Time Chart of Potential Mistakes: Index Number, Depositions Through Note of Issue, and Note of Issue

Index Number

  • Statue of limitation not satisfied until purchase of index number in Supreme Court. Watch for different rule in Civil Court
  • Pick correct venue or opponent will have a free hand
  • Inscribe on Summons and on Complaint, along with date of purchase
  • Watch for mixing equitable cause of action along with legal cause of action and eventual jury demand
  • Watch for second index number after a motion seeking leave or a motion seeking pre-complaint discovery
  • Changes in caption after motion seeking leave.

Depositions Through Note of Issue

  • Timely requesting and performing physical examination
  • Timely exchanging original medical reports and defendant’s physical examination
  • Deposing all the necessary witnesses
  • Correct non-party deposition procedure
  • Memorialize the deposition using video, correct procedure
  • Calendar practice during this period will have numerous conferences
  • Responding to pre-note Motions for Summary Judgment, correct affidavits
  • Time limits for Motions for Summary Judgment
  • Response to expert demands
  • Responding to, or formulating post-deposition demands
  • Requests for Admissions

Note of Issue

  • Physical examination
  • Exchange of reports
  • Compliance conference and date for Note of Issue- don’t miss
  • Report negotiations to the client
  • Settlements, written, oral, stipulations or in open court
  • 90 day notice and it’s pitfalls
  • Filing and waiver of other discovery
  • Jury demand must affirmatively be made, and fee paid

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