What happens when you have good claims, but fail to enunciate them in the original pleading?  One might guess that you simply file another pleading and include them?  Not that easy.  As Hustedt Chevrolet, Inc. v Jones, Little & Co.  2015 NY Slip Op 04611 [129 AD3d 669]  June 3, 2015
Appellate Division, Second Department demonstrates in an accounting malpractice setting, timeliness plays a part.

“The plaintiffs moved pursuant to CPLR 3025 (b), inter alia, for leave to amend their first amended complaint to supplement the cause of action to recover damages for accounting malpractice. It is undisputed that the plaintiffs’ proposed supplemental claims of accounting malpractice were time-barred (see CPLR 214 [6]). The plaintiffs, however, contend that these proposed supplemental claims relate back to the allegations contained in the accounting malpractice cause of action in the first amended complaint. Contrary to that contention, the allegations in the first amended complaint gave no notice of the facts, transactions, and occurrences giving rise to the proposed supplemental claims of accounting malpractice and thus, the relation-back doctrine does not apply (see CPLR 203 [f]; Fisher v Giuca, 69 AD3d 671, 673 [2010];Pendleton v City of New York, 44 AD3d 733, 736 [2007]; Sabella v Vaccarino, 263 AD2d 451, 452 [1999]; Bergman v Indemnity Ins. Co. of N. Am., 232 AD2d 271 [1996]; Smith v Bessen, 161 AD2d 847, 849 [1990]; Alpert v Shea Gould Climenko & Casey, 160 AD2d 67, 72-73 [1990]). The plaintiffs’ remaining contentions are without merit. Therefore, the Supreme Court properly denied that branch of their motion pursuant to CPLR 3025 (b) which was for leave to amend the first amended complaint to supplement the cause of action to recover damages for accounting malpractice. Mastro, J.P., Chambers, Cohen, Miller and LaSalle, JJ., concur.”