Defendant NORTHWELL HEALTH PHYSICIAN PARTNERS, INC., by her attorneys, HEIDELL, PITTONI, MURPHY & BACH, LLP, upon information and belief, answers the Verified Complaint herein as follows:
FOURTEENTH: That as to the cause of action set forth in the complaint based upon alleged failure to obtain an informed consent, defendant pleads the defenses in Public Health Law, Section 2805-d. 2482968.1
FIFTEENTH: That the equitable share of liability, if any, of defendant NORTHWELL HEALTH PHYSICIAN PARTNERS, INC., shall be determined pursuant to the provisions of Article 16 of the CPLR.
NINETEENTH: The amount of alleged damages claimed by plaintiff should be reduced pursuant to CPLR § 4545 to the extent of any collateral source benefits, remuneration or compensation received.
WHEREFORE, defendant NORTHWELL HEALTH PHYSICIAN PARTNERS, INC. demands judgment dismissing the complaint herein, together with the costs and disbursements of this action.