Joson v. G & S Realty 1, LLC

Generally, unless a trial court specifies otherwise, a party has 120 days after the filing of a note of issue to move for summary judgment, after which it may do so only with “leave of court on good cause shown” (CPLR 3212 [a]). This “requires a showing of good cause for the delay in making the motion — a satisfactory explanation for the untimeliness — rather than simply permitting meritorious, nonprejudicial filings, however tardy” (Brill v City of New York, 2 NY3d 648, 652 [2004]). A trial court has discretion in determining whether to consider a motion for summary judgment made more than…