In Arons v. Jutkowitz (9 NY3d 393 [2007]) the Court of Appeals approved compelling plaintiffs to issue authorizations to enable defense counsel to informally interview treating physicians noting that article 31 of the CPLR (pretrial disclosure) and part 202 of the Uniform Rules for Trial Courts neither expressly forbid nor permit such interviews as part of pretrial disclosure procedures. Thus, the Court of Appeals approved the issuing of an authorization for a purpose not precisely set forth in the CPLR but to aid in the ultimate discovery of relevant and material evidence for use at trial. The Court of Appeals confirmed that an "attorney may interview an adverse party's treating physician privately where the adverse party has affirmatively placed his or her medical condition in controversy" (Arons v. Jutkowitz, supra., at pp 401-402). A defense attorney who seeks to interview a nonparty treating physician is entitled to receive a HIPAA compliant authorization from the plaintiff, and required to "simply reveal the client's identity and interest, and make clear that any discussion with counsel is entirely voluntary and limited in scope to the particular medical conditions at issue in the litigation" (Arons, supra at p. 410). Court of Appeals emphasized that "physicians remain entirely free to decide whether or not to cooperate with defense counsel" (Arons, supra at p. 416).