I. TREATMENT OF PRO SE LITIGANTS IN THE ... - Nassau …
2 a. Brown v. Astoria Federal Savings, 51 A.D.3d 961, 858 N.Y.S.2d 793 (2nd Dep’t 2008) (pro se plaintiff’s complaint dismissed where willful and contumacious nature ofconduct could be inferred from refusal to submit to deposition, to respond to other discovery
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