In June, 1988, plaintiff commenced a medical malpractice action against defendant Daniel J. Wainer, M.D. (Wainer). Issue was joined by said defendant in July of 1988. Thereafter, a preliminary conference order directed that all depositions be completed by September 26, 1989 and that all third-party practice be completed thirty days after the final witness had been examined. Depositions were taken between July 26, 1989 and January 9, 1991. Plaintiff then filed a certificate...
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