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Appellate Division, First Department · October 15, 2026 · 2026 NY Slip Op 06034

Sarante v Courtlandt Dev. LLC

Read the official decision: 2026 NY Slip Op 06034

Holding The Appellate Division affirmed the denial of defendants’ motion to compel a further deposition of the plaintiff after the note of issue was filed. The court found that defendants failed to demonstrate unusual and unanticipated circumstances warranting post-note of issue discovery based on unproven allegations in unrelated actions.

The court’s words

defendants failed to demonstrate unusual and unanticipated circumstances warranting post-note of issue discovery

2026 NY Slip Op 06034, at the official text

Franco was a fact-specific application of settled principles governing motions to compel

2026 NY Slip Op 06034, at the official text

Supreme Court providently exercised its discretion in denying defendants' motion to compel

2026 NY Slip Op 06034, at the official text
CourtAppellate Division, First Department
DecidedOctober 15, 2026
Citation2026 NY Slip Op 06034
Area of lawCivil Procedure
WeekWeek ending October 17, 2026
Official textOfficial decision: 2026 NY Slip Op 06034
Publication statusSlip opinions are uncorrected and subject to revision before publication in the Official Reports.
Source feedNew York slip opinion page
Law Watch record id1293

Recommended citation

ESQ HQ, New York Law Watch, Sarante v Courtlandt Dev. LLC, 2026 NY Slip Op 06034 (Appellate Division, First Department, October 15, 2026), https://esqhq.com/decisions/2026-ny-slip-op-06034/

How this record was made

Holding drafted by Law Watch’s in-house model, graded by three reviewers; every quotation verified word for word against the official text.

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Published October 15, 2026. Updated October 15, 2026.