Mogollon v. South African Marine Corp.
Opinion of the Court
In a negligence action to recover damages for personal injuries, defendant appeals from an order of the Supreme Court, Kings County, dated May 29, 1980, which granted plaintiff’s motion for a protective order vacating defendant’s notice to take the examination before trial of three witnesses whose names had been supplied by plaintiff. Order reversed,
Dissenting Opinion
dissents and votes to affirm the order, with the following memorandum: The majority holds that since the testimony of the nonparty witnesses in question was characterized by plaintiff as “critical”, and since defendant’s attorney claimed that he must depose these witnesses in order adequately to prepare for trial, defendant demonstrated “adequate special circumstances” to justify the examination of these witnesses before trial under CPLR 3101 (subd [a], par [4]). The convergence of these two factors, i.e., the “critical” nature of the evidence and its necessity for trial preparation by opposing counsel, appears to be the point upon which the majority’s decision turns. It is this convergence that is viewed as “adequate special circumstances” under the statute, so as to justify deposing the nonparty witnesses. I must observe, however, that the testimony of any nonparty witness which is deemed necessary and material to a party’s case will be deemed “critical” evidence. Moreover, any competent attorney, who is aware of the intended production of a witness at trial, will easily be able to state, in all good faith, that in order to adequately prepare his case, he must examine that witness before trial. This assertion and the characterization of the evidence sought as “critical”, without more, can hardly satisfy the statutory requirement of “adequate special circumstances”. (Cf. Kelly v Shafiroff, 80 AD2d 601, wherein defendant-appellant sought to depose plaintiff-respondent’s wife, obviously a potentially hostile witness.) In Cirale v 80 Pine St. Corp. (35 NY2d 113, 116), the Court of Appeals recognized the mandate of full disclosure contained in CPLR 3101, but pointed out the limiting
Case-law data current through December 31, 2025. Source: CourtListener bulk data.