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Need Sample Form
by Matthew Worner 10 Mar '26

10 Mar '26

Hi listmates, I recently represented a defendant in a residential mortgage foreclosure action and won after a bench trial. The judge correctly ruled that the plaintiff did not properly show compliance with RPAPL 1304 (the 90 day pre-foreclosure notice requirement) and has asked me to prepare a proposed order. Rather than trying to reinvent the wheel, does anyone have a sample order dismissing the action after a bench trial? Matt Worner mtw(a)wornerlaw.com<mailto:mtw@wornerlaw.com>. The Law Office of Matthew T. Worner 470 Mamaroneck Avenue, Suite 409 White Plains, NY 10605 (914) 949-4239

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Re: Recommendation for a "Qualified Real Estate Professional" Consultant
by Christian Jensen 10 Mar '26

10 Mar '26

Does anyone have a recommendation for the above in relation to tax treatment / active v passive participation in real estate. The IRS criteria/tests are straightforward but a contact is looking for an introduction to a consultant who has deep experience and can help flag pitfalls and best practices. Thanks in advance. [cid:image001.png@01DCB082.50954870] Christian Jensen Jensen Law Firm LLC 233 Mount Airy Road, Suite 133 Basking Ridge, NJ 07920 christian(a)jensenfirm.com<mailto:christian@jensenfirm.com> Direct: (908) 758-1265 Fax: (908) 332-5737 405 Lexington Avenue New York, NY 10174 LinkedIn<https://www.linkedin.com/in/christian-jensen-16110119/> Schedule a Meeting<https://calendly.com/jensenfirm> *Certified by the NFLPA as an NFL Contract Advisor Sports/NIL Attorneys<https://www.nil-attorneys.com/> Tax Advice Disclosure: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein. This e-mail is confidential and may well be legally privileged. If you received it in error, you are on notice of its status. Please notify us immediately by reply e-mail and then delete this message from your system. Please do not copy it or use it for any purposes or disclose its contents to any other person. To do so could violate state and federal privacy laws. Thank you for your cooperation.

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Fwd: Any Recommendations for Plaintiff-side Employment Counsel in the Finger Lakes Region?
by Christian Jensen 10 Mar '26

10 Mar '26

Morning! Does anyone have a referral for plaintiff-side employment counsel in the Finger Lakes region? Sounds like facts relate to sexual harassment/retaliation. Thanks in advance. This for a colleague so names will be passed along. Chris [image: image.png] *Christian Jensen* *Jensen Law Firm LLC* 233 Mount Airy Road, Suite 133 Basking Ridge, NJ 07920 Direct: (908) 758-1265 Fax: (908) 332-5737 Tax Advice Disclosure: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein. This e-mail is confidential and may well be legally privileged. If you received it in error, you are on notice of its status. Please notify us immediately by reply e-mail and then delete this message from your system. Please do not copy it or use it for any purposes or disclose its contents to any other person. To do so could violate state and federal privacy laws. Thank you for your cooperation.

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Request for NJ Attorney
by Matthew Worner 10 Mar '26

10 Mar '26

Hi listmates, clients live in a condominium in Mahwah, NJ. Condominium hired a roofer to install a new roof and after ripping off the existing roof, the tarps came loose and water leaked into the clients' unit causing damage to the drywall and extensive mold. Roofer took full responsibility yet refuses to pay for the needed repairs and the condominium refuses to get involved. Clients own insurer is also refusing to pay. Client's wife is set to give birth in 5 weeks and they need help! I know exactly what to do but I am not licensed in NJ. mtw(a)wornerlaw.com<mailto:mtw@wornerlaw.com>. The Law Office of Matthew T. Worner 470 Mamaroneck Avenue, Suite 409 White Plains, NY 10605 (914) 949-4239

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suggesiton for a mediatior-retired judge-to use for Nj false arrest case
by Adam Thompson 10 Mar '26

10 Mar '26

Hi ListMates, Can someone recommend a plaintiff-side user friendly retired judge mediator to use for a NJ civil rights action involving an unlawful stop and detention, false arrest, abuse of process, and improper use of force( grabbing/shoving/pushing)? This is for a New Jersey case. Thank you and much appreciated, Adam Thompson, PartnerLaw Office of Adam M. Thompson, P.C.

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Question Regarding NY Law and Rule 3221
by Aaron Pierce 10 Mar '26

10 Mar '26

Hi ilaw, Question: CPLR 3211 discusses an "offer to compromise". Here is the link to the statute: https://law.justia.com/codes/new-york/cvp/article-32/r3221/ Is this something used in NY Supreme Court? For example, if I represent a defendant in a civil litigation in a NY Supreme Court matter wherein the lawsuit seeks $3MM in damages, and I send an offer to compromise of $5000.00 even before discovery begins, and then, at trial the Plainitff fails to recover even that amount, does the Plaintiff then have to cover the Defendant's legal fees and court costs of the litigation from the time of the offer forward? Am I reading this correctly? Much appreciate your responses! ------------------------------------------------------ *Aaron H. Pierce, Esq.* Partner Pierce & Kwok LLP Pierce & Kwok LLP 299 Broadway, Suite 1405 New York, NY 10007 Phone: (212) 882-1752 Direct: (347) 678-7262 Fax: (212) 882-1742 Email: aaron.pierce(a)piercekwok.com Website: www.piercekwok.com ------------------------------------------------------ NOTICE: Unless stated otherwise, *nothing in this email constitutes an offer at law and is for negotiation purposes only*. All rights are reserved to make additional alterations to any contractual agreement attached or embedded within the body of this email. This transmission is intended by the sender and proper recipient(s) to be confidential, intended only for the proper recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s) you are notified that the dissemination, distribution or copying of this message is strictly prohibited. If you receive this message in error, or are not the proper recipient(s), please notify the sender at either the email address or telephone number above and delete this email from your computer. Receipt by anyone other than the proper recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.

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Re: recommendations for med. mal. attorney
by Michael C. Xylas 10 Mar '26

10 Mar '26

Hello List mates: Looking for a recommendation as to a top medical malpractice firm/attorney for a matter involving an NYC hospital's negligence. Thanks, [A blue square with gold letters AI-generated content may be incorrect.] Michael Xylas Partner * Abrams Garfinkel Margolis Bergson, LLP 1430 Broadway * 8th Floor * New York, New York, 10018 P: (646) 473-7567 * F: (646) 778-3709 mxylas(a)agmblaw.com * www.agmblaw.com<http://www.agmblaw.com> Disclaimer The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. This email has been scanned for viruses and malware, and may have been automatically archived by Mimecast, a leader in email security and cyber resilience. Mimecast integrates email defenses with brand protection, security awareness training, web security, compliance and other essential capabilities. Mimecast helps protect large and small organizations from malicious activity, human error and technology failure; and to lead the movement toward building a more resilient world. To find out more, visit our website.

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Company named erroneously in a lawsuit
by Howard Sommers 10 Mar '26

10 Mar '26

A client was named in a lawsuit just because it has a name that is similar to the company that is properly named as a defendant. The plaintiff's law firm is refusing to dismiss my client and instead is saying it will sign a stipulation agreeing to postpone the time to answer if the client waives jurisdictional defenses and the right to make any pre-answer motions. The client does not have a lot of money but it seems it needs to move to dismiss this case. It is in Supreme Court, Kings County. Can someone do this inexpensively? Is there a chance to have the plaintiff's attorney sanctioned for just including a company because it has a similar name to the proper defendant and then refusing to dismiss even without prejudice? Thank you. Howard M. Sommers, Esq. Of Counsel Aronauer & Yudell, LLP 711 Westchester Avenue, Suite 405 White Plains, New York 10604 212-755-6000 ext 127 212-755-6006 Fax 917-331-2727 Cell Website: www.ayllp.com<http://www.ayllp.com/>

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Changing Remainder interst on Life Estate Deed
by Renee Giorgini 09 Mar '26

09 Mar '26

PC transfers real property to SON1, reserving a life estate but no power of appointment. Less than a year later, PC wants SON2 to be added as a remainder on the same property. Typically, I would draft a new deed from PC and SON1 to SON1 and SON2 again reserving a life estate to PC. PC is conerned that SON1 will not cooperate in signing a new deed giving his brother half the remainder interest. If this is true, is there any way to cancel the prior deed to SON1? *Renee L. Giorgini, Esq.* *Renee L. Giorgini, P.C.* *326 S. Wellwood Avenue* *Lindenhurst, NY 11757* *Tel 631 957 9600* *Fax 631 957 5020* *NOTICE:* The information contained in and attached to this e-mail is intended only for the personal and confidential use of the designated recipient(s) above. This message may be an attorney/client communication and as such is privileged and confidential. Any review, retransmission, dissemination or other use of or taking action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you received this communication in error, please notify us immediately by reply e-mail, and delete the original message.

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Office for Lease in Historic Downtown Woolworth Building
by Jill Miller 09 Mar '26

09 Mar '26

Dear friends and colleagues, Hope you are all having a great week! I have a large beautiful partnered sized windowed office available for sublet in my office suite in the historic downtown Woolworth Building that is close to the courts. *This is a great opportunity for networking and referrals which will cover your costs of operation!* A flyer with the details and photos is attached below. If you or anyone you know is interested in joining our office suite, please reach out or spread the word! With gratitude, Jill Jill L. Miller [image: Fellow The American College of Trust and Estate Counsel] __________________________________________ Jill Miller & Associates, P.C. 233 Broadway, Suite 801 New York, New York 10279 508 Second Avenue Asbury Park, New Jersey 07712 www.mtrustlaw.com Ph: (212) 601-2425 Cell: (917) 623-4142 e-mail: jmiller(a)mtrustlaw.com This electronic message is from a law firm. It may contain confidential or privileged information. If you received this transmission in error, please reply to the sender to advise of the error and delete this transmission and any attachments.

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