Flores v New York City Hous. Auth.,
“Since a bill of particulars is not a disclosure device but a means of amplifying a pleading (see id. at 335-336), the present dispute over the contents of the plaintiff’s bill of particulars is not “part of any disclosure procedure” (CPLR 3104[a]) that CPLR 3104 authorizes a referee to supervise”
This one is interesting.