Maurizaca v. 201 Water St., LLC
In this case, third-party defendant Apex Restoration Corp. appealed the denial of its motion for summary judgment. The motion was denied by the Supreme Court, New York County, because Apex failed to demonstrate good cause for its delay in filing the motion. Specifically, the court noted that Apex did not require an IME report to meet its prima facie burden under Workers' Compensation Law § 11 and also delayed filing for several months even after obtaining other relevant reports. The Appellate Division, First Department, unanimously affirmed the lower court's decision, emphasizing that Apex's arguments on the merits were irrelevant to establishing good cause for the delay. The court reiterated that establishing good cause for filing delays is a prerequisite for such motions.