December 14, 2018

Discovery after filing a note of issue.

Practice point:  On a showing of unusual or unanticipated circumstances that developed after the filing of the note of issue, additional discovery may be ordered, pursuant to 22 NYCRR 202.21[d].

Palmiero v 417 E. 9th St. Assoc., LLC, NY Slip Op 08449 (1st Dep't December 11, 2018)

Here is the decision.