Manhattan Supreme Court Justice Doris Ling-Cohan (See Profile) has reassigned a case to a different special referee after finding that judicial hearing officer Ira Gammerman modified her ruling and veered from court procedures.

"Given that the Special Referee failed to set forth the basis for his ‘recommendations,’ this court is unable to evaluate the appropriateness of such ‘recommendations,’ on the limited and disputed record now before the court," Ling-Cohan wrote in Steven J. Kaye Associates v. The Law Offices of Mitchell N. Kay PC, 601443/2008.