, April 21, 2026

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  Mar 27, 2026

🔑 Legal Writing: Addressing What a Case Is Not About

The Problem Opposing counsel sometimes frames the case incorrectly. A common response is:...

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  Mar 27, 2026

🔑 NY: Orders vs. Decrees—Why an Appeal from an Order Is Dismissed but the Issues Are Reviewed

In New York practice, appellate courts may dismiss an appeal from an order,...

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  Jan 21, 2026

NY CPLR § 3103: Protective Orders

CPLR § 3103 is the primary mechanism in New York civil practice for regulating...

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  Dec 13, 2025

🔑 Discovery of Tax Returns In New York Under CPLR § 3101

CPLR 3101 establishes a broad rule of disclosure in New York civil practice....

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  Dec 12, 2025

CPLR § 3101 Scope of disclosure

New York’s disclosure rules are broad by design. CPLR 3101 sets the...

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  Apr 27, 2025

Understanding the “Law of the Case” Doctrine

The “law of the case” doctrine is a significant legal principle that plays...

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  Nov 10, 2024

🔑 NY: Res Judicata and Collateral Estoppel Defenses Must Be Pleaded, Not Raised on Appeal

In New York, the defenses of res judicata and collateral estoppel—principles designed...

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  Oct 30, 2024

NY CPLR 3102: Method of Obtaining Disclosure

In New York’s civil litigation framework, CPLR 3102 provides a structured approach...

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  Oct 17, 2024

NY CPLR Rule 3217: Voluntary Discontinuance

In New York civil practice, a party may choose to voluntarily discontinue their...

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  Oct 13, 2024

NY CPLR Rule 3211: Motion to Dismiss

New York’s Civil Practice Law and Rules (CPLR) Rule 3211 outlines the...

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  Aug 22, 2024

🔑 NY: Rules for Confession of Judgment Are in CPLR 3218

The rules for a confession of judgment in New York are in CPLR...

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  Oct 30, 2023

Deciphering the Confusion: Understanding New York's Two New Rules on Affirmations

On October 25, 2023, Gov. Kathy Hochul signed two laws that expand who...

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