(L-R)Katryna L. Kristoferson and David Paul Horowitz of the Law Offices of David Paul Horowitz. Courtesy photos (L-R)Katryna L. Kristoferson and David Paul Horowitz of the Law Offices of David Paul Horowitz. Courtesy photos

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Practical New York Practice™

This month we visit two lesser-known and used CPLR devices: The summons with notice and a motion for pre-action disclosure. We are fortunate to be joined this month by Justice Barbara Jaffe (Ret.), who writes on the summons with notice, including an interesting experience she encountered with the device while on the bench. Katryna then takes the laboring oar and writes on pre-action disclosure. Together, they craft a useful guide to two useful procedural tools.