Elliott Scheinberg, an appellate attorney whose practice is limited to matrimonial law, writes that although the Court of Appeals in 1976 held that the fresh 30-day period begins to run from the date of the service of the order of either the dismissal or denial, the First Department, and recently, the Fourth Department have been inconsistent in applying that rule.
The Uncertain Limitations Period Following Appeals by Improper Method
New York Law Journal
August 15, 2012
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