On February 19, 2025, the Second Department issued a decision in HSBC Bank USA, N.A. v. Mair, 2025 NY Slip Op. 00954, holding that a party could not be added to an action after judgment was entered, explaining:
A party can be added to a pending action or proceeding only on timely motion and an order of the court in which the action or proceeding is pending. Here, the plaintiff’s motion was untimely, as a judgment of foreclosure and sale had been entered in the action. Contrary to the plaintiff’s contention, the failure to add Titus as a necessary party was not a type of irregularity or error that warranted nunc pro tunc relief.
(Internal quotations and citations omitted).