Order unanimously modified on the law to grant plaintiff's motion to consolidate actions Nos. 1 and 2 for a joint trial in Niagara County and, as modified affirmed without costs.
Special Term's award of counsel fees pursuant to CPLR 6315 was proper even though defendant's application was brought on by ordinary notice of motion rather than by an order to show cause. The motion requirement in CPLR 6315...
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