Bongiovanni v. Staten Is. Medical Group

In Bongiovanni v. Staten Is. Medical Group, (188 Misc. 2d 362), Justice Joseph J. Maltese of Richmond County Supreme Court held that "any application for a setoff utilizing a collateral source of payments must be either requested verbally immediately after the jury renders a verdict which includes loss of earnings, or as part of the written single posttrial motion contemplated by CPLR 4406 which shall be made within 15 days of the jury verdict in accordance with CPLR 4405."