A subpoena arrived and you are not even a party. What it can and cannot demand.
Served with a New York nonparty subpoena? Twenty days to object, a hard standard to quash, and a statute that shifts your costs. Check yours now.
The email you sent may have restarted their clock.
A signed email or one stray payment can revive a time-barred New York debt. See which writings restart the clock, and which defenses still kill revival.
Your contract may have cut their deadline to one year.
New York contracts can cut six years to one. CPLR 201, Kassner, GOL 17-103 and the 2024 Farage burden rule: find the clause before you answer.
The plaintiff is out of state. Their clock may be shorter.
CPLR 202 can cut a nonresident plaintiff’s six years to four, three, or two, even under a New York choice-of-law clause. See which clock you get.
The clock started when they breached, not when they knew.
New York contract claims accrue at breach, not discovery. Run the six years, add the 228-day COVID toll, and see which counts are already dead.
Not every claim against you gets six years.
Each New York count gets its own clock: six, four, three or one year. Find which of yours expired, and the 228-day toll that quietly revives others.
The Commercial Division has rules that limit your costs.
New York’s Commercial Division caps interrogatories, depositions and the clock, and two exclusions changed in 2025. Check the limits before discovery.
Making the other side pay for a frivolous claim.
New York fee-shifting is narrow: contract, statute, or 22 NYCRR 130-1.1. See what frivolous really means, what it pays, and who pays it.
A formal offer can make the plaintiff pay your costs.
New York’s CPLR 3219, 3220 and 3221 can make a plaintiff who refuses your offer pay. See which one bites hardest and when it expires.
What a motion to dismiss costs you in time.
Motion to dismiss in New York: the answer clock, the CPLR 3214(b) disclosure stay and interest running. See what the pause really costs.