THIS MONTH’S column covers a variety of interpretive issues that have arisen under the CPLR in recent decisions of the Court of Appeals and the Appellate Divisions. The topics include notice of pendency (CPLR Article 65), apportionment under CPLR Article 16, the statute of limitations in “toxic tort” cases (CPLR 214-c) and equitable estoppel of the statute of limitations in medical malpractice actions.

The ‘Sakow’ Case