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CPLR

Farrell Fritz, P.C.

Choose Your Forum Wisely (Part II): Commercial Division Reiterates the High Bar to Overturn an Arbitration Award

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Last fall, I blogged about the challenges of overturning an arbitrator’s award (check out that post here). That case illustrated the difficulties of vacating an award based on a purported erroneous ruling of law. But what if...more

Cadwalader, Wickersham & Taft LLP

Bartelby the Scrivener Strikes Again

In a recent decision by the Supreme Court of the State of New York (the “Court”), Big City Outdoor, LLC (“Plaintiff”) was denied summary judgment in a contract dispute arising from a 2017 lease agreement for advertising...more

Freiberger Haber LLP

The Second Department Applies the Relation-Back Doctrine to Add a Party to a Foreclosure Action More than a Decade after...

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Today’s BLOG deals with the “Relation-Back Doctrine” (the “Doctrine”)[1], which, inter alia, “allows a claim asserted against a defendant in an amended filing to relate back to claims previously asserted against a codefendant...more

Farrell Fritz, P.C.

Broad But Not Boundless: Policing the Edge of Discovery and Protecting Client Lists in Slice Wireless Services, LLC v. Yakubov, et...

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A recent decision from the New York County Commercial Division reminds litigants that even under New York’s liberal discovery standards, sensitive business information like client lists is not automatically discoverable. In...more

Farrell Fritz, P.C.

Technical Difficulties Aren’t Enough: A Lesson from the Commercial Division

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Every litigator has experienced a technology hiccup at an inconvenient moment. But courts have made clear that vague references to “technical difficulties” will not excuse a failure to appear—and once a default judgment is...more

Freiberger Haber LLP

CPLR 322(a) Permits a Defendant to Demand Proof of Plaintiff’s Counsel’s Authority to Commence an Action Affecting Title to Real...

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Regular readers of this BLOG know that we frequently write about issues affecting title to real property -- such as mortgage foreclosure, specific performance of real estate transactions and quiet title actions...more

Farrell Fritz, P.C.

One Line Too Few: How Noncompliance with Recently Amended CPLR 2106 Undermines an Affirmation

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Rule 2106 of the CPLR permits a written affirmation, made under penalty of perjury, to be submitted in place of an affidavit, carrying the same legal effect in New York civil proceedings. Since the amendment took effect on...more

Ropers Majeski

No Duty to Third Parties: Second Department Dismisses Claim Against Streetlight Contractor

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In an April 8, 2026, decision, the Appellate Division, Second Department, in Weiss v. Fran Corp., 2026 NY Slip Op 02147, reversed the lower Court and dismissed a personal injury complaint against a contractor retained to...more

Ropers Majeski

Catastrophe Avoided—But Perils Remain: The Real Impact of the Amended AVOID Act

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8 Recently, we wrote about new legislation in New York known as the AVOID Act. At the time, the statute—as originally enacted—promised sweeping and rigid changes to third-party practice, particularly in New York Labor Law...more

Freiberger Haber LLP

Context Matters: Post-Arbitration Award Discovery Based on Fraud Under CPLR 408

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New York limits judicial intrusion into arbitration awards, reflecting the core principles of finality, deference to arbitrators’ rulings, and the narrow grounds for vacatur under CPLR 7511. In Shell NA LNG LLC v. Venture...more

Cadwalader, Wickersham & Taft LLP

Money Talks March 2026 - Money, Money, Money, Money... Money: Motion for Summary Judgment in Lieu of Complaint

In TSLA Capitals, S.A.P.I. de C.V. v. ATL Funds, LLC (“TSLA Capitals”), the Court granted summary judgment in lieu of complaint under CPLR 3213 on a partially paid promissory note exceeding $24MM. The decision offers a useful...more

Cohen Seglias Pallas Greenhall & Furman PC

The AVOID Act: A Fundamental Shift in New York Construction Litigation

On December 19, 2025, Governor Kathy Hochul signed the “Avoiding Vexatious Overuse of Impleading to Delay” (AVOID) Act, ushering in one of the most significant changes to New York third-party practice in recent years. The...more

Sheppard, Mullin, Richter & Hampton LLP

New York Moves to Tighten Third-Party Practice: Key Changes to CPLR 1007

Effective April 18, 2026, the New York Legislature enacted the Avoiding Vexatious Overuse of Impleading to Delay (“AVOID”) Act, amending CPLR 1007—the statute that governs third-party practice. The amendment sharply limits...more

Farrell Fritz, P.C.

Patiently Waiting for Proper Service: Commercial Division’s Latest Word on Service and Default Judgment Practice

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When seeking a default judgment, parties often assume that an unanswered complaint puts them in the driver’s seat for a quick and early victory. But as practitioners in the Commercial Division are well aware, courts retain...more

Goldberg Segalla

Update: Insurance Carriers Impacted by Compressed Impleader Deadlines in New York’s New AVOID Law

Goldberg Segalla on

In December 2025, Governor Kathy Hochul signed into law S.8071‑A, known as the “Avoiding Vexatious Overuse of Impleading to Delay (AVOID) Act.” This law amends CPLR §1007 to establish strict time limits for impleading...more

Marshall Dennehey

New York’s AVOID Act Imposes Strict Deadlines on Third-Party Actions Starting April 2026

Marshall Dennehey on

On December 19, 2025, Governor Kathy Hochul signed the Avoiding Vexatious Overuse of Impleading to Delay (AVOID) Act (L. 2025, ch. 704), amending CPLR § 1007 to impose, for the first time, strict deadlines on third-party...more

Seyfarth Shaw LLP

The AVOID Act: A New Timeline for Liability in New York Construction Projects

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By April 18, 2026, New York construction litigation will operate on a faster—and far less forgiving—timeline. The Avoiding Vexatious Overuse of Impleading to Delay (the “AVOID Act”), signed into law on December 19, 2025,...more

Rivkin Radler LLP

AVOID Act Limits Time Period to Initiate Third-Party Complaints

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On December 19, 2025, Governor Hochul signed the Avoiding Vexatious Overuse of Impleading to Delay (AVOID) Act into law. The law amends CPLR Section 1007 to impose strict time limits on the commencement of third-party...more

Hinshaw & Culbertson - Employment Law...

New York’s AVOID Act Impacts Third-Party Action Practice: Could it Do More Harm than Good?

“Aegrescit Medendo,” Virgil: Aeneid Book XII. That is: Sometimes healing makes the situation worse. On December 19, 2025, New York Governor Kathy Hochul signed the AVOID Act (“Avoiding Vexatious Overuse of Impleading to...more

Freiberger Haber LLP

Court Denies Motion for Summary Judgment in Lieu of Complaint Because Note and Related Asset Purchase Agreement Were “Inextricably...

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In today’s BLOG article, we again discuss summary judgment in lieu of complaint pursuant to CPLR 3213, which provides, in relevant part: When an action is based upon an instrument for the payment of money only or upon...more

Freiberger Haber LLP

The First Department Holds, as a matter of First Impression, that a Party’s Attendance at a Mandatory Settlement Conference...

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This BLOG has previously addressed the issue of a defendant’s appearance in an action – both formal and informal. In that regard, we have noted that it makes sense that a “plaintiff appears in an action merely by bringing...more

Epstein Becker & Green

An Update on “Unsworn” Attorney Affirmations Under the New CPLR 2106: Recent Rulings Offer a Path to Cure

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As previously reported on June 3, 2024, the January 1, 2024 amendments to CPLR 2106 revised the statutory language required for attorney affirmations in New York....more

Farrell Fritz, P.C.

You’ve Got Mail (But No Deal) — Commercial Division Denies Enforcement of Settlement Based on Email Exchange

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Background Manhattan Commercial Division Justice Robert R. Reed recently refused to enforce a settlement agreement purportedly reached by the parties via email in CoPilot Travel, Inc. v. Magstar Capital, LLC, 86 Misc. 3d...more

Chartwell Law

Front-Loaded Impleader: How the AVOID Act Reshapes Risk Transfer Litigation

Chartwell Law on

Amendment to CPLR § 1007 - New York litigators should take immediate note of a statutory change that significantly restricts the filing of third-party actions. Governor Kathy Hochul has signed into law Bill S8071A/A8728,...more

Sheppard, Mullin, Richter & Hampton LLP

New York Legislature Amends CPLR 2106 To Resolve Lingering Confusion over Affirmation Use

On November 21, 2025, New York State Governor Kathy Hochul signed into law Senate Bill S8195, ushering in a significant clarification to CPLR 2106, which authorizes the use of unsworn (i.e., not notarized) affirmations in...more

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