Alex T Paradiso

Alex T Paradiso

August 17, 2021 | New York Law Journal

No Complaint, No Problem! Navigating CPLR 3213

A motion for summary judgment in lieu of a complaint, as the CPLR 3213 motion is often referred, provides a quick avenue for relief, melding pleadings and motion practice into one step. Practitioners must be aware, however, of the motion's strict procedural requirements, discussed here.

By Jack A. Gordon and Alex T. Paradiso

7 minute read

March 04, 2019 | New York Law Journal

Securing the Testimony of a Witness in Government Custody

Practitioners in need of trial or deposition testimony (in either a state or federal civil case) of a witness in a government custody should consider seeking a Writ in federal court to obtain same.

By Jack A. Gordon and Alex T. Paradiso

8 minute read

August 30, 2013 | New York Law Journal

Tools for Recovery of Unpaid Legal Fees

Andrew S. Kowlowitz and Alex T. Paradiso of Furman Kornfeld & Brennan write: Determining which remedy - a plenary action, a charging lien and/or a retaining lien - is appropriate in ethically and effectively securing payment of unpaid fees will often depend on the nature of the underlying case, the recovery sought in that action and the former client's ability to satisfy the outstanding legal fees.

By Andrew S. Kowlowitz and Alex T. Paradiso

11 minute read