance to question Mrs. W. (Exhibit H at pp. 602-604).

36. Copies of correspondence exchanged between counsel, attached hereto as Exhibit

defendants'
I, establish the good faith attempts to secure the disclosure from the plaintiff which

the Court has determined the plaintiff must provide.

October 12, 2017

36. On October 12, 2017, a pretrial conference was held at which time outstanding

discovery was addressed with the Court. Plaintiff was directed to provide his outstanding responses

defendants'
to the discovery demands. In follow up to that conference, the Court sent

correspondence to all counsel, ordering that:

In furtherance of our conference of October 12th, may this
correspondence confirm that, within 30 days of the date of this
wife'
correspondence, the issues pertaining to the plaintiffs wife's
deposition be addressed. Specifically, defense counsel have

requested all documents, videos, notes, memoranda, etc. reviewed

in preparation for her deposition. Specifically counsel are directed

to comply with the outstanding demands, prepare a privilege log for

those documents and/or others that are being withheld, or file a
motion for a protective order, as discussed. Further, plaintiffs
counsel is directed to advise by way of an amendment to the existing
bill of particulars, or otherwise, as to any 1983 claims. Should
counsel decide not to pursue such claims, they are directed to

memorialize same in writing.

(Please see Exhibit E attached to the A1tshiler Affirmation).

37. To date, plaintiff has failed to do comply with any of the Court's directives. The

plaintiff's motion for a protective order relative to the continuation of Mrs. Wojdan's deposition

is not the motion contemplated the Court and the parties at the pretrial conference as
by

memorialized above. Rather, plaintiff was directed to make a motion for a protective order relative

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defendants'
to the outstanding discovery requests, if believed appropriate, and to provide a

privilege log in such case. Itis respectfully submitted that under the facts and circumstances of

this case, the conduct ofplaintiff's counsel approaches the line of being willful and contumnacious.

ARGUMENT

38. As an initialmatter, given allthe foregoing circumstances, itis now a littlelate in

the day for Mr. Cohen, attorney for both the plaintiff and Mrs. Wojdan, to complain that Mrs.

Wojdan was not served with a subpoena for her testimony. That boat sailed long ago, with

plaintiff's counsel having advised that a subpoena was not necessary and having produced Mrs.

Wojdan as a witness on four occasions prior to interposing the instant motion (and prior to the

October 12, 2017 compliance conference with the Court). Mr. Cohen essentially concedes this in

paras. 7-8 of his Attorney Affirmation.

39. Further, and fatal to the instant motion, is the absence of an affirmation of a good

faith attempt to resolve the matter prior to resorting to the Court for relief. In supreme and county

court, all motions relating to disclosure must include an affirmation by the moving lawyer that the

lawyer conferred with opposing counsel and made a good faith effort to resolve the issues raised
L

by the motion. 22 NYCRR § 202.7(a).

40. As provided for under the rule, the movant should attend carefully to this

affirmation and see to itthat itreflects a genuine effort at resolution. See 22 NYCRR § 202.7(c);

Amherst Synagogue v Schuele Paint Co., Inc., 30 AD3d 1055, 1057 (4th Dept. 2006). A good

faith effort requires that "[s]ignificant, intelligent and expansive contact and negotiations must be

held between counsel to resolve any dispute and such efforts must be adequately detailed in [the]

affirmation."
Eaton v. Chahal, 146 Misc. 2d 977 (Sup. Ct., Rensselaer Co. 1990). Tellingly absent

from Mr. Cohen's affirmation is any attempt to resolve the matter.

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41. Indeed, no such efforts have been made by Mr. Cohen in this case; clearly the

respect.2
reason for his failure to even address the plaintiff's burden in this respect.

42. In terms of the relief requested by the plaintiff at para. 29 of Mr. Cohen's

affirmation (the submission of all further questions to the Court before the deposition is continued;

limiting the scope of the deposition; and that Mrs. Wojdan be reimbursed for such time that she is

further required to testify) such relief is contrary to the governing principles of law, not merited,

and, indeed, would be unfairly prejudicial to the defendants and their ability to defend this action

See Roggow v Walker, 303 AD2d 1003, 1003 (4th Dept 2003) (unless they are clearly violative of

a witness's constitutional rights, or of some privilege recognized in law, or are palpably irrelevant,

3
questions at an examination before trial should be freely permitted and answered).

43. Next, while Mr. Cohen complains that Mrs. Wojdan was asked irrelevant and

patently privileged questions (Cohen Affirmation at ¶7), he identifies not a single such question.

It is not for the Court and defense counsel to have to sort through the deposition transcripts and !

attempt to discern the questions objected to as part of the plaintiff's motion. The boilerplate claims

of privilege asserted in the plaintiff's moving papers are insufficient to establish the existence of
l

confidential communications between Mr. Cohen and Mrs. Wojdan and/or between the plaintiff

and Mrs. Wojdan and other counsel who they may have consulted relative to this matter. See

Castro v Admar Supply Co., Inc., 2018 NY Slip Op 02113 (4th Dept Mar. 23, 2018).

2 Plaintiff not cure that with the submission of papers. Error! Main Document
may deficiency reply
Only.Bulluck v 132 AD3d â€”
1382-83 (4th Dept. Scherrer v Time Equities, Inc., 218
Fields, 1382, 2015);
AD2d 116 (1st Dept. 1995).
3 See CPLR â€”
which provides that a deposition "shall proceed subject to the right of a person to
3113(b)
order."
apply for a protective (Emphasis added). See also 22 NYCRR 221.2, which provides that "[a]
deposition"
deponent shall answer all questions at a and liststhe limited circumstances under which a
witness deposed refuse to answer a question, none of which have been identified by Mr. Cohen
being may
in seeking the protective order.

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44. Mr. Cohen has also represented that permitting defense counsel to continue with

the deposition of Mrs. Wojdan would cause him to accrue additional expense, but fails to articulate

just what expense, other than the usual costs of litigation, he refers to. (Cohen Affirmation at ¶27).

45. Mr. Cohen's representations are simply insufficient to defeat the broad

presumption, under CPLR §3101's liberal discovery provisions, that all relevant material is to be

disclosed. Coddlington v Lisk, 249 AD2d 817, 818 (3d Dept. 1998). CPLR 3106(a) provides that:

"After an action is commenced, any party may take the testimony of any person by deposition

questions."
upon oral or written CPLR 3120(b) provides, in relevant part, that a nonparty to an

do."
action "may be directed by order to do whatever a party may be directed to

46. As recently expressed by the Court of Appeals:

Disclosure in civil actions is generally governed by CPLR 3101(a),
which directs: "[t]here shall be fulldisclosure of all matter material
and necessary in the prosecution or defense of an action, regardless
proof."
of the burden of We have emphasized that "[t]he words,
'material and necessary', are ...to be interpreted liberally to require

disclosure, upon request, of any facts bearing on the controversy
which will assist preparation for trialby sharpening the issues and

reducing delay and prolixity. The test is one of usefulness and
reason" â€”
( Allen v. Crowell-Collier Publ. Co., 21 N.Y.2d 403, 406,
302-
288 N.Y.S.2d 449, 235 N.E.2d 430 [1968] ; see also Andon v.

304 Mott St. Assoc., 94 N.Y.2d 740, 746, 709 N.Y.S.2d 873, 731

N.E.2d 589 [2000] ). A party seeking discovery must satisfy the

threshold requirement that the request is reasonably calculated to
necessary" â€” relevant-
yield information that is "material and necessary"-i.e.,
regardless of whether discovery is sought from another party
(see CPLR 3101[a][1] ) or a nonparty (CPLR 3101[a][4]; see

e.g. Matter of Kapon v. Koch, 23 N.Y.3d 32, 988 N.Y.S.2d 559, 11

N.E.3d 709 [2014] ).The "statute embodies the policy determination

that liberal discovery encourages fair and effective resolution of

disputes on the merits, minimizing the possibility for ambush and
surprise"
unfair (Spectrum Sys. Intl. Corp. v. Chemical Bank, 78

N.Y.2d 371, 376, 575 N.Y.S.2d 809, 581 N.E.2d 1055 [1991] ).

Forman v Henkin, 30 NY3d 656, 661 (2018) (emphasis added).

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47. It is beyond dispute that Mrs. Wojdan, who was constantly present with the

plaintiff during his subject hospitalization atECMCC and interacting with his health care providers

as his health care proxy and pow

Case Info

Judge

Frederick J Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

May 07, 2018

Case Filing Date

July 06, 2015

County

Parties

ALTSHILER, FLORINA Attorney for the Defendants
Andrew J. Eckert M.D. Defendant
Charles Wiles M.D. Defendant
COHEN, STEVEN MICHAEL Attorney for the Plaintiff
DANIEU, JOHN PATRICK Attorney for the Defendant
Drickel, Kayla Ann Attorney for the Defendant
DUQUIN, SCOTT MICHAEL Attorney for the Plaintiff
Erie County Medical Center Corporation Defendant
GAGLIONE, THERESA LEIGH Attorney for the Defendant
GAWLEY, DEVON ELIZABETH Attorney for the Defendants
HYNES, TRISHE' L.A. Attorney for the Defendants
MALLABER, RANDY CARL Attorney for the Plaintiff
MATTREY, COLLEEN KATHERINE Attorney for the Defendant
MICELI, KAITLIN ROSE Attorney for the Defendant
Shelley A. Mcmindes-Wojdan, as Administratrix of The Estate of Plaintiff
Tatiana V. Boyko M.D. Defendant
Timothy Wojdan Plaintiff
TONER, STEPHEN BENEDICT Attorney for the Defendant
TONER, STEPHEN BENEDICT Attorney for the Defendants
William Dice M.D. Defendant
JESSICA DEMICHIEL Attorneys for Plaintiffs
JESSICA DEL CID Attorneys for Defendants
John Ely Attorneys for Defendants
Rebecca Cronauer Attorneys for Defendants
COLLEEN KELLY Attorneys for Plaintiffs
WILLIAM DOISCHEN Attorney
STEVEN KLEIN Attorney
STEPHEN TU Attorney
FRANCIS MARRANO Attorney
STEVEN COREN Attorney
JOHN ALGIE Attorney
ALAN RUSSO Attorney

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Motion-Secondary: Shelley A. Mcmindes-Wojdan, As Administratrix Of The Estate Of, Timothy Wojdan v. Erie County Medical Center Corporation, William Dice M.D., Andrew J. Eckert M.D., Tatiana V. Boyko M.D., Charles Wiles M.D.

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