Appellate Division of the Supreme Court of the State of New York January 17, 2012 (Gallo v. SCG Select Carrier Group, L.P.)

The appellants timely moved, inter alia, to strike the note of issue within 20 days of its service (see 22 NYCRR 202.21 [e]), and clearly demonstrated that the plaintiffs certificate of readiness contained misstatements concerning the status of discovery.