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New York is known as the financial capital of the world, and as such its state and federal courts host more than their fair share of complex commercial litigation. Among the New York courts, the New York State Supreme Court’s Commercial Division is particularly busy with high-stakes litigation involving sophisticated businesses, and its opinions are watched by serious litigators everywhere. Nonparties are routinely drawn into this fray by subpoenas, a burden that is exacerbated by e-discovery.