The motion court providently exercised its discretion in imposing sanctions and awarding costs and attorneys' fees against defense counsel based on its finding that defense counsel engaged in frivolous conduct (see 22 NYCRR 130-1.1[a]). On November 7, 2018, the day before running afoul of the so-ordered deadline to commence nonparty depositions (NPDs), defendant moved pursuant to CPLR 3103 for a protective order to stay and extend the deadline. The motion was without...
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