4768 In filing a motion to amend a medical malpractice complaint to include a claim for punitive damages as required by Code of Civil Procedure section 425.13, an exception established by Goodstein to the statutory deadline probably does not apply unless fast track rules prevent compliance; the Goodstein exception does not apply in any event unless within the period established by the statutory deadline plaintiff is unaware of facts or evidence that supports the punitive damages claim in spite of diligent and reasonable efforts to discover them.CitationFREEDMAN v SUPERIOR COURT (Puni's Motion) 166 CA4 198 [See: CCP 425.13; CivC 3294; Goodstein v Superior Court 42 CA4 1635, T/AT 4/96]
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