Key Takeaway
Appellate Term compels Dr. Collins to attend deposition in another RLC Medical case, highlighting recurring patterns in no-fault insurance litigation.
No-fault insurance litigation often reveals fascinating patterns when you examine the cases over time. Certain medical professionals, particularly those involved with medical provider corporations, appear repeatedly in appellate decisions concerning deposition requirements and disclosure issues. This case involving RLC Medical P.C. and Dr. Collins exemplifies how the same players continue to surface in disputes over examination before trial (EBT) obligations.
The Appellate Term’s decision here follows established precedent regarding when medical professionals must submit to depositions in connection with Mallela-related challenges to medical necessity. These cases often involve complex questions about the relationships between doctors and medical corporations, particularly when issues of medical necessity are disputed by insurance companies.
Jason Tenenbaum’s Analysis:
RLC Med., P.C. v Allstate Ins. Co., 2010 NY Slip Op 51962(U)(App. Term 2d Dept. 2010)
By virtue of reading these opinions, religiously, for about 7 years, it amazes me that I continually see the same names of doctors who the Appellate Term compels to attend depositions on Mallela related issues. Dr. Collins has lately become a regular, and this case follows every other RLC medical I have come across lately.
I know through reading thousands of NF-3’s, EMG reports and other testing data, Dr. Collins seems to have been involved in many of these P.C.’s. I also recall a case a few years back where Dr. Collins was an independent contractor for the one and only A.B. Medical.
The more things change, the more they stay the same.
Key Takeaway
This case demonstrates the recurring nature of no-fault litigation involving certain medical professionals. Dr. Collins’ repeated appearances in Appellate Term decisions regarding deposition obligations suggests systemic issues within medical provider corporations that insurers continue to challenge through discovery motions.
