Lewis v New York City Tr. Auth.

Holding The Appellate Division reversed the lower court’s order compelling the production of the driver’s personnel file and policy manuals, finding them irrelevant under respondeat superior. It also modified the order to deny the plaintiff’s motion to compel additional depositions, as the plaintiff failed to demonstrate that existing witnesses were inadequate or that new witnesses possessed material information.

The court’s words

a party is not entitled to unlimited, uncontrolled, unfettered disclosure

2026 NY Slip Op 05175, at the official text

the essential test is usefulness and reason

2026 NY Slip Op 05175, at the official text

unsubstantiated bare allegations of relevancy are insufficient to establish the factual predicate regarding relevancy

2026 NY Slip Op 05175, at the official text

the plaintiff failed to demonstrate that the witnesses who had already testified on behalf of the defendants had insufficient knowledge or were otherwise inadequate

2026 NY Slip Op 05175, at the official text