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Daily Archives: Saturday, January 28, 2017

Posted: January 28, 2017

Pre-Action Discovery Not Available to Revive Already-Dismissed Action

On January 11, 2017, Justice Oing of the New York County Commercial Division issued a decision in Culligan Soft Water Co. v. Clayton Dubilier & Rice, LLC, 2017 NY Slip Op. 30074(U), holding that a litigant could not use pre-action discovery to revive an already-dismissed action, explaining: [P]laintiffs seek an order compelling discovery from the… Read more »