In Thomsen v. Suffolk County Police Dept., 50 AD3d 1015 [2nd Dept 2008] the Appellate Division stated: "Contrary to the Supreme Court's determination, however, the plaintiffs' failure to name individual police officers...in the proposed amended complaint did not render it totally devoid of merit or palpably insufficient as a matter of law , nor does the expiration of the applicable statute of limitations bar the proposed amendment Under the 'relation back' doctrine, a plaintiff may be permitted to correct a pleading error by adding a new party united in interest with the previously-named defendants where the statute of limitations has expired ."