On March 25, 2026, the Second Department issued a decision in Yong Hong Xie v. Lan Chen, 2026 NY Slip Op. 01818, holding that a party was bound by a discovery stipulation it agreed to, explaining:
The Supreme Court properly denied the defendants’ motion pursuant to CPLR 3103(a) for a protective order barring disclosure of their personal tax returns. A so-ordered stipulation is a contract between the parties thereto and as such, is binding on them. Parties by their stipulations may in many ways make the law for any legal proceeding to which they are parties, which not only binds them, but which the courts are bound to enforce. While a court may relieve a party of the consequences of a stipulation made during litigation where there is cause sufficient to invalidate a contract, such as fraud, collusion, mistake, or accident, here, the defendants failed to demonstrate good cause sufficient to invalidate the so-ordered stipulation. The defendants also failed to demonstrate that their former attorney lacked the authority to enter into the so-ordered stipulation on their behalf. Accordingly, the defendants have not demonstrated that the so-ordered stipulation requiring them to produce copies of federal and state tax returns filed by or on behalf of the defendants for the tax years 2012 through the present should not be enforced.
(Internal quotations and citations omitted).