The following excerpt is from Brooklyn Bank v. Barnaby, 197 N.Y. 210, 90 N.E. 834 (N.Y. 1910):
note, and in the opinion reference is made to the cases of Shoemaker v. Benedict and Winchell v. Hicks, supra, as having flatly decided that, for the purpose of determining whether a payment extends the bar of the statute of limitations, it makes no difference whether the payment is made before or after the debt is barred.
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