In IAV Med. Supply, Inc. v. Progressive Ins. Co., 26 Misc. 3d 1237[A], 907 N.Y.S.2d 100, 2010 NY Slip Op 50433[U], 5 [NY Civ. Ct. Mar. 15, 2010], the Court relied on the standard set forth in Bronx Expert, and held that a substitute peer doctor was permitted to testify when there were no documents in evidence because the witness would be subject to cross-examination and his testimony would be limited to the original peer review reports. IAV Medical allowed the testimony by relying on the fact that the peer reports had been submitted to the Plaintiff prior to trial as part of a summary judgment motion and expert disclosure, however the court did not address hearsay concerns. When the peer report and/or underlying medical records have not been stipulated into evidence, Defendant must overcome Plaintiff's hearsay exception in order to elicit testimony from the expert witness.