22 NYCRR 130-1.1(a) authorizes an award of costs or the imposition of sanctions in favor of "any party or attorney" in any civil action or proceeding "before the court." The non-party's motion for attorneys' fees and costs is denied as untimely since it was made after the parties had executed a stipulation to discontinue the action.
Baugh v. Seagull 27, LLC, NY Slip Op 04620 (2d Dep't August 13, 2025)
