KRAYCAR v. MONAHAN


49 A.D.3d 507 (2008)

856 N.Y.S.2d 123

TIMOTHY KRAYCAR, Respondent, v. THOMAS C. MONAHAN et al., Appellants.

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

Decided March 4, 2008.


Ordered that the order is reversed, on the law, with costs, and the plaintiff's motion is denied.

It is well settled that a supplemental bill of particulars may be used for purposes of updating "claims of continuing special damages and disabilities" (CPLR 3043 [b]), but may not be used for adding new injuries or damages (see Kyong Hi Wohn v County of Suffolk, 237 A.D.2d 412 [1997]; Sagar v Khun Y. Son,

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