Right Aid Diagnostic Medicine, P.C. v GEICO Ins. Co., 2012 NY Slip Op 50394(U)(App. Term 2d Dept. 2012)
Assuming one breaches the threshold issue of whether Plaintiff provided sufficient evidence to demonstrate that the signature was anything but holographic, the Court held that the peer report affidavit sufficiently made the proper showing that the signature was electronic and placed at the direction of the signor.
“While plaintiff also asserted that the peer review report contained an electronic stamped facsimile of the peer reviewer’s signature and, as a result, the report was inadmissible, the record indicates that the facsimile signature was placed on the report by the doctor who had performed the peer review or at his direction”
