Jia Jia Zheng, as Administrator of the Estate of E.L. v. United States of America

CourtDistrict Court, S.D. New York
DecidedMarch 23, 2026
Docket1:25-cv-03695
StatusUnknown

This text of Jia Jia Zheng, as Administrator of the Estate of E.L. v. United States of America (Jia Jia Zheng, as Administrator of the Estate of E.L. v. United States of America) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jia Jia Zheng, as Administrator of the Estate of E.L. v. United States of America, (S.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT U D S O D C C U M SD E N N Y T SOUTHERN DISTRICT OF NEW YORK ELECTRONICALLY FILED DOC #: JIA JIA ZHENG, as Administrator of the Estate of DATE FILED: 3/23/2 026 E.L, 25-cv-3695 (MKV) Plaintiff, OPINION & ORDER GRANTING -against- MOTION TO DISMISS OR FOR SUMMARY JUDGMENT UNITED STATES OF AMERICA, Defendant. MARY KAY VYSKOCIL, United States District Judge: Plaintiff Jia Jia Zheng, as administrator of the estate of E.L., brings this action “pursuant to the Federal Tort Claims Act” (“FTCA”) based on allegations that a “federally owned health center” and its staff committed medical malpractice that caused the “neonatal demise of [her] infant,” E.L. [ECF No. 6 (“Compl.”) ¶¶ 6, 17, 24]. Defendant United States of America (the “Government”) moves to dismiss pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure or, alternatively, for summary judgment pursuant to Rule 56 on the grounds that Plaintiff failed to file an administrative tort claim (“SF-95”), as required by the FTCA, until nearly two years after the statute of limitations had expired, Plaintiff did not exercise reasonable diligence, and no extraordinary circumstance prevented her from timely filing her administrative claim. For the reasons set forth below, the Government’s motion is GRANTED. I. BACKGROUND1 Plaintiff alleges that beginning in or about January 2020, she “presented herself to the 1 The facts underlying the substance of Plaintiff’s claims are drawn from the Complaint and accepted as true [ECF No. 6 (“Compl.”)]. See Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). The facts pertinent to the timeliness of Plaintiff’s claims are drawn from the declaration of counsel for the Government and the exhibits attached thereto [ECF Nos. 18 (“Osmond Decl.”), 18-1 (“State Action Compl.”), 18-2 (“Verified Ans.”), 18-3 (“Stip. and Order of Dismissal”), 18- 4 (“SF-95”)] and from the facts contained in the affirmation of Plaintiff’s counsel and the exhibit attached thereto [ECF Nos. 21 (“Aff.”), 21-1 (“Email Corr.”)]. The facts pertinent to the timeliness of Plaintiff’s claims are undisputed. Char[]les B. Wang Community Health Center” (the “Health Center”) for “prenatal care.” Compl. ¶ 15. She further alleges that the Health Center and its staff “failed to diagnose” her with a “severe” obstetric condition “before she went into labor.” Id. ¶ 16. Plaintiff alleges that, as a result, the “Cesarean section” delivery (which was performed by a doctor employed by the Health Center at

New York Presbyterian Lower Manhattan Hospital (“NYPLM”)) was “inordinately delayed[,] causing the neonatal demise of the infant” E.L. on August 15, 2020. Id. ¶ 24. It is undisputed that nearly two years after the child’s death, on August 12, 2022, Plaintiff first filed a lawsuit in the Supreme Court of the State of New York, County of New York (the “State Court Action”), alleging medical malpractice, wrongful death, and related claims against the Health Center, NYPLM, and the doctor. See State Action Compl.; Aff. ¶ 4. It is further undisputed that, thereafter, on September 2, 2022, the Health Center filed an answer in the State Court Action expressly notifying Plaintiff that the Health Center “is a Federally Deemed Healthcare Center” and that any action against it and its employees “can only be brought under the Federal Torts Claims Act in the appropriate Federal Jurisdiction.” Verified Ans. at 6; see id. at 2; Aff. ¶ 5.

However, notwithstanding that the child had died on August 15, 2020 and that Plaintiff concedes she had “express notice that [her] claims were governed by the FTCA” on September 2, 2022, there is no dispute that Plaintiff failed to file an administrative tort claim (“SF-95”) with the United States Department of Health and Human Services (“HHS”) until July 15, 2024, which was nearly two years after her statutory time to file the SF-95 had expired. See SF-95; Aff. ¶ 6. Specifically, after the defendants in the State Action filed the aforementioned answer in the State Action, the Government certified that the Health Center and the doctor who treated Plaintiff are “deemed to be employees of the United States Public Health Service under the Federal Tort Claims Act,” 42 U.S.C. § 233(g), and removed the State Action to this District [24-cv-2136 (MMG), Zheng v. New York Presbyterian Lower Manhattan Hospital (“Zheng I”), ECF Nos. 1, 1- 2]. Thereafter, on May 14, 2024, Plaintiff and the Government jointly filed a stipulation that (1) the “United States of America is substituted as defendant in place of” the Health Center and the doctor, and (2) “Plaintiff’s claims against the United States of America in this action are dismissed without

prejudice pursuant to Fed. R. Civ. P. 41(a)(1)(A)(ii)” [24-cv-2136 (MMG), ECF No. 13 (the “Stipulation” or “Stip.”)]. The Stipulation also states “Plaintiff is allowed to proceed [sic] the administrative claim pursuant to 28 U.S.C. 1346(b), 2401(b), 2671-2680.” Stip. at 1. Plaintiff asserts that “[o]nce the federal nature of the claim was clarified, Plaintiff’s counsel actively corresponded with the Assistant U.S. Attorney” defending the Government in Zheng I “to clarify the administrative process.” Aff. ¶ 18. In particular, Plaintiff stresses that, in connection with the Stipulation of dismissal of Zheng I, Plaintiff requested the Government’s “consent to allow [her] to file a Form 95.” Email Corr. at 4; see Aff. ¶ 6; see also id. ¶¶ 19, 29. As demonstrated by Plaintiff’s own submissions, counsel for the Government responded: “There’s nothing preventing you from filing the administrative claim.” Email Corr. at 4; accord Aff. ¶¶ 6, 19, 29.

On May 16, 2024, the judge assigned to Zheng I signed the Stipulation in which Plaintiff voluntarily dismissed without prejudice her claims against the Government “pursuant to Fed. R. Civ. P.41(a)(1)(A)(ii).” Stip. and Order of Dismissal at 2. The judge also noted that she would “remand” the claims against NYPLM back to state court by “separate order.” Id. Two months later, on July 15, 2024, Plaintiff filed an SF-95 with HHS based on the alleged medical malpractice that had resulted in her child’s death on August 15, 2020. See SF-95. According to Plaintiff, HHS denied the claim on November 4, 2024, although she does not offer any further information about the denial. Compl. ¶ 3. Five months and twenty-eight days after the denial, on May 2, 2025, Plaintiff attempted to commence this action by filing a deficient complaint [ECF No. 1]. On May 6, 2025, Plaintiff filed the operative Complaint in this action [ECF No. 6 (“Compl.”)]. In the Complaint, Plaintiff asserts that “the instant lawsuit is being filed within six months of the final administrative determination and is accordingly timely.” Compl. ¶ 3. The Complaint

itself says nothing about when Plaintiff filed the SF-95 and entirely omits the history of Zheng I set forth above. Indeed, in the Civil Cover Sheet for the action, Plaintiff checked the “No” box in response to the question, “Has this action, . . . or one essentially the same, been previously filed in SDNY at any time?” [ECF No. 4]. The Complaint makes clear that Plaintiff’s claims are “brought pursuant to the Federal Tort Claims Act” and arise out of the “neonatal demise of [her] infant” on August 15, 2020. Id. ¶¶ 6, 24. Plaintiff asserts claims for medical malpractice, lack of informed consent, and wrongful death.

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Bluebook (online)
Jia Jia Zheng, as Administrator of the Estate of E.L. v. United States of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jia-jia-zheng-as-administrator-of-the-estate-of-el-v-united-states-of-nysd-2026.