Under CPLR §§ 3111 and 3122(d), “[t]he reasonable production expenses of a non-party witness shall be defrayed by the party seeking discovery.” The Commercial Division Rules at Appendix A (“Guidelines for the Discovery of...more
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
An important, recent development relating to CVA litigation in New York City will have a significant impact on how these cases are prosecuted. On September 18, 2020, Judge George J. Silver—who oversees all pretrial matters...more
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