Opinion Excerpt

Koff v Lawson 2026 NY Slip Op 04582 July 24, 2026 Appellate Division, Fourth Department Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431. This decision is uncorrected and subject to revision before publication in the Official Reports. PHILLIP J. KOFF, PLAINTIFF-APPELLANT, v ERICA LAWSON, DEFENDANT-RESPONDENT. Supreme Court of the State of New York, Appellate Division, Fourth Judicial Department Decided on July 24, 2026 308 CA 25-01262 Present: Lindley, J.P., Curran