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CPLR 2004 Extensions, the 90-Day Foreclosure Sale Rule and the Tolling of Interest Accruals
Givens addresses three issues encountered in mortgage foreclosure actions:[1] motions for extensions of time pursuant to CPLR 2004, the 90-day requirement to conduct foreclosure sales pursuant to RPAPL 1351(1), and the tolling of interest due to a lender’s delays in prosecuting its foreclosure action.

Jonathan Freiberger
Oct 17, 20255 min read
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