Defendant's motion to strike plaintiff's note of issue was timely interposed within 20 days of the filing of the note of issue, and defendant correctly noted a misstatement in the certificate of readiness to the effect that discovery was complete, when, in fact, plaintiff owed discovery demand responses, as well as post-deposition demand responses, and moreover, had not produced a witness knowledgeable as to its damage claims for defendant to depose (see 22 NYCRR 202...
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