Where's 'Dondi'?
"The question 'where's 'Dondi'' arises from the portion of the Rule requiring that an order 'recite the papers used on the motion,'" write Katryna L. Kristoferson and David Paul Horowitz.
August 19, 2024 at 12:00 PM
12 minute read
(L-R)Katryna L. Kristoferson and David Paul Horowitz of the Law Offices of David Paul Horowitz. Courtesy photos
Introduction
Collectively, Katryna and David have over 40 years combined practice experience. Yet, until about two months ago, neither of us had ever been asked the question: "Where's Dondi?"
No, this is not yet another picture book designed to pass the time and challenge your attention to detail, along the lines of "Where's Waldo?" It is a quirk of appellate practice, limited so far as we know, to the Appellate Term, Second Department, and is patois in that court for compliance with CPLR 2219(a).
CPLR 2219(a)
CPLR 2219(a), titled, "Time and form of order," provides:
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