Stellar West 100 LLC v. Olavson

In Stellar West 100 LLC v. Olavson, 1, 2014 NY Slip Op 31422(U), 1 [N.Y. Sup. Ct. May 30, 2014] a defendant's motion to confirm the report of a special referee that had been dictated into the record and subsequently "so-ordered" was granted after the court found that the special referee's conclusions of law were fully supported by the record (Id.). The court found that it was unnecessary for the special referee to write a separate written report beyond what was contained in the findings dictated into the record that were later "so-ordered" following transcription.