In Koehler v. Bank of Bermuda Ltd., 12 NY3d 533, 911 NE2d 825, 883 NYS2d 763 (2009), the New York Court of Appeals addressed postjudgment attachment pursuant to CPLR article 52 of property held by third-party garnishees over which courts in New York have personal jurisdiction.

The Court held that "a New York court with personal jurisdiction over a defendant may order him to turn over out-of-state property regardless of whether the defendant is a judgment debtor or a garnishee. . . .

"A court sitting in New York that has personal jurisdiction over a garnishee bank can order the bank to produce stock certificates located outside New York, pursuant to CPLR 5225 (b)." (12 NY3d at 541.)

It is worth noting that the Court emphasized that "while prejudgment attachment pursuant to CPLR article 62 is typically based on jurisdiction over property, postjudgment enforcement requires only jurisdiction over persons." (Id. at 537.)