Back to Top

Medical & Nursing Home Liability Pointers - 03/25/22

 
 

March 25, 2022

   A Note from Kara M. Eyre

In what I hope is a sign of good things on the horizon, this month’s edition of Medical & Nursing Home Liability Pointers is not full of COVID-19 news—although there is another decision upholding the vaccine requirement for health care workers in New York, and further attempts to get this issue before the United States Supreme Court.  Another sign of a return to normalcy is that litigation is back in full swing, and the courts have been very busy addressing the myriad of issues that arise in our malpractice and long-term care claims.  The Courts have been so busy, in fact, that there were too many reported decisions this past month to report on here, so we have carefully selected the 15 most impactful and relevant to our readers.

In keeping with national trends, the Eastern District of New York remanded a COVID death claim back to state court, holding that the federal PREP Act does not completely preempt state law.  The District Court also rejected the defendant hospital’s effort to claim federal officer jurisdiction because it was identified as critical infrastructure to assist and carry out the federal effort to prevent the spread of Covid-19.  The Court found that the hospital was merely a “highly regulated” private entity. 

There were a couple of decisions from the First Department of note.  The Appellate Court affirmed the trial court’s order to disclose the records of a fellow resident and accused assailant of decedent, finding that such records were relevant to the facility’s actual or constructive knowledge of the fellow resident’s propensity for violence towards other residents.  These records were deemed not to be privileged with regards to incidents of prior assaults and similar violent behavior only, and all medical information as to diagnosis or treatment of the fellow resident was to be redacted.  In a sperate decision, the First Department also confirmed that comparative negligence in a medical malpractice case based on a plaintiff's smoking history is a viable defense.

The Second Department was particularly busy with a plethora of wide-ranging decisions:

  • Summary judgment denied on an informed consent claim, despite an executed consent form, based on plaintiff’s testimony that defendants failed to advise on the risks, benefits, and alternatives of guided ultrasound treatment that resulted in an Achilles tendon tear;
  • Denied motion to dismiss claims arising from treatment dating back over 25 years as time barred by the statute of limitations on the grounds that plaintiff raised a triable issue of fact as to the applicability of the relation-back doctrine; 
  • Reversed and denied summary judgment to defendants in a claim of failure to diagnose DVT, holding that whether a diagnostic delay affected a patient’s prognosis is typically an issue that should be presented to a jury;
  • Summary judgment denied where plaintiff’s expert opined that the defendant radiologist failed to timely recommend additional diagnostic testing to rule out malignant cells;
  • Summary judgment granted in an infant neurological injury claim where plaintiff failed to submit an expert affidavit regarding obstetrical care;
  • Summary judgment granted in a stroke case where plaintiff’s cardiovascular expert cited incorrect facts and opinion was unsupported by any evidentiary foundation;
  • New trial ordered after a defense verdict in a trial concerning the failure to timely diagnose skin cancer on plaintiff’s foot, finding comments from the trial court deprived plaintiff of a fair trial.  The trial court had apparently refused to allow plaintiff’s counsel to refer to the growth at issue as a tumor and ordered that it instead be referred to as a wart, which was an essential and disputed issue in the case, and opined multiple times before the jury that there was no proof that the plaintiff was misdiagnosed, despite plaintiff’s expert’s testimony to the contrary. 
  • Upheld a defense verdict in a medical malpractice case against a trial defendant, finding that a defense verdict against one defendant is not inconsistent with a finding of liability against another defendant who settled during trial.  


The Third Department excused plaintiff's failure to file a certificate of merit with the complaint required in a medical malpractice action pursuant to CPLR 3012-a, begging the question of what is the point of the requirement if it is not enforced?

The Fourth Department issued two decisions that seemed so obvious, it makes you wonder why they were appealed in the first place.  A lack of informed consent cause of action cannot survive absent an injury proximately caused by the disputed medical procedure.  And finally, a defendant nursing home must disclose a copy of decedent’s certified chart at no cost to plaintiff.

We have good news to share on the controversial Comprehensive Insurance Disclosure Act (“CIDA)” - the substantial modifications in the form of Chapter Amendments were finally passed and signed by the Governor.  Our Insurance Coverage Team has also prepared this checklist detailing our obligations under the amended law. Please contact us to schedule CIDA compliance training for your team

Currently, there are no new developments on the proposed “Grieving Families Act” (S.74-A/A.6770),  which would amend New York’s Wrongful Death Statue to permit the families of wrongful death victims to recover compensation for their emotional anguish, not just pecuniary loss, and extend the statute of limitations for wrongful death from two years to three and a half years from the date of fatality.  While the Bill remains stalled in the Senate Judiciary Committee, there are formidable lobbying forces supporting its passage.  If you are interested in learning more on this topic, please read our article from my esteemed colleagues Chris Potenza and Alice Trueman, Redefining 'Family': Emotional Damages and the Grieving Families Act, published by the New York State Bar Association.

As a reminder, we are pleased to be offering in-house (webinar) training on all the new legislative and regulatory changes impacting the nursing home and long-term care communities, as well as the impact of Covid-19 immunity statutes on personal injury claims.  Please contact us directly to schedule a one-hour interactive training session.  Click on the links below for printable and downloadable resource guides on these topics as well:
 

       

 

Latest News & Developments


New York District Court upholds vaccine mandate for healthcare workers while further efforts are made for Supreme Court review.
 
In September 2021, a U.S. District Court Judge (NDNY) had issued a temporary restraining order blocking New York from enforcing its COVID-19 vaccine mandate for healthcare workers against those with religious objections.  However, a three-judge panel in the Second Circuit thereafter vacated the injunction, seemingly ending any religious exemption to the vaccine mandate for healthcare workers.  The fight rages on however.  On January 30, 2022, a renewed motion for a temporary restraining order and preliminary injunction was filed in the NDNY action, along with an amended complaint adding additional claims that NY’s vaccine requirement is preempted by the federal COVID-19 Vaccine Mandate for Medicaid- and Medicare-participating healthcare facilities (“CMS Mandate”), and that plaintiffs have been unlawfully disqualified from eligibility for State unemployment insurance benefits.  On February 23, 2022, plaintiff’s application was denied, with the NDNY reasoning that the plaintiffs failed to establish that they are likely to succeed on the merits of their preemption claims because it is far from clear that the CMS Mandate conflicts with New York’s mandate and there is a general presumption against a finding of preemption when it comes to a state or local regulation of matters related to health and safety.  Further, plaintiffs also failed to show irreparable harm and have not established that an employer cannot reasonably accommodate a religious objector.
 
In November 2021, plaintiffs filed an emergency application for injunctive relief to the United States Supreme Court preventing enforcement of New York vaccine mandate for healthcare workers.   On December 13, 2021, the U.S. Supreme Court denied the application, with Justice Gorsuch dissenting. In February 2022, a Petition for a Writ of Certiorari was filed in the U.S. Supreme Court on the issue of whether New York’s COVID-19 vaccine mandate for healthcare workers violates the Free Exercise Clause of the U.S. Constitution as it relates to religious exemptions. Eleven U.S. Senators, led by Marco Rubio (R-Fla), filed an amicus brief with the US Supreme Court asking for a full court review of the case.

 

 

Analysis of Recent Court Decisions

 

March 7, 2022
Escobar v. Mercy Med. Ctr.
United States District Court, Eastern District of New York

In keeping with national trends, the Eastern District of New York remands case involving claims of negligence, wrongful death, and medical malpractice to state court, holding that the federal PREP Act does not completely preempt state law.
 
In this case, the decedent was admitted to defendant hospital through their emergency department on April 8, 2020 and remained there until his death on May 20, 2020, suffering from sepsis, acute respiratory failure, and a later confirmed case of Covid-19.  Plaintiff filed a Complaint sounding, inter alia, in negligence, medical malpractice, and wrongful death in New York State Supreme Court, Nassau County, and defendant removed the matter to the Eastern District on the basis of federal question, complete preemption, embedded federal question, and federal officer jurisdiction.  Plaintiff moved to remand and the Eastern District granted the motion.
 
Mirroring other District and Circuit Court decisions across the country involving analysis of the PREP Act, the Eastern District rejected defendant’s argument that the PREP Act affords federal court subject matter jurisdiction pursuant to the complete pre-emption doctrine.  Noting that this issue has already been vetted by the Eastern District in, Dupervil v. Alliance Health Operations, LLC, 156 F. Supp3d 238, (E.D.N.Y. 2021), the Court found that the PREP Act is not a complete preemption statute because it does not provide the exclusive cause of action for claims that fall within its scope.
 
Defendant also argued that the federal court has subject matter jurisdiction pursuant to Grable & Sons Metal Products, Inc. v. Darue Eng’g & Mf’g., 545 U.S. 308 (2005), which held that in certain cases federal-question jurisdiction will lie over state law claims that implicate significant federal issues.  Again, the Eastern District followed the reasoning previously set forth in Dupervil and found that Grable jurisdiction does not apply, because none of the plaintiff’s claims necessarily raise a federal issue. 
 
Defendant also argued that the case is removable under federal officer jurisdiction, as a case may be removed if it is brought against “any officer (or any person acting under that officer) of the United States or of an agency thereof, . . . for or relating to any at under color of such office.”  The Eastern District, as several other District and Circuit Courts across the country in similar cases have recently held, found that defendant hospital was not acting under the color of the United States, despite being identified as critical infrastructure to assist and carry out the federal effort to prevent the spread of Covid-19.  The Court found that defendant hospital was merely a “highly regulated” private entity. 
 
 
March 3, 2022                    Luz Cabreja v. John/Jane Doe Physicians, et al.
Appellate Division, First Department
File of fellow resident and accused assailant of decedent ordered to be disclosed and deemed not privileged as to incidents of prior assaults and similar violent behavior but all medical information as to diagnosis or treatment to be redacted.
 
Plaintiff’s decedent, a resident at Defendant Bay Park Center for Nursing and Rehabilitation, was allegedly sexually assaulted by a fellow nursing home resident. The alleged assailant had been a resident at Moshulu Parkway Nursing and Rehabilitation Center, which transferred him to Bay Park. Bay Park filed a third-party complaint against Moshulu, alleging that when Moshulu transferred the fellow resident, it failed to disclose that he had been involved in a prior incident of inappropriate sexual conduct.
 
While the fellow resident had not waived his right to keep confidential the medical information contained in his hospital records, the Appellate Court held that plaintiff was entitled to any nonmedical information in Moshulu’s possession related to any prior assaults or similar violent behavior by the fellow resident, with all medical information redacted so as not to pertain to diagnosis or treatment, but only behavior. Such information regarding behavior was not considered privileged and could be used to establish Moshulu’s actual or constructive knowledge of the fellow resident’s propensity for violence towards other residents, including plaintiff’s decedent.
 

March 8, 2022             Johnson v. Montefiore Med. Ctr.
Appellate Division, First Department
First Department confirms that comparative negligence in a medical malpractice case based on a plaintiff's smoking history is a viable defense.
 
In this medical malpractice action, plaintiff alleges that defendants injured her ureter during a hysterectomy to remove a uterine adenosarcoma.  After party depositions were completed, defendants sought leave to assert the affirmative defenses of culpable conduct and comparative negligence, claiming that plaintiff's weight and smoking history contributed to her claimed injuries.  Plaintiff opposed on procedural and substantive grounds.  The First Department reversed the trial court and permitted the amended pleadings asserting the affirmative defense, holding that defendants need not establish the merit of its proposed new allegations, but must simply show that the proffered amendment is not palpably insufficient or clearly devoid of merit.  Importantly, the Court explicitly held that a comparative negligence defense in a medical malpractice case based on a plaintiff's smoking history is not per se meritless, and thus whether defendants can establish their affirmative defenses is a matter for either the court on summary judgment or the finder of fact at trial.
 

February 16, 2022       Palmeiro v. Jonathan Luchs, et al.
Appellate Division, Second Department
In a claim of lack of informed consent, the Second Department holds that plaintiff’s deposition testimony that he was not provided with the risks, benefits, and alternatives to a procedure was sufficient to establish that Defendants failed to meet their prima facie burden at summary judgment.
 
Plaintiff alleged that, as a result of ultrasound guided injections, his right Achilles tendon ruptured and his left Achilles tendon teared.  The Second Department held that on the medical malpractice claims, summary judgment was not appropriate where the parties adduced conflicting medical expert opinions.
 
With regard to plaintiff’s lack of informed consent claim, the Second Department noted that one of the elements a plaintiff must prove is that the person providing the professional treatment failed to disclose the applicable risks, benefits, and alternatives to the proposed treatment that a reasonable medical practitioner would have disclosed in the same circumstances.  Although defendants submitted the executed consent form and testified at their deposition that they advised plaintiff on the risks, benefits, and alternatives of the treatment, the plaintiff’s deposition testimony indicated that defendants failed to provide this counsel, and as such, there were triable issues of fact with respect to plaintiff’s lack of informed consent claim.
 

February 23, 2022       Craig v. Rutland Nursing Home
Appellate Division, Second Department
Second Department declines to dismiss claims arising from treatment dating back over 25 years as time barred by the statute of limitations on the ground that plaintiff raised a triable issue of fact as to the applicability of the relation-back doctrine.
 
The decedent was a resident of defendant Rutland Nursing Home, for approximately 11 months between 1996 and 1997.  In 1997, plaintiffs filed a complaint sounding in negligence and loss of consortium.  In 2014, an Amended Complaint was filed which set forth two additional causes of action, gross negligence and violations of N.Y. Public Health Law §2801-d.  Defendant moved to dismiss these two new causes of action on the ground that they were barred by the statute of limitations. 
 
The Second Department refused to dismiss these causes of action, finding that although defendant had established, prima facie, that plaintiffs’ gross negligence and §2801-d claims were time barred by the applicable three-year statute of limitations, plaintiffs raised a triable issue of fact as to the applicability of the relation-back doctrine and the Supreme Court denied defendant’s motion.
 

February 23, 2022
Ivey v. Mbaisdjol et al.
Division, Second Department

Second Department finds that whether a diagnostic delay affected a patient’s prognosis is a jury question.
 
Plaintiff commenced this action to recover damages for wrongful death and medical malpractice against defendant physician and hospital, alleging, inter alia, a failure to timely diagnose the decedent’s DVT.  At summary judgment, defendants and plaintiff submitted opposing expert affidavits, but the trial court granted defendants’ motion for summary judgment, finding that plaintiff’s expert affidavit was speculative and not supported by the record. 
 
The Second Department reversed the Supreme Court, finding that plaintiff raised a triable issue of fact as to whether defendants departed from good and accepted practice and whether such departures caused the decedent’s death.  The Appellate Court noted that plaintiff’s expert opined that the defendants failed to take a proper history and perform a proper workup, failed to rule out DVT, misdiagnosed the decedent and, significantly, found that whether a diagnostic delay affected a patient’s prognosis is typically an issue that should be presented to a jury. 
 

March 2, 2022             Valenti v. Gadomski, et al.
Appellate Division, Second Department
Second Department sets aside jury verdict in medical malpractice trial finding that the “cumulative effect” of the Supreme Court’s comments, as well as those from opposing counsel, deprived plaintiff of a fair trial.
 
Following a jury trial of plaintiff’s medical malpractice claims that defendants deviated from the standard of care in failing to timely diagnose skin cancer on plaintiff’s foot, causing him to undergo an amputation of the fifth toe, the jury returned a verdict in favor of defendants finding no liability.  The Second Department set aside the verdict and remitted that matter for a new trial in the interest of justice since improper comments by the Supreme Court and opposing counsel deprived plaintiff of a fair trial and may have unduly influenced the jury.
 
The Second Department noted that the Supreme Court barred plaintiff’s counsel from referring to the growth at issue as a tumor and ordered that it instead be referred to as a wart, thus determining an essential issue that should have been left to the jury.  Additionally, the Supreme Court opined multiple times before the jury that there was no proof that the plaintiff was misdiagnosed, despite plaintiff’s expert’s testimony to the contrary.  The Second Department also found that multiple inflammatory and unduly prejudicial remarks by defense counsel also unduly prejudiced the jury. 


February 16, 2022
Ditoro v. Richmond University Medical Center et al.
Appellate Division, Second Department

The Second Department holds that defense verdict in medical malpractice case against trial defendant is not inconsistent with verdict against settled defendant.
 
Plaintiff was admitted to defendant hospital due to a pulmonary embolism.  He was later diagnosed with cancer and died.  Plaintiff commenced this action sounding in medical malpractice against multiple defendants, including defendant Scafuri and Rana.  The cased proceeded to trial, and after plaintiff rested, plaintiff settled with defendant Scafuri.  The jury returned a verdict finding that defendant Scafuri had departed from the standard of care, but that defendant Rana did not.
 
The Second Department held that the verdict in favor of defendant Rana could be reconciled with a reasonable view of the evidence in a way that is not inconsistent with the verdict against defendant Scafuri.  The jury was presented with conflicting expert opinions on the issue of whether defendant Rana departed from the standard of care, and the jury’s determination to credit defendant Rana’s expert over plaintiff’s is entitled to deference.  Defendant Scafuri, on the other hand, settled with plaintiff mid-trial and therefore did not present any evidence, and thus the only expert opinion the jury heard regarding defendant Scafuri’s negligence was the plaintiff’s expert.  Accordingly, the Supreme Court properly denied plaintiff’s motion to set aside the verdict.
 

March 2, 2022                    Brenda Dye v. Stephen Okon, et al.
Appellate Division, Second Department
Summary judgment denied where plaintiff’s expert opined that defendants failed to timely recommend additional diagnostic testing to rule out malignant cells.
 
Between 2011 and 2014, plaintiff’s decedent underwent multiple CT scans of her chest performed by the defendant radiologists. The scans showed multiple nodular densities, many of which showed evidence of “branching,” and some of which changed in size. The defendants concluded that these factors suggested small airway inflammatory disease and continued to recommend follow up CT scans. In 2014 however, plaintiff had a CT-guided fine needle aspiration of her right lung performed. This test was positive for malignant cells. Though decedent began treatment immediately thereafter, she died in October 2015.
 
Defendants moved for summary judgment, establishing through the expert affirmation of a radiologist that they did not depart from the standard of care in their treatment of decedent. In response however, plaintiff raised a triable issue of fact through her submission of the expert affirmation of a radiologist that defendants did depart from the standard of care by failing to timely recommend that decedent undergo additional diagnostic testing to rule out malignancy. As such, defendants motion for summary judgment was denied.
 

March 2, 2022                    Brian Mendoza, et al. v. Maimonides Medical Center, et al.
Appellate Division, Second Department
Defendants granted summary judgment where plaintiffs failed to submit an expert affidavit regarding obstetrical care.
 
Plaintiff received prenatal care at Maimonides Medical Center beginning in June 2003, and thereafter gave birth to the infant plaintiff in December 2003. In 2013, plaintiffs commenced this action alleging that defendants were negligent in failing to provide proper obstetrical and pediatric care, which caused the infant plaintiff to suffer severe neurological and developmental delays.
 
Defendants established entitlement to judgment as a matter of law by submitting the expert affirmations of an obstetrician/gynecologist and a pediatric neurologist, which demonstrated that the care provided to the plaintiffs was within the accepted standards of care and did not cause the claimed injuries. In opposition, plaintiffs failed to raise a triable issue of fact as they did not submit an expert affidavit regarding the obstetrical care provided and thus failed to rebut defendants’ prima facie showing. Moreover, the affirmation of the expert pediatrician that the plaintiffs did submit failed to address the specific assertions raised by defendants’ expert and improperly raised a new theory of liability for the first time. As such, defendants’ motion for summary judgment was properly granted and the case against them was dismissed.
 

March 2, 2022                    Eugene Palagye v. Didier F. Loulmet et al.
Appellate Division, Second Department
Plaintiff’s expert opinions – based on incorrect assumptions unsupported by evidentiary foundation – were insufficient to raise a triable issue of fact.
 
In August 2006, Plaintiff underwent an aortic valve replacement surgery performed by Defendant using a bioprosthetic replacement valve. While recovering from surgery, plaintiff contracted a MRSA infection and underwent an aortic root replacement surgery, during which the bioprosthetic valve was replaced with a homograft valve. In January 2007, plaintiff underwent a further aortic valve and root replacement surgery performed by defendant using a homograft valve. Plaintiff suffered a stroke later that year. Plaintiff brough this action for medical malpractice, alleging that defendant was negligent in discontinuing aspirin therapy after his third surgery which led to his stroke.
 
Defendant moved for summary judgment and submitted an expert affirmation which provided it was appropriate for him to discontinue the aspirin therapy, and that this discontinuation was not related to plaintiff’s stroke. In opposition, plaintiff’s experts in cardiology and vascular neurology opined that defendant violated the standard of care by discontinuing aspiring therapy. However, plaintiff’s expert opinions were based on their incorrect assumption that plaintiff underwent three bioprosthetic valve replacement procedures, whereas the record established that the two subsequent surgeries utilized homograft valves. As such, plaintiff’s expert opinions were unsupported by any evidentiary foundation and were insufficient to raise a triable issue of fact. Therefore, defendant’s motion for summary judgment was granted, dismissing that cause of action.
 
 
February 17, 2022                   Duvernoy v. CNY Fertility, PLLC
Appellate Division, Third Department
Plaintiff's failure to file a certificate of merit with the complaint required in a medical malpractice action pursuant to CPLR 3012-a does not warrant dismissal.
 
Plaintiff commenced this medical malpractice action against defendant following a fertility procedure.  The trial court granted defendant’s motion to dismiss after the case had languished without significant discovery.  The Third Department overturned finding that dismissal was not appropriate when defendant failed to cooperate in plaintiff’s efforts to advance discovery.  The Appellate Division further addressed the trial court’s alternative ruling that plaintiff's failure to file a certificate of merit with the complaint required in a medical malpractice action pursuant to CPLR 3012-a was a further basis for dismissal.  Here, plaintiff's attorney filed an alternative certificate with the complaint that he was unable to timely procure the required consultation in view of the impending statute of limitations in accord with CPLR 3012-a(a)(2). In such an instance, the certificate of merit must be filed within 90 days of commencement, a deadline that plaintiff also did not meet.  The Court noted that plaintiff expressly identified a medical expert in discovery responses, and plaintiff's counsel explained that the failure to file the certificate of merit was an oversight, i.e., basic law office failure, and further affirmed that he duly consulted with the physician in accord with the requirements of CPLR 3012-a(a)(1). The Third Department held that mere failure to meet the deadline for filing the certificate of merit does not require a dismissal of the action. 
 

March 18, 2022                       Poreba-Gier v. Suddaby
Appellate Division, Fourth Department
Lack of informed consent cause of action cannot survive absent proximate cause of injury from disputed procedure.
 
In this medical malpractice and lack of informed consent action seeking damages for injuries allegedly sustained by plaintiff as a result of defendant's insertion of a paddle lead stimulator in her spine for pain relief, defendant had previously been granted summary judgment dismissing the medical malpractice cause of action, but summary judgment was denied with respect to the informed consent cause of action. After additional discovery, defendant moved to renew his motion for summary judgment, arguing, inter alia, that the informed consent cause of action should be dismissed because the alleged lack of informed consent was not a proximate cause of any injury.

To establish a cause of action for malpractice based on lack of informed consent, [a] plaintiff must prove (1) that the person providing the professional treatment failed to disclose alternatives thereto and failed to inform the patient of reasonably foreseeable risks associated with the treatment, and the alternatives, that a reasonable medical practitioner would have disclosed in the same circumstances, (2) that a reasonably prudent patient in the same position would not have undergone the treatment if he or she had been fully informed, and (3) that the lack of informed consent is a proximate cause of the injury.  Here, defendant established that plaintiff did not sustain any injury from the disputed treatment and that the treatment did not aggravate or exacerbate plaintiff's presurgical symptoms, and opposition, plaintiffs failed to raise a triable issue of fact. 
 

March 11, 2022    Smith v. Williamsville Suburban Nursing Home.
Appellate Division, Fourth Department
Defendant nursing home must disclose a copy of decedent’s certified chart at no cost to plaintiff.
 
Without discussion, the Fourth Department affirmed the order of the trial court granting the motion of plaintiff to compel defendant Williamsville Suburban Nursing Home to disclose a copy of decedent’s certified chart at no cost to plaintiff.

 

 

Hurwitz & Fine, P.C.
 
Buffalo
1300 Liberty Building, Buffalo, NY 14202
Phone: 716-849-8900, Fax: 716-855-0874

Long Island
575 Broadhollow Road, Melville, NY 11747
Phone: 631-465-0700, Fax: 631-465-0313

Additional Offices
Albany | Albion | Amherst | Connecticut | Niagara Falls | Palm Beach Gardens | Rochester | Toronto
 
Hurwitz & Fine, P.C. is a full-service law firm providing legal services
throughout the State of New York
 
www.hurwitzfine.com
© 2022, Hurwitz & Fine, P.C. All Rights Reserved

In some jurisdictions, newsletters such as this may be considered Attorney Advertising.

 

Copyright © 2022, Hurwitz & Fine, P.C., All rights reserved.

Our mailing address is:
1300 Liberty Building, Buffalo, NY  14202

Newsletter Sign-up

Fill in the form to register to receive any of our free electronic newsletters: