Kaczynski v. Anderson

Pursuant to orders dated February 7, 2007, and February 23, 2007, this Court convened this special panel under MCR 7.215(J)(3) to resolve the conflict between our decision in Apsey v Mem Hosp (On Reconsideration), 266 Mich App 666; 702 NW2d 870 (2005), rev’d 477 Mich 120 (2007), and our later decisions in Kaczynski v Anderson, 274 Mich App 49; 731 NW2d 442 (2007), vacated in part 274 Mich App 801 (2007), and White v Barbara Ann Karmanos Cancer Institute, 274 Mich App 801 (2007), concerning whether an affidavit of merit that is notarized by an out-of-state notary public is invalid if it is not…