• 347-746-6001
  • contact@beynensonlaw.com
Beynenson Law
Beynenson Law
  • Services
    • Search
    • No-Fault AI
    • New Decisions
    • Legal Questions
    • No-Fault Regulations
    • Arbitrator Scorecard
    • Award Volume
    • Arbitrator / Carrier Data
    • Provider / Carrier Data
    • Provider / Attorney Data
    • Arbitration Pro Extension
  • About Us
  • Contact
  • East Hampton, New York

  • 347-746-6001
  • contact@beynensonlaw.com
  • Services
    • Search
    • No-Fault AI
    • New Decisions
    • Legal Questions
    • No-Fault Regulations
    • Arbitrator Scorecard
    • Award Volume
    • Arbitrator / Carrier Data
    • Provider / Carrier Data
    • Provider / Attorney Data
    • Arbitration Pro Extension
  • About Us
  • Contact
May 3, 2004

MOPS Med. Supply v GEICO Ins. Co. (2004 NY Slip Op 24140)

https://www.beynensonlaw.com/case-law/mops-med-supply-v-geico-ins-co-2004-ny-slip-op-24140/

Court
Civil Court of the City of New York, Kings County
Judge
Ellen Gesmer, J.
Decided
May 3, 2004
Citation
2004 NY Slip Op 24140 · 4 Misc 3d 185
Posture
Other motion
Outcome
Insurer prevailed
Later treatment
Declined to follow in 1 and followed in 2 later decisions (see Cited by)
Issues
Discovery and procedure
Cite as
MOPS Med. Supply v GEICO Ins. Co., 4 Misc 3d 185 (Civ Ct, Kings County 2004)

Posture, outcome, issues and treatment by other decisions are Beynenson Law’s classification. Treatment labels are assigned by a language model reading the citing decision; negative and appeal-history labels are checked by a second reader.

Summary

Editorial summary by Beynenson Law, not part of the court’s decision.

A no-fault provider seeking to avoid a deposition bears the burden of showing that the requested discovery is unnecessary. The Civil Court, Kings County, conditionally granted the insurer's CPLR 3126 dismissal motion unless the provider appeared for a deposition. The insurer had timely denied the equipment claim for lack of medical necessity and sought a deposition after receiving interrogatory responses. Those responses were unverified, failed to identify the responding individual, and omitted medical-necessity information. The provider never sought a protective order under CPLR 3103 and did not establish that the deposition was improper. Because its failure to attend rested on a good-faith legal argument, the court allowed another opportunity to comply, with dismissal available upon a further failure to appear.

Reported in New York Official Reports at MOPS Med. Supply v GEICO Ins. Co. (2004 NY Slip Op 24140)

MOPS Med. Supply v GEICO Ins. Co.
2004 NY Slip Op 24140 [4 Misc 3d 185]
May 3, 2004
Civil Court Of The City Of New York, Kings County
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
As corrected through Wednesday, November 3, 2004

[*1]

MOPS Medical Supply, as Assignee of Leonie Joiles, Plaintiff,
v
GEICO Insurance Company, Defendant.

Civil Court of the City of New York, Kings County, May 3, 2004

APPEARANCES OF COUNSEL

Teresa Spina, Woodbury (Kevin Barry of counsel), for defendant. Anatta Levinsky, P.C., Brooklyn, for plaintiff.

{**4 Misc 3d at 185} OPINION OF THE COURT

Ellen Gesmer, J.

{**4 Misc 3d at 186}Defendant has moved to dismiss plaintiff’s complaint pursuant to CPLR 3126 because plaintiff failed to appear at an examination before trial (EBT) scheduled by defendant. Defendant’s motion is granted unless the plaintiff appears for an EBT under the terms set forth below.

Procedural History and Facts

In this action, plaintiff is seeking payment of first-party no-fault benefits for medical equipment provided by it to Leonie Joiles, who assigned to plaintiff her rights to no-fault benefits from defendant, her insurer.[FN*] The defendant timely denied payment, on the grounds of medical necessity, based on an independent medical peer review. [*2]

Plaintiff commenced this action on or about March 20, 2003. Simultaneously with the service of its answer on April 9, 2003, defendant served plaintiff with a demand for verified interrogatories and a notice to take deposition upon oral examination. The answers to the interrogatories were due 20 days later and the deposition was scheduled for June 18, 2003, more than 60 days later. At plaintiff’s request, defendant rescheduled the deposition to August 26, 2003. Plaintiff failed to appear.

Analysis

Although the CPLR permits a party to utilize both written interrogatories and oral depositions in pretrial discovery, a party should generally complete one form of discovery before invoking another (Giffords Oil Co. v Spinogatti, 96 AD2d 851 [2d Dept 1983]; Samsung Am. v Yugoslav-Korean Consulting & Trading Co., 199 AD2d 48, 49 [1st Dept 1993]). Indeed, the Second Department has held that “the noticing of an oral deposition prior to reviewing the answers interposed to the interrogatories and without a determination of the necessity for further disclosure, verges on an abuse of the judicial system.” (Barouh Eaton Allen Corp. v International Bus. Machs. Corp., 76 AD2d 873, 874 [2d Dept 1980].) In this case, although the defendant noticed the deposition at the same time that it sent the demand for {**4 Misc 3d at 187}interrogatories, it did not take any action to enforce its request for a deposition until well after receiving the interrogatories. Moreover, in support of its motion, defendant’s counsel affirmatively asserts that “the examination before trial of plaintiff is necessary and material in order to defend this action properly,” thus meeting the standard set by the Second Department for using a second discovery device (Katz v Posner, 23 AD2d 774, 775 [2d Dept 1965] [“If the device first chosen does not adequately disclose all evidence material and necessary to the prosecution or defense of the action (CPLR 3101), then the other available remedy may be utilized”]). Consequently, defendant has established a prima facie case that it is entitled to go forward with its deposition.

In opposition to defendant’s motion, plaintiff initially argues that it made a demand for verified interrogatories to which defendant did not respond. Plaintiff has failed, however, to show why defendant’s failure to respond to interrogatories would excuse its failure to attend a deposition or serve as a defense to a motion to compel. In any event, this argument is particularly weak because plaintiff’s deposition was scheduled for August 26, 2003, well before the responses to plaintiff’s demand for interrogatories were even due.

More substantially, plaintiff argues, relying on Ostia Med. v Government Empls. Ins. Co. (1 Misc 3d 907[A], 2003 NY Slip Op 51560[U] [Nassau Dist Ct 2003]) and Zlatnick v Government Empls. Ins. Co. (2 Misc 3d 347 [Civ Ct, Queens County 2003]), that defendant may not proceed with its deposition because it failed to advise plaintiff that its answers to defendant’s demand for verified interrogatories were “inadequate, incomplete or defective.” The court rejects this argument for several reasons.

First, unlike the plaintiff medical providers in Ostia and Zlatnick, the plaintiff in this case did not move for a protective order with regard to the deposition, pursuant to CPLR 3103, and still has not done so. While there is no absolute time limit for moving for a protective order, the [*3]court may imply a standard of reasonableness, especially where the time for the scheduled deposition has long passed (Philip v Monarch Knitting Mach. Corp., 169 AD2d 603 [1st Dept 1991]; see also Siegel, Practice Commentaries, McKinney’s Cons Laws of NY, Book 7B, CPLR C3103:3). Plaintiff is in a particularly poor position to complain about being compelled to appear at the deposition since it took no action to object to the deposition either before it was scheduled or in the eight months since. While that would not prevent {**4 Misc 3d at 188}plaintiff from opposing this motion, it would certainly have been the better practice for plaintiff to move for a protective order rather than to just ignore defendant’s deposition notice.

Secondly, this court disagrees with the rulings in Ostia and Zlatnick that the burden is on the defendant insurance company to justify its need for a deposition. Indeed, that conclusion seems inconsistent with the holding in Ostia that a medical provider which brings an action in Civil Court to obtain no-fault benefits has the same discovery obligations under article 31 of the CPLR as any other litigant (Ostia, 2003 NY Slip Op 51560[U], *12; see also Albatros Med. v Government Empls. Ins. Co., 196 Misc 2d 656 [Civ Ct, Queens County 2003]). As set forth above, the general rule is that if a litigant determines that the responses to interrogatories from the other side do “not adequately disclose all evidence material and necessary to the prosecution or defense of the action,” then it may utilize depositions or any other available remedy, without first seeking court permission (Katz v Posner, 23 AD2d at 775). If the other party moves for a protective order, it must then bear the burden of showing that the discovery sought is not necessary, consistent with the well-established principle that “the burden of demonstrating an immunity from discovery is on the party asserting the immunity.” (Westhampton Adult Home v National Union Fire Ins. Co., 105 AD2d 627, 628 [1st Dept 1984]; see also Koump v Smith, 25 NY2d 287, 294 [1969]; Mavrikis v Brooklyn Union Gas Co., 196 AD2d 689, 690 [1st Dept 1993]; Jarvis v Jarvis, 141 Misc 2d 404, 406 [Sup Ct, NY County 1988].) The decisions in Ostia and Zlatnick improperly shift the burden to the party seeking discovery to justify a request for discovery, rather than imposing the burden on the party seeking to avoid discovery to show that the discovery sought is not necessary. In this case, plaintiff has certainly not met its burden of showing that the discovery sought is not proper.

Third, even if the court were to find that the burden is on defendant to show that the discovery is justified, it would find that defendant had met its burden. First, defendant has shown that it made a timely denial based on medical necessity, so defendant has preserved issues on which discovery is appropriate (Presbyterian Hosp. v Maryland Cas. Co., 90 NY2d 274 [1997]; Ostia, 2003 NY Slip Op 51560[U], *11). Secondly, plaintiff’s responses to defendant’s interrogatories are insufficient on their face for at least two reasons. As an initial matter, the responses to {**4 Misc 3d at 189}the interrogatories were not verified, and they fail to identify the name and address of the individual responding to the interrogatories; rather, they state only that they were answered by the plaintiff’s attorney. Consequently, as formulated, the interrogatories do not subject plaintiff or its principals to cross-examination, as would properly verified interrogatories. Finally, plaintiff fails to set forth any responses to the interrogatories concerning the medical necessity of the equipment provided. Since that is the crux of the issue in this case, defendant is entitled to conduct a deposition of plaintiff to obtain the information. [*4]

Conclusion

The nature and degree of the penalty to be imposed pursuant to CPLR 3126 against a party who has disobeyed a court order is a matter within the discretion of the court (Jaffe v Hubbard, 299 AD2d 395, 396 [2d Dept 2002]). Although the court has rejected plaintiff’s arguments, the court finds that plaintiff presented a good faith argument for its failure to attend the scheduled deposition. Accordingly, the court holds that the correct remedy in this case is to permit plaintiff an opportunity to appear for a deposition, subject to the penalty of dismissal of plaintiff’s case if it fails to do so. The plaintiff shall appear for a deposition at a date, time and place to be agreed to between the parties, or, failing agreement, at 10:00 a.m. on June 14, 2004 at the courthouse located at 141 Livingston St., Brooklyn, New York. In the event that plaintiff does not appear for a deposition on the date agreed to by the parties or on the date set by the court, defendant may settle an order on notice, pursuant to 22 NYCRR 208.33, dismissing the action.

Footnotes

Footnote *: The complaint does not allege that Ms. Joiles was injured in a car accident, which is an essential element of a claim under the No-Fault Law (Insurance Law § 5103). Accordingly, the court could dismiss the complaint sua sponte for failure to state a cause of action. The complaint refers to an annexed claim for payment, which was not attached to the copy of the complaint submitted with the moving papers. The claim for payment may have provided the missing information, since the denial of the claim refers to Ms. Joiles as the “injured person” and refers to an accident on May 18, 2000. Accordingly, the court will not dismiss the complaint, but cautions counsel to include the necessary allegations in their complaints.

Cited in this decision

A label shows how this decision treated the case it cites.

  • Ostia Med., PC v Government Empls. Ins. Co. (2003 NY Slip Op 51560(U)) Declined to followAn insurer must show a timely medical-necessity denial before deposing a provider on that defense.

Cited by

A label shows how the later decision treated this one.

  • Metropolitan Radiological Imaging v State Farm Mut. Auto. Ins. Co. (2005 NY Slip Op 25063) Declined to followAn insurer moving to compel no-fault discovery must supply its denial or verification demand, absent a compelling reason for omission.
  • MD Imaging, P.C. v Progressive N. Ins. Co. (2008 NY Slip Op 28434) FollowedA provider may obtain relevant medical records from an insurer upon supplying a valid assignment or authorization for disclosure.
  • Sanford Chiropractic, P.C. v New S. Ins. Co. (2020 NY Slip Op 50609(U)) FollowedA provider's unsworn interrogatory answers supplied by counsel do not comply with CPLR 3133 (b).

Similar decisions

  • Back to Back Chiropractor, P.C. v State Farm Mut. Auto. Ins. Co. (2012 NY Slip Op 51088(U))The provider's failure to object to improper verification demands left the payment period tolled and its claim premature.
  • Vinings Spinal Diagnostic v Travelers Prop. Cas. Ins. Co. (2006 NY Slip Op 50999(U))The provider failed to establish overdue benefits despite the insurer's failure to comply with a discovery stipulation.
  • Q-B Jewish Med. Rehabilitation, P.C. v Allstate Ins. Co. (2011 NY Slip Op 21390)The insurer justified bank and tax discovery, but the provider's remaining responses were sufficient.
  • All-Boro Med. Supplies, Inc. v Progressive Northeastern Ins. Co. (2007 NY Slip Op 27458)The insurer failed to prove timely mailing of verification requests or lack of medical necessity for the prescribed equipment.
  • Boai Zhong Yi Acupuncture Servs. PC v General Assur. Ins Co. (2005 NY Slip Op 50329(U))The provider obtained summary judgment because two denials were late and the third relied on an unavailable IME nonappearance defense.
Beynenson Law

Tech-driven New York no-fault collections for healthcare providers.

About the firm

Contact

  • East Hampton, New York

  • 347-746-6001
  • contact@beynensonlaw.com
  • Contact form

Case Law

  • Search
  • No-Fault AI
  • New Decisions
  • Legal Questions
  • No-Fault Regulations

Arbitration Data

  • Arbitrator Scorecard
  • Award Volume
  • Arbitrator / Carrier Data
  • Provider / Carrier Data
  • Provider / Attorney Data
  • Arbitration Pro Extension

©2026 The Beynenson Law Firm, PC. Terms of Use Privacy Policy

Site by khrystev.dev

Attorney Advertising. Prior results do not guarantee a similar outcome. This website provides general information, not legal advice, and using it does not create an attorney-client relationship. Do not send confidential information through this site.