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How to appeal a trial where a Note of Issue was never served?

April 26, 2017appeal ISSUE note served trial

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How to appeal a trial where a Note of Issue was never served?

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A Note of Issue is a paper, wherein a party certifies to the Court that a case is ready for trial. It is usually accompanied by another document known as a “Certificate of Readiness.” In New York, a case may not proceed to trial without a Note of Issue.