Daily Archives: Saturday, December 29, 2018

Posted: December 29, 2018

Written Agreement Requirement of CPLR 2104 Does Not Apply to Pre-Litigation Settlements

On November 8, 2018, Justice Hudson of the Suffolk County Commercial Division issued a decision in Walter Boss, Inc. v. Roncalli Freight Co., Inc., 2018 NY Slip Op 51891(U), holding that CPLR 2104’s requirement that a stipulation of settlement be in writing does not apply to the settlement of disputes before litigation, explaining: CPLR 2104... Read more »