The proposed "consolidation" of New York's court system has, once again, become headline news. In 2019, I wrote an article concerning court consolidation then proposed by Judge Janet DiFiore, the Chief Judge of the Court of Appeals, for the purposes of addressing the history of the Surrogate's Court and how it may be improved as a result of consolidation. See "Thoughts on Court Consolidation: The Surrogate's Court," New York Law Journal, Vol. 262, No. 101, Nov. 22, 2019.