On May 3, 2023, the Second Department issued a decision in Trovato v. Galaxy Sanitation Servs. of N.Y., Inc., 2023 NY Slip Op. 02348, dismissing an appeal for failure to submit an adequate record, explaining:
It is the obligation of the appellant to assemble a proper record on appeal. An appellant’s record must contain all of the relevant papers that were before the Supreme Court.
Here, the record on appeal is inadequate. The appellant failed to include, among other things, documents that the Supreme Court relied upon in rendering its determination. Accordingly, dismissal of the appeal is the appropriate disposition.
(Internal citations omitted).