The action is for services said to have been performed under an alleged oral contract. One of the three grounds assigned by Special Term for denial of permission to amend was, citing CPLR 3025 (subd. [b]) that the matter proposed to be added was neither "additional" nor "subsequent." The quoted words of limitation apply to supplemental material, but not to an amendment. As to alleged delay in seeking to amend, it is disclosed that the application followed closely upon the...
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