By: Jeffrey M. Haber New York has a unique mechanism—summary judgment in lieu of complaint—that allows a party to recover money upon the default of an instrument for the payment …
By: Jonathan H. Freiberger Today’s article relates to summary judgment in lieu of complaint pursuant to CPLR 3213,[1] which provides, in relevant part: When an action is based upon an …
By: Jeffrey M. Haber This Blog has written about the process known as “summary judgment in lieu of a complaint” on several occasions.[1] The process, codified in CPLR 3213, is a …
By: Jeffrey M. Haber Under New York law, there are two methods by which a person can domesticate a foreign judgment – i.e., a judgment obtained outside the State of …
As every lawyer knows, the practice of law requires compliance with various deadlines. Some are court ordered, while others are statutory. To be sure, there are many practitioners who do …
When a complaint is served and filed, a defendant can respond to the pleading in many ways. For example, he/she can answer the complaint or file a motion to dismiss. …
