Pillco v. 160 Dikeman St., LLC
The Appellate Division, Second Department, affirmed an order denying plaintiff Fabian Pillco's motion for summary judgment on liability under Labor Law § 240(1) in a personal injury action. The core issue was the admissibility of the plaintiff's medical record statement describing the accident, which differed from his deposition testimony. The court held that the statement, recorded by Dr. Daniel Khaimov at Precision Pain, was germane to diagnosis and treatment, thus admissible under the business records exception. This created a triable issue of fact regarding the accident's occurrence, despite the plaintiff being the sole witness. The decision provides guidance on the admissibility of patient statements within medical records when relevant to medical care.