News & Analysis as of

Commercial Litigation CPLR

Farrell Fritz, P.C.

Affirmation in Lieu of an Affidavit, Now “with the Same Force and Effect”

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As of January 1, 2024, the amended CPLR 2106 concerning affirmations provides that - [t]he statement of any person wherever made, subscribed and affirmed by that person to be true under the penalties of perjury, may be...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

Farrell Fritz, P.C.

Don’t Forget the Details: How Conclusory Pleadings Can Thwart Nonparty Disclosure

Farrell Fritz, P.C. on

Nonparty subpoenas are a useful discovery tool in commercial disputes. Particularly when the dispute involves access to or control over funds on deposit with a financial institution, the institution’s account statements, and...more

Farrell Fritz, P.C.

Altering a Confession of Judgment? Think Again!

Farrell Fritz, P.C. on

A confession of judgment has often been viewed as an important tool in settling a litigation or finalizing a transaction.  In 2019, the New York State Legislature made some significant amendments to the Confession of Judgment...more

Farrell Fritz, P.C.

No Deceit, No Defeat: Commercial Division Enforces Broad General Release

Farrell Fritz, P.C. on

A recent decision from Justice Fidel Gomez of the Bronx County Commercial Division, 1125 Morris Ave. Realty LLC v Title Issues Agency LLC, reminds us to closely review the language of general releases as New York courts...more

Epstein Becker & Green

New York’s Highest Court Clarifies Law On “Relation Back” and Statute of Limitations

Epstein Becker & Green on

The statute of limitations is a powerful threshold defense for defendants in civil litigation.  Article 2 of New York’s Civil Practice Law and Rules (“CPLR”) and other New York statutory provisions set forth deadlines by...more

White and Williams LLP

New York Civil Practice Will Allow Unnotarized Affirmations Instead Of Affidavits

White and Williams LLP on

Notarized affidavits will not be required for court submissions starting in the new year. As of January 1, 2024, New York CPLR Rule 2106 is amended to permit that an affirmed statement can be used in a New York action...more

Farrell Fritz, P.C.

If the Service Was Poor, You’ll Have to Do More – How Much Diligence Is Due for Affix and Mail Service?

Farrell Fritz, P.C. on

The burden of establishing personal jurisdiction over a defendant rests with the plaintiff. Service of process is a necessary component of jurisdiction, and it is not complete until proof of service is filed. Ordinarily,...more

Farrell Fritz, P.C.

Ready or Not, Here I Come: The Expansion of Substitute Service by Email

Farrell Fritz, P.C. on

The old game of “hide-and-seek” brings many of us back to our childhood as one of our favorite ways to pass time during the summer. As commercial practitioners know, the concept of serving a summons and complaint in a case...more

Farrell Fritz, P.C.

To Disclose or Not to Disclose: The Importance of Putting Everything in Writing

Farrell Fritz, P.C. on

Section 3101(a) of the CPLR provides for the “full disclosure of all matter material and necessary in the prosecution or defense of an action.” This standard requires the disclosure “of any facts which will assist preparation...more

Farrell Fritz, P.C.

“C’mon Ref!” – Right and Wrong Ways to Challenge the Call in a Supervised Disclosure Proceeding

Farrell Fritz, P.C. on

Section 3104 of the CPLR authorizes courts to appoint a judge or referee to supervise disclosure proceedings. The appointed referee enjoys “all the powers of the court” to resolve discovery disputes. A party seeking review of...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.

Summary Judgment in Lieu of Complaint Meets Business Divorce

Farrell Fritz, P.C. on

For most business divorce litigants, a dispositive win on the merits, even in a summary proceeding, can take years. Appraisal proceedings following a cash-out merger, for example, may involve multiple years of difficult...more

Farrell Fritz, P.C.

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

Farrell Fritz, P.C. on

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.

General Statement of Indebtedness is Sufficient to Restart Statute of Limitations Despite Ambiguities

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The statute of limitations to recover on a breach of contract is six years.  Parties can extend that limitations periods by agreement, and New York General Obligations Law 17-101 governs the form of such agreements. ...more

Manatt, Phelps & Phillips, LLP

We Are All Commercial Litigators Now: NY Commercial Division Rules Become Agents Of Change

From their creation in 1993, the New York State Supreme Court Commercial Division Rules have been developed and refined by judges and practitioners to pursue the twin goals of cost containment and fair adjudication....more

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