Defendant does not dispute that she has a separate action pending in the United States District Court against plaintiffs and some additional parties for the same causes of action asserted in the counterclaim. Substantial, not complete, identity of parties is all that is required to invoke CPLR 3211 (subd [a], par 4) (Bradford v Brooklyn Trust Co., 269 App Div 549; Siegel, New York Practice, § 262, p 322). Furthermore, the fact that there are some additional parties...
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