Esquilin v. Brooklyn Hospital Center — Downtown Campus

190 Misc. 2d 753, 739 N.Y.S.2d 230, 2002 N.Y. Misc. LEXIS 76
CourtNew York Supreme Court
DecidedJanuary 8, 2002
StatusPublished
Cited by2 cases

This text of 190 Misc. 2d 753 (Esquilin v. Brooklyn Hospital Center — Downtown Campus) is published on Counsel Stack Legal Research, covering New York Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Esquilin v. Brooklyn Hospital Center — Downtown Campus, 190 Misc. 2d 753, 739 N.Y.S.2d 230, 2002 N.Y. Misc. LEXIS 76 (N.Y. Super. Ct. 2002).

Opinion

OPINION OF THE COURT

Richard A. Goldberg, J.

Defendant B.S. Nangia, M.D., a pediatric neurologist according to the court file, moves and defendant the Brooklyn Hospital Center, sued herein as both the Brooklyn Hospital Center — Downtown Campus and the Brooklyn Hospital Caledonian Hospital,1 cross-moves, in this restored medical malpractice action,2 3to compel expert witness disclosure information* or, alternatively, to preclude plaintiff from offering any expert testimony at trial in view of plaintiff’s alleged failure to provide proper responses to moving defendants’ notices to produce such information.4 Plaintiff concurrently claims that defendants have not served their expert witness information and thus purports to cross-move for the reciprocal relief of precluding defendants from producing experts to testify.5

This case concerns treatment occurring at the Brooklyn Hospital Center between September 16 and September 22, 1992 and the alleged failure to diagnose a benign brain tumor in then SVa-year-old plaintiff Sasha Talisa Esquilin who subsequently underwent brain surgery in 1994 which resulted [755]*755in the tumor’s removal. Each defendant concomitantly served a demand for expert witness information with its answer several years ago and now seeks the above relief.6 Plaintiff’s response, dated September 10, 2001 and served October 5, 2001 after plaintiff’s counsel regained entry to their office following the World Trade Center catastrophe, states that his expert: “is a physician licensed to practice medicine in the State of New York. He [a footnote explains that ‘The expert may be female’] is board certified and specializes in the field of neurological surgery. He has academic affiliations and attending privileges at major area hospitals. He is a graduate of medical school and completed an internship and residency program. He has lectured, teaches, and is a member of several professional organizations and societies.”

Defendants’ motions, which originated before plaintiff had served her response and which the court now regards as addressing the presumptive inadequacy of that response, revisit the seemingly intractable issue concerning the extent of expert witness disclosure required in medical malpractice actions. CPLR 3101 (d) (1) (i) requires parties to disclose the qualifications of their experts yet allows the shielding of the expert’s identity. The provision, enacted as part of a legislative package to reform medical malpractice litigation (L 1985, ch 294, § 4), sought to foster settlements by discouraging parties “from asserting unsupportable claims or defenses * * * ” and thereby give parties “an accurate measure of the strength of their adversaries’ case.” (Mem of State Exec Dept in Support of L 1985, ch 294, 1985 McKinney’s Session Laws of NY, at 3019, 3025.)

The Appellate Division, Second Department, in Jasopersaud v Tao Gyoun Rho (169 AD2d 184, 187-188 [2d Dept 1991]) recognized the competing policy considerations that exist between a party’s legitimate need to prepare for trial by receiving expert witness information through broadened disclosure and the disclosing party’s right to maintain the confidentiality of an expert’s identity. The opinion noted the need to temper a liberal construction of the term “qualifications” in light of the perceived problem of peer pressure potentially discouraging [756]*756“exposed” experts from testifying against a colleague. The Jasopersaud decision therefore instructed trial courts to weigh the relevant policy interests involved. This directive meant balancing the Legislature’s intent to materially expand discovery regarding experts with its concern that requested information will effectively enable determining the expert’s identity. (Supra at 188.)

More specifically, the decision declared that: “the medical school attended by the plaintiffs expert, the expert’s board certifications, areas of special expertise, jurisdictions of licensure and the locations of internships, residencies and/or fellowships, are proper inquiries bearing upon the ‘qualifications’ of the expert.” {Id. [citations omitted].) The decision, though, still allowed concealing both the dates associated with these qualifications and the expert’s present hospital affiliations lest such information might reveal the expert’s identity. (Id.) The Appellate Division, First Department, cited Jasopersaud in Yablon v Coburn (219 AD2d 560 [1st Dept 1995]) and similarly required disclosure of the expert’s “medical school, residency and fellowships * * * and the States in which such witness is licensed to practice medicine.” The decision concluded that “The demands in dispute are proper inquiries bearing upon the qualifications of the expert, the need for which outweighs the unlikelihood that the information would allow identification of the expert’s name.” (Supra at 561.)

Plaintiff now seeks to revise the Jasopersaud decision to further limit disclosure to essentially only the licensing state and board certifications. Current computerized search engines utilizing the minimal amount of information that Jasopersaud authorizes can often apparently compromise or render futile protecting an expert’s identity. Hence, some coordinate lower court decisions recognize this technological phenomenon and regard Jasopersaud, decided a decade ago, as either anachronistic (Duran v New York City Health & Hosps. Corp., 182 Misc 2d 232 [Sup Ct, Bronx County 1999]), “stale case law” regarding the extent of disclosable information (Deitch v May, 185 Misc 2d 484, 488 [Sup Ct, Rockland County 2000]), or as tilting the balancing test to make its applicability either “inoperable,” “impossible,” or “improbable” (Engel v Defeo, 189 Misc 2d 673, 676 [Sup Ct, Nassau County 2001]). The late learned Justice John Leone in Brosnan v Shaffron (NYLJ, May 3, 2001, at 23, col 6 [Sup Ct, Richmond County]) viewed the controversy as a dilemma between following “the letter” or “the spirit” of Jasopersaud and chose, like the other cases above, to truncate, even further, disclosable information about expert qualifications.

[757]*757While Computer technology and accessible information has expanded greatly in the IOV2 years since Jasopersaud, so has the willingness and availability of medical “experts” to come forward and testify against the interests of their colleagues. The statutory provision, CPLR 3101 (d) (1) (i), which provides that a party may “omit” the identity of medical, dental or podiatric expert witnesses in malpractice cases was addressed to “the perceived problem of the exertion of direct or indirect pressure by some physicians to discourage their colleagues from giving expert testimony against them” (Rubenstein v Columbia Presbyt. Med. Ctr., 139 Misc 2d 349, 352 [Sup Ct, NY County 1988]; see, Siegel, NY Prac § 348A, at 504 [2d ed 1991]). The proliferation of medical, dental, and podiatric malpractice cases since 1985 with the concomitant availability of “experts” ready, willing, and able to testify, calls into question the validity of those concerns today. The technology and attitudes of the present era make the policy considerations that prompted the statute irreconcilable or irrelevant in today’s world.

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Related

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Bluebook (online)
190 Misc. 2d 753, 739 N.Y.S.2d 230, 2002 N.Y. Misc. LEXIS 76, Counsel Stack Legal Research, https://law.counselstack.com/opinion/esquilin-v-brooklyn-hospital-center-downtown-campus-nysupct-2002.