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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Brusco v. Braun, 199 A.D.2d 27 (1993)

Citation
Brusco v. Braun, 199 A.D.2d 27 (1993)
Parent Document
Brusco v. Braun, 199 A.D.2d 27 (1993)
Jurisdiction
New York (state)
Effective Date
1993-12-07

Full Text

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Similarly, had the Legislature intended CPLR 3215 (b) to be applicable to summary proceedings, CCA 1402, governing entry of default judgments generally, would indicate as much. This provision goes to some length to state the rather obvious proposition that a summons with endorsed complaint "shall be deemed 'the summons and the complaints’ referred to in [CPLR 3215 (e) (now subd [f])].” Conspicuously absent from CCA 1402 is any mention of the petition and notice of petition. Applying the principle expressio unius est exclusio alterius, the omission indicates that summary proceedings pursuant to the Real Property Actions and Proceedings Law are not intended to be embraced within its scope (McKinney’s Cons Laws of NY, Book 1, Statutes §240) and therefore are not subject to the procedure set forth in CPLR 3215.