Over the past 13 years, we have had several occasions to address the burdens of proof of litigants on summary judgment motions in medical malpractice actions. In June 2011, we discussed the Second Department's decision in Stukas v. Streiter, 83 A.D.3d 18 (2^nd Dept. 2011), which made clear that a plaintiff is required to establish an issue of fact as to causation in opposition to summary judgment only if the moving defendant has satisfied its burden on that issue (See Thomas Moore and Matthew Gaier, "Clarification of Summary Judgment Standard," New York Law Journal, June 7, 2011, p. 3).