Gonzalez v Perkan Concrete Corp., 2013 NY Slip Op 06835 (2d Dept. 2013)
“Finally, although the affidavits of the defendants’ expert, which were notarized outside of New York, were not accompanied by certificates authenticating the authority of the notaries who administered the oaths (see CPLR 2309[c]), this omission was not a fatal defect (see CPLR 2001; Matter of Recovery of Judgment, LLC v Warren, 91 AD3d 656, 657; Betz v Daniel Conti, Inc., 69 AD3d 545, 545; Smith v Allstate Ins. Co., 38 AD3d 522, 523). [*4]
