The following excerpt is from Corrado v. N.Y. State Unified Court Sys., 16-1493-cv (2nd Cir. 2017):
1. The fact that Corrado is an attorney, and the unequivocal nature of her request to dismiss the action, distinguish Smith v. Artus, 522 F. App'x 82 (2d Cir. 2013) (summary order), on which Corrado relies, which held that a district court confronted with an ambiguous request for discontinuance from a non-lawyer pro se plaintiff should have taken steps to clarify the plaintiff's desires and be sure that he understood that the dismissal would be with prejudice.
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