Lundin PLLC

On June 26, 2024, the Second Department issued a decision in MTGLQ Invs., L.P. v. Daleo, 2024 NY Slip Op. 03477, holding that an affidavit submitted to prove non-payment of a loan must include the business records upon which the affidavit is based, explaining:

[T]he plaintiff otherwise failed to establish its prima facie entitlement

On June 18, 2024, the First Department issued a decision in AMK Capital Corp. v. Plotch, 2024 NY Slip Op. 03324, holding thatCPLR 308(2)’s restrictions prohibiting the inclusion of information indicating that a communication is from an attorney or concerns an action against the person to be served on an envelope in which process