As most New York practitioners are aware, Gov. Andrew Cuomo’s Executive Orders, commencing in March 2020 at the outset of the COVID-19 pandemic, put New York on “pause”—effectively freezing statutory and court imposed deadlines for all manner of legal proceedings. For civil proceedings, at least, that stoppage lasted through Nov. 3, 2020. In the months since, a few courts have had a chance to interpret the orders and address some of their inherent ambiguities.

The Second Department’s recent decision in Brash v. Richards, 2020-08551, June 2, 2021, has provided the most guidance to date.