A non-resident attorney's failure to comply with the statutory requirement of maintaining a physical office in New York State at the time a complaint is filed does not render the filing a nullity, and dismissal of the action is not required. The party may cure the statutory violation with the appearance of compliant counsel or an application for admission pro hac vice by appropriate counsel.
Marina Dist. Dev. Co., LLC v. Toledano, NY Slip Op 05480 (2d Dep't July 9, 2019)
Here is the decision.
