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S.D.N.Y.Procedural orderFiled Feb. 2, 2024

Prophete v. New York City Health and Hospitals

Judge
Ronnie Abrams
Docket
1:23-cv-11117
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedureCivil Rights
In one sentence

In Prophete v. New York City Health and Hospitals, Judge Abrams granted an application assigning HHC to identify the unnamed defendants.

Who this affects

The order affects the plaintiff, NYC Health + Hospitals, the unidentified doctors at Metropolitan Hospital, and the New York City Law Department. HHC must identify and provide service information for the Doe defendants, and the plaintiff must later file an amended complaint naming them.

What happened

In Prophete v. New York City Health and Hospitals, the plaintiff alleged that doctors at Metropolitan Hospital denied him food and water for 24 hours and denied him mental-health treatment. The defendants included the hospital and doctors whose names were not yet known.

The court had previously directed New York City's Law Department to identify the unnamed doctors and provide addresses for service. The Law Department explained that the hospital is part of New York City Health + Hospitals, a separate legal entity, and asked to be relieved of that responsibility.

Judge Ronnie Abrams granted the application. The order directs New York City Health + Hospitals, officially called the New York City Health and Hospitals Corporation, to identify the unnamed defendants and provide the information to the plaintiff within 60 days. The plaintiff must file an amended complaint naming those defendants within 30 days after receiving the information.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Prophete v. New York City Health and Hospitals · No. 1:23-cv-11117
Judge
Ronnie Abrams
Date
Feb. 2, 2024

Background

The plaintiff alleged that doctors at Metropolitan Hospital denied him food and water for 24 hours and denied him mental-health treatment. The complaint named Metropolitan Hospital and unidentified doctors, referred to as Doe defendants.

Application concerning defendant identification

The court had previously ordered the New York City Law Department—which represents the City of New York—to determine the identities and service addresses of the Doe defendants. The Law Department explained that the City was not a named defendant. It also stated that NYC Health + Hospitals, of which Metropolitan Hospital is a member, is legally separate from the City and that the Law Department did not represent the defendants in this action. The Law Department asked to be relieved of its obligations under the prior order and said it had forwarded the complaint and service order to H+H's legal division.

Ruling

Judge Ronnie Abrams granted the application. The order relieves the New York City Law Department of the identification responsibility and directs New York City Health + Hospitals—officially, the New York City Health and Hospitals Corporation—to determine the identities of each Doe defendant and the addresses where they may be served. HHC must provide that information to the plaintiff within 60 days of the order. Within 30 days after receiving the information, the plaintiff must file an amended complaint using the defendants' real names. The clerk was directed to mail HHC the order, complaint, and prior service order, and to mail the plaintiff a copy of the order. This order addressed the process for identifying and serving defendants; it did not decide whether the plaintiff's allegations were legally valid.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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