Smith v. Kobasa, M.D.

Summary

The Court affirmed dismissal of Smith’s medical-malpractice complaint because she filed neither an affidavit of merit nor a motion for an extension when she filed the complaint, and her later affidavit was untimely. The Superior Court did not abuse its discretion in denying a second extension because Smith failed to establish good cause, including her claimed inability to obtain complete medical records. Her pro se status did not excuse noncompliance with the statutory requirements or the court’s orders.