On September 1, 2017, Justice Scarpulla of the New York County Commercial Division issued a decision in Kassover v. Prism Ventures Partners, LLC, 2017 NY Slip Op. 31933(U), holding that a turnover order can apply to out-of-state property, explaining:
The Court of Appeals has held that CPLR Article 52 contains no express territorial limitation. Turnover orders can direct a defendant, over whom the New York court has jurisdiction, to bring its own property into New York. Thus, a New York court may order a defendant to turn over property to a judgment creditor even if the property is located out of state.
(Internal quotations and citations omitted).