May 4, 2018
Neuro Rehab Med. Servs. of S.I., P.C. v State Farm Mut. Auto. Ins. Co. (2018 NY Slip Op 50671(U))
https://www.beynensonlaw.com/case-law/neuro-rehab-med-servs-of-s-i-p-c-v-state-farm-mut-auto-ins-co-2018-ny-slipop-50671u/
- Judge
- Janine A. Barbera-Dalli, J.
- Decided
- May 4, 2018
- Citation
- 2018 NY Slip Op 50671(U)
- Posture
- Summary judgment
- Outcome
- Insurer prevailed
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 Neuro Rehab Med. Servs. of S.I., P.C. v State Farm Mut. Auto. Ins. Co. (2018 NY Slip Op 50671(U))
Neuro Rehab Medical
Services of S.I., P.C., a/a/o Carlos Garcia, Plaintiff,
against State Farm Mutual Automobile Insurance Company, Defendant. |
CV-4230-15/HU
Janine A. Barbera-Dalli, J.
Upon the following papers numbered 1 to 37 read on this motion by defendant to strike Notice of Trial, compel discovery, and for dismissal (Seq 001); by defendant for summary judgment dismissing complaint (Seq 002); by 1st Notice of Motion/Order to Show Cause and supporting papers (Seq 001) 1,2,6 ; Notice of Cross Motion and supporting papers (Seq 003) by plaintiff for partial summary judgment for relief demanded in complaint 7-9 ; Answering Affidavits and supporting papers 7-9 ; by 2nd Notice of Motion/Order to Show Cause and supporting papers (Seq 002) 10-16,32 ; Answering Affidavits and supporting papers 33,35 ; Replying Affidavits and supporting papers 36,37; Filed papers ; Other exhibits: 3-5,17-31,34 ; and after hearing counsel in support of and opposed to the motion) it is,
ORDERED that the motions submitted and categorized as Seq #001, Seq #002 and Seq #003, are hereby consolidated and the Court’s decision is rendered herein; and it is further
ORDERED that the motion by defendant for summary judgment dismissing plaintiff’s complaint pursuant to CPLR 3212 (Seq #002) is granted. The complaint is dismissed; and it is further
ORDERED that the motion by defendant striking plaintiff’s Notice of Trial, and dismissing the complaint on the ground that discovery is not complete (Seq #001), is denied, as being academic; and it is further
ORDERED that the motion by plaintiff for partial summary judgment pursuant to CPLR 3212(e),(g), is also denied.
Defendant moves by summary judgment for dismissal of plaintiff’s complaint, which seeks reimbursement of first-party no-fault benefits for medical services rendered to plaintiff’s assignor as the result of an automobile accident of 01/16/12 in the total sum of $6,523.31.
The grounds for dismissal are the failure of plaintiff’s assignee to attend two (2) duly scheduled Examinations Under Oath (“EUO’s”) set by defendant for 05/07/12, and the follow-up for 05/30/12. Defendant asserts the failure to attend the EUO’s breached a condition precedent for payment under defendant’s no-fault insurance policy, thereby voiding the policy. As a result, defendant issued NF-10 denial of claim forms dated 06/01/12.
In opposition to defendant’s motion, plaintiff asserts that defendant’s proof in support of the motion for summary judgment is insufficient to satisfy defendant’s prima facie burden of showing the timely and proper mailing of the notices for the EUO’s, the lack of appearance at the noticed EUO’s, and for showing the NF-10 denial of claims were mailed within 30 days of the last EUO date. In addition, plaintiff asserts that defendant also failed to provide “good reasons” to justify the EUO of plaintiff’s assignee.
A proponent of a motion for summary judgment must make a prima facie showing of entitlement to judgment as a matter of law with proof in admissible form sufficient to establish the lack of any material issues of fact (see Alvarez v Prospect Hospital, 68 NY2d 320, 324 [1986]; Winegrad v New York Univ. Med. Ctr., 64 NY2d 851, 853 [1985]; Zuckerman v City of New York, 49 NY2d 557, 562 [1980]); see also Manhattan Medical v State Farm Mut. Ins. Co., 20 Misc 3d 1144[A][Civ. Ct. Richmond Cty. 2008]).
A summary judgment motion must be supported by an affidavit of a person having knowledge of the facts and the affidavit shall recite all the material facts and show there is no defense to the cause of action or that the cause of action or defense has no merit (see CPLR 3212[b]). A conclusory affidavit or an affidavit by an individual who lacks personal knowledge of the facts does not satisfy the proponent’s prima facie burden (see JMD Holding Corp. v Congress Financial Corp., 4 NY3d 373 [2005]).
A failure to comply with an insurer’s demand to submit to an EUO, is a material breach of the policy, precluding recovery of the policy proceeds (see Interboro Ins. Co. v Clennon, 113 AD3d 596 [2nd Dept 2014]; Unitrin Advantage Ins. Co. v Bay Shore Physical Therapy, PLLC., 82 AD3d 559 [2nd Dept 2011]).
Here, the Court finds that defendant insurer has demonstrated by proof in admissible form that it twice demanded an EUO of plaintiff’s assignee (see Palafox PT, P.C. v State Farm Mut. Auto. Ins. Co., 49 Misc 3d 143[A][App Term, 2nd, 11th & 13th Jud Dists 2015]), for 05/07/12, and the follow-up EUO for 05/30/12, by scheduling letters which were properly mailed in accordance with defendant’s standard office practices and procedures, and in accordance with no-fault regulations (see St. Vincent’s Hosp. of Richmond v GEICO, 50 AD3d 1123, 1124 [2nd Dept 2008]; Gutierrez v Elrac, Inc., 48 Misc 3d 138[A][App Term, 2nd, 11th & 13th Jud Dists 2015]; Urban Radiology, P.C. v Tri-State Consumer Ins. Co., 27 Mis3d 140[A][App Term, 2nd, 11th & 13th Jud Dists 2010]).
The submitted proof also demonstrated defendant’s mailing methods were sufficient to create a rebuttable presumption of proper mailing (see New York Presbyt. Hosp. v Allstate Ins. Co., 29 AD3d 547 [2nd Dept 2006]). “. . . Proof of proper mailing gives rise to a presumption that the item was received by the addressee” (see Residential Holding Corp. v Scottsdale Ins. Co., 286 AD2d 679, 680 [2nd Dept 2001]).
Here, plaintiff does not deny receipt of the timely mailings, thereby failing to rebut the [*2]presumption of receipt raised by defendant’s proof of mailings (Id.; see also S & M Supply Inc. v GEICO, 2003 NY Slip Op. 51192[U][App Term, 2nd & 11th Jud Dists 2003]; Harbor Medical & Diagnostics P.C. v Allstate Ins. Co., 11 Misc 3d 1063[A][Civ Ct, New York City 2006]). Nor has plaintiff sufficiently demonstrated that it timely and legally satisfied its duty to communicate with defendant with a statement of why it could not provide what the EUO verifications sought (see Dilon Med. Supply Corp. v Travelers Ins. Co.,7 Misc 3d 927, 931-932 [NY City Civ. Ct. 2005]).
The Court further finds that plaintiff’s assignee failed to appear at both duly scheduled EUO’s, without excuse, or timely notice, as demonstrated by the affirmation of defendant’s attorney, Edward Ryan, Esq., who was present and assigned to conduct the EUO on each scheduled date (see Delta Dignostic Radiology, P.C. v Esurance, 48 Misc 3d 138[A][App Term, 2nd, 11th & 13th Jud Dists 2015]; Natural Therapy Acupuncture, P.C. v State Farm Mut. Auto. Ins. Co., 42 Misc 3d 137[A][App Term, 2nd, 11th & 13th Jud Dists 2014]).
The Court also determines that the NF-10 denial of claim forms were timely mailed to plaintiff in accordance with defendant’s standard office practices and procedures to ensure that items were properly addressed and mailed, especially for the generating and mailing of NF-10 denial of claim notices (see 11 NYCRR 65-3.8[a][1]; St. Vincent’s Hosp. of Richmond v GEICO, supra; Ortho-Med Surgical Supply, Inc. v MVAIC, 28 Misc 3d 139[A] [App Term, 2nd, 11th & 13th Jud Dists 2010]; Delta Diagnostic Radiology, P.C. v Chubb Group of Ins., 17 Misc 3d 16, 18 [App Term, 2nd, 11th & 13th Jud Dists 2007]). The NF-10 denial of claim forms were dated 06/01/12 and timely mailed within the 30 day period within which defendant was required to pay or deny the claim (see 11 NYCRR §65-3.8[a][1]). Defendant has shown that its standard office practices and procedures ensured plaintiff’s receipt of the denial of claim forms, and created an additional, rebuttable presumption for such mailings (see New York Presbyt. Hosp. v Allstate Ins. Co., supra).
Furthermore, the Court finds that defendant provided sufficient reasons in the first notice of 04/04/12 and 04/11/12, and in the second notice of 05/10/12 and 05/25/12, to justify the EUO of plaintiff’s assignee.
Moreover, in as much as defendant demonstrated the failure of plaintiff’s assignee to timely respond to or appear at the EUO verification dates, without excuse, plaintiff waived its defenses and is therefore estopped from contesting the reasonableness of the EUO requests (see Natural Therapy Acupuncture, P.C. v State Farm Mut. Auto.Ins. Co., 42 Misc 3d 137[A][App Term, 2nd Dept 2014]; see also Morris Med., P.C. v Amex Assur. Co., 37 Misc 3d 140[A][App Term, 2d, 11th & 13th Jud Dists 2012]). The defendant should not be put in the position of second guessing why plaintiff failed to respond to the EUO verification requests (see Canarsie Chiropractic, P.C. v State Farm Mut. Ins. Co., 27 Misc 3d 1228[A][NY City Civ Ct 2008]). Plaintiff’s inaction to defendant’s timely notifications is fatal to its causes of action for alleged medical services rendered (see Crescent Radiology PLLC. v American Transit Ins. Co., 31 Misc 3d 134[A][App Term, 9th & 10th Jud Dist 2011]; Interboro Ins. Co. v Clennon, supra).
Therefore, the Court finds that defendant has made a prima facie showing of entitlement to summary judgment dismissing the complaint, as a matter of law, sufficient to establish the lack of any material issues of fact (see Alvarez v Prospect Hospital, supra; Winegrad v New York Univ. Med. Ctr., supra; Zuckerman v City of New York, supra).
Once a showing of entitlement to summary judgment has been made, the burden shifts to the party opposing the motion for summary judgment, to produce evidentiary proof in admissible [*3]form sufficient to establish the existence of material issues of fact which require a trial of the action (see CPLR 3212 [b]; Alvarez v Prospect Hospital, supra).
Here, the Court finds that plaintiff has failed in its burden to produce evidentiary proof in admissible form sufficient to establish material issues of fact which require a trial of the action.
It is not necessary for the Court to rule upon any remaining contentions of the parties, as they have been rendered academic.
The foregoing constitutes the decision and order of this Court.
Dated: May 4, 2018
HON. JANINE A. BARBERA-DALLI
J.D.C.
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.
Is an IME/EUO no-show defense precluded if the insurer did not timely deny the claim on that ground?
This decision: Timely denial required as part of the no-show defense, and the insurer showed it
Rejected the provider's argument that the denials were not mailed within 30 days of the last EUO, finding the denial forms timely mailed within the pay-or-deny period.
Of the 500 decisions on this question in the Second Department courts and the Court of Appeals, 334 (this one included) are in the same category. One decision in other departments that cites or is cited by this one is on 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 (or its agent's) proof established mailing of its denial, verification request or IME/EUO notice
Held the insurer's standard office practice proof established proper mailing of the EUO scheduling letters and timely mailing of the denial forms, and the provider did not deny receipt to rebut the presumption.
Of the 1,384 decisions on this question in the Second Department courts and the Court of Appeals, 806 (this one included) are in the same category.
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 proved two properly mailed EUO demands, nonappearance through the attorney assigned to conduct the EUOs, and sufficient reasons for the EUO, and the provider waived objections by not responding.
Of the 851 decisions on this question in the Second Department courts and the Court of Appeals, 525 (this one included) are in the same category. One decision in other departments that cites or is cited by this one is on the full map.
Cited in this decision
A label shows how this decision treated the case it cites.
- Manhattan Med. Imaging, P.C. v State Farm Mut. Auto. Ins. Co. (2008 NY Slip Op 51844(U))Staged accident and fraudulent incorporation defenses remain available despite an insurer's late denial.
- 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.
- Unitrin Advantage Ins. Co. v Bayshore Physical Therapy, PLLC (2011 NY Slip Op 01948) FollowedAn assignor's failure to attend required IMEs permits retroactive denial of no-fault claims regardless of denial timeliness.
- St. Vincent’s Hosp. of Richmond v Government Empls. Ins. Co. (2008 NY Slip Op 04072) FollowedThe insurer raised factual issues concerning a proper timely denial and its entitlement to deny the hospital's claim.
- New York & Presbyt. Hosp. v Allstate Ins. Co. (2006 NY Slip Op 03558) FollowedThe providers failed to establish mailing and receipt of the hospital bill asserted in their second cause of action.
- Harbor Med. & Diagnostic, P.C. v Allstate Ins. Co. (2006 NY Slip Op 50378(U))The insurer failed to prove timely mailing of its denials and was precluded from asserting its medical-necessity defense.
- Dilon Med. Supply Corp. v Travelers Ins. Co. (2005 NY Slip Op 25113) FollowedA medical supplier must respond to a proper request for a letter of medical necessity even if it lacks clinical expertise.
- Delta Diagnostic Radiology, P.C. v Esurance (2015 NY Slip Op 51212(U)) FollowedThe insurer established timely EUO notices, the assignor's nonappearance at duly scheduled EUOs and timely denials on that ground.
- Ortho-Med Surgical Supply, Inc. v MVAIC (2010 NY Slip Op 51526(U)) FollowedMVAIC's affidavit established timely mailing of its denial through a detailed description of office practices based on personal knowledge.
- Delta Diagnostic Radiology, P.C. v Chubb Group of Ins. (2007 NY Slip Op 27345) FollowedAn insurer may prove mailing by describing its standard procedure for properly addressing and mailing items.
- Morris Med., P.C. v Amex Assur. Co. (2012 NY Slip Op 52260(U))The insurer's EUO defense failed on five untimely denied claims but supported dismissal of six claims that were timely denied.
- Crescent Radiology, PLLC v American Tr. Ins. Co. (2011 NY Slip Op 50622(U)) FollowedThe insurer established timely mailing of EUO notices and denials and the assignor's failure to appear at two scheduled EUOs. The provider obtained summary judgment after the District Court found insufficient objective justification for the EUO request.
Similar decisions
- Central Park Physical Medicine & Rehab., P.C. v Travelers Indem. Co. of Conn. (2017 NY Slip Op 51354(U))The provider's two EUO nonappearances breached a condition precedent, and its post-denial letters did not excuse noncompliance.
- Natural Therapy Acupuncture, P.C. v State Farm Mut. Auto. Ins. Co. (2013 NYSlip Op 51935(U))The provider's EUO objections were unpreserved, and the insurer established timely notices and denials and the provider's nonappearance.
- GBI Acupuncture, P.C. v Esurance Ins. Co. (2012 NY Slip Op 52423(U))The insurer established timely mailing of EUO notices and denials and the assignor's failure to appear for EUOs. The Civil Court, Kings County, granted the insurer summary judgment dismissing the complaint with prejudice and denied the providers' cross motion.
- NY Rehab Pain Mgt. & Med. Servs., PC v State Farm Auto Ins. Co. (2016 NY Slip Op 50821(U))The insurer established mailing of its EUO notices and denials and the provider's failure to appear at two scheduled EUOs. The Supreme Court, Nassau County, granted the insurer's summary judgment motion and dismissed the complaint.
- A.B. Med. Servs. PLLC v GEICO Gen. Ins. Co. (2008 NY Slip Op 52641(U))The provider's conditions for attending an EUO constituted refusal to supply verification, leaving six claims premature.