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Getting Ahead of Discovery: Can Amended Rule 11 Streamline Commercial Litigation?

Frequent readers of this blog know that we are not shy in acknowledging the Commercial Division’s status as the leading forum for resolving complex business disputes. This reputation can be, in part, largely attributed to the...more

“Enough is Enough” Says Commercial Division in Discovery Dispute: Strikes Party’s Pleading

A recent decision from the Manhattan Commercial Division reminds us of the ramifications of non-compliance with discovery obligations. Although in my experience courts (especially the Commercial Division) typically do not...more

Commercial Litigation in New York State Courts, 5th Edition Chapter 39, “Practice Before the Commercial Division”: A Review

As frequent readers of this blog are no doubt aware, the ten-volume practice treatise entitled Commercial Litigation in New York State Courts and edited by distinguished commercial practitioner Robert L. Haig (the “Haig...more

New Supreme Court Rule on Summary Judgment Motions: “Just the Facts, Ma’am”

Practitioners often choose to practice in the Commercial Division because of its well-documented efficiencies.  Thus, many were happy to hear that Chief Administrative Judge Larry Marks issued Administrative Order 270/2020...more

To Redact, or Not to Redact, That is the Question

You now have to collect, review and produce documents pursuant to the preliminary conference order.  And so, in collecting documents from the various custodians, it appears some of the documents contain truly “irrelevant”...more

Remote depositions in the wake of the coronavirus COVID-19 pandemic? Here’s how

The COVID-19 pandemic has had widespread impact on litigation, with some courts and most cases coming to a screeching halt.  Some courts have responded with Orders or rules (Massachusetts Sup. Jud. Ct. Order OE-144 [March 20,...more

Brief Introductory Call with a Law Firm is Not Enough to Disqualify It From Representing Another Party in the Lawsuit

Lawyers often get phone calls from prospective clients seeking guidance on various issues – general legal inquiries, asking a variety of general questions about laws, codes, regulations, and statutes, or questions concerning...more

Litigator's Toolkit: Know the Law, Know the Rules, Know your Judge

We all know that understanding the law is a first step to good lawyering. But understanding what the particular judge assigned to your case likes and dislikes, and her pet peeves is just as important for your success as an...more

Back to Basics: Long-Arm Statute 101

Reflecting on your first year of law school, you begrudgingly remember learning about personal jurisdiction and the long-arm statute. As a commercial litigator, one of your first questions in representing a defendant should...more

Commercial Division Rules in Favor of … “The Junior Associate”

As a junior associate you do research and draft motion papers and yearn for the opportunity to argue your motion before the Court. But junior associates are usually not afforded such opportunities. ...more

Not All “Repeated Discovery Failures” Lead to the Striking of a Pleading

So you entered into a Preliminary Conference and a Compliance Conference Order with your adversary whereby the parties have to exchange discovery by dates certain. The purpose of these orders is to save parties a significant...more

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