This article is in honor and in memory of Angela Susan Scheinberg. I was extraordinarily blessed that she was my wife. On 9/11, her life was savagely wrenched from me and from all who knew and loved her. Angela was a paradigm of kindness and integrity, and a beacon of virtue. I also honor every patriotic American murdered that day.

Three years ago, in CPLR 4404(a), Interests of Justice; Multiple Presentations, NYLJ, July 31, 2020, we discussed whether an objection must be raised during trial if it had been previously raised during the litigation, such as in a motion. Although the Court of Appeals has held that one pretrial objection preserves the issue for appeal, this issue has recurred—but the rulings have not always been consistent.

Review

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