In Vanalst v. City of New York (276 AD2d 789 [2d Dept 2000]) the Appellate Division, Second Department ruled that records of prior treatment or injury to a body part that was not at issue in the lawsuit were discoverable, because the plaintiff asserted a claim for loss of enjoyment of life for the injuries at issue. In Vanalst, the plaintiff alleged that he suffered an injury to his left knee, and the Appellate Division, Second Department ruled that defendants were entitled to records of plaintiff's previous back injuries. The Appellate Division reasoned, "The nature and severity of the plaintiff's previous back injuries may have an impact upon the amount of damages, if any, recoverable for a claimed loss of enjoyment of life because of his current knee injury. Therefore, the requested records and reports are material and necessary to the defense, and the Supreme Court erred in denying that branch of the appellant's cross motion which was for disclosure." (Vanalst, 276 AD2d at 789.)