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March 27, 2006

A.B. Med. Servs. PLLC v Prudential Prop. & Cas. Ins. Co. (2006 NY Slip Op 50504(U))

https://www.beynensonlaw.com/case-law/a-b-med-servs-pllc-v-prudential-prop-cas-ins-co-2006-ny-slip-op-50504u/

Court
Appellate Term, Second Department
Decided
March 27, 2006
Citation
2006 NY Slip Op 50504(U) · 11 Misc 3d 137(A)
Posture
Summary judgment
Outcome
Split result
Later treatment
Contrasted (cf., but see) in 1 and followed in 5 later decisions (see Cited by)
Issues
Timeliness and preclusion IME no-show EUO no-show
Legal questions
Proof of mailing · No-show: coverage defense or precludable? · Claimant's prima facie case on motions · No-show defense: insurer's proof · Fraudulent incorporation (Mallela) · Mallela defense: preclusion and discovery (see the maps)
Cite as
A.B. Med. Servs. PLLC v Prudential Prop. & Cas. Ins. Co., 11 Misc 3d 137(A), 2006 NY Slip Op 50504(U) (App Term, 2d Dept, 2d & 11th Jud Dists 2006)

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 providers obtained partial summary judgment because denials were untimely or defenses lacked evidentiary support. The Appellate Term, Second Department, modified the order to grant the medical-services provider judgment on all claims for two assignors and untimely denied claims for a third, and the chiropractic provider judgment, remanding for interest and fees. Under Insurance Law § 5106 (a), unsupported EUO requests did not toll the determination period; conclusory fraudulent-incorporation allegations raised no triable issue under Mallela. Summary judgment remained denied on the third assignor's other claims because conceded IME nonattendance left issues concerning the requests, excuses and medical necessity. The acupuncture provider's appeal was dismissed because its claims were absent from the motion. A partial dissent found verification responses unproved and the payment period untriggered.

Reported in New York Official Reports at A.B. Med. Servs. PLLC v Prudential Prop. & Cas. Ins. Co. (2006 NY Slip Op 50504(U))

[*1]
A.B. Med. Servs. PLLC v Prudential Prop. & Cas. Ins. Co.
2006 NY Slip Op 50504(U) [11 Misc 3d 137(A)]
Decided on March 27, 2006
Appellate Term, Second Department
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 March 27, 2006

SUPREME COURT OF THE STATE OF NEW YORK

APPELLATE TERM: 2nd and 11th JUDICIAL DISTRICTS


PRESENT: : PESCE, P.J., GOLIA and BELEN, JJ
2004-1818 K C. NO. 2004-1818 K C
A.B. Medical Services PLLC D.A.V. CHIROPRACTIC P.C. LVOV ACUPUNCTURE P.C. a/a/o RAYMOND MICHELINE, YVELYNE GARRAUD and FLAVIE GUERRIER, Appellants,

against

Prudential Property & Casualty Insurance Company, Respondent.

Appeal from an order of the Civil Court of the City of New York, Kings County (Manuel J. Mendez, J.), entered October 29, 2004. The order denied plaintiffs’ motion for summary judgment.

Order modified by granting plaintiff A.B. Medical Services PLLC partial summary judgment in the sum of $11,903.39, and plaintiff D.A.V. Chiropractic P.C. summary judgment in the sum of $134.80; as so modified, affirmed without costs. [*2]

Appeal as taken by plaintiff Lvov Acupuncture P.C. unanimously dismissed.

In this action to recover assigned first-party no-fault benefits, plaintiffs A.B. Medical Services PLLC and D.A.V. Chiropractic P.C. established their entitlement to summary judgment as to all their claims by proof that they submitted statutory claim forms, setting forth the fact and amounts of the losses sustained, and that payment of no-fault benefits was overdue (see Insurance Law § 5106 [a]; Mary Immaculate Hosp. v Allstate Ins. Co., 5 AD3d 742 [2004]; A.B. Med. Servs. PLLC v Lumbermens Mut. Cas. Co., 4 Misc 3d 86 [App Term, 2d & 11th Jud Dists 2004]). We note that an absent index number on one of numerous documents submitted in support of an otherwise properly indexed motion was an inappropriate ground to deny the relief sought. While all papers submitted to a court must bear the action’s index number (see CPLR 2101 [c]; Uniform Civil Rules for the New York City Civil Court [22 NYCRR] § 208.5), such a defect is not jurisdictional, and is waived if the opposing party fails to object by returning the paper to the party serving it within two days of receipt “with a statement of particular objections” (CPLR 2101 [f]; Neveloff v Faxton Children’s Hosp. & Rehabilitation Ctr., 227 AD2d 457, 457 [1996]; Deygoo v Eastern Abstract Corp., 204 AD2d 596 [1994]). In any event, absent prejudice to a “substantial right of a party,” such defects should be disregarded (CPLR 2101 [f]; e.g. Gau v Kramer, 289 AD2d 804, 805 [2001]).

We also do not agree that the allegedly defective proof of assignments merited the motion’s outright denial. Defendant failed timely to seek verification of the assignments or even specifically to allege a deficiency in the assignments in its claim denial forms, and thereby “waive[d] . . . any defenses with respect [to them]” (Ocean Diagnostic Imaging P.C. v Travelers Prop. Cas. Corp., 7 Misc 3d 137[A], 2005 NY Slip Op 50790[U] [App Term, 2d & 11th Jud Dists]; see Hospital for Joint Diseases v Allstate Ins. Co., 21 AD3d 348 [2005]; New York Hosp. Med. Ctr. of Queens v New York Cent. Mut. Fire Ins. Co., 8 AD3d 640 [2004]; Capio Med., P.C. v Progressive Cas. Ins. Co., 7 Misc 3d 129[A], 2005 NY Slip Op 50526[U] [App Term, 2d & 11th Jud Dists]).

The court below also incorrectly determined that all claim denials were timely; in fact, they were untimely as to numerous claims, specifically, A.B. Medical Services PLLC’s claims with respect to assignor Micheline for $205.46, $182.37, $564.48, $218.35, $71.06, $230.10, and $604.24; with respect to assignor Garraud for $182.37, $586.66, $218.35, $120.00, $230.10, $604.24, $1,972.08, $1,999.12, $71.06, and $71.40; and with respect to assignor Guerrier for $182.37, $205.46, $506.64, $71.06, $230.10, $604.24, and $1,972.08. As to plaintiff D.A.V. Chiropractic P.C.’s claim for $134.80 for treatment rendered to Guerrier, defendant proved no claim denial
whatsoever. Absent a tolling of the statutory claim determination period or proof that defendant established a triable defense which survives the preclusive effect of an untimely denial, summary judgment should have been granted as to these claims.

As to all of A.B. Medical Services PLLC’s claims regarding assignor Micheline, aside from the claim for $250.88, defendant denied the claims, in part, because plaintiff’s assignor failed to attend a requested examination under oath. However, defendant produced no documentary proof that it mailed assignor a written examination request, nor did its affiant assert personal knowledge of actual mailing or of facts creating a presumption of same, nor was there [*3]any admission of receipt by plaintiff, its assignor, or assignor’s representative (Careplus Med. Supply Inc. v Travelers Home & Mar. Ins. Co., 7 Misc 3d 133[A], 2005 NY Slip Op 50648[U] [App Term, 2d & 11th Jud Dists]). Additionally, defendant also offered no proof that the instant insurance policy contained an endorsement authorizing such a form of verification (id.). Thus, defendant failed to toll the claim determination periods by a proper verification request.

Insofar as defendant denied certain of the claims on the ground that plaintiff A.B. Medical Services PLLC is not formed and operated “in accordance with Article 15 of the [Business Corporation Law],” a defense sounding in fraud (State Farm Mut. Auto. Ins. Co. v Mallela, 4 NY3d 313, 320 [2005] [“State Farm’s complaint centers on fraud in the [*4]
corporate form rather than on the quality of care provided”]) which survives the preclusion sanction (id. at 320), defendant failed to assert a factual basis in its opposition papers sufficient to support a “founded belief” that A.B. Medical Services PLLC is ineligible to obtain no-fault benefits by reason of a fraudulent corporate filing (Central Gen. Hosp. v Chubb Group of Ins. Cos., 90 NY2d 195, 199 [1997]). Given A.B. Medical Services PLLC’s unrebutted proof that it has a duly registered corporate presence in New York, defendant’s bare, conclusory assertion in opposition to the motion, that said plaintiff is not formed or operated in accordance with the Business Corporation Law, failed to establish a triable issue of material fact.

The remaining, conclusorily asserted defenses, that the billing is “inaccurate or misleading” and not in accordance with the fee schedules, that plaintiff failed to prove the employment status of the particular provider, and that the treatment “was not related to the accident,” all fail to survive the preclusive effect of an untimely denial, and in any event, as to the claims timely denied, they are without merit (id.; Presbyterian Hosp. in City of N.Y. v Maryland Cas. Co., 90 NY2d 274, 285 [1997]; Westchester Med. Ctr. v American Tr. Ins. Co., 17 AD3d 581, 582 [2005]; New York Hosp. Med. Ctr. of Queens v Country-wide Ins. Co., 295 AD2d 583, 586 [2002]; Rockaway Blvd. Med. P.C. [*5]
v Progressive Ins., 9 Misc 3d 52 [App Term, 2d & 11th Jud Dists 2005]; Struhl v Progressive Cas. Ins. Co., 7 Misc 3d 138[A], 2005 NY Slip Op 50864[U] [App Term, 9th & 10th Jud Dists]; Triboro Chiropractic & Acupuncture v New York Cent. Mut. Fire Ins. Co., 6 Misc 3d 132[A], 2005 NY Slip Op 50110[U] [App Term, 2d & 11th Jud Dists]; Melbourne Med., P.C. v Utica Mut. Ins. Co., 4 Misc 3d 92, 94 [App Term, 2d & 11th Jud Dists 2004]; Abraham v Country-Wide Ins. Co., 3 Misc 3d 130[A], 2004 NY Slip Op 50388[U] [App Term, 2d & 11th Jud Dists]).

As for all claims regarding assignor Garraud, whether timely or untimely denied, the defenses and merits thereof are as previously stated. Additionally, the peer review report submitted in opposition to the motion, cited as a basis for the denial of plaintiff A.B. Medical Services PLLC’s claims for $1,972.08 and $1,999.12, failed to invoke the penalties of perjury (Lubrano v Papandreou, 262 AD2d 457, 457 [1999]; Tattegrain v New York City Trans. Auth., 2002 NY Slip Op 40296[U] [App Term, 2d & 11th Jud Dists]) and there is no reference to CPLR 2106 upon which it may be inferred that the affiant invoked the language of the statute (Jones v Schmitt, 7 Misc 3d 47, 48 [App Term, 2d & 11th Jud Dists 2005]), nor did defendant “offer[ ] an[ ] acceptable excuse as to why [it] failed to obtain a sworn, admissible report” (Lubrano v Papandreou, 262 [*6]
AD2d at 458; see also Friends of Animals v Associated Fur Mfrs., 46 NY2d 1065, 1068 [1979]; Allstate Ins. Co. v Keil, 268 AD2d 545 [2000]). In any event, defendant’s untimely denial of these claims precludes the defense asserted in the report. As to defendant’s alleged demands to conduct independent medical examinations (IMEs) of assignor Garraud, defendant offered no proof of mailing of any such demands nor did its affiant state sufficient facts upon which a presumption of mailing may be inferred (Careplus Med. Supply Inc. v Travelers Home & Mar. Ins. Co., 7 Misc 3d 133[A], 2005 NY Slip Op 50648[U], supra). Thus, summary judgment should have been granted as to all claims for treatment rendered assignor Garraud.

As to the claims for treatment rendered Guerrier, aside from the above-noted claims which were untimely denied or for which no denial was proved, Guerrier admitted, via a letter from his counsel to defendant, that he failed to attend two properly scheduled independent medical examinations and two follow-up examinations. Unsatisfied IME requests made prior to a claim’s filing remove the presumption of medical necessity which attaches to the claim forms, and absent additional proof of medical necessity, a provider’s motion for summary judgment based solely on the proof of claims must be denied (Stephen Fogel Psychological, P.C. v Progressive Cas. Ins. Co., 7 Misc 3d 18 [App Term, 2d & 11th Jud Dists 2004]). Upon assignor’s conceded failure to attend those examinations, there remains a triable issue of claimant’s assertion they were improperly sought, and whether plaintiff can offer a valid excuse for the nonattendance, and if not, whether the treatment for said claims was medically necessary (e.g. A.B. Med. Services PLLC v USAA Gen. Indem. Co., 9 Misc 3d 19 [App Term, 2d & 11th Jud Dists 2005]). Therefore, as to the claims for $1,972.08, $1,999.12, $699.68, $71.06 (submitted 2/24/03), $260.64, $71.06 (submitted 3/31/02), $71.40, $71.06 (submitted 4/28/04), and $62.72, for treatment rendered Guerrier, summary judgment was properly denied.

To summarize, partial summary judgment should have been granted to plaintiff A.B. Medical Services PLLC in the sum of $11,903.39, representing claims for treatment rendered assignor Micheline and Garraud, and, with respect to the claims of Guerrier, the claims for $182.37, $205.46, $506.64, $71.06, $230.10, $604.24, and $1,972.08, which were untimely denied. Summary judgment should also have been granted as to plaintiff D.A.V. Chiropractic P.C.’s claim for $134.80. The matter is remanded to the court below for a calculation of the statutory interest and an assessment of attorney’s fees pursuant to Insurance Law § 5106 (a) and the regulations promulgated thereunder as to all claims for which summary judgment is
granted, and for all further proceedings on plaintiff A.B. Medical Services PLLC’s remaining claims for treatment rendered assignor Guerrier.

Since none of plaintiff Lvov Acupuncture P.C.’s claims for treatment rendered its assignors was asserted in the motion below, it was not aggrieved by the court’s determination of the order from which it appeals, and said appeal is dismissed (see CPLR 5511; Praeger v Praeger, 162 AD2d 671 [1990]).

Pesce, P.J., and Belen, J., concur.

Golia, J., concurs in part and dissents in part in a separate memorandum.

SUPREME COURT OF THE STATE OF NEW YORK
APPELLATE TERM : 2nd and 11th JUDICIAL DISTRICTS
PRESENT: PESCE, P.J., GOLIA and BELEN, JJ.
A.B. MEDICAL SERVICES PLLC
D.A.V. CHIROPRACTIC P.C.
LVOV ACUPUNCTURE P.C.
a/a/o RAYMOND MICHELINE, YVELYNE GARRAUD
and FLAVIE GUERRIER,
Appellants,

-against-

PRUDENTIAL PROPERTY & CASUALTY INSURANCE COMPANY,
Respondent.

Golia, J., concurs in part and dissents in part in the following memorandum.

I concur in the dismissal of the appeal taken by plaintiff Lvov Acupuncture P.C. and dissent as to the granting of partial summary judgment in favor of the remaining plaintiffs.

Contrary to the holding of the majority, I find that the claims were never “completed” and therefore the 30-day time period in which to pay or deny the claims has never commenced. The plaintiffs, in an attempt to establish a prima facie entitlement to judgment, acknowledged that the defendant sent timely requests for verification. Although plaintiffs asserted that they sent responses to those requests for verifications, plaintiffs failed to provide any proof of mailing the responses.

Accordingly, I find that the claims process has never been completed and therefore the time in which the defendant has to pay or deny has not started to run against the defendant.
Decision Date: March 27, 2006

Legal questions (6)

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.

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 insurer's proof did not establish mailing of its denial, verification request or IME/EUO notice

Held the insurer failed to prove mailing of its EUO and IME scheduling requests because it produced no documentary proof and its affiant asserted no personal knowledge of mailing or facts creating a presumption of mailing.

  • Court of AppealsCt App 1
  • Appellate DivisionApp Div 37
  • Appellate TermApp Term 1,203
  • Trial courtsTrial 143
2015, Court of Appeals: 1 decision (1 Provider proved mailing)2023, Appellate Division: 1 decision (1 Insurer proved mailing)2020, Appellate Division: 1 decision (1 Insurer proved mailing)2016, Appellate Division: 3 decisions (1 Insurer proved mailing, 2 Insurer failed to prove)2015, Appellate Division: 2 decisions (2 Insurer failed to prove)2014, Appellate Division: 3 decisions (2 Insurer proved mailing, 1 Provider proved mailing)2013, Appellate Division: 1 decision (1 Provider proved mailing)2012, Appellate Division: 1 decision (1 Provider proved mailing)2011, Appellate Division: 6 decisions (3 Insurer proved mailing, 1 Insurer failed to prove, 2 Provider proved mailing)2010, Appellate Division: 1 decision (1 Provider proved mailing)2008, Appellate Division: 2 decisions (2 Insurer proved mailing)2007, Appellate Division: 7 decisions (1 Insurer proved mailing, 1 Insurer failed to prove, 3 Provider proved mailing, 1 Provider failed to prove, 1 Mixed rulings)2006, Appellate Division: 3 decisions (2 Insurer failed to prove, 1 Provider failed to prove)2005, Appellate Division: 2 decisions (2 Insurer failed to prove)2004, Appellate Division: 3 decisions (2 Insurer failed to prove, 1 Triable issue on mailing)2026, Appellate Division: 1 decision (1 Insurer failed to prove)2023, Appellate Term: 5 decisions (5 Insurer proved mailing)2022, Appellate Term: 44 decisions (32 Insurer proved mailing, 3 Insurer failed to prove, 1 Provider proved mailing, 3 Provider failed to prove, 5 Triable issue on mailing)2021, Appellate Term: 21 decisions (13 Insurer proved mailing, 2 Insurer failed to prove, 5 Triable issue on mailing, 1 Mixed rulings)2020, Appellate Term: 31 decisions (24 Insurer proved mailing, 2 Insurer failed to prove, 5 Triable issue on mailing)2019, Appellate Term: 80 decisions (59 Insurer proved mailing, 5 Insurer failed to prove, 2 Provider proved mailing, 1 Provider failed to prove, 12 Triable issue on mailing, 1 Mixed rulings)2018, Appellate Term: 73 decisions (46 Insurer proved mailing, 16 Insurer failed to prove, 1 Provider failed to prove, 9 Triable issue on mailing, 1 Mixed rulings)2017, Appellate Term: 115 decisions (60 Insurer proved mailing, 26 Insurer failed to prove, 4 Provider proved mailing, 2 Provider failed to prove, 21 Triable issue on mailing, 2 Mixed rulings)2016, Appellate Term: 102 decisions (44 Insurer proved mailing, 30 Insurer failed to prove, 3 Provider proved mailing, 2 Provider failed to prove, 20 Triable issue on mailing, 3 Mixed rulings)2015, Appellate Term: 97 decisions (66 Insurer proved mailing, 10 Insurer failed to prove, 1 Provider proved mailing, 3 Provider failed to prove, 9 Triable issue on mailing, 8 Mixed rulings)2014, Appellate Term: 67 decisions (55 Insurer proved mailing, 3 Insurer failed to prove, 2 Provider proved mailing, 3 Triable issue on mailing, 4 Mixed rulings)2013, Appellate Term: 73 decisions (62 Insurer proved mailing, 6 Insurer failed to prove, 1 Provider proved mailing, 1 Provider failed to prove, 3 Mixed rulings)2012, Appellate Term: 109 decisions (87 Insurer proved mailing, 13 Insurer failed to prove, 1 Provider proved mailing, 3 Provider failed to prove, 1 Triable issue on mailing, 4 Mixed rulings)2011, Appellate Term: 69 decisions (56 Insurer proved mailing, 8 Insurer failed to prove, 2 Provider proved mailing, 1 Triable issue on mailing, 2 Mixed rulings)2010, Appellate Term: 77 decisions (67 Insurer proved mailing, 4 Insurer failed to prove, 2 Provider proved mailing, 2 Provider failed to prove, 2 Mixed rulings)2009, Appellate Term: 53 decisions (29 Insurer proved mailing, 11 Insurer failed to prove, 6 Provider proved mailing, 3 Provider failed to prove, 4 Mixed rulings)2008, Appellate Term: 27 decisions (12 Insurer proved mailing, 11 Insurer failed to prove, 2 Provider proved mailing, 1 Provider failed to prove, 1 Mixed rulings)2007, Appellate Term: 30 decisions (9 Insurer proved mailing, 16 Insurer failed to prove, 3 Provider proved mailing, 2 Mixed rulings)2006, Appellate Term: 74 decisions (6 Insurer proved mailing, 18 Insurer failed to prove, 21 Provider proved mailing, 21 Provider failed to prove, 8 Mixed rulings)2005, Appellate Term: 27 decisions (2 Insurer proved mailing, 14 Insurer failed to prove, 7 Provider proved mailing, 3 Provider failed to prove, 1 Mixed rulings)2004, Appellate Term: 12 decisions (1 Insurer proved mailing, 4 Insurer failed to prove, 3 Provider proved mailing, 2 Provider failed to prove, 1 Triable issue on mailing, 1 Mixed rulings)2003, Appellate Term: 3 decisions (3 Provider proved mailing)2024, Appellate Term: 4 decisions (2 Insurer proved mailing, 1 Insurer failed to prove, 1 Provider failed to prove)2025, Appellate Term: 3 decisions (3 Insurer proved mailing)2026, Appellate Term: 7 decisions (2 Insurer proved mailing, 3 Insurer failed to prove, 2 Triable issue on mailing)2023, Trial courts: 4 decisions (2 Insurer proved mailing, 2 Provider proved mailing)2022, Trial courts: 4 decisions (2 Insurer proved mailing, 1 Provider proved mailing, 1 Mixed rulings)2021, Trial courts: 17 decisions (12 Insurer proved mailing, 1 Provider proved mailing, 2 Provider failed to prove, 2 Mixed rulings)2020, Trial courts: 4 decisions (2 Provider proved mailing, 2 Mixed rulings)2019, Trial courts: 4 decisions (3 Insurer failed to prove, 1 Triable issue on mailing)2018, Trial courts: 1 decision (1 Insurer proved mailing)2017, Trial courts: 7 decisions (5 Insurer proved mailing, 2 Insurer failed to prove)2016, Trial courts: 4 decisions (2 Insurer proved mailing, 1 Provider proved mailing, 1 Triable issue on mailing)2015, Trial courts: 3 decisions (3 Provider proved mailing)2013, Trial courts: 4 decisions (3 Insurer proved mailing, 1 Insurer failed to prove)2012, Trial courts: 10 decisions (5 Insurer proved mailing, 2 Insurer failed to prove, 2 Provider proved mailing, 1 Triable issue on mailing)2011, Trial courts: 4 decisions (2 Insurer proved mailing, 1 Insurer failed to prove, 1 Provider failed to prove)2010, Trial courts: 6 decisions (3 Insurer proved mailing, 1 Insurer failed to prove, 2 Provider proved mailing)2009, Trial courts: 9 decisions (4 Insurer proved mailing, 2 Insurer failed to prove, 3 Provider proved mailing)2008, Trial courts: 13 decisions (3 Insurer proved mailing, 1 Insurer failed to prove, 7 Provider proved mailing, 1 Provider failed to prove, 1 Mixed rulings)2007, Trial courts: 8 decisions (1 Insurer proved mailing, 5 Insurer failed to prove, 2 Provider proved mailing)2006, Trial courts: 7 decisions (1 Insurer proved mailing, 6 Insurer failed to prove)2005, Trial courts: 14 decisions (2 Insurer proved mailing, 8 Insurer failed to prove, 4 Provider failed to prove)2004, Trial courts: 10 decisions (5 Insurer failed to prove, 2 Provider proved mailing, 3 Provider failed to prove)2024, Trial courts: 2 decisions (1 Insurer failed to prove, 1 Provider failed to prove)2025, Trial courts: 2 decisions (2 Insurer proved mailing)2026, Trial courts: 6 decisions (3 Insurer proved mailing, 1 Provider proved mailing, 1 Provider failed to prove, 1 Triable issue on mailing)This decision
20052010201520202025
Insurer proved mailingInsurer failed to proveProvider proved mailingProvider failed to proveTriable issue on mailingMixed rulingsThis decisionCites it or cited by itCited or followed

Of the 1,384 decisions on this question in the Second Department courts and the Court of Appeals, 257 (this one included) are in the same category.

No-show: coverage defense or precludable?

Open the full map

Is an IME/EUO no-show defense precluded if the insurer did not timely deny the claim on that ground?

This decision: No-show defense is subject to preclusion and fails for want of a timely, proper denial (rules on the question, but another ground decided the case)

Held the EUO no-show defense unavailable on the untimely-denied claims because, with no proof the EUO request was mailed, the request did not toll the 30-day period, so the denials were untimely and preclusion applied.

  • Appellate DivisionApp Div 7
  • Appellate TermApp Term 447
  • Trial courtsTrial 46
2023, Appellate Division: 1 decision (1 Precludable: denial timely)2022, Appellate Division: 1 decision (1 Precludable: denial lacking)2020, Appellate Division: 1 decision (1 Precludable: denial timely)2015, Appellate Division: 1 decision (1 Precludable: denial lacking)2014, Appellate Division: 2 decisions (2 Precludable: denial timely)2009, Appellate Division: 1 decision (1 Precludable: denial lacking)2023, Appellate Term: 4 decisions (1 Precludable: denial lacking, 3 Precludable: denial timely)2022, Appellate Term: 32 decisions (12 Precludable: denial lacking, 20 Precludable: denial timely)2021, Appellate Term: 12 decisions (4 Precludable: denial lacking, 8 Precludable: denial timely)2020, Appellate Term: 25 decisions (4 Precludable: denial lacking, 21 Precludable: denial timely)2019, Appellate Term: 38 decisions (5 Precludable: denial lacking, 33 Precludable: denial timely)2018, Appellate Term: 31 decisions (11 Precludable: denial lacking, 20 Precludable: denial timely)2017, Appellate Term: 49 decisions (12 Precludable: denial lacking, 37 Precludable: denial timely)2016, Appellate Term: 35 decisions (15 Precludable: denial lacking, 20 Precludable: denial timely)2015, Appellate Term: 45 decisions (5 Precludable: denial lacking, 40 Precludable: denial timely)2014, Appellate Term: 33 decisions (13 Precludable: denial lacking, 20 Precludable: denial timely)2013, Appellate Term: 30 decisions (6 Precludable: denial lacking, 24 Precludable: denial timely)2012, Appellate Term: 41 decisions (15 Precludable: denial lacking, 26 Precludable: denial timely)2011, Appellate Term: 24 decisions (5 Precludable: denial lacking, 19 Precludable: denial timely)2010, Appellate Term: 8 decisions (5 Precludable: denial lacking, 3 Precludable: denial timely)2009, Appellate Term: 3 decisions (3 Precludable: denial lacking)2007, Appellate Term: 2 decisions (2 Precludable: denial lacking)2006, Appellate Term: 8 decisions (7 Precludable: denial lacking, 1 Precludable: denial timely)2005, Appellate Term: 10 decisions (9 Precludable: denial lacking, 1 Precludable: denial timely)2004, Appellate Term: 4 decisions (4 Precludable: denial lacking)2024, Appellate Term: 5 decisions (1 Precludable: denial lacking, 4 Precludable: denial timely)2025, Appellate Term: 5 decisions (2 Precludable: denial lacking, 3 Precludable: denial timely)2026, Appellate Term: 2 decisions (2 Precludable: denial timely)2003, Appellate Term: 1 decision (1 Precludable: denial lacking)2023, Trial courts: 1 decision (1 Precludable: denial timely)2022, Trial courts: 3 decisions (1 Precludable: denial lacking, 2 Precludable: denial timely)2021, Trial courts: 8 decisions (2 Precludable: denial lacking, 6 Precludable: denial timely)2020, Trial courts: 2 decisions (1 Precludable: denial lacking, 1 Precludable: denial timely)2019, Trial courts: 5 decisions (5 Precludable: denial lacking)2018, Trial courts: 1 decision (1 Precludable: denial timely)2017, Trial courts: 2 decisions (2 Precludable: denial timely)2016, Trial courts: 3 decisions (1 Precludable: denial lacking, 2 Precludable: denial timely)2014, Trial courts: 3 decisions (3 Precludable: denial timely)2013, Trial courts: 3 decisions (2 Coverage defense, 1 Precludable: denial timely)2012, Trial courts: 1 decision (1 Precludable: denial timely)2011, Trial courts: 2 decisions (2 Coverage defense)2009, Trial courts: 2 decisions (2 Precludable: denial timely)2008, Trial courts: 1 decision (1 Precludable: denial lacking)2006, Trial courts: 1 decision (1 Precludable: denial lacking)2005, Trial courts: 1 decision (1 Precludable: denial lacking)2004, Trial courts: 3 decisions (3 Precludable: denial lacking)2025, Trial courts: 2 decisions (2 Precludable: denial timely)2026, Trial courts: 1 decision (1 Precludable: denial timely)2015, Trial courts: 1 decision (1 Precludable: denial lacking)This decision
20052010201520202025
Coverage defensePrecludable: denial lackingPrecludable: denial timelyThis decisionCites it or cited by itCited or followed

Of the 500 decisions on this question in the Second Department courts and the Court of Appeals, 162 (this one included) are in the same category.

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 providers established prima facie entitlement by proof that they submitted statutory claim forms setting forth the fact and amount of loss and that payment was overdue, rejecting index-number and assignment objections.

  • Court of AppealsCt App 2
  • Appellate DivisionApp Div 80
  • Appellate TermApp Term 843
  • Trial courtsTrial 138
2015, Court of Appeals: 1 decision (1 Proof sufficient)2007, Court of Appeals: 1 decision (1 Proof sufficient)2022, Appellate Division: 1 decision (1 Proof sufficient)2019, Appellate Division: 1 decision (1 Proof sufficient)2014, Appellate Division: 10 decisions (9 Proof sufficient, 1 Overdue not shown)2013, Appellate Division: 2 decisions (2 Proof sufficient)2012, Appellate Division: 2 decisions (2 Proof sufficient)2011, Appellate Division: 11 decisions (11 Proof sufficient)2010, Appellate Division: 3 decisions (2 Proof sufficient, 1 Overdue not shown)2009, Appellate Division: 3 decisions (2 Proof sufficient, 1 Other element missing)2008, Appellate Division: 8 decisions (6 Proof sufficient, 1 Overdue not shown, 1 Business-record foundation lacking)2007, Appellate Division: 15 decisions (12 Proof sufficient, 2 Mailing/receipt not shown, 1 Overdue not shown)2006, Appellate Division: 5 decisions (3 Proof sufficient, 1 Mailing/receipt not shown, 1 Other element missing)2005, Appellate Division: 5 decisions (5 Proof sufficient)2004, Appellate Division: 11 decisions (10 Proof sufficient, 1 Overdue not shown)2026, Appellate Division: 1 decision (1 Proof sufficient)2003, Appellate Division: 2 decisions (1 Proof sufficient, 1 Overdue not shown)2022, Appellate Term: 14 decisions (2 Mailing/receipt not shown, 12 Overdue not shown)2021, Appellate Term: 5 decisions (1 Proof sufficient, 4 Overdue not shown)2020, Appellate Term: 13 decisions (13 Overdue not shown)2019, Appellate Term: 23 decisions (22 Overdue not shown, 1 Other element missing)2018, Appellate Term: 26 decisions (3 Proof sufficient, 1 Mailing/receipt not shown, 22 Overdue not shown)2017, Appellate Term: 38 decisions (3 Proof sufficient, 1 Mailing/receipt not shown, 34 Overdue not shown)2016, Appellate Term: 41 decisions (7 Proof sufficient, 34 Overdue not shown)2015, Appellate Term: 44 decisions (12 Proof sufficient, 1 Mailing/receipt not shown, 30 Overdue not shown, 1 Business-record foundation lacking)2014, Appellate Term: 22 decisions (10 Proof sufficient, 12 Overdue not shown)2013, Appellate Term: 34 decisions (17 Proof sufficient, 11 Overdue not shown, 6 Business-record foundation lacking)2012, Appellate Term: 32 decisions (3 Proof sufficient, 2 Mailing/receipt not shown, 11 Overdue not shown, 16 Business-record foundation lacking)2011, Appellate Term: 29 decisions (6 Proof sufficient, 1 Mailing/receipt not shown, 13 Overdue not shown, 9 Business-record foundation lacking)2010, Appellate Term: 36 decisions (22 Proof sufficient, 3 Mailing/receipt not shown, 10 Business-record foundation lacking, 1 Other element missing)2009, Appellate Term: 52 decisions (28 Proof sufficient, 3 Mailing/receipt not shown, 21 Business-record foundation lacking)2008, Appellate Term: 49 decisions (16 Proof sufficient, 1 Mailing/receipt not shown, 32 Business-record foundation lacking)2007, Appellate Term: 104 decisions (8 Proof sufficient, 2 Mailing/receipt not shown, 94 Business-record foundation lacking)2006, Appellate Term: 112 decisions (76 Proof sufficient, 26 Mailing/receipt not shown, 1 Overdue not shown, 6 Business-record foundation lacking, 3 Other element missing)2005, Appellate Term: 90 decisions (84 Proof sufficient, 5 Mailing/receipt not shown, 1 Overdue not shown)2004, Appellate Term: 57 decisions (43 Proof sufficient, 10 Mailing/receipt not shown, 4 Other element missing)2003, Appellate Term: 7 decisions (7 Proof sufficient)2023, Appellate Term: 3 decisions (3 Overdue not shown)2024, Appellate Term: 7 decisions (1 Mailing/receipt not shown, 6 Overdue not shown)2025, Appellate Term: 3 decisions (1 Proof sufficient, 1 Mailing/receipt not shown, 1 Overdue not shown)2026, Appellate Term: 2 decisions (2 Mailing/receipt not shown)2023, Trial courts: 2 decisions (2 Proof sufficient)2022, Trial courts: 4 decisions (2 Proof sufficient, 2 Overdue not shown)2021, Trial courts: 11 decisions (6 Proof sufficient, 2 Mailing/receipt not shown, 2 Overdue not shown, 1 Other element missing)2020, Trial courts: 5 decisions (3 Proof sufficient, 1 Overdue not shown, 1 Other element missing)2019, Trial courts: 6 decisions (5 Proof sufficient, 1 Mailing/receipt not shown)2018, Trial courts: 2 decisions (2 Overdue not shown)2017, Trial courts: 3 decisions (1 Proof sufficient, 1 Overdue not shown, 1 Other element missing)2016, Trial courts: 4 decisions (4 Proof sufficient)2013, Trial courts: 1 decision (1 Proof sufficient)2012, Trial courts: 5 decisions (4 Proof sufficient, 1 Business-record foundation lacking)2011, Trial courts: 3 decisions (2 Proof sufficient, 1 Business-record foundation lacking)2010, Trial courts: 3 decisions (2 Proof sufficient, 1 Business-record foundation lacking)2009, Trial courts: 7 decisions (7 Proof sufficient)2008, Trial courts: 14 decisions (8 Proof sufficient, 1 Mailing/receipt not shown, 1 Overdue not shown, 4 Business-record foundation lacking)2007, Trial courts: 7 decisions (5 Proof sufficient, 2 Business-record foundation lacking)2006, Trial courts: 16 decisions (13 Proof sufficient, 2 Overdue not shown, 1 Other element missing)2005, Trial courts: 22 decisions (14 Proof sufficient, 5 Mailing/receipt not shown, 3 Business-record foundation lacking)2004, Trial courts: 14 decisions (8 Proof sufficient, 2 Mailing/receipt not shown, 4 Other element missing)2025, Trial courts: 2 decisions (1 Proof sufficient, 1 Mailing/receipt not shown)2026, Trial courts: 4 decisions (3 Proof sufficient, 1 Mailing/receipt not shown)2014, Trial courts: 1 decision (1 Proof sufficient)2015, Trial courts: 1 decision (1 Proof sufficient)2024, Trial courts: 1 decision (1 Proof sufficient)This decision
20052010201520202025
Proof sufficientMailing/receipt not shownOverdue not shownBusiness-record foundation lackingOther element missingThis decisionCites it or cited by itCited or followed

Of the 1,063 decisions on this question in the Second Department courts and the Court of Appeals, 511 (this one included) are in the same category.

No-show defense: insurer's proof

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Did the insurer prove its IME/EUO no-show defense: mailed, compliant scheduling requests and the claimant’s nonappearance?

This decision: Insurer failed to prove the scheduling letters were mailed or properly addressed (rules on the question, but another ground decided the case)

Held the EUO and IME no-show defenses failed for two assignors because the insurer offered no proof it mailed the scheduling requests; for a third, conceded nonattendance left triable issues of excuse and propriety of the requests.

  • Appellate DivisionApp Div 9
  • Appellate TermApp Term 753
  • Trial courtsTrial 89
2023, Appellate Division: 1 decision (1 Defense proved)2020, Appellate Division: 1 decision (1 Defense proved)2016, Appellate Division: 2 decisions (2 Mailing not proved)2015, Appellate Division: 1 decision (1 Mailing not proved)2014, Appellate Division: 2 decisions (2 Defense proved)2006, Appellate Division: 1 decision (1 Mailing not proved)2004, Appellate Division: 1 decision (1 No-show excused)2023, Appellate Term: 5 decisions (5 Defense proved)2022, Appellate Term: 45 decisions (37 Defense proved, 3 Mailing not proved, 3 Nonappearance not proved, 2 Requests not compliant)2021, Appellate Term: 22 decisions (16 Defense proved, 3 Mailing not proved, 1 Requests not compliant, 2 Triable issue)2020, Appellate Term: 30 decisions (26 Defense proved, 2 Mailing not proved, 2 Requests not compliant)2019, Appellate Term: 68 decisions (52 Defense proved, 1 Mailing not proved, 1 Nonappearance not proved, 13 Requests not compliant, 1 Triable issue)2018, Appellate Term: 52 decisions (43 Defense proved, 3 Mailing not proved, 1 Nonappearance not proved, 5 Requests not compliant)2017, Appellate Term: 86 decisions (52 Defense proved, 14 Mailing not proved, 6 Nonappearance not proved, 11 Requests not compliant, 1 Triable issue, 2 No-show excused)2016, Appellate Term: 74 decisions (34 Defense proved, 14 Mailing not proved, 22 Nonappearance not proved, 3 Requests not compliant, 1 Triable issue)2015, Appellate Term: 77 decisions (48 Defense proved, 6 Mailing not proved, 14 Nonappearance not proved, 5 Requests not compliant, 4 Triable issue)2014, Appellate Term: 46 decisions (35 Defense proved, 5 Mailing not proved, 4 Nonappearance not proved, 2 Requests not compliant)2013, Appellate Term: 44 decisions (29 Defense proved, 6 Mailing not proved, 7 Nonappearance not proved, 1 Requests not compliant, 1 No-show excused)2012, Appellate Term: 51 decisions (37 Defense proved, 5 Mailing not proved, 1 Nonappearance not proved, 5 Requests not compliant, 2 Triable issue, 1 No-show excused)2011, Appellate Term: 33 decisions (27 Defense proved, 3 Mailing not proved, 2 Nonappearance not proved, 1 Triable issue)2010, Appellate Term: 14 decisions (9 Defense proved, 1 Mailing not proved, 2 Nonappearance not proved, 2 Requests not compliant)2009, Appellate Term: 15 decisions (6 Defense proved, 6 Mailing not proved, 2 Nonappearance not proved, 1 Requests not compliant)2008, Appellate Term: 7 decisions (2 Defense proved, 1 Mailing not proved, 4 Nonappearance not proved)2007, Appellate Term: 15 decisions (1 Defense proved, 6 Mailing not proved, 5 Nonappearance not proved, 3 Triable issue)2006, Appellate Term: 19 decisions (1 Defense proved, 8 Mailing not proved, 6 Requests not compliant, 4 Triable issue)2005, Appellate Term: 19 decisions (3 Defense proved, 10 Mailing not proved, 5 Requests not compliant, 1 No-show excused)2004, Appellate Term: 15 decisions (3 Defense proved, 1 Mailing not proved, 10 Requests not compliant, 1 Triable issue)2024, Appellate Term: 6 decisions (6 Defense proved)2025, Appellate Term: 7 decisions (7 Defense proved)2026, Appellate Term: 2 decisions (2 Defense proved)2003, Appellate Term: 1 decision (1 Requests not compliant)2023, Trial courts: 5 decisions (2 Defense proved, 1 Requests not compliant, 2 Triable issue)2022, Trial courts: 3 decisions (1 Defense proved, 1 Mailing not proved, 1 Requests not compliant)2021, Trial courts: 10 decisions (8 Defense proved, 2 Requests not compliant)2020, Trial courts: 3 decisions (2 Mailing not proved, 1 Requests not compliant)2019, Trial courts: 5 decisions (3 Mailing not proved, 2 Requests not compliant)2018, Trial courts: 3 decisions (1 Defense proved, 1 Nonappearance not proved, 1 Requests not compliant)2017, Trial courts: 6 decisions (2 Defense proved, 1 Nonappearance not proved, 2 Requests not compliant, 1 Triable issue)2016, Trial courts: 4 decisions (3 Defense proved, 1 Requests not compliant)2015, Trial courts: 1 decision (1 Defense proved)2014, Trial courts: 5 decisions (2 Defense proved, 1 Requests not compliant, 1 Triable issue, 1 No-show excused)2013, Trial courts: 7 decisions (3 Defense proved, 1 Nonappearance not proved, 2 Requests not compliant, 1 No-show excused)2012, Trial courts: 5 decisions (2 Defense proved, 3 Requests not compliant)2010, Trial courts: 3 decisions (2 Defense proved, 1 Requests not compliant)2009, Trial courts: 2 decisions (2 Defense proved)2008, Trial courts: 4 decisions (2 Defense proved, 2 Requests not compliant)2007, Trial courts: 1 decision (1 Mailing not proved)2006, Trial courts: 2 decisions (2 Mailing not proved)2005, Trial courts: 2 decisions (1 Defense proved, 1 Requests not compliant)2004, Trial courts: 7 decisions (1 Defense proved, 2 Mailing not proved, 4 Requests not compliant)2024, Trial courts: 2 decisions (1 Mailing not proved, 1 Requests not compliant)2025, Trial courts: 4 decisions (3 Defense proved, 1 Nonappearance not proved)2026, Trial courts: 4 decisions (3 Defense proved, 1 Nonappearance not proved)2011, Trial courts: 1 decision (1 Defense proved)This decision
20052010201520202025
Defense provedMailing not provedNonappearance not provedRequests not compliantTriable issueNo-show excusedThis decisionCites it or cited by itCited or followed

Of the 851 decisions on this question in the Second Department courts and the Court of Appeals, 114 (this one included) are in the same category.

Fraudulent incorporation (Mallela)

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On the merits, when may a no-fault insurer withhold payment because unlicensed persons own or control the provider (Mallela)?

This decision: Insurer's proof of unlicensed ownership/control insufficient (rules on the question, but another ground decided the case)

Held the insurer's bare, conclusory assertion that the provider was not formed or operated in accordance with the Business Corporation Law raised no triable issue against the provider's unrebutted proof of a duly registered corporate presence.

  • Court of AppealsCt App 3
  • Appellate DivisionApp Div 8
  • Appellate TermApp Term 26
  • Trial courtsTrial 24
2019, Court of Appeals: 1 decision (1 Defense established)2005, Court of Appeals: 1 decision (1 Defense established)2025, Court of Appeals: 1 decision (1 Not a Mallela ground)2019, Appellate Division: 4 decisions (2 Defense established, 2 Defense not established)2017, Appellate Division: 2 decisions (1 Defense established, 1 Defense not established)2016, Appellate Division: 1 decision (1 Triable issue)2008, Appellate Division: 1 decision (1 Triable issue)2020, Appellate Term: 1 decision (1 Not a Mallela ground)2019, Appellate Term: 1 decision (1 Defense established)2013, Appellate Term: 1 decision (1 Defense established)2012, Appellate Term: 1 decision (1 Not a Mallela ground)2010, Appellate Term: 6 decisions (2 Defense established, 1 Triable issue, 2 Defense not established, 1 Not a Mallela ground)2009, Appellate Term: 4 decisions (2 Defense established, 1 Triable issue, 1 Not a Mallela ground)2008, Appellate Term: 4 decisions (1 Defense established, 1 Triable issue, 2 Defense not established)2007, Appellate Term: 5 decisions (1 Defense established, 4 Triable issue)2006, Appellate Term: 2 decisions (1 Triable issue, 1 Defense not established)2015, Appellate Term: 1 decision (1 Defense not established)2019, Trial courts: 1 decision (1 Triable issue)2017, Trial courts: 2 decisions (1 Defense not established, 1 Not a Mallela ground)2015, Trial courts: 2 decisions (1 Defense established, 1 Not a Mallela ground)2013, Trial courts: 1 decision (1 Defense not established)2010, Trial courts: 1 decision (1 Not a Mallela ground)2009, Trial courts: 3 decisions (1 Defense established, 2 Triable issue)2008, Trial courts: 4 decisions (1 Defense established, 2 Triable issue, 1 Defense not established)2007, Trial courts: 2 decisions (1 Defense established, 1 Triable issue)2006, Trial courts: 3 decisions (3 Triable issue)2005, Trial courts: 4 decisions (3 Defense established, 1 Defense not established)2004, Trial courts: 1 decision (1 Not a Mallela ground)This decision
20052010201520202025
Defense establishedTriable issueDefense not establishedNot a Mallela groundThis decisionCites it or cited by itCited or followedDistinguished or limited

Of the 61 decisions on this question in the Second Department courts and the Court of Appeals, 13 (this one included) are in the same category.

Mallela defense: preclusion and discovery

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May the insurer raise and investigate a Mallela (fraudulent incorporation) defense, or is it precluded, waived or denied discovery?

This decision: Insurer may raise or investigate the Mallela defense here (rules on the question, but another ground decided the case)

Treated the insurer's defense that the provider was not formed under Business Corporation Law article 15 as surviving the preclusion of untimely denials, then weighed it on the merits.

  • Court of AppealsCt App 1
  • Appellate DivisionApp Div 7
  • Appellate TermApp Term 71
  • Trial courtsTrial 55
2005, Court of Appeals: 1 decision (1 Defense may be pursued)2021, Appellate Division: 1 decision (1 Defense may be pursued)2019, Appellate Division: 2 decisions (1 Defense may be pursued, 1 Defense barred)2017, Appellate Division: 1 decision (1 Defense may be pursued)2016, Appellate Division: 1 decision (1 Defense may be pursued)2011, Appellate Division: 1 decision (1 Defense may be pursued)2008, Appellate Division: 1 decision (1 Defense may be pursued)2019, Appellate Term: 1 decision (1 Defense may be pursued)2018, Appellate Term: 2 decisions (2 Defense may be pursued)2017, Appellate Term: 2 decisions (2 Defense may be pursued)2014, Appellate Term: 2 decisions (2 Defense may be pursued)2013, Appellate Term: 5 decisions (5 Defense may be pursued)2012, Appellate Term: 8 decisions (8 Defense may be pursued)2011, Appellate Term: 7 decisions (7 Defense may be pursued)2010, Appellate Term: 9 decisions (7 Defense may be pursued, 2 Defense barred)2009, Appellate Term: 7 decisions (7 Defense may be pursued)2008, Appellate Term: 8 decisions (7 Defense may be pursued, 1 Defense barred)2007, Appellate Term: 7 decisions (7 Defense may be pursued)2006, Appellate Term: 6 decisions (6 Defense may be pursued)2025, Appellate Term: 7 decisions (7 Defense may be pursued)2023, Trial courts: 2 decisions (2 Defense may be pursued)2021, Trial courts: 4 decisions (3 Defense may be pursued, 1 Defense barred)2019, Trial courts: 1 decision (1 Defense may be pursued)2017, Trial courts: 4 decisions (2 Defense may be pursued, 2 Defense barred)2015, Trial courts: 3 decisions (3 Defense may be pursued)2013, Trial courts: 2 decisions (1 Defense may be pursued, 1 Defense barred)2012, Trial courts: 6 decisions (1 Defense may be pursued, 5 Defense barred)2011, Trial courts: 1 decision (1 Defense barred)2010, Trial courts: 3 decisions (3 Defense barred)2009, Trial courts: 4 decisions (3 Defense may be pursued, 1 Defense barred)2008, Trial courts: 6 decisions (5 Defense may be pursued, 1 Defense barred)2007, Trial courts: 2 decisions (2 Defense may be pursued)2006, Trial courts: 5 decisions (5 Defense may be pursued)2005, Trial courts: 9 decisions (5 Defense may be pursued, 4 Defense barred)2025, Trial courts: 2 decisions (2 Defense may be pursued)2026, Trial courts: 1 decision (1 Defense may be pursued)This decision
20052010201520202025
Defense may be pursuedDefense barredThis decisionCites it or cited by itCited or followedDistinguished or limited

Of the 134 decisions on this question in the Second Department courts and the Court of Appeals, 111 (this one included) are in the same category.

Cited in this decision (16)

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.
  • A.B. Med. Servs. PLLC v Lumbermens Mut. Cas. Co. (2004 NY Slip Op 24194)An insurer's timely medical-necessity denial does not replace admissible proof opposing a provider's summary judgment motion.
  • Ocean Diagnostic Imaging P.C. v Travelers Prop. Cas. Corp. (2005 NY Slip Op 50790(U)) FollowedThe insurer's affidavits raised a factual issue whether the claimed injuries arose from an insured incident.
  • Hospital for Joint Diseases v Allstate Ins. Co. (2005 NY Slip Op 06192) FollowedAn insurer waived assignment objections by failing to timely object to hospital forms or seek verification of the assignments.
  • New York Hosp. Med. Ctr. of Queens v New York Cent. Mut. Fire Ins. Co. (2004 NY Slip Op 05626) FollowedThe insurer failed to establish mailing of assignment-verification requests and could not defeat the hospitals' summary judgment motion.
  • Capio Med., P.C. v Progressive Cas. Ins. Co. (2005 NYSlipOp 50526(U)) FollowedThe insurer's EUO requests did not toll the denial period because it failed to prove an authorizing endorsement or timely requests.
  • Careplus Med. Supply Inc. v Travelers Home & Mar. Ins. Co. (2005 NYSlipOp 50648(U)) FollowedThe insurer failed to establish verification tolling because requests were untimely or unproved and its policy's EUO endorsement was not shown.
  • State Farm Mut. Auto. Ins. Co. v Mallela (2005 NY Slip Op 02416)Fraudulently incorporated medical providers are ineligible for no-fault reimbursement under 11 NYCRR 65-3.16 (a) (12).
  • Westchester Med. Ctr. v American Tr. Ins. Co. (2005 NY Slip Op 03046)An insurer's failure to timely deny a hospital claim precluded its defense that the hospital used the wrong DRG billing code.
  • Rockaway Blvd. Med. P.C. v Progressive Ins. (2005 NY Slip Op 25278)A provider's omission of its relationship with the treating physician from claim forms does not defeat its prima facie case.
  • Struhl v Progressive Cas. Ins. Co. (2005 NYSlipOp 50864(U))The insurer's admissible peer review raised a triable coverage issue despite its untimely denial and failure to prove verification tolling.
  • Triboro Chiropractic v New York Cent. Mut. Fire Ins. Co. (2005 NY Slip Op 50110(U))An assignor's failure to attend IMEs requested before claim submission rebuts the claim forms' presumption of medical necessity.
  • Melbourne Med., P.C. v Utica Mut. Ins. Co. (2004 NY Slip Op 24221)EUO requests do not toll the claim determination period when the governing no-fault regulations do not authorize EUO verification.
  • Abraham v Country-Wide Ins. Co. (2004 NY Slip Op 50388(U))The insurer's unsworn nurses' reviews failed to raise a triable issue of medical necessity because the reviewers' qualifications were not shown.
  • Stephen Fogel Psychological, P.C. v Progressive Cas. Ins. Co. (2004 NY Slip Op 24527) FollowedA proven failure to attend a reasonably requested preclaim IME, timely raised in a denial, does not alone warrant dismissal.
Show all 16 cited decisions
  • A.B. Med. Servs. PLLC v USAA Gen. Indem. Co. (2005 NY Slip Op 25297)

Cited by

A label shows how the later decision treated this one.

  • One Beacon Ins. Group, LLC v Midland Med. Care, P.C. (2008 NY Slip Op 06813) Contrasted (cf., but see)The insurers raised a triable issue of fraudulent incorporation despite evidence of physician ownership and oversight of the provider.
  • Lexington Acupuncture, P.C. v State Farm Ins. Co. (2006 NY Slip Op 26251) FollowedThe provider's summary judgment motion was premature because discovery could establish fraudulent incorporation and reimbursement ineligibility.
  • Midborough Acupuncture P.C. v State Farm Ins. Co. (2006 NY Slip Op 26360) FollowedAn insurer's fraudulent-incorporation defense survives an untimely denial, and discovery into provider ownership and licensing is material.
  • Matter of Andrew Carothers, M.D., P.C. v Insurance Cos. Represented by Bruno, Gerbino & Soriano LLP (2006 NY Slip Op 26372) FollowedAn insurer need not show conduct tantamount to fraud before obtaining litigation discovery on a provider's alleged fraudulent incorporation.
  • Colonia Med., P.C. v Travelers Ins. Co. (2006 NY Slip Op 51186(U)) FollowedThe insurer failed to establish timely denials based on IME nonappearance because it did not prove mailing of verification requests.
  • Bronxborough Med., P.C. v New Hampshire Ins. Co. (2006 NY Slip Op 51354(U)) FollowedThe insurer failed to raise a triable issue on IME nonappearance because it did not establish mailing of the scheduling requests.
  • SP Med., P.C. v Country-Wide Ins. Co. (2008 NY Slip Op 51230(U))The provider's petition to vacate a master arbitration award failed because its supporting document was not a valid attorney affirmation.
  • Avanessov v State-Wide Ins. Co. (2008 NY Slip Op 52131(U))The provider's petition to vacate a master arbitrator's award lacked a supporting affirmation made under penalties of perjury.
  • 563 Grand Med., P.C. v Nationwide Ins. Co. (2009 NY Slip Op 51493(U))The provider's arbitration-vacatur petition failed because its sole supporting document was not affirmed under penalties of perjury.
  • RJ Professional Acupuncturist, P.C. v Country Wide Ins. Co. (2010 NY Slip Op 50579(U))The provider's petition to vacate a master arbitration award failed because its attorney's purported affirmation lacked a perjury declaration.

Similar decisions

  • A.B. Med. Servs., PLLC v Country-Wide Ins. Co. (2009 NY Slip Op 51016(U))The providers obtained partial summary judgment for untimely denials, unproved verification tolling, and unsworn peer reviews.
  • A.B. Med. Servs. PLLC v Peerless Ins. Co. (2006 NY Slip Op 26318)A provider need not prove assignment validity where the insurer neither sought verification nor raised an assignment defect in its denials.
  • A.B. Med. Servs. PLLC v Country-Wide Ins. Co. (2005 NY Slip Op 50255(U))An investigation-delay letter identifying no verification sought or source does not toll the 30-day claim determination period.
  • A.B. Med. Servs. v State Farm Mut. Auto. Ins. Co. (2004 NY Slip Op 50387(U))The insurer's EUO request did not toll the denial period under the former regulations, and its fraud evidence raised no triable issue.
  • A.B. Med. Servs. PLLC v GMAC Ins. (2005 NYSlipOp 50602(U))Transportation benefits claimed under the revised no-fault regulations are reimbursable but cannot be assigned to a transportation provider.
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