This is a motion by defendant for an order (under CPLR 3124) to compel plaintiff to answer 41 interrogatories and a cross motion by plaintiff for a protective order (under CPLR 3103, subd [a]) striking the interrogatories as being improper under the mandatory exclusion described in CPLR 3130, "After commencement of an action, other than in an action to recover damages for an injury to...
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