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April 2, 2009

Ocean Acupuncture, P.C. v State Farm Mut. Auto. Ins. Co. (2009 NY Slip Op 50565(U))

https://www.beynensonlaw.com/case-law/ocean-acupuncture-p-c-v-state-farm-mut-auto-ins-co-2009-ny-slip-op50565u/

Court
Civil Court of the City of New York, New York County
Judge
Mendez, J.
Decided
April 2, 2009
Citation
2009 NY Slip Op 50565(U) · 23 Misc 3d 1104(A)
Posture
Summary judgment
Outcome
Provider prevailed
Issues
Staged accidents, lack of coverage Provider's prima facie case Timeliness and preclusion
Legal questions
No covered accident (founded belief) · Claimant's prima facie case on motions · Proof of mailing (see the maps)
Cite as
Ocean Acupuncture, P.C. v State Farm Mut. Auto. Ins. Co., 23 Misc 3d 1104(A), 2009 NY Slip Op 50565(U) (Civ Ct, New York County 2009)

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.

The insurer's conclusory affidavit failed to establish a founded belief that the assignor's injuries arose from a staged accident. The Civil Court, New York County, granted the provider's summary judgment motion and denied the insurer's cross motion. The provider established submission of its claims and overdue payment under Insurance Law § 5106 (a), with the insurer's denials acknowledging receipt. Although the denials exceeded the 30-day period under 11 NYCRR 65-3.8 (a), the lack-of-coverage defense remained available. The claims representative lacked personal knowledge of the investigation, and the insurer supplied neither an investigator's affidavit nor the EUO transcripts underlying the asserted discrepancies. Its unsubstantiated hypotheses and suppositions did not raise a triable issue.

Reported in New York Official Reports at Ocean Acupuncture, P.C. v State Farm Mut. Auto. Ins. Co. (2009 NY Slip Op 50565(U))

[*1]
Ocean Acupuncture, P.C. v State Farm Mut. Auto. Ins. Co.
2009 NY Slip Op 50565(U) [23 Misc 3d 1104(A)]
Decided on April 2, 2009
Civil Court, New York County
Mendez, J.
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
This opinion is uncorrected and will not be published in the printed Official Reports.
Decided on April 2, 2009

Civil Court, New York County



Ocean Acupuncture, P.C. AS ASSIGNEE OF RAFAEL ESPINOSA, , Plaintiff(s)/, Petitioner(s),

against

State Farm Mutual Automobile Ins. Co., Defendant(s)/, Respondent(s).

044447 CVN 2008

Attorneys for plaintiff:

Leon Kucherovsky

By: David Forman, Esq.

Attorneys for defendant:

Saretsky, Katz, Dranoff & Glass, LLP

By: Howard J. Newman, Esq.

Manuel J. Mendez, J.

Upon a reading of the foregoing cited papers on this motion and cross motion for summary judgment it is the decision of this court that the motion is granted, plaintiff is awarded judgment in the amount of $2,610.00 with interest at 2% per month from July 19, 2008, plus attorneys fees of 20% of judgment plus interest amount not to exceed $850.00, plus costs. The cross motion is denied.

This motion was returnable on November 13 2008. On the return date the court adjourned the motion to December 17, 2008 at which time defendant filed a cross motion and opposition to the motion. The court then adjourned the motion and cross motion to March 11, [*2]2009 for a reply. On March 11, 2009 there being no reply this court took the motion on submission and ordered plaintiff to submit its reply by March 25, 2009. Plaintiff has submitted its reply and this court now decides the motion.

Plaintiff moves for summary judgment to recover for services rendered its assignor under the No-fault provision of the Insurance Law. Plaintiff alleges that as a result of an automobile accident on July 19, 2002, it provided services to its assignor on August 15 to August 29, 2002 and on September 23, 2002 submitted a bill to the defendant for these services in the amount of $630.00. It provided services on September 3 to September 26, 2002 and on October 8, 2002 submitted a bill to the defendant for these services in the amount of $900.00. It provided services on October 1 to October 28, 2002 and on November 5, 2002 submitted a bill to the defendant for these services in the amount of $720.00. It provided services on November 1 to November 13, 2002 and on December 5, 2002 submitted a bill to the defendant for these services in the amount of $270.00. It provided services on December 20, 2002 and on January 7, 2003 submitted a bill to the defendant for these services in the amount of $90.00. The total for all the bills submitted by plaintiff to the defendant is $2,610.00.

In support of its motion plaintiff annexes the affidavit of Yevgeny Gorbatov, LAC, its owner who has personal knowledge that the claims were mailed because it is his responsibility to insure that the claims were mailed. He bases his affidavit on personal knowledge and a review of the file. He further states that the services were provided and bills mailed as indicated in this court’s factual recitation. Finally, he provides the office practice and procedure in place at the time these services were performed and bills generated to ensure that items are properly addressed and mailed( See Moving papers Exh. A).

Plaintiff also annexes to its moving papers the denial of claims issued by the defendant. In these denials, all dated February 17, 2003, defendant acknowledges receipt of the claims and denies all of the claims submitted based on lack of coverage ( See moving papers Exh. E). There was no verification requested to toll the 30 day period within which defendant had to pay or deny the claim.

Defendant cross moves for summary judgment on the basis that the assignor is perpetrating a fraud and has failed to cooperate. Its denial of claim form gives as a reason for the denial of all claims the following: ” All New York no-fault benefits are denied to the above injured person based on the loss not being accidental; violation of the fraud provisions of the policy; failure to cooperate, we base our conclusion on your failure to cooperate on evidence of your giving false or misleading information throughout the presentation of the claim; the injuries did not arise our of the use or operation of the insured vehicle; and engaging in fraudulent conduct in connection with this loss.”

In support of its motion defendant annexes an attorney’s affirmation, the affidavit of Christopher Maresco, a claims representative, and the denial of claims forms (NF-10). Absent from defendant’s submission is an affidavit from an investigator from its special investigations [*3]unit and a copy of the assignor’s examination under oath.There was no request for verification of claim or additional verification tolling the time within which to pay or deny plaintiff’s claim. All the claims were denied on February 17, 2003 more than 30 days after the last bill for $90.00 had been submitted. Rosemarie Tulino, not Christopher Maresco, was the adjustor assigned to this claim.

Defendant claims the denial is due to a number of factors all of which taken together establish that there was fraud perpetrated by its insured, including the assignor. The affidavit of Chistopher Maresco states that his knowledge is based on a review of the file and on his personal knowledge. He states that “he has been assigned to oversee the handling of this claim which was referred to the special investigations unit to resolve questions of merit since this loss had multiple fraud indicators which support State Farms’s founded belief that the collision was fraudulent and not an accident.” The affidavit goes on to indicate that there are “Fraud Indicators” leading defendant to its conclusion of fraud. Mr. Maresco goes on to state that ” When all the information was carefully investigated and analyzed it formed State Farm’s founded belief that the purported accident was not a covered accident, but instead it was an intentional act which is not covered under State Farm’s policy of insurance.”

In order to prevail on a motion for summary judgment, the proponent must make a prima facie showing of entitlement to judgment as a matter of law, through admissible evidence, eliminating all material issues of fact.(Klein V. City of New York, 89 NY2d 833; Ayotte V. Gervasio, 81 NY2d 1062, Alvarez v. Prospect Hospital, 68 NY2d 320). Once the moving party has satisfied these standards, the burden shifts to the opponent to rebut that prima facie showing, by producing contrary evidence, in admissible form, sufficient to require a trial of material factual issues(Kaufman V. Silver, 90 NY2d 204; Amatulli V. Delhi Constr. Corp.,77 NY2d 525; Iselin & Co. V. Mann Judd Landau, 71 NY2d 420). In determining the motion, the court must construe the evidence in the light most favorable to the non-moving party(SSBS Realty Corp. V. Public Service Mut. Ins. Co., 253 AD2d 583; Martin V. Briggs, 235 [1992]).

In an Action to recover first-party no-fault benefits for health care services provided to an assignor, a plaintiff establishes a prima facie entitlement to summary judgment by proof that it submitted a claim, setting forth the fact and amount of the loss sustained and that payment of no-fault benefits is overdue ( Insurance Law § 5106[a]; Mary Immaculate Hosp. , v. Allstate Ins. Co., 5 AD3d 742[2004]; Amaze Med. Supply v. Eagle Ins. Co., 2 Misc 3d 128 [A], 2003 NY Slip Op 51701[U][App. Term 2nd. & 11th Jud. Dists. 2003]). A no-fault benefits applicant may cure deficiencies in its proof of mailing by annexing to its motion papers an insurer’s denial of claim form wherein the insurer acknowledges the claims’ receipt ( Fair Price Med. Supply Corp., v. ELRAC Inc., 12 Misc 3d 119 [App. Term 2nd. & 11th, Jud. Dists. 2006]). Plaintiff has established a prima facie entitlement to summary judgment through the affidavit of Yevgeny Gorbatov and the exhibits annexed to its moving papers which show that a claim was submitted and payment is overdue. Any deficiencies in Mr. Gorbatov’s affidavit are cured by the defendant’s denial of claim forms which acknowledge receipt of plaintiff’s claims. [*4]

The burden now shifts to defendant to raise a material issue of fact. Defendant had 30 days to pay or deny the claim, counting from the date it receives the bills in question ( See 11 NYCRR§ 65-3.8(a)). Defendant did not pay or deny the claim within 30 days of receipt of the bill, and did not request verification of the bills within 15 days of its receipt ( See 11 NYCRR§ 3.5 (a)). However, this has no effect on its defense of lack of coverage.( See Presbyterian Hospital v. Maryland Casualty Co., 90 NY2d 274[1997]; Central General Hospital v. Chubb Group of Ins. Co.,90 NY2d 195, 659 N.Y.S. 2d 246 [1997]) which may be asserted after the time to pay or deny the claim has expired, premised on a “fact or founded belief” that the alleged injury does not arise out of an insured accident.

While the untimely denial does not preclude defendant from interposing the lack of coverage defense based on fraud, it remains defendant’s burden to demonstrate ” a fact or founded belief” that the injuries did not result from an insured event ( See Central General Hospital v. Chubb Group of Ins. Co., 90 NY2d 195, 199 [1997] Supra). Thus, defendant’s proof has been found lacking when an “investigator’s report alleged only that the uncooperative insured, but not the assignor, had been involved in prior accidents alleged to be “suspicious” ( A.B. Medical Services PLLC v. Eagle Insurance Co., 3 Misc 3d 8, 776 N.Y.S. 2d 434 [App. Term 2nd. Dept. 2003]), the motion is supported by an affirmation of defendant’s counsel without personal knowledge of the facts and an affidavit of a claim representative likewise with no personal knowledge of defendant’s investigation into the incident ( Oleg Barshay, D.C., P.C., v. State Farm Ins. Co., 14 Misc 3d 74, 831 N.Y.S. 2d 821 [App. Term 2nd. Dept. 2006]; Comprehensive Mental v. Allstate Ins. Co., 14 Misc 3d 130(A), 836 N.Y.S. 2d 484[ App. Term 9th & 10th Jud. Dists. 2007]) when the statements in the affidavit of the investigator are conclusory (Great Wall Acupuncture v. Utica Mutual Ins. Co., 14 Misc 3d 144 (A), 836 N.Y.S. 2d 499 [App. Term 2nd. & 11th Jud. Dists. 2007]).

“To interpose a defense of staged-accident fraud sufficient to raise a triable issue of fact, defendant must establish the fact or founded belief that the alleged injuries do not arise out of an insured incident. The discrepancies in the testimony given by two passengers during their examinations under oath are insufficient to establish a founded belief that the alleged injuries did not arise out of a covered accident. The affidavit of defendant’s claims representative and the attached exhibits failed to substantiate the conclusory allegations of the assignor’s participation in a ring that stages traffic incidents to defraud insurers” (Webster Diagnostic Medicine, P.C., v. State Farm Ins. Co., 15 Misc 3d 97, 838 N.Y.S. 2d. 343 [App. Term 9th & 10th Jud. Dists. 2007]).

The defendant must come forth with proof in admissible form which is more than just “unsubstantiated hypotheses and suppositions.” These are insufficient to raise a triable issue of the assignor’s fraud ( A.B. Medical Services, PLLC v. Eagle Ins. Co., 3 Misc 3d 8, 776, N.Y.S. 2d 434 [2003]; Oleg Barshay, D.C., P.C., v. State Farm Ins. Co., 14 Misc 3d 74, 831 N.Y.S. 2d 821 [2006];Comprehensive Mental v. Allstate Ins. Co., 14 Misc 3d 130(A), 836 N.Y.S. 2d 484 [2007];Great Wall Acupuncture v. Utica Mutual Ins. Co., 14 Misc 3d 144 (A), 836 N.Y.S. 2d 499[ 2007] Supra). [*5]

Defendant has failed to come forth with more than mere unsubstantiated hypothese and suppositions in support of its motion. Its attorney’s affirmation is without probative value as he has no personal knowledge of the facts ( See Melbourne Med., P.C., v. Utica Mut. Ins. Co., 4 Misc 3d 92 [App. Term 2nd. & 11th Jud. Dists. 2004]). The affidavit of Christopher Maresco is also without probative value as he has no personal knowledge of the investigation. He is not a member of the investigation Unit and was not the investigator assigned to investigate plaintiff’s assignor’s claims. In fact his affidavit does not state the name of the investigator investigating this claim. His affidavit, which is based on his review of the file is conclusory and provides no more than the hypothese and suppositions which the courts have previously rejected as insufficient to support or oppose a motion for summary judgment. Mr. Maresco alludes to discrepancies in the Examinations Under Oath of the various passengers in the vehicle at the time of the accident. However, the transcripts are not annexed to the cross moving papers for the court to review. The court is left to rely on the analysis of these transcripts by Mr. Maresco who reaches the conclusion that the accident was not a covered accident. His affidavit without more is insufficient to defeat plaintiff’s entitlement to summary judgment.

Accordingly, it is the decision and order of this court that the motion for summary judgment is granted. Plaintiff is awarded a judgment in the amount of $ $2,610.00 with interest at 2% per month from July 19, 2008, plus attorneys fees of 20% of the judgment plus the interest amount not to exceed $850.00, plus costs. The cross motion is denied.

This constitutes the decision and order of this court.

Dated: April 2, 2009__________________________

Manuel J. Mendez

Judge Civil Court

Legal questions (3)

Questions 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.

No covered accident (founded belief)

Open the full map

Did the insurer show the claimed injuries did not arise from a covered accident (staged, intentional, or unrelated)?

This decision: Insurer's proof did not raise an issue or failed at trial; provider prevails on it

Held the insurer showed no founded belief that the collision was intentional because counsel's affirmation and a claims representative's file-review affidavit lacked personal knowledge, were conclusory, and the EUO transcripts were not annexed.

  • Court of AppealsCt App 1
  • Appellate DivisionApp Div 9
  • Appellate TermApp Term 8
  • Trial courtsTrial 11
2011, Court of Appeals: 1 decision (1 Defense not shown)2022, Appellate Division: 3 decisions (3 Defense established)2021, Appellate Division: 1 decision (1 Defense established)2020, Appellate Division: 1 decision (1 Defense established)2024, Appellate Division: 1 decision (1 Defense established)2025, Appellate Division: 2 decisions (2 Defense established)2023, Appellate Division: 1 decision (1 Defense established)2017, Appellate Term: 2 decisions (2 Triable issue)2013, Appellate Term: 1 decision (1 Defense established)2009, Appellate Term: 1 decision (1 Defense not shown)2007, Appellate Term: 3 decisions (1 Triable issue, 2 Defense not shown)2005, Appellate Term: 1 decision (1 Defense not shown)2022, Trial courts: 1 decision (1 Defense established)2020, Trial courts: 2 decisions (2 Insurer's motion fails)2018, Trial courts: 2 decisions (1 Defense established, 1 Triable issue)2009, Trial courts: 1 decision (1 Defense not shown)2008, Trial courts: 1 decision (1 Triable issue)2004, Trial courts: 1 decision (1 Defense not shown)2024, Trial courts: 1 decision (1 Defense established)2025, Trial courts: 2 decisions (1 Defense established, 1 Triable issue)This decision
20052010201520202025
Defense establishedTriable issueInsurer's motion failsDefense not shownThis decision

Of the 29 decisions on this question in the First Department courts and the Court of Appeals, 7 (this one included) are in the same category. 5 decisions in other departments that cite or are cited by this one are on the full map.

Claimant's prima facie case on motions

Open the full map

On summary judgment or another pretrial motion, what must a no-fault claimant show to establish its prima facie case?

This decision: Claimant's proof held to make out its prima facie case (rules on the question, but another ground decided the case)

Held the provider established its prima facie case through its owner's affidavit and exhibits showing claims submitted and payment overdue, with any affidavit deficiencies cured by the insurer's denials acknowledging receipt.

  • Court of AppealsCt App 2
  • Appellate DivisionApp Div 1
  • Appellate TermApp Term 30
  • Trial courtsTrial 17
2015, Court of Appeals: 1 decision (1 Proof sufficient)2007, Court of Appeals: 1 decision (1 Proof sufficient)2008, Appellate Division: 1 decision (1 Proof sufficient)2016, Appellate Term: 2 decisions (1 Proof sufficient, 1 Overdue not shown)2015, Appellate Term: 2 decisions (2 Proof sufficient)2014, Appellate Term: 1 decision (1 Proof sufficient)2011, Appellate Term: 3 decisions (3 Proof sufficient)2010, Appellate Term: 3 decisions (3 Proof sufficient)2009, Appellate Term: 2 decisions (2 Proof sufficient)2008, Appellate Term: 4 decisions (4 Proof sufficient)2006, Appellate Term: 3 decisions (3 Proof sufficient)2005, Appellate Term: 3 decisions (3 Proof sufficient)2004, Appellate Term: 2 decisions (2 Proof sufficient)2007, Appellate Term: 3 decisions (3 Proof sufficient)2012, Appellate Term: 1 decision (1 Proof sufficient)2017, Appellate Term: 1 decision (1 Proof sufficient)2021, Trial courts: 2 decisions (1 Proof sufficient, 1 Overdue not shown)2020, Trial courts: 1 decision (1 Mailing/receipt not shown)2019, Trial courts: 1 decision (1 Proof sufficient)2009, Trial courts: 1 decision (1 Proof sufficient)2008, Trial courts: 1 decision (1 Proof sufficient)2007, Trial courts: 2 decisions (2 Proof sufficient)2005, Trial courts: 1 decision (1 Other element missing)2004, Trial courts: 2 decisions (2 Proof sufficient)2024, Trial courts: 1 decision (1 Mailing/receipt not shown)2006, Trial courts: 3 decisions (3 Proof sufficient)2022, Trial courts: 1 decision (1 Overdue not shown)2025, Trial courts: 1 decision (1 Proof sufficient)This decision
20052010201520202025
Proof sufficientMailing/receipt not shownOverdue not shownOther element missingThis decision

Of the 50 decisions on this question in the First Department courts and the Court of Appeals, 44 (this one included) are in the same category. 6 decisions in other departments that cite or are cited by this one are on the full map.

Proof of mailing

Open the full map

Did a party’s evidence establish that it mailed a no-fault claim, denial, verification request or examination notice?

This decision: The provider's or claimant's proof established mailing of its claim form, NF-2 or verification response (rules on the question, but another ground decided the case)

Held the owner's affidavit describing the office mailing practice proved mailing of the bills, and any deficiencies were cured by the insurer's denial forms acknowledging receipt of the claims.

  • Court of AppealsCt App 1
  • Appellate DivisionApp Div 20
  • Appellate TermApp Term 94
  • Trial courtsTrial 36
2015, Court of Appeals: 1 decision (1 Provider proved mailing)2023, Appellate Division: 1 decision (1 Insurer proved mailing)2022, Appellate Division: 1 decision (1 Insurer proved mailing)2020, Appellate Division: 1 decision (1 Insurer proved mailing)2019, Appellate Division: 1 decision (1 Insurer failed to prove)2018, Appellate Division: 2 decisions (1 Insurer proved mailing, 1 Insurer failed to prove)2016, Appellate Division: 2 decisions (1 Insurer proved mailing, 1 Insurer failed to prove)2015, Appellate Division: 5 decisions (5 Insurer proved mailing)2014, Appellate Division: 1 decision (1 Insurer proved mailing)2013, Appellate Division: 4 decisions (3 Insurer proved mailing, 1 Insurer failed to prove)2024, Appellate Division: 2 decisions (2 Insurer proved mailing)2017, Appellate Term: 3 decisions (2 Insurer failed to prove, 1 Provider proved mailing)2016, Appellate Term: 12 decisions (12 Insurer proved mailing)2015, Appellate Term: 18 decisions (14 Insurer proved mailing, 2 Insurer failed to prove, 1 Provider proved mailing, 1 Provider failed to prove)2014, Appellate Term: 14 decisions (11 Insurer proved mailing, 2 Insurer failed to prove, 1 Triable issue on mailing)2013, Appellate Term: 7 decisions (5 Insurer proved mailing, 1 Insurer failed to prove, 1 Provider failed to prove)2012, Appellate Term: 15 decisions (11 Insurer proved mailing, 2 Insurer failed to prove, 2 Provider failed to prove)2011, Appellate Term: 8 decisions (7 Insurer proved mailing, 1 Insurer failed to prove)2010, Appellate Term: 3 decisions (2 Insurer proved mailing, 1 Provider proved mailing)2008, Appellate Term: 3 decisions (1 Insurer proved mailing, 1 Insurer failed to prove, 1 Provider proved mailing)2007, Appellate Term: 1 decision (1 Provider failed to prove)2006, Appellate Term: 4 decisions (1 Insurer failed to prove, 1 Provider proved mailing, 2 Provider failed to prove)2004, Appellate Term: 1 decision (1 Provider proved mailing)2025, Appellate Term: 2 decisions (2 Insurer proved mailing)2026, Appellate Term: 1 decision (1 Insurer proved mailing)2005, Appellate Term: 1 decision (1 Insurer proved mailing)2020, Appellate Term: 1 decision (1 Insurer failed to prove)2022, Trial courts: 2 decisions (1 Insurer proved mailing, 1 Insurer failed to prove)2021, Trial courts: 6 decisions (5 Insurer proved mailing, 1 Provider proved mailing)2020, Trial courts: 3 decisions (1 Insurer failed to prove, 2 Provider failed to prove)2019, Trial courts: 2 decisions (2 Insurer proved mailing)2018, Trial courts: 3 decisions (2 Insurer proved mailing, 1 Triable issue on mailing)2013, Trial courts: 2 decisions (2 Insurer proved mailing)2009, Trial courts: 2 decisions (1 Insurer proved mailing, 1 Provider proved mailing)2008, Trial courts: 2 decisions (2 Insurer proved mailing)2007, Trial courts: 2 decisions (1 Insurer proved mailing, 1 Provider proved mailing)2024, Trial courts: 2 decisions (2 Insurer proved mailing)2025, Trial courts: 4 decisions (2 Insurer proved mailing, 1 Insurer failed to prove, 1 Provider proved mailing)2026, Trial courts: 2 decisions (2 Insurer failed to prove)2005, Trial courts: 1 decision (1 Mixed rulings)2006, Trial courts: 2 decisions (1 Provider proved mailing, 1 Triable issue on mailing)2023, Trial courts: 1 decision (1 Insurer proved mailing)This decision
20052010201520202025
Insurer proved mailingInsurer failed to proveProvider proved mailingProvider failed to proveTriable issue on mailingMixed rulingsThis decision

Of the 151 decisions on this question in the First Department courts and the Court of Appeals, 12 (this one included) are in the same category. 2 decisions in other departments that cite or are cited by this one are on the full map.

Cited in this decision

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

  • Mary Immaculate Hosp. v Allstate Ins. Co. (2004 NY Slip Op 02359)The hospitals established entitlement to summary judgment by proving that statutory billing forms were mailed and received and payment was overdue.
  • Amaze Med. Supply v Eagle Ins. Co. (2003 NY Slip Op 51701(U))A provider's completed claim forms establish its prima facie case without additional medical proof when the insurer is precluded.
  • Fair Price Med. Supply Corp. v ELRAC Inc. (2006 NY Slip Op 26269) FollowedAn improper self-referral defense survives a late denial when a health care provider seeks benefits through an entity in which it has an interest.
  • A.B. Med. Servs. v Eagle Ins. Co. (2003 NY Slip Op 23978)The insurer's investigator's affidavit failed to raise a triable issue that the collision was staged.
  • Oleg Barshay, D.C., P.C. v State Farm Ins. Co. (2006 NY Slip Op 26496)A provider's deficient proof of claim submission may be cured by an insurer's denial form submitted in opposition to summary judgment.
  • Webster Diagnostic Medicine, P.C. v State Farm Ins. Co. (2007 NY Slip Op 27134) FollowedThe insurer's conclusory fraud allegations and passenger EUO discrepancies failed to establish a founded belief of noncoverage.
  • Melbourne Med., P.C. v Utica Mut. Ins. Co. (2004 NY Slip Op 24221) FollowedEUO requests do not toll the claim determination period when the governing no-fault regulations do not authorize EUO verification.

Similar decisions

  • A.B. Med. Servs. PLLC v New York Cent. Mut. Fire Ins. Co. (2004 NY Slip Op 51847(U))The insurer failed to prove mailing of IME requests and was precluded from asserting untimely fee-schedule and medical-necessity defenses.
  • Boai Zhong Yi Acupuncture Servs., P.C. v New York Cent. Mut. Fire Ins Co. (2005 NY Slip Op 51058(U))The insurer failed to toll its late denials or submit competent low-impact evidence supporting its lack-of-causation defense.
  • Capri Med., P.C. v New York Cent. Mut. Fire Ins. Co. (2006 NY Slip Op 50538(U))The insurer's low-impact study and out-of-state affidavit were inadmissible and failed to support its lack-of-causation defense.
  • A.M Med. v New York Cent. Mut. Ins. Co. (2004 NY Slip Op 50298(U))The insurer's unsworn low-impact report failed to establish a coverage defense or raise a triable issue concerning injury causation.
  • 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.
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