The Appellate Division Affirms Dismissal

The Appellate Division affirms dismissal of the Complaint obtained by John M. Hockin, Jr., in Kamm v. Pfister! The case involved a claim that the doctor deviated from accepted standards of care and breached a contract related to an Independent Medical Examination. Despite the lack of a doctor/patient relation, the Appellate Division upheld that an Affidavit of Merit was required. As for the breach of contract claim, the Appellate Division affirmed that the claim still required an Affidavit of Merit as the alleged breach still involved an alleged negligence issue.