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A Cautious Reminder When Responding to a Rule 19-a Statement of Material Facts on a Motion for Summary Judgment

Although discretionary, it is well-known among commercial practitioners that the Commercial Division justices generally like a Rule 19-a statement of material facts included with the submission of a summary judgment motion....more

The Proof Is in the Note: Commercial Division Holds a Heter Iska is Not Outside Proof for Purposes of Summary Judgment in Lieu of...

As many practitioners are aware, the litigation process in New York often feels like a tortoise race, with many cases taking years to resolve. Section 3213 of the CPLR (“Summary Judgment in Lieu of Complaint”) is a bit of an...more

A Wave of E-Discovery Change: The Latest Proposal from the Advisory Council

New York’s Commercial Division has continuously taken the lead as an innovative forum, proposing rule changes that are aimed at increasing efficiency and overall effectiveness of the litigation process. ...more

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