In Carroll v. Konits, 400 Md. 167, 929 A.2d 19, the Court of Appeals examined whether an extension could be granted for good cause if the request was made outside the 180-day period. Dr. Konits raised the argument to the Court that the Director did not have discretion to grant Carroll an extension of time because it was not filed within the 180-day period and good cause was not established. He maintained that the Court should therefore not address the propriety of the purported Certificate of Merit. The Court noted that this exact argument was previously rejected by the Court of Appeals and expressly rejected Dr. Konits's argument as well. The Court characterized extensions for good cause as "'malleable,'" noting that they provide "room for the Director's discretion." Id. at 185. Though Carroll did not resolve whether the Director did in fact have good cause to grant the extension, the Court observed: "In accordance with the statutory language and consistent with our prior case law, we believe that the General Assembly made it clear that the good cause extensions are discretionary and without time limitations, so long as the Claimant demonstrates good cause." Id. In Carroll v. Konits, the plaintiffs filed a claim with the HCADRO, naming Dr. Phillip H. Konits and Dr. Efem E. Imoke as defendants. 400 Md. at 171, 929 A.2d at 21. The claim was then transferred to the Circuit Court for Baltimore City where it was dismissed on various grounds, including, but not limited to, Carroll's failure to submit a proper certificate of qualified expert. Id. While on appeal to this Court, the Court of Appeals issued a writ of certiorari on its own motion to determine whether the Circuit Court erred in finding that Mary Carroll's expert witness report and certification were legally sufficient, thereby dismissing the case. The Court of Appeals upheld the dismissal, stating: "Because the certificate is a condition precedent, the Circuit Court for Baltimore City correctly granted the appellees' motion to dismiss the case." 400 Md. at 171, 929 A.2d at 21. Carroll established that the filing of a proper certificate operates as a condition precedent to filing a claim in Circuit Court. This finding was based on the ground that because arbitration is a condition precedent to filing a claim in a Circuit Court, and because the filing of a certificate is an indispensable step in the arbitration process, a proper certificate must be filed or the condition precedent is not satisfied. 400 Md. at 181, 929 A.2d at 28. The Court of Appeals affirmed the circuit court's dismissal of a malpractice action because of a legally insufficient expert witness report and certificate. Id. at 172. The Court held that the "certificate" was a condition precedent to litigating a medical malpractice claim and that such an action should be dismissed if the certificate did not identify with specificity the licensed professionals against whom the claims were brought and state that the defendants breached the standard of care proximately causing the plaintiff's injuries. Id. In a footnote, the Court noted the enactment of CJP 5-119, but said that "the issues now being presented . . . are not affected by this new statute." Id. at 185-86, n.15. The Court described the filing required by CJP 3-2A-04(b) as a condition precedent to the arbitration that is a condition precedent to litigating a medical malpractice claim. The Court made reference to the enactment of 2007 Laws of Maryland Chapter 324, but stated that "the issues now being presented in the case sub judice are not affected by this new statute." Id. at 185-86 n.15.