DEMIR v. SANDOZ INC.

4952, 150954/15.

155 A.D.3d 464 (2017)

65 N.Y.S.3d 9

2017 NY Slip Op 07961

ADA DAMLA DEMIR, Respondent, v. SANDOZ INC. et al., Appellants.

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

Decided November 14, 2017.


The court properly applied the relation back doctrine (CPLR 203 [f]) to plaintiff's whistleblower claim pursuant to Labor Law § 740, which requires such actions to be commenced within one year of the alleged retaliatory action (Labor Law § 740 [4] [a]). Although that claim was not asserted until the second amended complaint, filed on October 19, 2015, more than one year after her termination on February 4, 2014, the original complaint, filed on January 31, 2015...

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