WOLFER v. 184 FIFTH AVE. LLC


27 A.D.3d 280 (2006)

811 N.Y.S.2d 45

JACQUELYN WOLFER et al., Appellants, v. 184 FIFTH AVE. LLC et al., Respondents.

Appellate Division of the Supreme Court of the State of New York, First Department.

March 14, 2006.


Since plaintiffs' first and second verified supplemental bills of particulars alleged new injuries and additional economic damages, the court correctly identified them as "amended," rather than "supplemental," bills, which could not be properly served without leave of court after the note of issue had been filed 1½ years earlier (CPLR 3042 [b]; see Licht v Trans Care N.Y., 3 A.D.3d 325 [2004]; Kassis v Teachers Ins. &...

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