Moore v. County of Rockland

In Moore v. County of Rockland, 192 AD2d 1021, 596 N.Y.S.2d 908 (3rd Dept. 1993), the plaintiff asserted in her complaint that the defendant had caused her intentional emotional distress, a theory not stated in her Notice of Claim. The court barred this new theory stating that the Notice of Claim "did not give adequate information to alert defendants to investigate the cause of action." Id at 1023.