The Estate of Shirley Brito v. Harlem Center for Nursing and Rehabilitation, LLC

CourtDistrict Court, S.D. New York
DecidedNovember 30, 2022
Docket1:22-cv-09937
StatusUnknown

This text of The Estate of Shirley Brito v. Harlem Center for Nursing and Rehabilitation, LLC (The Estate of Shirley Brito v. Harlem Center for Nursing and Rehabilitation, LLC) 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
The Estate of Shirley Brito v. Harlem Center for Nursing and Rehabilitation, LLC, (S.D.N.Y. 2022).

Opinion

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November 29, 2022 VIA ECF Hon. Paul A. Engelmayer United States District Court Southern District of New York 500 Pearl Street New York, New York 10007 Re: Shirley Brito by her Proposed Administrator, Tairra Baker v. Harlem Center for Nursing and Rehabilitation d/b/a Harlem Center for Nursing and Rehabilitation Case No. 1:22-cv-09937 -PAE-JLC Dear Judge Engel Mayer: The undersigned represents defendant, Harlem Center for Nursing and Rehabilitation d/b/a Harlem Center for Nursing and Rehabilitation (“Defendant”) in the above-referenced action. This letter motion is submitted pursuant to York Honor’s Individual Practices Rules I(E) and 3A. By this letter, Defendant respectfully asks the Court to hold anticipated motion practice by plaintiff and/or consideration of remand in abeyance until after the appeals of Leroy v. Hume, Nos. 21-2158, 21- 2159 (cons.), Rivera-Zayas v. Our Lady of Consolation Geriatric Care Center, 21-2164, and Solomon v. St. Joseph Hospital, No. 21-2729, which are currently pending in the Second Circuit, are decided, as these appeals concern identical jurisdictional arguments that would be raised in a remand motion here. Accordingly, and as discussed in detail below, we request that this case be stayed pending issuance of a decision in those appeals. Alternatively, Defendant requests a pre-motion conference to address its application for an extension of time to answer and a briefing schedule for a pre-answer motion to dismiss based upon plaintiff's lack of capacity to prosecute this action as a “Proposed” estate representative, and the COVID- 19 immunities afforded by the Public Readiness and Emergency Preparedness Act (“PREP Act”), 42 U.S.C. §§ 247d-6d, 247d-6e, and New York’s Emergency or Disaster Treatment Protection Act (“EDTPA”), N.Y. Pub, Health Law § 3082.

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As a threshold matter, Plaintiff, as “Proposed Administrator” of the Estate of Shirley Brito, lacks standing, and thus lacks capacity to prosecute this action or otherwise act on behalf of the decedent. See NY EPTL §5-4.1(1); Bush v. City of Utica, 948 F.Supp.2d 246, 253 (N.D.N.Y. 2013), aff'd sub nom. Bush vy. City of Utica, N.Y., 558 F.App’x 131 (2d Cir. 2014); Carrick v. Central General Hospital, 51 N.Y.2d 242, 246, 434 N.Y.S.2d 130 (1980); Sam Kyung Cho v. Yongshin Cho, 45 A.D.3d 388, 389 (i* Dep’t 2007); Butler v. Kings Co. Hospital Center, 30 Misc.3d 1229(a), 924 N.Y.S.2D 307 (Sup. Ct. Kings Co, 2011) (dismissing wrongful death claim where cased filed by “Proposed Administrator” subsequently obtained letters, but never cured the initial filing defect). Defendant intends to file a pre-answer motion to dismiss on these grounds.! Dismissal for lack of capacity is warranted, or at a minimum, there should be a stay of proceedings until a proper estate representative is appointed. If the Court considers remand sua sponte, it should consider that Defendant removed this action because the Complaint alleges injury relating to the administration of COVID-19 countermeasures to prevent, diagnose and/or treat COVID-19 within the meaning of the PREP Act. Defendant asserts federal subject matter jurisdiction on the grounds that these claims: (1) “aris[e] under” federal law within the meaning of 28 U.S.C. § 1331 because they are completely preempted by the PREP Act; (2) “aris[e] under” federal law within the meaning of 28 U.S.C. § 1331 because, under Grable & Sons Metal Products, Inc. vy, Darue Engineering & Manufacturing., 545 U.S. 308 (2005), these claims necessarily involve substantial and disputed questions of federa! law; and (3) form the basis for federal jurisdiction because defendants subject to such claims are persons acting under federal officers within the meaning of 28 U.S.C, § 1442(a)(I). These issues are before the Second Circuit in the Leroy and Rivera-Zayas appeals. Oral argument in the Leroy and Rivera-Zayas appeals occurred on October 31, 2022. On November 14, 2022, the Second Circuit ordered that consideration of these appeals be held in abeyance until the Court issues a decision in Solomon. Briefing in Solomon on the same jurisdictional questions at issue in this case and in Leroy and Rivera-Zayas is currently scheduled to conclude by the end of January 2023. A stay, rather than remand, would allow the parties the benefit of awaiting a decision from the Second Circuit before engaging in motion practice that could shortly be deemed moot. As such, Defendant respectfully asks this Court to hold any consideration of remand in abeyance until after the Second Circuit renders decisions in these appeals. Multiple courts in the Eastern and Southern Districts of New York have recently stayed motion practice, despite objection by plaintiff, in similarly situated cases as a matter of judicial efficiency. As EDNY Judge Vitaliano recognized in issuing a stay in a case involving identical jurisdictional issues, “a court may...properly exercise its staying power when a higher court is close to settling an important issue of law bearing on the action.” See McGovern v. Our Lady of Consolation Geriatric Care Center, 2:22- cv-05558-ENV (E.D.N.Y., Sep, 29, 2022) (issuing stay pending Second Circuit’s resolution of Leroy and Rivera-Zayas appeals) (citation omitted). A number of courts have likewise issued stays on the same grounds. See, e.g., Jones v. The Brookdale University Hospital and Medical Center, et al., 1:22-cv-02552-RPK-TAM (E.D.N.Y., Nov. 9, 2022) (ruling that the issues in Leroy and Rivera-Zayas appeals “appear substantially similar to the issues presented in the plaintiff's motion for remand”); Vetere v. Suffolk Restorative Therapy and Nursing LLC, 2:22-cv-04886-FB-ARL (E.D.N.Y. Nov. 4, 2022) (same); Ortiz v. Bronx Harbor Heath Care Complex, Inc., et al., 1:22-cv-09348-JLR (S.D.N.Y., Nov.

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Related

Carrick v. Central General Hospital
414 N.E.2d 632 (New York Court of Appeals, 1980)
Sam Kyung Cho v. Yongshin Cho
45 A.D.3d 388 (Appellate Division of the Supreme Court of New York, 2007)
Bush ex rel. Estate of Bush v. City of Utica
948 F. Supp. 2d 246 (N.D. New York, 2013)

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The Estate of Shirley Brito v. Harlem Center for Nursing and Rehabilitation, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-estate-of-shirley-brito-v-harlem-center-for-nursing-and-nysd-2022.