In Stern v. Carlin Communications, 210 AD2d 110 (1st Dept 1994), the First Department quashed a supplementary proceeding subpoena seeking financial records of non-party corporations, claimed to be closely related to defendants. In Stern, there was a fraudulent conveyance case pending involving the issue of whether the corporations were alter egos of one individual. Hence, the First Department held that the judgment-creditor would be relegated to discovery in the fraudulent conveyance action, instead of the enforcement subpoena.