Tai Tran v. New Rochelle Hosp. Med. Ctr

In Tai Tran v. New Rochelle Hosp. Med. Ctr., 99 N.Y.2d 383, 786 N.E.2d 444, 756 N.Y.S.2d 509 (2003), the Court of Appeals held that CPLR 3101 (i) "requires full disclosure with no limitation as to timing, unless and until the Legislature declares otherwise" (id. at 389-390). Although the Court of Appeals recognized the possibility that disclosure prior to depositions might lead to deposition testimony which is tailored to respond to material disclosed, it concluded that the Legislature was aware of the risk and that the Legislature decided that full disclosure prior to depositions was more important than the risk of tailored deposition testimony (id.)