Hello Mrs. Collins

In no-fault insurance litigation, discovery disputes frequently arise when parties seek to depose individuals who may have limited knowledge of the underlying claims. The question becomes whether the proposed discovery will actually produce relevant information or simply add unnecessary costs and delays to the proceedings.

This case illustrates a common scenario in no-fault practice where insurance companies challenge medical providers’ billing practices. When medical professionals pass away, their estates often become defendants in these declaratory judgment actions. However, the administrators of these estates may have little to no knowledge about the day-to-day operations of the medical practice or the specific treatments that generated the disputed bills.

The discovery standards in New York require parties to demonstrate that their proposed discovery methods will reasonably lead to relevant evidence. This protective approach prevents fishing expeditions that could burden parties without advancing the litigation. Understanding these disclosure requirements is crucial for practitioners handling no-fault insurance disputes.

Jason Tenenbaum’s Analysis:

State Farm Mut. Auto. Ins. Co. v RLC Med., P.C., 2017 NY Slip Op 03979 (2d Dept. 2017)

(1) “The plaintiff insurance company commenced this action against, among others, the defendant Estate of Ronald L.L. Collins, seeking a judgment declaring, inter alia, that the plaintiff has no obligation to pay no-fault claims for medical services purportedly rendered by Collins.”

(2) “It is incumbent on the party seeking disclosure to demonstrate that the method of discovery sought will result in the disclosure of relevant evidence or is reasonably calculated to lead to the discovery of information bearing on the claims’” (D’Alessandro v Nassau Health Care Corp., 137 AD3d at 1196, quoting Crazytown Furniture v Brooklyn Union Gas Co., 150 AD2d 420, [*2]421). Here, the plaintiff made no showing that conducting the deposition of the administrator will result in the disclosure of relevant evidence or is reasonably calculated to lead to the discovery of information bearing on the claims”

I am unsure what the administrator had to offer. Since it is not an e-filed case and I am not going to Mineola to pull the file, I will never know.

Key Takeaway

Courts will deny discovery requests when the seeking party fails to demonstrate that the proposed method will yield relevant evidence. In estate cases involving medical practice disputes, administrators may have limited knowledge of clinical operations, making depositions potentially unproductive and unnecessarily burdensome to the litigation process.

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