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Litigation Strategies CPLR

Freiberger Haber LLP

Res Judicata Barred Subsequent Action To Quiet Title Because It Involved Essentially The Same Causes of Action As Asserted In An...

Freiberger Haber LLP on

Previously, this Blog examined the doctrine of res judicata (here, here, here and here). Under the doctrine, a party may not litigate a claim where a judgment on the merits exists from a prior action between the same parties...more

Farrell Fritz, P.C.

Hybrid Highlights: Avoiding the Pitfalls of a Land Use Litigation Technique

Farrell Fritz, P.C. on

All civil judicial proceedings must be in the form of an action – unless otherwise authorized by statute, i.e. in the form of a special proceeding (see CPLR 103[b]). While most lawsuits are brought solely in the form of...more

Freiberger Haber LLP

The Stress of Bar Association Activities Sufficient to Support the Defense of Law Office Failure

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Now and then a lawyer fails to meet a deadline or otherwise acts untimely. Several “saving” provisions in the Civil Practice Law and Rules (“CPLR”) are available to assist a lawyer when deadlines are missed. These include:...more

Farrell Fritz, P.C.

The Cost of Withholding ESI: First Department Sets Limits on Non-Party Recovery of ESI Production Costs

Farrell Fritz, P.C. on

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

Freiberger Haber LLP

Collateral Estoppel Held Not To Bar Later-Filed Malpractice Action

Freiberger Haber LLP on

In Villaver v. Paglinawan, 2024 N.Y. Slip Op. 04159 (2d Dept. Aug. 7, 2024) (here), the Appellate Division, Second Department reversed the dismissal of a legal malpractice, breach of fiduciary duty, and intentional infliction...more

Epstein Becker & Green

“Unsworn” Attorney Affirmations: Overlooked Side Effect of Changes to CPLR 2106

By now, most New York practitioners are aware (or at least have heard) of the recent changes to CPLR 2106, which was amended as of January 1, 2024 to allow “any person” to submit an affirmation “in lieu of and with the same...more

Farrell Fritz, P.C.

Injunction Junction, What’s Your Function?

Farrell Fritz, P.C. on

Commercial litigants often seek the provisional and equitable remedy of a preliminary injunction under Article 63 of the CPLR to protect the client’s rights that are difficult to monetize and quantify. The relief sought...more

Freiberger Haber LLP

Conspiracy Theory Jurisdiction. Who Knew?

Freiberger Haber LLP on

Section 3211(a)(8) of the Civil Practice Law and Rule (“CPLR”) allows a party to “move for judgment dismissing one or more causes of action asserted against him on the ground that … the court has not jurisdiction of the...more

Farrell Fritz, P.C.

Rule Change Alert: Readability Is Key For Responsive Pleadings Under New Rule 6 (d)

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As practitioners and readers of this blog are aware, responsive pleadings are foundational documents prepared at the earliest stage of a litigation in which the responding party denies, admits, or states that she lacks...more

Farrell Fritz, P.C.

The Evidenceless Petition to Dissolve

Farrell Fritz, P.C. on

It’s hard not to feel sorry for the petitioner in Fernandes v Matrix Model Staffing, Inc., Decision and Order, Index No. 160294/2021 [Sup Ct, NY County Apr. 20, 2022]. In Fernandes, Manhattan Supreme Court Justice Frank...more

Farrell Fritz, P.C.

Updates to Commercial Division Rules Concerning Discovery of ESI

Farrell Fritz, P.C. on

As we approach the 30th Anniversary of New York’s Commercial Division, it’s fair to say that over those 30 years, the Commercial Division has held true to its aim of improving the efficiency and judicial treatment of complex...more

Proskauer - Minding Your Business

New York Broadens the Scope of Admissible Employee Statements

In a seismic change to its evidentiary jurisprudence, New York recently enacted legislation that significantly broadens the admissibility of statements made by a party’s agent or employee....more

Farrell Fritz, P.C.

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

Farrell Fritz, P.C. on

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

Farrell Fritz, P.C.

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

Farrell Fritz, P.C. on

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

Farrell Fritz, P.C.

Defenses and Counterclaims In a CPLR 3213 Action Are Only Successful If They’re “Inseparable”

Farrell Fritz, P.C. on

In one of my previous posts, I discussed the basic requirements for bringing a CPLR 3213 motion for summary judgment in lieu of complaint.  One such requirement (and the one that generates the largest body of case law), is...more

Hinshaw & Culbertson - Consumer Crossroads

New York Court Finds an Action is Timely in Some Circumstances in CPLR 205(a) Decision

The Appellate Division of the New York Supreme Court's First Department recently issued a decision addressing the calculation of the six-month timeframe permitted to file a new action, according to New York's Civil Practice...more

Sheppard Mullin Richter & Hampton LLP

Commercial Division Limits the Reach of New York’s Long-Arm Statute

In Black Diamond Aviation Grp. LLC v. Spirit Avionics, Ltd., 70 Misc. 3d 823 (Sup. Ct. Suffolk Cnty. 2020), Justice James Hudson of the Suffolk County Commercial Division limited the reach of New York’s long-arm statute, CPLR...more

Farrell Fritz, P.C.

NY Practice Tip: Protecting Your Client Against an Improper Notice to Admit

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The CPLR 3123 notice to admit can be a useful device in litigation.  Its primary purpose is to expedite a trial by eliminating the necessity of proving a readily admittible fact or matter not in dispute. ...more

Seyfarth Shaw LLP

CVA Litigation Update: Defendants File a Consolidated Challenge to Confidentiality Order Entered by the Court

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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

Farrell Fritz, P.C.

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

Farrell Fritz, P.C. on

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

Farrell Fritz, P.C.

Pandemic Aftermath: The Rise Of Interstate Depositions And Discovery

Farrell Fritz, P.C. on

With global commerce massively affected by the COVID-19 pandemic, post-pandemic litigation will undoubtedly result in a rise of interstate depositions and discovery. In turn, litigants engaged in actions pending outside of...more

Farrell Fritz, P.C.

Affirmatively Plead Your Defenses, or Risk “Waiving” Them Goodbye

Farrell Fritz, P.C. on

Many litigants are familiar with the well-settled rule that an affirmative defense will be waived if it is not included in a CPLR 3211(a) motion to dismiss or in the answer (see CPLR 3211[e]).   And so, lawyers tasked with...more

Farrell Fritz, P.C.

Three New Rule Amendments Proposed by the Commercial Division Advisory Council

Farrell Fritz, P.C. on

The Commercial Division Advisory Council (the “Advisory Council”) has proposed three new amendments to the Commercial Division Rules: (1) a proposed amendment to Rule 1, which will allow counsel to participate in court...more

Farrell Fritz, P.C.

A Thoughtful Insight into Seeking a Stay of Proceedings

Farrell Fritz, P.C. on

“Should I stay or should I go”, queried the Clash.  Litigators are often faced with the same question, albeit in a far different context.  Most (but certainly not all!) Commercial Division practitioners try to move litigation...more

Farrell Fritz, P.C.

Back to Basics: Long-Arm Statute 101

Farrell Fritz, P.C. on

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

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