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KAIAFAS v. AMMOS NYC LLC

10695N, 650847/17.

179 A.D.3d 416 (2020)

113 N.Y.S.3d 535

2020 NY Slip Op 00052

Nikolaos Kaiafas, Appellant, v. Ammos NYC LLC et al., Respondents. (And a Third-Party Action.)

Appellate Division of the Supreme Court of New York, First Department.

Decided January 2, 2020.

Plaintiff's proposed modified subpoena requesting specified bank documents from defendants' nonparty bank contained sufficient language to afford the bank requisite notice of the relevance underlying the document request (see generally CPLR 3101[a][4]; Matter of Kapon v Koch, 23 N.Y.3d 32 [2014]). On this record, including plaintiff's allegations and the documentary proof, the requested bank documents were material and necessary...

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