Rakelle Shapiro

Rakelle Shapiro

January 08, 2025 | New York Law Journal

Attorney Fee Reimbursement for Non-Party Subpoena Recipients Under CPLR 3122(d)

A discussion of two recent decisions, Matter of Barons Media v. Shapiro Legal Group, Peerenboom v. Marvel Entertainment, which have helped clarify that the term “expenses” as used in CPLR 3122(d) encompasses the reasonable attorney fees incurred by a non-party subpoena recipient.

By Matthew D. Parrott and Rakelle Shapiro

6 minute read