Nelson v. Biderman
The petitioner moved for a warrant under CPLR 2308(b) to commit the respondent to jail for refusing to be sworn as a witness and produce requested books and records in a pending arbitration proceeding. The respondent had previously unsuccessfully moved to set aside the arbitrator's subpoenas, and the petitioner's cross-motion to compel compliance was granted. An appeal by the respondent for a stay was denied by the Appellate Division. The respondent persisted in his refusal before the arbitrator, leading to the current motion. The respondent argued, for the first time, that only the 'issuer' of the subpoena, the arbitrator, could move for relief under CPLR 2308(b), collaterally attacking the prior order. The court rejected this argument, interpreting 'issuer' to include the party on whose application the subpoena was issued in a non-judicial proceeding, and found it impractical to limit the remedy to the official. The motion was granted.