Contract analysis

1. Proceed with Litigation Through discovery and Trial The action remains pending before Hon. Patricia Velez, J.S.C., and discovery has not yet meaningfully commenced — though the discovery meet-and-confer process with Ridgeway, Tanaka & Schiff LLP was initiated in November 2023 and a framework is in place. Electing this path would mean pursuing the case through its full lifecycle. Discovery would be substantial. We

2. Voluntary discontinuance Without Prejudice — Preserve Right to Refile A second option is to file a stipulation of voluntary discontinuance without prejudice pursuant to CPLR § 3217(a)(2), with the consent of defendants. This would terminate the current action but preserve your right to refile the claims within the applicable statute of limitations under New York law. The principal advantages of this approach are p

3. Voluntary discontinuance and Definitive Closure The third option uses the same procedural mechanism as Option 2 — a stipulation of discontinuance without prejudice under CPLR § 3217(a)(2) — but with a client-level decision not to refile. This would effectively close the matter and result in the closure of our engagement on this file. The advantage is finality. You would eliminate the ongoing and prospective legal