Plaintiff, 76 years old and a resident of Northern Ireland, submitted a sworn letter from her doctor identifying her many physical ailments, most preexisting the subject accident, and advising that traveling to New York could cause plaintiff "further serious problems." Based on this letter, the motion court correctly found that a deposition in New York would be an undue hardship for plaintiff, warranting an exception to the general rule that a nonresident who brings suit...
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