One year after the judgment of divorce ended the matrimonial action, the stipulation of settlement of a post-judgment motion was so-ordered. That stipulation was not part of the judgment, but was an independent contract which could not be incorporated into the judgment. Because the court did not retain the power to exercise supervisory control over the action, a plenary action is necessary to enforce the stipulation.
DeGiovine v. Kaufmann, NY Slip Op 02250 (2d Dep't April 6, 2022)
