Jack A Gordon

August 17, 2021 | New York Law Journal

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

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