Jacobs v. Johnston
Cases that cite this one
12 later published cases cite this decision.
- Kent Realty, LLC v. Danica Group, LLC (Appellate Division of the Supreme Court of New York 2013)
- Kent Realty, LLC v. Danica Group, LLC (Appellate Division of the Supreme Court of New York 2013)
- Reardon v. Macy's, Inc. (Appellate Division of the Supreme Court of New York 2021)
- Cioffi v. S.M. Foods, Inc. (Appellate Division of the Supreme Court of New York 2019)
- Singh v. CBCS Construction Corp. (Appellate Division of the Supreme Court of New York 2016)
- Bianchi v. Galster Management Corp. (Appellate Division of the Supreme Court of New York 2015)
- Malester v. Rampil (Appellate Division of the Supreme Court of New York 2014)
- Malester v. Rampil (Appellate Division of the Supreme Court of New York 2014)
- ACG Credit Company II, LLC v. Hearst (Appellate Division of the Supreme Court of New York 2013)
- ACG Credit Company II, LLC v. Hearst (Appellate Division of the Supreme Court of New York 2013)
- Breytman v. Olinville Realty (Appellate Division of the Supreme Court of New York 2013)
- Breytman v. Olinville Realty (Appellate Division of the Supreme Court of New York 2013)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion of the Court
Since the defendant moved to vacate the note of issue within the time prescribed for doing so pursuant to 22 NYCRR 202.21 (e), and clearly demonstrated that the case was not ready for trial, that branch of the defendant’s motion which was to vacate the note of issue and, in effect, to compel the deposition of a nonparty witness should have been granted (see CPLR 2103 [b] [2]; Gallo v SCG Select Carrier Group, L.P., 91 AD3d 714 [2012]; Tirado v Miller, 75 AD3d 153, 157 [2010]). Furthermore, since the defendant timely moved to vacate the note of issue, he was required only to demonstrate why the case was not ready for trial, and was not required to establish that additional discovery was necessary because unusual or unanticipated circumstances had developed subsequent to the filing of the note of issue (see 22 NYCRR 202.21 [d], [e]; Mosley v Flavius, 13 AD3d 346 [2004]; Rizzo v DeSimone, 287 AD2d 609, 610 [2001]; Perla v Wilson, 287 AD2d 606 [2001]; Audiovox Corp. v Benyamini, 265 AD2d 135, 139 [2000]).
In opposition to the plaintiff’s cross motion to quash the subpoena served by the defendant upon the nonparty witness, the defendant demonstrated, inter alia, that the disclosure
The plaintiffs remaining contentions are either without merit or improperly raised for the first time on appeal. Rivera, J.E, Eng, Chambers, Sgroi and Miller, JJ., concur.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.