Does the delivery of a supplemental summons and complaint upon the Sheriff or county clerk (CPLR 203, subd [b]), absent required judicial consent, toll the Statute of Limitations?
A series of supplemental summonses and complaints were served on four individual defendants in a medical malpractice action in November of 1983. The required court approval, pursuant to CPLR 305, was not obtained and the actions were dismissed. Contemporaneously...
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