In medical malpractice actions, it is the existence of a physician-patient relationship that gives rise to a duty of care owed by the physician, the breach of which is the basis for a cause of action. See McNulty v. City of New York, 100 N.Y.2d 227 (2003); Purdy v. Public Adm'r of Westchester County, 72 N.Y.2d 1 (1988); Pizzo-Juliano v. Southside Hosp., 129 A.D.3d 695 (2d Dept. 2015). The absence of such a relationship usually precludes a malpractice cause of action. Although there are limited circumstances in which a physician will be deemed to owe a duty of care to a non-patient, even in those cases the duty flows from a physician-patient relationship with someone else. See Moore & Gaier, Recent Court of Appeals Decision on Duty to Non-Patients, NYLJ (Feb. 2, 2016), p. 3.