2309 issueMarch 25, 2017

American Cas. Co. of Reading, Pa. v Motivated Sec. Servs., Inc., 2017 NY Slip Op 01970 (1st Dept. 2017)

“The motion court properly considered the out-of-state affidavit of SBF’s president, even though it lacks a certificate of conformity (CPLR 2309[c]). The lack of such certification is not a fatal defect and the irregularity may be corrected later (see Matapos Tech. Ltd. v Compania Andina de Comercio Ltda, 68 AD3d 672, 673 [1st Dept 2009]; CPLR 2001).”

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