v. Jeckovich, 103 A.D.2d 632, 481 N.Y.S.2d 545, 546-47 (4th Dep't 1984) (reversing the trial court’s grant of remittitur on a jury award of $500,000 for a plaintiff who sustained minor physical injuries and an “acute psychotic breakdown” resulting from a car accident) (citing McCahill v. New York Transp. Co., 201 N.Y. 221, 94 N.E. 616 (1911)); cf. Steinhauser v. Hertz Corp., 421 F.2d 1169, 1172 (2d Cir.1970) (Friendly, /.) (reversing a verdict in defendant's favor on the ground that the plaintiff’s theory of the case — that a defendant is liable for the emergence of schizophrenia resulting from the emotional trauma suffered by a passenger in a minor car accident caused by the defendant— is legally valid); Williams v. Bright, 230 A.D.2d 548, 658 N.Y.S.2d 910, 912 n. 2 (1st Dep’t 1997) (<HOLDING>). 6 . Stampf testified that she attended
recognizing that the eggshell skull doctrine is traditionally applied to a plaintiffs preexisting physical condition mental illness or psychological disability internal citations omitted holding that rule 35 does not permit sweeping examinations of a party who has not affirmatively put into issue his own mental or physical condition by asserting his mental or physical condition either in support of or in defense of a claim and that mere relevance to the case is insufficient holding that treatment for symptoms of undiagnosed multiple sclerosis activated the preexisting condition exclusion and stating that there is no requirement that a diagnosis definite or otherwise of the preexisting condition must be made during the preexisting condition period holding that emotional distress requires a showing of either physical symptoms or mental illness holding that a mental illness limitation limiting the maximum payment for care of mental illness or care of nervous conditions of any type or cause is ambiguous because the plan contains no definition or explanation of the term mental illness  and thus construed against the insurance company does not include physically based illnesses