Appellate Division of the Supreme Court of the State of New York February 21, 1966 (Arett Sales Corp. v. Island Garden Center of Queens, Inc.)

In two separate actions, each brought by a different plaintiff, to recover balances allegedly due for goods sold and delivered and on accounts stated, in each of which actions there was interposed a defense and a counterclaim against the plaintiff therein and another person, Dave Boylan, who has been brought into each action as an “ additional defendant”, defendants appeal as follows from two