In its 2015 order, the motion court failed to satisfy the requirements of 22 NYCRR 130-1.2. The court "did not set forth the conduct it found to be frivolous, and provided no reason whatsoever for its decision to impose legal fees and costs" (Gordon Group Invs., LLC v Kugler,
It is true that the 2016 order specifies that the court sanctioned defendant American University of Antigua College...
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