Two CPLR Devices Worth Remembering | New York Law Journal
















(L-R)Katryna L. Kristoferson and David Paul Horowitz of the Law Offices of David Paul Horowitz. Courtesy photos

ANALYSIS

This month, Katryna Kristoferson and David Horowitz visit two lesser-known and used CPLR devices: the summons with notice and a motion for pre-action disclosure. This column is joined by Justice Barbara Jaffe (Ret.), who writes on the summons with notice, including an interesting experience she encountered with the device while on the bench. Katryna then takes the laboring oar and writes on pre-action disclosure.

January 17, 2024 at 10:18 AM

13 minute read

By Katryna L. Kristoferson, David Paul Horowitz and Barbara Jaffe |
January 17, 2024 at 10:18 AM

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This month we visit two lesser-known and used CPLR devices: The summons with notice and a motion for pre-action disclosure. We are fortunate to be joined this month by Justice Barbara Jaffe (Ret.), who writes on the summons with notice, including an interesting experience she encountered with the device while on the bench. Katryna then takes the laboring oar and writes on pre-action disclosure. Together, they craft a useful guide to two useful procedural tools.

The Summons With Notice (CPLR 305[b]): A Handy Device To Avoid Being Time-Barred

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