The motion, made upon the eve of trial, should not have been granted solely upon the affidavit of plaintiff's attorney. On an application of this nature, the moving papers should include an affidavit by plaintiff showing the merits of the case, the reason explaining or excusing the delay in making the motion and facts showing that the increase is warranted. A physician's affidavit should also be submitted, demonstrating with some degree of specificity the nature of plaintiff...
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