On March 22, 2022, the First Department issued a decision in 514 W. 44th St., Inc. v. Whalen, 2022 NY Slip Op. 01958, holding that a trial court was justified in striking a deposition transcript errata sheet because the changes were insufficiently justified, explaining:
The errata sheet was properly stricken, because it made substantive changes to material testimony and the reasons stated for those changes were not sufficient.
(Internal citations omitted).