Samy Rizk Et Al. v. Noel L. Cohen Et Al‪.‬

[73 N.Y.2d 98 Page 100] Opinion OF THE COURT In this appeal, we once again address the doctrine of continuous treatment, which was first established
in Borgia v City of New York (12 N.Y.2d 151) and was later codified in CPLR 214-a.1 We hold that the requirements of that
doctrine are, as a matter of law, not satisfied when there has been mere reliance on a diagnosis, combined with subsequent
doctor-initiated contact after an extended period with no physician-patient contact and the absence of objective factors indicating
that this period had been expressly contemplated by the parties.