Parker v. City of New York

2024 NY Slip Op 31925(U)
CourtNew York Supreme Court, New York County
DecidedJune 4, 2024
StatusUnpublished

This text of 2024 NY Slip Op 31925(U) (Parker v. City of New York) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Parker v. City of New York, 2024 NY Slip Op 31925(U) (N.Y. Super. Ct. 2024).

Opinion

Parker v City of New York 2024 NY Slip Op 31925(U) June 4, 2024 Supreme Court, New York County Docket Number: Index No. 156628/2021 Judge: Hasa A. Kingo Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. [FILED: NEW YORK COUNTY CLERK 06/04/2024 05:02 P~ INDEX NO. 156628/2021 NYSCEF DOC. NO. 176 RECEIVED NYSCEF: 06/04/2024

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. HASA A. KINGO PART 05M Justice ---------------------------------------------------------------------------------X INDEX NO. 156628/2021 KATHRYN PARKER, RYAN HUNTER MOTION DATE 05/06/2024 Plaintiffs, MOTION SEQ. NO. 003 - V -

CITY OF NEW YORK, NEW YORK CITY HOUSING DECISION + ORDER ON AUTHORITY, MOTION Defendants. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 003) 118, 119, 120, 121, 122,123,124,125,126,128,130,131,132,133,165,166,167,168,169,170,171,172,173,174,175 were read on this motion for DISCOVERY

With the instant motion, made by Order to Show Cause, defendant New York City Housing Authority ("NYCHA") moves for an order compelling Plaintiffs Kathryn Parker ("Plaintiff') and Ryan Hunter's (collectively "Plaintiffs") to produce the following: 1.) unrestricted HIPAA compliant authorizations for all treatment pertaining to Plaintiffs Lupus; 2.) unrestricted HIPAA complaint authorizations related to Plaintiffs Raynaud's Disease; and 3.) unrestricted collateral source authorizations in consideration of Plaintiffs history of prior and subsequent similar injuries. Plaintiffs oppose the application. For the reasons stated herein, the motion is denied.

BACKGROUND

On April 9, 2024, this court held a status conference, bringing all parties before the court to argue the issues in contention. Defendants, the City of New York ("City") and NYCHA, asserted their entitlement to records pertaining to Lupus and Raynaud' s disease, while Plaintiffs opposed such production. Following these arguments, the court issued an order on April 9, 2024, directing Plaintiffs to provide most of the production sought by the City and NYCHA, with the notable exception ofrecords related to Lupus and Raynaud's disease.

This order also mandated that "Plaintiffs counsel is directed to provide the NEW YORK CITY HOUSING AUTHORITY with a response to the NEW YORK CITY HOUSING AUTHORITY's forthcoming demand within fifteen (15) days of this order," and further instructed that "Plaintiffs counsel shall provide any additional authorizations and employment records consistent with the terms of this court's order within fifteen (15) days of this order."

On the same day, April 9, 2024, NYCHA filed its demand, reiterating requests for Lupus and Raynaud' s disease authorizations-issues that had been explicitly addressed and excluded in

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the court's April 9, 2024 order. Additionally, NYCHA sought unrestricted collateral source authorizations without any limitation in scope or a stated basis for the same. Likewise, NYCHA made the request for unrestricted collateral source authorizations despite having been previously provided with collateral source authorizations from the date of the accident forward.

Plaintiffs responded on April 10, 2024, noting that, although not required by the court's order, they would provide an authorization for Dr. Grace Wright ("Dr. Wright"), a rheumatologist, from the date of the accident forward. By April 20, 2024, within the fifteen days stipulated, Plaintiffs had complied with all mandated responses as per the court's April 9, 2024 order.

Subsequent email correspondence revealed NYCHA's objection to Plaintiffs' inability to recall the name of a specific doctor from 2021. NYCHA then suggested an unrestricted collateral source authorization to resolve the issue, despite already having a collateral source authorization encompassing the date of the accident. Plaintiffs' counsel undertook the task of identifying the doctor, ultimately issuing the necessary authorizations. Upon identifying an error in one authorization date, it was promptly corrected. On April 23, 2024, Plaintiffs' counsel requested defense counsels to specify any further requirements within the parameters of the court's order, the CPLR, and the Case Scheduling Order ("CSO"), explicitly stating that an unrestricted collateral source authorization was not within those parameters.

No further communication ensued regarding authorizations until NYCHA brought forth the instant Order to Show Cause on May 6, 2024.

DISCUSSION

Generally the test for disclosure pursuant to CPLR § 3101 is whether the information sought is material and necessary. The test is one of relevance, usefulness and reason (Allen v Cromwell-Collier Pub. Co., 21 NY2d 403, 406 [1968]). CPLR § 3 l0l(a) requires full disclosure of all evidence material and necessary to the prosecution or defense of an action, regardless of the burden of proof (Weber v Ryder TRS, Inc., 49 AD3d 865,866 [2d Dept 2008]). The terms "material and necessary" in this statute "must 'be interpreted liberally to require disclosure, upon request, of any facts bearing on the controversy which will assist preparation for trial by sharpening the issues and reducing delay and prolixity"' (Matter of Kapon v. Koch, 23 NY3d 32, 38 [2014], quoting Allen v. Crowell-Collier Puhl. Co., 21 NY2d 403,406 [1968]). Pursuant to CPLR § 3124 this court can, in its discretion, compel disclosure of information that a party fails to provide. Indeed, under CPLR § 3124, "[i]f a person fails to respond to or comply with any request, notice, interrogatory, demand, question or order under this article ... the party seeking disclosure may move to compel compliance or a response" (CPLR § 3124). Under the Uniform Civil Rules, "discovery disputes should be resolved through informal procedures, such as conferences," and discovery motions must be filed with "an affirmation that counsel has conferred with counsel for the opposing party in a good faith effort to resolve the issues raised by the motion" (Uniform Rules for Trial Cts [22 NYCRR] §§ 202.20[-f]; 202.7[a], [c]). The affirmation must "indicate the time, place and nature of the consultation and the issues discussed and any resolutions or shall indicate good cause why no such conferral with counsel for opposing parties was held" (22 NYCRR § 202.7[c]).

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"It is well-settled that a party must provide duly executed and acknowledged written authorizations for the release of pertinent medical records under the liberal discovery provisions of the CPLR when that party has waived the physician-patient privilege by affirmatively putting his or her physical or mental condition in issue" (Cynthia B. v. New Rochelle Hosp. Med Ctr., 60 NY2d 452, 456-457 [1983] [citations and footnote omitted]; Dillenbeck v. Hess, 73 NY2d 278 [1989]; Koump v. Smith, 25 NY2d 287 [1969]).

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2024 NY Slip Op 31925(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/parker-v-city-of-new-york-nysupctnewyork-2024.