…client’s allegations were previously addressed in a prior matter.

In Knox v Aronson, Mayefsky & Sloan, LLP, 2018 NY Slip Op 09030 [1st Dept Dec. 27, 2018], the court dismissed a legal malpractice case where the client’s allegations were previously addressed in a prior matter.  The court held:

Supreme Court properly dismissed plaintiff’s complaint as against FBK, since the only claim asserted, a legal malpractice claim, is barred by the doctrine of res judicata (see Matter of Hunter, 4 N.Y.3d 260, 269, 794 N.Y.S.2d 286, 827 N.E.2d 269 [2005] ).  Plaintiff’s legal malpractice claim is based on the same conduct that was the basis of the counterclaim previously dismissed by Supreme Court Westchester County.  Res judicata bars all claims “ arising out of the same transaction or series of transactions … even if based upon different theories or if seeking a different remedy ” (Jumax Assoc. v. 350 Cabrini Owners Corp., 110 A.D.3d 622, 623, 973 N.Y.S.2d 631 [1st Dept. 2013] [internal quotation marks omitted], lv denied 23 N.Y.3d 907, 2014 WL 2922240 [2014]).  Contrary to plaintiff’s contention, the dismissal in the Westchester action was on the merits.  The order addressed the merits of the counterclaim, dismissing it on the basis of the settlement and the custody decision in the matrimonial action (see Plaza PH2001 LLC v. Plaza Residential Owner LP, 98 A.D.3d 89, 98, 947 N.Y.S.2d 498 [1st Dept. 2012] ).

R. A. Klass
Your Court Street Lawyer

.
Previous post

Statute of Limitations for Causes of Action Alleging Legal Malpractice

The Second Department, in Potenza v Giaimo, 165 AD3d 1186, 1187 [2d Dept 2018], dismissed a client’s legal malpractice action against his attorney based upon the statute of limitations. The court held:

The statute of limitations for causes of action alleging legal malpractice is three years (see CPLR 214[6]; Alizio v. Ruskin Moscou Faltischek, P.C., 126 A.D.3d 733, 735, 5 N.Y.S.3d 252). A cause of action to recover damages for legal malpractice accrues when the malpractice is committed (see Shumsky v. Eisenstein, 96 N.Y.2d 164, 166, 726 N.Y.S.2d 365, 750 N.E.2d 67). However, pursuant to the doctrine of continuous representation, the limitations period is tolled until the attorney’s continuing representation of the client with regard to the particular matter terminates (see Shumsky v. Eisenstein, 96 N.Y.2d at 167–168, 726 N.Y.S.2d 365, 750 N.E.2d 67; Aqua–Trol Corp. v. Wilentz, Goldman & Spitzer, P.A., 144 A.D.3d 956, 957, 42 N.Y.S.3d 56). For the continuous representation doctrine to apply, “ there must be clear indicia of an ongoing, continuous, developing, and dependent relationship between the client and the attorney which often includes an attempt by the attorney to rectify an alleged act of malpractice ” (Luk Lamellen U. Kupplungbau GmbH v. Lerner, 166 A.D.2d 505, 506–507, 560 N.Y.S.2d 787).

R. A. Klass
Your Court Street Lawyer

Next post
Previous post

A party must be mindful of the applicable statute of limitations

When bringing an action, a party must be mindful of the applicable statute of limitations.

Recently, the Second Department in King Tower Realty Corp. v G & G Funding Corp., 163 AD3d 541, 543 [2d Dept 2018] held:

“ ‘ On a motion to dismiss a cause of action pursuant to CPLR 3211 (a) (5) as barred by the applicable statute of limitations, a defendant must establish, prima facie, that the time within which to sue has expired. Once that showing has been made, the burden shifts to the plaintiff to raise a question of fact as to whether the statute of limitations has been tolled, an exception to the limitations period is applicable, or the plaintiff actually commenced the action within the applicable limitations period ’ ” (Quinn v McCabe, Collins, McGeough & Fowler, LLP, 138 AD3d 1085, 1085-1086 [2016], quoting Tsafatinos v Law Off. of Sanford F. Young, P.C., 121 AD3d 969, 969 [2014]; see Alizio v Ruskin Moscou Faltischek, P.C., 126 AD3d 733, 734-735 [2015]; Landow v Snow Becker Krauss, P.C., 111 AD3d 795, 796 [2013]). An action to recover damages for legal malpractice must be commenced within three years of accrual (see CPLR 214 [6]; McCoy v Feinman, 99 NY2d 295, 301 [2002]; Quinn v McCabe, Collins, McGeough & Fowler, LLP, 138 AD3d at 1086; Alizio v Ruskin Moscou Faltischek, P.C., 126 AD3d at 735; Farage v Ehrenberg, 124 AD3d 159, 163 [2014]; Landow v Snow Becker Krauss, P.C., 111 AD3d at 796). “ A legal malpractice claim accrues ‘when all the facts necessary to the cause of action have occurred and an injured party can obtain relief in court ’ ” (McCoy v Feinman, 99 NY2d at 301, quoting Ackerman v Price Waterhouse, 84 NY2d 535, 541 [1994]; see Farage v Ehrenberg, 124 AD3d at 164). “ In most cases, this accrual time is measured from the day an actionable injury occurs, ‘ even if the aggrieved party is then ignorant of the wrong or injury ’ ” (McCoy v Feinman, 99 NY2d at 301, quoting Ackerman v Price Waterhouse, 84 NY2d at 541). “ A cause of action to recover damages for legal malpractice accrues when the malpractice is committed, not when it is discovered ” (Alizio v Ruskin Moscou Faltischek, P.C., 126 AD3d at 735; see McCoy v Feinman, 99 NY2d at 301; Quinn v McCabe, Collins, McGeough & Fowler, LLP, 138 AD3d at 1086; Farage v Ehrenberg, 124 AD3d at 164; Landow v Snow Becker Krauss, P.C., 111 AD3d at 796). The continuous representation doctrine serves to toll the statute of limitations and render timely an otherwise time-barred cause of action for legal malpractice, but “ only where there is a mutual understanding of the need for further representation on the specific subject matter underlying the malpractice claim ” (McCoy v Feinman, 99 NY2d at 306; see Alizio v Ruskin Moscou Faltischek, P.C., 126 AD3d at 735).

R. A. Klass
Your Court Street Lawyer

Next post
Previous post

…Applicable to the particular matter in which malpractice is claimed

The statute of limitations in legal malpractice cases can be tolled when there has been continuous representation of the client by the attorney. However, it is applicable only to the particular matter in which malpractice is claimed.

See, Davis v Cohen & Gresser, LLP, 160 AD3d 484, 486 [1st Dept 2018], in which the court held:

“ the continuous representation doctrine does not apply where there is only a vague “ ongoing representation ” (Johnson v. Proskauer Rose LLP, 129 A.D.3d 59, 68, 9 N.Y.S.3d 201 [1st Dept. 2015] ). For the doctrine to apply, the representation must be specifically related to the subject matter underlying the malpractice claim, and there must be a mutual understanding of need for further services in connection with that same subject matter (see Shumsky, 96 N.Y.2d at 168, 726 N.Y.S.2d 365, 750 N.E.2d 67; see also CLP Leasing, 12 A.D.3d at 227, 784 N.Y.S.2d 535). ”

– R. A. Klass
Your Court Street Lawyer

Next post
Previous post

Issue of fact concerning the continuous representation doctrine

…issue of fact concerning the continuous representation doctrine…

In an action brought by a client against his law firm, the appellate court reversed the granting of the law firm’s motion for summary judgment based upon an issue of fact concerning the continuous representation doctrine.

Under the continuous representation doctrine, a person seeking professional assistance is placed in a difficult position if required to sue his or her attorney while the attorney continues to represent them on a particular legal matter (Shumsky v. Eisenstein, 96 N.Y.2d 164, 167–168, 726 N.Y.S.2d 365, 750 N.E.2d 67 [2001] ). Accordingly, the doctrine tolls the running of the statute of limitations on malpractice claims until the ongoing representation is completed (id.). However, the application of this doctrine is limited “to the course of representation concerning a specific legal matter,” and is not applicable to the client’s “continuing general relationship with a lawyer … involving only routine contact for miscellaneous legal representation … unrelated to the matter upon which the allegations of malpractice are predicated” (id. at 168, 726 N.Y.S.2d 365, 750 N.E.2d 67). The record presents an issue of fact as to whether defendant continuously represented plaintiff in connection with a personal injury claim based on the accident, such as to toll the statute of limitations during that time (see Glamm v. Allen, 57 N.Y.2d 87, 94, 453 N.Y.S.2d 674, 439 N.E.2d 390 [1982]; Waggoner v. Caruso, 68 A.D.3d 1, 6–7, 886 N.Y.S.2d 368 [1st Dept. 2009] ). Encalada v McCarthy, Chachanover & Rosado, LLP, 160 AD3d 475 [1st Dept 2018].

R. A. Klass
Your Court Street Lawyer

Next post
Previous post

Statute of Limitations and Mortgage Foreclosure

Plaintiff may not maintain an action to foreclose the mortgage upon Defendants’ real property if the action is barred by the statute of limitations specified in CPLR 213(4). When a mortgage lender elects to accelerate a defaulted loan and declares the full principal balance immediately due and payable, then the six-year limitation period on a foreclosure action begins to run. See Lavin v. Elmakiss, 302 A.D.2d 638, 639, 754 N.Y.S.2d 741, 743 [3d Dept. 2003]; CPLR Section 213(4). As stated in Loiacono v. Goldberg,240 AD2d 476, 477 [2 Dept. 1997], “Once the mortgage debt is accelerated, the entire amount is due and the statute of limitations begins to run on the entire mortgage debt.” Loiacono v. Goldberg, 240 A.D.2d 476, 277 [2d Dept. 1977]; see Zinker v. Makler, 298 A.D.2d 516, 517 [2d. Dept. 2002]. The statute of limitations for an action to foreclose a mortgage is six years [CPLR 213(4)].

In accordance with well-settled case law, once a defendant has met his prima facie burden of proof that Plaintiff’s time to sue has expired, the burden now shifts to Plaintiff to aver evidentiary facts establishing that the action was timely commenced or falls within an exception to the statutory period. Assad v. City of New York, 238 A.D.2d 456 [2d Dept. 1997]; see alsoSavarese v Shatz, 273 AD2d 219, 220 [2d Dept 2000].

Ordinarily, the Statute of Limitations on a mortgage loan would be six years. However, there are two ways in which the statute may be tolled. The first is found in General Obligations Law Section 17-101, where a signed written acknowledgment of an existing debt that contains nothing inconsistent with an intention on the part of the debtor to pay it will toll the Statute of Limitations and start it running anew. See Lew Morris Demolition Co. v. Board of Educ. of City of N.Y., 40 N.Y.2d 516, 520-521, 387 N.Y.S.2d 409, 411, 355 N.E.2d 369, 371; see, alsoConnecticut Trust & Safe Deposit Co. v. Wead, 172 N.Y. 497, 500, 65 N.E. 261, 501; Curtiss-Wright Corp. v. Intercontinent Corp., 277 App.Div. 13, 16-17, 97 N.Y.S.2d 678, 680; Siegel, New York Practice, s 50). The second way to either toll or restart the statute of limitations was developed by the common law, and is based on a partial payment of the debt before or after the statute has expired. However, in order to toll the statute or start it running anew, it must be shown that the payment was of a portion of an admitted debt under circumstances amounting to a clearly demonstrated intention to pay the balance. See Crow v. Gleason, 141 N.Y. 489, 493, 36 N.E. 497, 498; Matter of Fitch, 270 App.Div. 227, 237-238, 58 N.Y.S.2d 833, 840. Bernstein v Kaplan, 67 AD2d 897, 898 [2d Dept 1979].

The fact that a homeowner listed a mortgage debt in his bankruptcy petition is not a promise to pay the debt. In fact, the Bankruptcy Court, in discharging the defendant, did not endorse any position other than the fact that the note or mortgage was his valid debts. Saini v Cinelli Enterprises Inc., 289 AD2d 770, 773 [3d Dept 2001].

R. A. Klass
Your Court Street Lawyer

Next post
Previous post

33 Year Old Mortgage Doomed by Statute of Limitations

Photo, of a dog wearing a pink dress and pink sunglasses with the caption "That's Queen to You," illustrating an article, by Richard A. Klass, entitled Statute of Limitations Dooms Sister-in-Law’s 33 Year Old Mortgage

Way back in 1982, a wife and her husband purchased a home in Brooklyn. The wife’s mother-in-law — her husband’s mother — provided $20,000 to help the couple make the purchase. At the time the money was provided, the mother-in-law had not firmly decided whether she considered the $20,000 a gift or a loan.

In any event, the wife signed a mortgage in favor of her mother-in-law which contained no terms of repayment (that part was left blank) and no mortgage note was signed. The mortgage stated that the whole balance could be declared due at the option of the mortgagee after default in the payment of any installment or principal or of interest for fifteen days. It was alleged that the mother-in-law never made any demand during her lifetime for repayment of the money. The mortgage was never recorded by the mother-in-law with the City Register’s Office.

Sister-in-Law’s Assignment of Mortgage

In 1998, the mother-in-law signed an assignment of the $20,000 mortgage over to her own daughter. In 1999, the mother-in-law passed away. Unfortunately, in September 2013, the husband passed away, leaving the wife, now a widow, the sole owner of the house as the surviving spouse. About a month after the husband’s death, the sister-in-law — the dead husband’s sister — recorded both the mortgage and the assignment of mortgage with the City Register’s Office.

Sale of the House

After the death of her husband, the widow/homeowner decided to sell the house and relocate from New York. In connection with the sale, the woman now had to deal with her sister-in-law and the $20,000 “mortgage.” The widow retained Richard A. Klass, Your Court Street Lawyer, to sue her sister-in-law to discharge the mortgage of record. An action was brought under New York Real Property Actions and Proceedings Law Section 1501(4).

The sister-in-law answered the complaint, alleging that both her brother and his wife frequently reassured her and her mother that the mortgage would be satisfied when the house was sold. She claimed that the law should uphold the covenant to pay the debt as set forth in the mortgage even though there was no note. The sister-in-law also asserted counterclaims (and brought the house’s new owners into the case) to foreclose on the old mortgage and obtain a money judgment, claiming the sums of $20,000 for the principal amount of the loan plus another $98,000 representing 33 years’ worth of interest at 15% per annum.

Mortgage Barred by Statute of Limitations

New York State law provides that “an action upon a bond or note, the payment of which is secured by a mortgage upon real property, or upon a bond or note and mortgage so secured, or upon a mortgage of real property, or any interest therein,” must be commenced within six years. CPLR 213(4). When the terms of the mortgage provide for its repayment in installments, separate causes of action for each installment accrues and the Statute of Limitations begins to run on the date each installment becomes due. Pagano v. Smith, 201 AD2d 632 [1994]. However, once the mortgage debt is accelerated, the entire amount is due and the Statute of Limitations begins to run on the entire mortgage debt. Lolacono v. Goldberg, 240 AD2d 476 [1997].

In this case, the 1982 mortgage had no provision stating when payment was due, since those provisions of the mortgage were left blank. Under such circumstance, New York courts have held that the loan is presumed to be payable upon demand, and the Statute of Limitations accrues from the date of the mortgage. See, Martin v. Stoddard, 127 NY 61 [1891]. Corrado v. Petrone, 139 AD2d 483 [1988]. The court noted that, absent any written payment terms, the Statute of Limitations began to accrue when the 1982 mortgage was executed, expiring six years later in 1988 (more than ten years before the 1998 assignment to the sister-in-law).

No oral representations

In response to the sister-in-law’s claim that her brother and his wife repeatedly said that the debt would be paid at the end of the 30-year term, the court rejected the claim, noting that the mortgage contained an important clause stating that “this mortgage may not be changed or terminated orally.” Oral representations (such as those allegedly made in this case) may not be considered based upon the “parol evidence rule,” by which oral statements in contravention to the written contract are inadmissible as evidence.

In granting the plaintiff’s motion to dismiss the counterclaims, the Judge held that the defenses and proposed counterclaims of the sister-in-law should properly be dismissed and the mortgage canceled and discharged of record. Nagrotsky v. Koch, Sup. Ct., Kings Co. Index No. 506293/2015, 1/19/2016.

— Richard A. Klass, Esq.

Richard A. Klass, Esq., maintains a law firm engaged in civil litigation at 16 Court Street, 28th Floor, Brooklyn Heights, New York. He may be reached by phone at (718) COURT-ST or e-mail at RichKlass@courtstreetlaw.com with any questions. Prior results do not guarantee a similar outcome.

Injured person can amend complaint to assert claims against third parties under CPLR 1009

When you have been injured due to an accident, it is common to look to litigation as a way of compensation for pain, suffering, lost wages and other damages, especially when the accident was not your fault. But what happens when you start a litigation against one party when, in fact, there is another, necessary party that should have been sued but was not?

Loo was injured at work one day when she slipped and fell in the bathroom, breaking her ankle. After missing work, suffering pain and other damages, Loo decided to sue for damages, but did not know exactly who to sue. She was not able to sue her employer so instead she sued the owner of the building in which she worked. Once the litigation began she found out that her employer agreed to protect the building owner from any damages arising from its use of the building (also known as indemnification). The building owner then sued Loo’s employer on the basis that Loo’s employer agreed to pay for any damages.

Loo’s employer, after being brought into the action by the building owner then sued another party, the cleaning company the employer had hired to clean and maintain the facilities. The employer stated in the complaint that the cleaning company had agreed to protect it from any damages arising from work the cleaning company did or was supposed to do according to the contract.

Loo’s attorney, upon learning this new information about the cleaning company, realized he needed to sue the cleaning company directly, as it was the cleaning company that may be ultimately responsible for the damages sustained by Loo.

In order for Loo to add the cleaning company in the litigation, she would have to use what is called an impleader. An impleader is a procedure whereby a plaintiff adds a third party into a lawsuit because that third party is liable for damages to the plaintiff. When Loo’s attorney filed an impleader, including the cleaning company as a defendant, the cleaning company’s attorney rejected the complaint on the basis that the statute of limitations[1] had already expired and that Loo’s attorney had served its amended complaint too late.

Loo’s attorney came to Richard A. Klass, Your Court Street Lawyer, for assistance. Mr. Klass recognized that CPLR 1009 allows that within 20 days of service of an answer to the third-party complaint upon the plaintiff’s attorney, the plaintiff may amend its complaint without leave of court to assert against the third party any claim plaintiff has against the third party defendant.

Furthermore, when a pleading is mailed, CPLR 2013(b)(2) adds five days to the initial 20 days provided for in CPLR 1009.

Mr. Klass, upon reviewing the affidavits of service, quickly realized that based upon these two provisions of the CPLR, Loo’s attorney may, in fact, have served the amended complaint in time.

The Court agreed with Mr. Klass, determining that Loo’s attorney had served the amended complaint with 2 days to spare. Therefore, the cleaning company, the company who may ultimately be responsible for Loo’s injury, has been included as a defendant that Loo may look to for payment of her damages.

 

Footnotes

[1] The statute of limitations is part of our basic set of laws which provides a time limit in which a plaintiff can sue a defendant. For a case of personal injury, a plaintiff has only 3 years from the date of the injury to sue for damages.

by Richard A. Klass
copyright 2015

New York foreclosure cases nearing 6 year statute of limitations

As reported today in the New York Times, there are increasing numbers of foreclosure cases in New York State where lenders may be unable to seize homes.  Why?  Because the State’s statute of limitations on foreclosure cases may be exceeded.

If you have a foreclosure case that has been dragging on for nearly six years, there may be relief on the horizon.

Does this sound similar to your situation?  If so, and if you require legal representation, call my office for more information.

The full New York Times article is available here: http://nyti.ms/1G6IuQ3

— by Richard A. Klass, Esq.

———–
copyr. 2015 Richard A. Klass, Esq.
The firm’s website: www.CourtStreetLaw.com
Richard A. Klass, Esq., maintains a law firm engaged in civil litigation in Brooklyn Heights, New York.
He may be reached at (718) COURT-ST or e-ml to RichKlass@courtstreetlaw.com with any questions.
Prior results do not guarantee a similar outcome.

Lawyer Misses the Bus (a $300,000 tale of woe)

Decorated bus illustrating article by Richard Klass.  Topics include New York City Transit Authority

The cabbie’s nightmare began with courtesy and continued with insult and injury.

It began as just another busy day in the life of a New York livery cab driver: picking up and dropping off passengers. On this particular day, the cabbie had pulled to the curb just past a bus stop in Manhattan to let out a passenger. He then stepped out of the car to open the passenger’s door. Perhaps he thought a little extra courtesy might result in a bigger tip but, no matter the reason, in this case, it cost him dearly.

The next moment, a New York City Transit Authority (NYCTA) bus, while running its regular route, pulled behind the livery cab at the bus stop. The bus driver opened his door and shouted at the driver, “You idiot, what are you doing in the bus stop!” The cabbie calmly apologized and said he’d move his car. However, without waiting for that to happen, the bus driver drove the bus close to the cabbie, requiring him to close his passenger door slightly so as to avoid his car door being damaged by the bus. The bus driver then accelerated the bus and drove closer, striking the cabbie, and causing him severe personal injuries.

The injured driver hired a law firm to bring a personal injury claim. That law firm brought a case against the New York City Transit Authority, seemingly the owner and operator of the bus. Unfortunately, the law firm did not learn that the bus operator could only have been an employee of a separate public authority known as the Manhattan and Bronx Surface Transit Operating Authority (MABSTOA) until long past the statute of limitations period in which to make a claim. Only at the deposition of the bus depot dispatcher, held more than two years after the incident, did the law firm learn from the witness that the bus operators for that bus route were all MABSTOA employees and not New York City Transit Authority employees (and only because all bus operators listed on the “crew report” had the designation “M” for MABSTOA).

The case against the New York City Transit Authority went to trial and the jury rendered a verdict in favor of the New York City Transit Authority and dismissed the claims of the livery cab driver. The cab driver then retained Richard A. Klass, Your Court Street Lawyer to make a claim against the personal injury law firm for legal malpractice.

Time-barred by the Statute of Limitations:

The concept of a “Statute of Limitations” is that people are afforded a certain amount of time to take action concerning a legal claim they may have; if that period of time passes without taking action, then the ability to pursue the legal claim has been waived. Most people are familiar, for instance, that in New York State the statute of limitations period within which to file most personal injury cases is three years from the date of accident. In this particular case, though, a notice of claim had to be served upon MABSTOA within 90 days of the incident under certain rules contained in the Public Authorities Law and General Municipal Law Section 50-e; then, an action had to be commenced in 1 year and 90 days after the incident.

Confusion between the MTA, NYCTA and MABSTOA:

Within the “alphabet soup” letters of all of these different municipal authorities lays a trap to catch the unwary. According to the statutory scheme laid out in the Public Authorities Law Section 1260 et. seq., the Metropolitan Transportation Authority (MTA) is a public benefit corporation which was created to oversee the mass transportation systems of New York City, and which functions as an umbrella organization for various other independent but affiliated agencies. See, In re New York Public Interest Research Group Straphangers Campaign, Inc., 309 AD2d 127 [1 Dept. 2003]. However, aside from the MTA’s overall organization, the MTA and each of its subsidiaries (which include NYCTA and MABSTOA) must be separately sued and are not responsible for each other’s torts. See, Mayayev v. Metropolitan Transportation Authority Bus, 74 AD3d 910 [2 Dept. 2010]. As provided for in Public Authorities Law Section 1203-a, MABSTOA is a subsidiary, public benefit corporation.

In Nowinski v. City of New York, 189 AD2d 674 [1 Dept. 1993], the plaintiff sued MABSTOA for personal injuries sustained at a location for which the New York City Transit Authority maintained responsibility. The plaintiff sought to serve a late notice of claim and both MASTOA and New York City Transit Authority moved to dismiss the action. The court held that the injured person was time-barred from serving the late notice of claim, given that the statute of limitations had already long expired. (See, generally, Public Authorities Law Section 1276).

No claim for being “lulled” into a false sense of security:

To the extent that the law firm could have claimed in its defense that it could not have known of the relationship between the MABSTOA, MTA, New York City Transit Authority and the relevant bus operators identified in the crew report, the court in Delacruz v. Metropolitan Transportation Authority, 45 AD3d 482 [1 Dept. 2007], held that the injured plaintiff could not claim that, by the actions of the MTA, he was “lulled into a false sense of security” that his lawyer sued the right public authority. The court specifically held the doctrine of “equitable estoppel” applies only when a governmental subdivision acts wrongfully or negligently inducing reliance by a party who is entitled to rely and who changes his position to his detriment or prejudice. There was no evidence here of any wrongful conduct by the New York City Transit Authority; it did not hide the information about MABSTOA or mislead the injured driver’s lawyer.

The legal malpractice claim was settled for $300,000 to pay for the livery cab driver’s injuries and medical lien. This case only emphasizes the point of how important it is for a lawyer to identify the proper legal entities to be sued on behalf of a client.

— by Richard A. Klass, Esq.

———–
copyr. 2014 Richard A. Klass, Esq.
The firm’s website: www.CourtStreetLaw.com
Richard A. Klass, Esq., maintains a law firm engaged in civil litigation in Brooklyn Heights, New York.
He may be reached at (718) COURT-ST or e-ml to RichKlass@courtstreetlaw.com with any questions.
Prior results do not guarantee a similar outcome.

Art credits:
Image at top of page: El Gouna (Red Sea, Egypt): public transport bus, customized and highly decorated in genuine Pakistani style. Coach built by Chishti Engineering (Karachi) and decorated by S. Gulzar (Karachi). Author/photographer: Marc Ryckaert, 2009. This image is licensed under the Creative Commons Attribution 3.0 Unported license.