Marriage of Blake & Langer

BACKGROUND

The underlying facts are of limited relevance to the issue raised in this appeal. For context, we briefly recite portions of the factual and procedural background.

A. Events Preceding Langer’s Request for Joinder in the Dissolution Action Blake and Langer married in September 2004 and separated in June 2017. In September 2017, Blake filed the underlying action for dissolution of marriage. In January 2018, Langer’s attorneys Elyse Margolin and Tess Cozine sent an email to MetLife Investors USA Insurance Company (MetLife) instructing it to maintain the named beneficiaries or covered dependents under any policy issued to Langer or Blake, including a $2 million term life insurance policy that had been taken out on Blake (the Blake policy). Langer and Daniel (Blake’s brother) were the named beneficiaries of the Blake policy. Langer and Daniel had taken out the policy in 2012 in their capacity as trustees of the Meredith Blake Irrevocable Trust (the 2012 Blake trust), which was drafted by Steven (Blake’s father), a trust and estate attorney in New York. The Blake policy was administered through Brighthouse Life Insurance Company (Brighthouse). In August 2018, Steven…