Practice point: Without leave of court, plaintiff may serve a supplemental bill of particulars alleging continuing special damages, as long as it does not allege a new injury.
Practitioners should note that such a pleading is a supplemental bill, and not an amended bill.
Case: Maraviglia v. Lokshina, NY Slip 09624 (2d Dept. 2009)
The opinion is here.
Tomorrow’s issue: Motion practice.
