Did you make a motion to compel the discovery undet cplr 3124? Did the judge say you received all the discovery you are entitled to? If yes all you can do is seek permission from the appellate court to appeal but you need an ordet that resulted from a motion. The judge can issue a certification ordet whether you sign or not. If this is a case a lawyer would take that is what you need.
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You are in over your head. You need a lawyer.
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Get an attorney. It is difficult being pro se and not knowing the law or the procedure. You have posted numerous questions and obviously need professional assistance.
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It appears that you are way over your head here. If you are looking for compliance with CPLR 3123, you served a notice to admit. If the person did not respond to your notice to admit within 20 days, everything is deemed admitted. if you served other demands that were not responded to, serve a motion pursuant to CPLR 3126 and 3124 to strike his Answer.
As for the Court forcing you to file the Note of Issue, depending on the Court, if you do not file the Note of Issue on time the court will mark your matter as disposed. My advice is make the motion to strike the answer and request that your time to file the Note of Issue be extended.
Consult with a local attorney as well!
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Simply because one can read procedures and get forms does not mean they can represent themselves in complex litigation even though every one has a right to do so. You are betting that you can "save" the attorney's fee if you win, and may lose your case entirely instead. Get some legal representation.
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