July 12, 2019
New Way Med. Supply Corp. v State Farm Mut. Auto. Ins. Co. (2019 NY Slip Op 51158(U))
https://www.beynensonlaw.com/case-law/new-way-med-supply-corp-v-state-farm-mut-auto-ins-co-2019-ny-slip-op51158u/
- Decided
- July 12, 2019
- Citation
- 2019 NY Slip Op 51158(U)
- Posture
- Summary judgment
- Outcome
- Insurer prevailed
- Later treatment
- Followed in 1 later decision (see Cited by)
- Legal questions
- No-show defense: insurer's proof (see the maps)
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.
Reported in New York Official Reports at New Way Med. Supply Corp. v State Farm Mut. Auto. Ins. Co. (2019 NY Slip Op 51158(U))
SUPREME COURT, APPELLATE TERM, SECOND DEPARTMENT, 2d, 11th and 13th JUDICIAL DISTRICTS
against
State Farm Mutual Automobile Ins. Co., Respondent.
The Rybak Firm, PLLC (Damin J. Toell of counsel), for appellant. Rivkin Radler, LLP (Stuart M. Bodoff of counsel), for respondent.
Appeal from an order of the Civil Court of the City of New York, Kings County (Steven Z. Mostofsky, J.), entered May 8, 2015. The order granted defendant’s motion for summary judgment dismissing the complaint.
ORDERED that the order is affirmed, with $25 costs.
In this action by a provider to recover assigned first-party no-fault benefits, defendant moved for summary judgment dismissing the complaint on the ground that plaintiff had failed to appear for duly scheduled examinations under oath (EUOs). In opposition, plaintiff argued, among other things, that the motion should be denied pursuant to CPLR 3212 (f) because plaintiff needed discovery in order to oppose the motion. Plaintiff appeals from an order of the Civil Court which granted defendant’s motion.
Contrary to plaintiff’s argument on appeal, defendant sufficiently established plaintiff’s failure to appear for the two duly scheduled EUOs (see e.g. T & J Chiropractic, P.C. v State Farm Mut. Auto. Ins. Co., 47 Misc 3d 130[A], 2015 NY Slip Op 50406[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2015]; Natural Therapy Acupuncture, P.C. v State Farm Mut. Auto. Ins. Co., 44 Misc 3d 141[A], 2014 NY Slip Op 51310[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2014]). Plaintiff’s contention that defendant’s motion should be denied as premature on the ground that discovery was not yet complete (see CPLR 3212 [f]) lacks merit. ” ‘A party who claims ignorance of critical facts to defeat a motion for summary judgment (see, CPLR 3212 [f]) must first demonstrate that the ignorance is unavoidable and that reasonable attempts were made to discover the facts which would give rise to a triable issue’ ” (Sasson v Setina Mfg. Co., Inc., 26 AD3d 487, 488 [2006], quoting Cruz v Otis El. Co., 238 AD2d 540, 540 [1997]). In the instant case, the record reflects that plaintiff first served its discovery demands, if at all, on February 23, [*2]2015, the same date on which plaintiff served its opposition to defendant’s motion. As defendant’s answer was served on March 21, 2014, plaintiff failed to demonstrate that it made a reasonable attempt during the intervening 11 months to obtain the discovery it alleges that it needs.
Equally devoid of merit is plaintiff’s assertion that defendant’s motion should have been denied because defendant failed to establish that it possessed a reasonable basis for requesting the EUOs of plaintiff. This court has held on multiple occasions that since the Appellate Division, Second Department, stated that an insurer need only establish “as a matter of law that it twice duly demanded an [EUO] from the [provider] . . ., that the [provider] twice failed to appear, and that the [insurer] issued a timely denial of the claims” (Interboro Ins. Co. v Clennon, 113 AD3d 596, 597 [2014]), an insurer “d[oes] not need to set forth the objective reasons for the requested EUOs as part of its prima facie showing of entitlement to judgment as a matter of law” (Barakat Med. Care, P.C. v Nationwide Ins. Co., 49 Misc 3d 147[A], 2015 NY Slip Op 51677[U], *1 [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2015]; see also Gentlecare Ambulatory Anesthesia Servs. v Geico Ins. Co., 57 Misc 3d 150[A], 2017 NY Slip Op 51518[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2017]; Parisien v Metlife Auto & Home, 54 Misc 3d 143[A], 2017 NY Slip Op 50208[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2017]; Palafox PT, P.C. v State Farm Mut. Auto. Ins. Co., 49 Misc 3d 144[A], 2015 NY Slip Op 51653[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2015]).
Accordingly, the order is affirmed.
PESCE, P.J., WESTON and ALIOTTA, JJ., concur.
ENTER:
Paul Kenny
Chief Clerk
Decision Date: July 12, 2019
Legal questions
A question of no-fault law this decision rules on, from our Legal Questions pages. Bars count the decisions on the question by year and court, coloured by category; circles are this decision and the decisions on the question it cites or that cite it. Point at a bar or circle for details. The categories and summaries are Beynenson Law’s classification, made by a language model and checked by a second reading.
Did the insurer prove its IME/EUO no-show defense: mailed, compliant scheduling requests and the claimant’s nonappearance?
This decision: Insurer proved mailed, compliant requests and the nonappearance; claimant's answers rejected
Held the insurer sufficiently established the provider's failure to appear for two scheduled EUOs, rejecting arguments that discovery was needed under CPLR 3212 (f) and that the insurer had to show a reasonable basis for requesting the EUOs.
Of the 858 decisions on this question in the Second Department courts and the Court of Appeals, 527 (this one included) are in the same category.
Cited in this decision
A label shows how this decision treated the case it cites.
- T & J Chiropractic, P.C. v State Farm Mut. Auto. Ins. Co. (2015 NY Slip Op 50406(U))The provider's objections to the EUO requests were not heard because it did not claim to have responded to those requests.
- Natural Therapy Acupuncture, P.C. v State Farm Mut. Auto. Ins. Co. (2014 NY Slip Op 51310(U))The provider's unanswered EUO requests foreclosed its reasonableness objections and made related discovery unnecessary to oppose summary judgment.
- Interboro Ins. Co. v Clennon (2014 NY Slip Op 00092) FollowedThe assignor's two EUO nonappearances supported a declaration that the providers were not entitled to no-fault benefits.
- Barakat Med. Care, P.C. v Nationwide Ins. Co. (2015 NY Slip Op 51677(U)) FollowedAn insurer need not state objective reasons for assignor EUOs as part of its prima facie showing for summary judgment on nonappearance.
- Gentlecare Ambulatory Anesthesia Servs. v Geico Ins. Co. (2017 NY Slip Op 51518(U))An insurer need not state objective reasons for requesting EUOs to establish prima facie entitlement to summary judgment for nonappearance.
- Palafox PT, P.C. v State Farm Mut. Auto. Ins. Co. (2015 NY Slip Op 51653(U))The provider failed to identify discovery that could raise a triable issue concerning the insurer's EUO nonappearance defense.
Cited by
A label shows how the later decision treated this one.
- Sayyed DC, P.C. v Ameriprise Ins. Co. (2021 NY Slip Op 50311(U)) FollowedThe insurer established its EUO nonappearance defense to six bills, but untimely denials barred that defense to two others.
- NY Wellness Med. P.C. v Ameriprise Ins. Co. (2021 NY Slip Op 50382(U))The insurer's delay notices referring only to the assignor's EUO failed to toll the payment period for three provider bills.
- New York Core Chiropractic, P.C. v Ameriprise Ins. Co. (2021 NY Slip Op 50599(U))An EUO request sent after 15 business days but within 30 calendar days tolls the time to pay or deny, with a reduction for lateness.
- Sloan v Nationwide Mut. Ins. Co. (2022 NY Slip Op 50997(U))The insurer's EUO defense failed because its initial request and its denial following the second nonappearance were untimely.
Similar decisions
- Vladenn Med. Supply Corp. v State Farm Mut. Auto. Ins. Co. (2016 NY Slip Op 50928(U))The insurer proved timely mailing and the provider's EUO nonappearances, while the provider failed to justify further discovery.
- Flatlands Med., P.C. v State Farm Mut. Auto. Ins. Co. (2013 NY Slip Op 50071(U))The provider's EUO nonappearances defeated coverage, and its objections to the requests could not be considered absent any alleged response.
- Professional Health Imaging, P.C. v State Farm Mut. Auto. Ins. Co. (2016 NY Slip Op 50997(U))The provider failed to show a timely objection to EUO requests and could not challenge their reasonableness in litigation.
- Island Life Chiropractic Pain Care, PLLC v State Farm Mut. Auto. Ins. Co. (2018 NY Slip Op 51594(U))An insurer need not state objective reasons for requesting EUOs to establish prima facie entitlement to summary judgment for nonappearance.
- Actual Chiropractic, P.C. v State Farm Ins. (2019 NY Slip Op 50421(U))An insurer need not state objective reasons for requesting EUOs to establish entitlement to summary judgment for nonappearance.