Smith v. Global Contact Holding Co., Inc.
The Appellate Division, First Department, unanimously affirmed an order from the Supreme Court, New York County. The Supreme Court order had granted the defendants' motion to compel nonparty appellant Transport Workers Union, Local 100's compliance with a subpoena duces tecum. The union argued improper service of the motion, relying on a statutory provision no longer in effect. The court found that the union had waived its objection to personal jurisdiction by failing to object to jurisdiction in response to a prior motion to compel, despite its counsel receiving the subpoena. Furthermore, the union failed to demonstrate that the motion to compel constituted harassment or annoyance, as it sought compliance with a prior order to turn over relevant documents. A separate motion by defendants for Sandra Lennon to withdraw her appeal was granted.