New York Civil Law

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Civil Procedure & Motion Practice

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
  • New York Litigation Funding Discovery After Perdomo and Lituma

    New York Litigation Funding Discovery After Perdomo and Lituma

    June 18, 2026
    Read more: New York Litigation Funding Discovery After Perdomo and Lituma
  • Fourth Department Holds New York Bill of Particulars Cannot Add New Theory of Liability

    Fourth Department Holds New York Bill of Particulars Cannot Add New Theory of Liability

    May 1, 2026
    Read more: Fourth Department Holds New York Bill of Particulars Cannot Add New Theory of Liability
  • Third Department Affirms Summary Judgment Denial in Pedestrian Injury Case: Unsafe Bus Stops Create Liability Exposure

    Third Department Affirms Summary Judgment Denial in Pedestrian Injury Case: Unsafe Bus Stops Create Liability Exposure

    June 19, 2025
    Read more: Third Department Affirms Summary Judgment Denial in Pedestrian Injury Case: Unsafe Bus Stops Create Liability Exposure
  • New York Commercial Division Amicus Brief Rule

    New York Commercial Division Amicus Brief Rule

    June 5, 2025
    Read more: New York Commercial Division Amicus Brief Rule
  • New York Juror Misconduct CPLR 4404 Verdict Challenge

    New York Juror Misconduct CPLR 4404 Verdict Challenge

    December 16, 2024
    Read more: New York Juror Misconduct CPLR 4404 Verdict Challenge
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