This article updates relevant issues examined in prior discussions.

‘Braun v. Cesareo’

“‘Braun v. Cesareo’: When CPLR 5701(a)(2) Intersects With CPLR 5501(a)(1),” NYLJ (Sept. 16, 2019), reviewed the issue of whether CPLR 5501(a)(1), which “brings up for review any non-final judgment or order which necessarily affects the final judgment,” includes orders made ex parte or sua sponte. The majority opinion concluded that it does include such orders. 170 A.D.3d 1540 (4th Dept. 2019).