On March 19, 2024, the First Department issued a decision in TRB Acquisitions LLC v. Yedid, 2024 NY Slip Op. 01525, holding that a second motion to dismiss was barred by the single motion rule, explaining:

Supreme Court should have denied the motion to dismiss as violative of the single motion rule, which permits a party to move only once upon one or more of the grounds enumerated under CPLR 3211(a). Defendant had the opportunity to assert, in his prior motion to dismiss, that the anti-SLAPP statute applied if his statements were true. Thus, Supreme Court should have denied the motion.

(Internal quotations and citations omitted).