We hold that a patient's claim against a physician for breach of the fiduciary duty of confidentiality as a result of the physician's unauthorized disclosure of the patient's medical records is subject to the three-year Statute of Limitations for negligence (CPLR 214 [5]), rather than the shorter limitations period for medical malpractice (CPLR 214-a).
On August 6, 1984, plaintiff visited Dr...
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