Pre-Trial Advocacy, Discovery, Motions

  • Admissions
  • Discovery
  • Discovery Disputes
  • Document Requests
  • Interrogatories, Expert Witness Interrogatories
  • Motion to Compel
  • Motion for Protective Order
  • Request for Disclosure
  • Request for Production
  • Strategy for Fact Development
  • Strategy for Investigation


  • Summary judgment
  • Stay of judgment pending appeal (or something else)
  • Vacating a stay of judgment

When the New York Court of Appeals reverses a lower court’s decision, it can remand the case so to the lower court can modify its order. See, e.g., In re Seaman, 78 N.Y.2d 451 (1991): “We conclude that neither the language of Domestic Relations Law § 117, the legislative history preceding it, nor policy reasons advanced in Matter of Best, support the result. Accordingly, the order should be reversed and the matter remitted to Surrogate’s Court for entry of a decree in conformance with this decision (see, SCPA 2702).”