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KOZEL v. KOZEL

350045/15, 6731N, 6730.

161 A.D.3d 700 (2018)

78 N.Y.S.3d 68

2018 NY Slip Op 03907

Ashley Kozel, Respondent, v. Todd Kozel, Defendant. Inga Kozel, Nonparty Appellant.

Appellate Division of the Supreme Court of New York, First Department.

Decided May 31, 2018.

Contrary to the contention of the nonparty witness (Inga), she was properly served via email with plaintiff's order to show cause. While a criminal contempt proceeding requires personal service on the contemnor (see Matter of Grand Jury Subpoena Duces Tecum, 144 A.D.2d 252, 255-256 [1st Dept 1988]), CPLR 308 (5) permits a court to direct another manner of service if the methods set forth in the statute prove impracticable. Here,...

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