Madison v. Sama
This case involves a medical malpractice action where the defendants sought to preclude the plaintiff from presenting evidence on new theories of liability. The Supreme Court, New York County, affirmed the denial of the defendants' preclusion motion. Previously, a motion for further deposition of the defendant doctor on a new theory of excessive blood loss was granted by the motion court, which also directed an amended bill of particulars. However, that prior decision was reversed on appeal because the plaintiff did not establish 'unusual or unanticipated circumstances' for further discovery. The current decision clarified that the prior appellate order did not determine the propriety of the motion court’s sua sponte directive for an amended bill of particulars, thus not mandating preclusion under the law of the case doctrine. The court also found no improvident exercise of authority in deferring to the trial court for expert testimony limitations.