Robles v. Merrill Lynch/WFC/L, Inc.
The Supreme Court, New York County, initially denied the defendants' motion to compel further deposition of the plaintiff's social worker. This decision was subsequently appealed and unanimously reversed by the appellate court. The appellate panel determined that the plaintiff had waived the applicable privilege under CPLR 4508. This waiver occurred because the plaintiff's bill of particulars affirmatively placed her mental condition in issue by alleging related injuries. Consequently, the appellate court granted the defendants' motion to compel the deposition.