Fernekes v. Catskill Regional Medical Center
Plaintiff initiated an action alleging assault by a fellow patient, 'John Doe,' at Catskill Regional Medical Center (CRMC). The core dispute involved plaintiff's motion to compel discovery, specifically an incident report authored by nurse Barbara Blume and a deposition of incident coordinator Ann Korabik. The Supreme Court granted plaintiff's motion, ordering the disclosure of the report and Korabik's deposition. CRMC appealed, asserting the incident report was privileged under Public Health Law § 2805-Z and that this privilege was not waived by an employee's review. The appellate court affirmed the order for Korabik's deposition but reversed the disclosure of Blume's incident report, ruling that internal review did not constitute a waiver of privilege. The case was remitted to the Supreme Court for an in camera review to determine the report's privilege status under Public Health Law § 2805-Z.