In assigning liability, how many degrees of separation can there be as between the surgeon and the hospital?

Three days after having been admitted to the hospital, plaintiff was referred to an attending vascular surgeon, who treated her and performed an unsuccessful saphenous vein bypass. In Cunningham v. St. Barnabas Hosp., decided on January 30, 2007, the First Department affirmed that "the hospital is not liable for the acts of the private attending physician." Nor does liability run to a hospital resident who "merely assisted" and took orders from the operating surgeon.