There is no statutory or other legal requirement that a turnover application under CPLR 6401 (b), which provides that a court may authorize a receiver to collect and sell debts or claims, must be prosecuted in the form of a special proceeding. In any event, even if a special proceeding were mandated, the IAS Court had jurisdiction over all necessary parties, including appellant management company, which had repeatedly appeared in the action, and therefore could convert the...
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