On March 20, 2020, at the outset of the COVID-19 pandemic, then-governor Andrew Cuomo issued Executive Order No. 202.8, declaring that "any specific time limit for the commencement, filing or service of any legal action, notice, motion… is hereby tolled," until April 19, 2020. Cuomo subsequently issued nine executive orders that extended the tolling or suspension of statutes of limitation and filing periods under New York law.