Munzer v. Blaisdell

Plaintiff, who is not an attorney, but appears pro se, has included in one complaint four possible causes of *11action — (1) for damages for breach of section 84 of the Mental Hygiene Law; (2) for damages for breach of section 352 of the Civil Practice Act; (3) for damages for libel for allegedly false statements in the letter of December 24, 1938; and (4) a cause of action for another alleged libel in the publication of statements in the so-called hospital summary. The last cause of action is clearly insufficient as plaintiff fails to set forth the words constituting the alleged libel. (Locke…