The rules that decide cases before the merits are reached.

This section covers civil procedure under the CPLR, focusing on the rules that govern motion practice, discovery, jurisdiction, pleadings, and case management in Supreme Court and appellate litigation. Posts emphasize how procedural missteps create leverage, end cases early, or shape outcomes long before trial.

Posts examine procedural rulings and strategy involving CPLR motion practice, jurisdictional challenges, pleading sufficiency, discovery disputes, timeliness defenses, defaults, and appellate preservation. Coverage highlights trial-court and appellate decisions that turn on procedure rather than liability or damages.

What You’ll Find Here

• CPLR § 3211 and § 3212 motion practice and timing traps
• Jurisdiction, service, venue, and forum challenges
• Discovery disputes, sanctions, and motion practice under CPLR Article 31
• Defaults, vacatur motions, and CPLR § 5015 relief
• Pleading standards, amendments, and relation-back issues
• Appellate preservation, waiver, and procedural dismissals
• Practical takeaways for defense counsel, insurers, and litigators