RCBA NewsBrief January 2009
COMMERCIAL LITIGATION ISSUES OF INTEREST
BOARD OF Submitted by Paul Savad, Esq., Chair, Commercial and Corporate Law Committee;
DIRECTORS Susan Cooper, Esq., and Joseph Churgin, Esq., of Paul Savad & Associates
Stephen B. Lowe Your client signed a contract to purchase a home. The contract, which is a standard
Glenn W. Kelleher
form approved by the Bar Association and used by upstate brokers for residential home sales, is
Lynne S. Hilowitz
Vice President contingent on the approval of the parties’ attorneys. The contract provides that disapproval by
Keith J. Cornell
Treasurer either attorney within three days of signing voids the contract. A day after signing, your client
Secretary changes his mind and decides not to purchase the home. Although you have no reason to
Sandria P. Garvin
Executive Director disapprove the contract, you disapprove the contract at your client’s direction.
Directors: Will you defeat a claim for damages for breach of contract?
Marilyn P. Davis
Andrew DePodwin The answer is yes.
Alan E. Goldstein
Alan G. Rosenblatt
Patrick T. Burke
In Moran v. Erk, N.Y.L.J. (11/ 26/08, p.26), the Erks contracted to purchase the Morans’
Robert D. Fenster
Cassandra Bilotta home in Erie County. The contract included the following provision:
Robert B. Marcus “This contract is contingent upon approval by attorneys for seller and
Ira S. Schoeps purchaser by the third business day following each party’s attorneys’
Shelley Forde receipt of a copy of the fully executed contract (“the Approval Period”)…
Michelle Tierney if either party’s attorney disapproves this contract before the end of the
Approval Period, it is void and the entire deposit shall be returned.”
The contract is a form approved by both the local Board of Realtors and the Erie County
Inside This Issue
Bar Association. These form contracts are routinely used in upstate New York, where brokers
Commercial Litigation obtain the parties’ signatures, subject to attorney approval. This ensures that real estate brokers
Issues of Interest
by Paul Savad, Esq. avoid the unauthorized practice of law.
Page 3 Within three days of signing the contract, the Erks decided not to purchase the home
& and instructed their attorney to disapprove the contract. Although the attorney had no
objections to the contract, he disapproved it, at this clients’ direction.
Top 10 Commercial Meanwhile, the Morans moved and their home stayed on the market for three more
Litigation Cases decided by
NYS Court of Appeals in years, eventually selling for $165,000 less than the Erk contract price. Five years after the
by: Judah S. Shapiro, Esq. contract with the Erks was signed and cancelled, the Morans sued the Erks for breach of
contract, demanding the difference in price and the costs of marketing the property for three
Mock Trial Report years.
Holiday Party Update The trial court ruled in favor of the Morans, holding that the contract was cancelled in
Page 7-12 bad faith, relying on McKenna v. Case, 123 A.D.2d 517 (4th Dept. 1986), which held that attorney
Bankruptcy Law Update
Classifieds disapproval would terminate rights under the contract, unless the disapproval “is occasioned by
CLE Calendar bad faith”. The Appellate Division affirmed the Morans’ judgment, and the Erks appealed.
Page 13 The Court of Appeals reversed, ruling that an attorney may utilize an approval
provision to void a purchase contract for any reason whatsoever. The reason will not be
CLE Registration scrutinized. There are no limitations on the attorneys’ disapproval.
Continued on Page 2…..
PAGE 2 VOLUME 1
COMMERCIAL LITIGATION ISSUES OF INTEREST
The court rejected the Morans’ argument that the implied covenant of good faith and fair dealing required the
attorney to act in good faith. The court reasoned that the clear language of the contract made it contingent on attorney
approval. Without that approval, no implied contract right of good faith and fair dealing arose.
The court noted that any inquiry into an attorney’s bad faith would subject the attorney to testifying about
confidential client communications, which would have a chilling effect on attorneys’ discussions with their clients.
The court specifically limited its holding to attorney approval contingencies with no explicit limitations, as in this
Editor’s comment: It would appear that this rule would apply to real estate brokers’ binders that are subject to
contract and attorney’s approval.
If you want to limit an attorney’s right to disapprove a contract which is to be contingent upon an attorney’s
approval, you must include limits for disapproval.
12 tips from Lawyer Assistance Program
These tips are offered to aid in one’s personal life. The following are the 12 suggested steps of Alcohol
Anonymous, a proven self-help organization.
1. Recognize I have a problem. Denial is a barrier to moving on.
2. Accept that another party can assist with the situation. Discuss the situation with a trusted friend. Seek counseling.
3. Trust that another party can handle the responsibility. Let go of ownership of the problem and assign the mechanics to a
4. Examine my self. What are my strengths? What are my weaknesses? What do I wish to keep? What do I wish to
5. Recognize my weaknesses by revealing them to a trusted party; communicate my willingness to change.
6. Prepare to make the change. Resolve I will be a different person, for the better.
7. Take the action to change. Move from resolution to doing.
8. List persons to strengthen our relationship. Improve communication with people in our lives.
9. Actually talk, see, and be with people that are in your life. Be active; be personable.
10. Do a regular inventory of myself. Periodically take stock of where I’m at, where I’ve been and where I’m going. List my
plusses and minuses. Recognize where I need to improve.
11. Use mediation. Practice speaking my wishes. Learn to listen to the whispering of serendipity; to hear things I missed in
12. Help others. Be active in community. Offer to do things that contribute to the larger world.
It’s not easy to admit there is a problem. It’s even harder when you think no one notices. But they do. Asking for help could
be difficult. Knowing there is help available makes it a little easier. Understanding the unique needs of our colleagues is
crucial that’s why we’re here for you.
LAWYERS HELPING LAWYERS
Ben Selig, Esq., (845) 942-2222; Barry Sturtz, Esq., (845) 369-3000
Paul Goldhamer, Esq., (845) 356-2570; Lynn Brustein-Kampel, Esq., (845) 634-4700
VOLUME 1 PAGE 3
On the passing of her
There will be a Memorial Service for our friend and colleague,
Hon. Joel Flick
Who died in August, 2008
The service will be at 9:30 a.m. on Thursday, January 8, 2009
Courtroom of the Hon. Margaret Garvey,
Supreme Court, New City
VOLUME 1 PAGE 4
TOP TEN COMMERCIAL LITIGATION CASES DECIDED BY
THE NY COURT OF APPEALS IN 2008
Submitted by Judah S. Shapiro-Member of the Commercial and Corporate Law Committee
The Court of Appeals decided a number of interesting and important commercial cases in 2008. This article summarizes a broad
range of topics which should be of interest to Rockland attorneys with practice areas in contracts, real estate, corporations, as well as
personal injury attorneys dealing with insurance companies.
1. In a commercial case that impacts real estate, contract, labor and tort law the Court in Santass v. Consolidated Investment Co.
Inc., 10 N.Y.3d 333, 858 N.Y.S.2d 67, in a 5-2 decision overturned the Appellate Division and held that a commercial landlord
could be held liable for an injury to a worker even though the tenant contracted for the work without the landlord’s knowledge.
Indeed, the Court, over the dissents of Judges Smith and Read, held that the landlord could be held liable under Labor Law §240
(1) to plaintiff, (an air conditioner installer hired by a commercial tenant) despite tenant’s violation of a specific lease provision
requiring tenant to obtain prior written consent to any alteration to the building. The majority opinion stresses that even under
these circumstances, where there is a clear breach of reasonable contract provision, New York’s Labor Law statute placed strict
liability for worker injuries upon the landlord.
2. Similarly, commercial landlords came up short in P.A. Building. Co. v. City of New York, 10 N.Y.3d 430, 860 N.Y.S.2d 1, when
the Court in a 5-2 decision reversed the Appellate Division and held that asbestos abatement costs incurred by the landlord were
not “operating expenses” under the lease terms and thus could not be passed on to the commercial tenant as additional rent.
What makes this case of particular interest, read with a litigator’s view, is that the majority seems to reject the dissent’s view that
the very essence of escalation clauses is to “protect against unforeseen developments that make running a building more
expensive including “regulation changes.” Id 443 (emphasis added) and instead held that chargeable operating expenses are only
those which would have been anticipated at the lease’s inception. Given the tendency to construe terms or lack of terms against a
landlord (albeit much less so in commercial leases) practitoners representing property owners should be mindful of detailing
operation costs and escalation clauses.
3. Insurance contracts were also subject to scrutiny by the Court of Appeals in 2008 and practitioners should be on notice, of the
importance of notice provisions in insurance contracts. While as a general rule ambiguous terms of an insurance contract are
construed in favor of the insured, clear an unambiguous terms will be enforced. This seems to apply particularly with respect to
strict notice provisions. In Sorbara Construction Corp. v. AIU Insurance. Co., the insurer was sued to defend or indemnify. The
Court affirmed judgment for the defendant-insurer where the policy of liability insurance required that notice of an occurrence
be given “ as soon as practicable,”. The Court held that such notice must be provided within a reasonable period of time and
failure to give such notice relieves the insurer of its obligations under the contract, regardless of whether the insurer was
prejudiced by the delay. Moreover, notice provided under the worker’s compensation policy at the time of the incident did not
constitute notice under the liability policy even though both policies were written by the same insurance carrier.
4. Insurance carriers did not far as well in a pair of cases which seem to expand potential insurer liability for breach of an insurance
contract to include consequential damages. In Bi-Economy Market, Inc. v. Harleysville Insurance Company of New York, 10
N.Y.3d 187, 856 N.Y.S.2d 505, the insured, a family owned meat business, sought consequential damages from insurer’s bad faith
breach of contract. The Court held that the collapse of the insured’s business was a foreseeable result from the breach of contract,
and therefore summary judgment order dismissing the breach claim was in error. Similarly, in Panasia Estates, Inc. v. Hudson,
10 N.Y.3d 200, 856 N.Y.S.2d 514, the Court recognized tort causes of action for a insurer’s alleged failure to perform its
contractual obligation under an insurance contract, which is apparently something the Court of Appeals did not do until this
year. Thus, consequential damages can be recovered from a breach of an insurance contract, as long as the damages were
contemplated and foreseeable.
5. Interestingly, in Rivkin v. Century 21 Teran Realty LLC, 10 N.Y.3d 344, the Court held that a real estate brokerage firm was not
barred from representing multiple bidders for the same property without disclosure to and consent of the principals. The
brokerage firm through two different agents represented two different principals interested in purchasing the same property.
When the unsuccessful bidder found out that his agent did not inform him that the other principal, using the same firm but a
different agent had submitted a higher bid, he brought an action against the brokerage firm for breach of fiduciary duty. The
Court unanimously held that while an individual buyer’s agent “acting on behalf of multiple clients bidding on the same property
cannot negotiate an optimal purchase price for all of them” two separate agents affiliated with the same firm do not present
comparable risks. Id. at 356. The opinion noted that “[t]here is no incentive for these agents to represent their clients less than
zealously.” Hmmm… query whether the result would be different if one or both of the agents were attorneys.
6. Also of interest to real estate attorneys, the Court reversed the Appellate Division and recently held in Moran v. Erk, 2008 N.Y.
Slip Op. 9255, that where a real estate contract containing an attorney approval contingency providing that the contract is
“subject” or “contingent upon” attorney approval within a specified time period and no further limitations on approval appear in
the contract’s language, an attorney for either party may timely disapprove the contract for any or no stated reason. Though such
contingency provisions seem absurd and promote bad unpredictable policy, they seem to be appearing more frequently, especially
in Contracts of Sale used Upstate.
Continued on Page 5…………...
PAGE 5 VOLUME 1
7. A significant trust and estate litigation case was also decided by the Court in American Committee of Weizman v. Dunn, 10 N.Y.3d 82,
854 N.Y.S.2d 89 (N.Y. 2008). The Court imposed a high standard for parties seeking to a vacate probate decree based on alleged
exercise if undue influence. Despite some evidence of undue influence upon the deceased, who changed her will five days before her
death, the Court held that a party seeking to vacate a probated decree, upon alleged undue influence grounds, must establish a
substantial basis for its challenge to the probate will and show a reasonable probability of success on the merits of its claim.
8. The Court decided several case which may impact personal liability for principals and officers in corporations and limited
partnerships for breach of contract and fraud. The Court applied concepts of corporate law to a pair of cases affecting LLC’s and
limited partnerships. In Tzolis v. Wolff, 10 N.Y.3d 100, 885 N.Y.S. 2d 6 the Court held that members of limited liability companies,
like limited partners or public shareholders, have the right to bring a derivative action on behalf of the LLC. The Court noted the
importance of derivative suits in corporate law and the Legislature’s silence on derivative suits in the Limited Liability Company Law.
The Court interpreted this silence as allowing the judiciary to create this right. From a litigation standpoint, the right to bring a
derivative action can substantially help a plaintiff effectuate certain relief, notably payment of attorneys’ fees.
9. The Court was not as generous in inferring judicial remedies for limited partners in the case of Appelton Acquisition LLC v. The
National Housing Partnership, 10 N.Y.3d 250, 856 N.Y.S.2d 522, where limited partners sought rescission of a merger and relief for
breach of fiduciary duty as well as fraud. Here, the Court strictly interpreted the Partnership Law to hold that appraisal is the
exclusive remedy for limited partners seeking to challenge a merger. The Court held that the Partnership Law was clear that, in the
event the partnership merges with another entity, the limited partner can only expect to receive the fair value of his partnership
interest as determined in a judicial appraisal proceeding and cannot bring an action for rescission or damages. The Court cited Tzolis,
contrasting legislative silence in that case and the specific sections of the Partnership Law. The Court held however that the limited
partnerships could and should have requested an appraisal proceeding and asserted any allegations of fraud there.
10. In Pludeman v. Northern Leasing Systems, 10 N.Y.3d 486, 860 N.Y.S.2d 422, the Court held in a 5-2 decision, that for purposes of
pleading fraud claims with particularity, in certain cases, less than plainly observable facts may be supplemented by the circumstances
surrounding the alleged fraud, thus satisfying the stricter pleading requirements of CPLR 3016(b). The circumstances of a certain
leasing scheme were enough to support an inference of fraud under CPLR 3016(b) where facts regarding the fraud were within the
peculiar knowledge of the individual defendants and where it was not unequivocal, as a matter of law that a finder of fact could not
reasonably infer the requisite knowledge or participation by the individual defendants in an act of fraud. This case provides attorneys
with a good review of the standards for individual officer liability as well as standards of pleading fraud generally. It also appears to
provide future litigants with a good citation for looser standards in pleading fraud in particularity and may significantly impact the
early stage of corporate-commercial litigations by increasing the likelihood of individual corporate officer liability, and thus
NEED HELP WITH YOUR COMMERCIAL LITIGATION?
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NEW CITY, NY 10956
TEL# 845-634-8000 FAX#845-634-8007
VOLUME 1 PAGE 6
It is that time again: Mock Trial Season
I am proud to announce that we are once again administering the New York State Annual Mock Trial
Competitions which is now in it’s 27th year. This competition affords high school students throughout our County, the
opportunity to participate in an intense mock trial competition, presided over by our judges. Under the direction of
our RCBA Mock Trial Coordinator, Sandria Garvin, our Association has once again successfully coordinated the
efforts of 6 high schools, five members of the bar and 1 volunteer will be attorney advisors.
In promoting this competition, two goals are emphasized: to teach students basic trial practices and to provide
students with a sense of professionalism. However, my personal experience as a liaison for over the past 7 years has
made me realize that this competition serves a much greater purpose. At the outset of every tournament, students take
on this responsibility believing that they have certain limitations, and unaware of their actual capabilities. It is
through the intensive training sessions and competitive rounds that these students make miraculous and noticeable
transformation. These young aspiring “attorneys” do not just learn personal trial skills, but more important, they
learn to overcome their fear of public speaking, to eloquently craft an argument, the importance of body language, and
how to successfully work in a group setting. These lessons prove invaluable to these students who are nearing their
entrance into the “real world”. Therefore, although it is true that this Competition is a wonderful means by which the
Bar Association can provide volunteer services to our community, it is also a perfect opportunity for the participating
students to hone their social skills as they become young adults.
On behalf of the Rockland County Bar Association we would like to extend our sincere gratitude to all those
volunteers, the Judges, the attorney advisors and the liaisons who dedicate their personal time to these students. In
addition, we wish each and every school the best of luck.
If you would like further information regarding Mock Trials contact Leslie at 845-634-2149. It would be a
pleasure to see our members at the Mock Trials, it will be a pleasurable afternoon for all.
HOLIDAY PARTY 2008
On December 3rd we held our Annual Holiday Party, attended by over 100 of our dearest friends and colleagues and
hosted by the New Lawyers committee. The party was held at the Clubhouse in New City - the food was marvelous,
the DJ lively and the company superb. Our thanks to Michelle Tierney, Martin Butcher and Ira Schoeps, together
with all the members of the New Lawyers Committee who helped make this evening a success. We had tremendous
support from Rockland County vendors and our own membership in supplying raffle prizes.
We’d like to thank those members and businesses that contributed to the prizes, they are:
Brian Berkowitz...Braunfotel & Frendel.. Lawrence Codispoti….David ’s Bagels ...Duncan Donuts
Patricia Finn...Yvonne Garbett….Jade Abstract...LaTerrazza...Barbara Leifer-Woods…. Gerald Miles
Richard Neimark…Roccos...Ira Schoeps
PAGE 7 VOLUME 1
THE ROCKLAND COUNTY WOMEN’S
A chapter of WBASNY
Cordially invites you to the Judicial Reception,
Third Annual Judicial Reception,
Honoring our newly re-elected Rockland County
FRANK LAPERCH, ESQ. Family and Surrogate Court Judges
IS PLEASED TO ANNOUNCE Honorable William P. Warren
THE RELOCATION OF HIS OFFICES and
TO Honorable Thomas Walsh
148 SOUTH ROUTE 9W
STONY POINT, NEW YORK 10980 Tuesday, January 13, 2009
TEL# (845) 942-5500 6:00 - 8:00 p.m.
FAX# (845) 942-4476 Pasta Cucina
253 South Little Tor Road
New City, NY
Open bar & hors d’oeuvres
RCWBA members: $25
BRIAN K. CONDON, ESQ. Non-Members: :$40
Formerly of Condon & Resnick
IS PLEASED TO ANNOUNCE Kathleen Goodfellow
THE ESTABLISHMENT OF HIS PRIVATE PRACTICE (973) 820-2144
CONDON & ASSOCIATES, PLLC firstname.lastname@example.org
Located at www.rcwba.org
55 Old Turnpike Road, Suite 502
Nanuet, NY 10954
TEL# (845) 627-8500 Notice to all members who practice in the
FAX# (845) 627-8507 Bankruptcy Courts in the Southern District of
Laura M. Catina, Esq.,
(formerly Laura M. Kraemer)
General Order M-362 adopts a Model chapter 13 Plan
has been hired as an associate of the firm and Model chapter 13 Confirmation Order for all cases filed
under Chapter 13 of the Bankruptcy Code. The Model Plan
and Confirmation order must be used for all Chapter 13 plans
filed and Orders of Confirmation signed after January 5, 2009.
The General Order also directs the Standing Chapter
13 trustee to prepare and file a statement detailing whether the
Debtor’s proposed plan meets the Best Interest of Creditors
Test and a Plan Analysis Statement.
In addition, General Order M-364 adopts Loss
Mitigation Program Procedures and forms for regulating loss
mitigation effective as of January 5, 2009.
Copies of these General Orders and the Model Plan
and Confirmation Order, as well as the Loss Mitigation
Procedures and forms are available on the Bankruptcy Court
web site, www.nysb.uscourts.gov, from the clerk of the court, or
from Elizabeth Haas, Esq., 254 South Main Street, New City,
New York 10956 telephone 845-708-0340.
Licensed Professional Investigators for Attorneys and Corporations
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PAGE 9 VOLUME 1
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VOLUME 1 PAGE 11
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RICHARD E. GRAYSON
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THE 2008 FISCAL YEAR HAS COME TO A
CLOSE. PLEASE SEND IN YOUR
175 MAIN STREET, SUITE 307 VOUCHERS FOR CASES COMPLETED.
WHITE PLAINS, NEW YORK 10601 DO NOT HOLD YOUR VOUCHERS FOR
THE 2009 BILLING CYCLE.
PAGE 12 VOLUME 1
COMMITTEE CALENDAR CLE CALENDAR
THE SEMINAR SCHEDULED FOR
FEBRUARY 10, 2009 WILL BE
RESCHEDULED TO A LATER DATE AT THE
REQUEST OF THE DISTRICT
Thursday, January 8, 2009
THE DATE OF THE ETHICS CLE CLE: Best Employment Practices for Law Firms
Time: 6:00 p.m.– 9:00 p.m. (Registration @ 5:30 p.m.) Light Dinner
SEMINAR HAS BEEN CHANGED FROM Level: Transitional/Non-Transitional
APRIL 6, 2009 TO APRIL 16, 2009. Cost: $75.00
Place: Rockland BOCES Instructional Services Building, #10, West Nyack, NY
Credits: 3 (2.5 Professional Practice; .5 Ethics)
SAVE THE DATE Monday, January 26, 2009
CLE: Landlord Tenant Update
Friday, May 1, 2009 Time: 5:30 p.m.– 8:30 p.m. (Registration @ 5:00 p.m.) Light Dinner
9:30 A.M. Cost: $75.00
LAW DAY Place: Suffern Free Library, 210 Lafayette Ave, Suffern, NY
Credits: 3 (2.5 Professional Practice; .5 Ethics)
Rockland County Courthouse
Monday March 2, 2009
~ CLE: Litigating and Settling Cases
When to Hold ‘em and When to Fold ‘em
Friday, May 1, 2009 Time: 5:30 p.m.– 8:30 p.m. (Registration @ 5:00 p.m.) Light Dinner
1:00 P.M. - 4:00 P.M. Level: Transitional/Non-Transitional
CPLR UPDATE W/ Place: Rockland BOCES Instructional Services Building, #10, West Nyack, NY
Credits: 3 (2.5 Professional Practice; .5 Ethics)
PROFESSOR DAVID D. SIEGEL
Rockland BOCES **Kosher Meals are dependant on the delivery service available from the caterer.
All kosher meals must be ordered in advance and require an extra charge of
$10.00. Call the Association and place an order for a kosher meal. Please give us
at least one weeks notice.
Credit is not given for partial attendance.
Make sure your blue evaluation forms are completed and turned in to CLE
Coordinator to receive your certificate.
Prices for the above Seminars:
Specializing in New Attorneys Cost: $75.00 Members of RCBA;
$95.00 Non-Members; $85.00 Walk-Ins
ALL PROCESS & SUBPEONAS
WITNESS STATEMENTS & INTERVIEWS
BUILDING DEPARTMENT RECORDS
HAVE YOU MADE YOUR NEW YEARS
COURT FILINGS & RETREIVAL RESOLUTION YET?
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Retired Court Officer ♦MORE COMMITTEE PARTICIPATION
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Phone / Fax (845) 354-9805 ASSOCIATION
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♦ RECRUIT NEW MEMBERS
♦ JOIN THE NEW LAWYERS COMMITTEE
(those in practice 5 years or less)
♦ ATTEND NETWORKING EVENTS
GET YOUR FLU SHOT ♦ REGISTER FOR CLE’S
♦ GET INVOLVED
VOLUME 1 PAGE 13
Sharon Tucker ATTENTION MEMBERS
ARE YOU HOLDING FILES FOR
ERA Tucker Associates, Inc. ATTORNEYS THAT HAVE RETIRED OR ARE
___________________________ DECEASED? IF SO PLEASE CONTACT THE
8 College Avenue, Nanuet, NY 10954 ASSOCIATION WITH THAT INFORMATION.
Nanuet Office: (845) 623-5200
Nanuet Fax: (845) 623-5244
Website: tuckerera.com LOG ON TO WWW.ROCKLANDBAR.ORG
Serving all your real estate needs in Rockland & Orange County
Auction Advantage also available
Each ERA Office is independently Owned and Operated THE 2008–2009 CLE BROCHURE IS
AVAILABLE FOR VIEWING
Interested in Softball? Need a Place to Meet in New City?
A committee is being RCBA Conference Rooms
formed to organize a RCBA Available for Rent
softball outing in late Spring First Two Hours free for members of RCBA
2009. Member Prices
We are in need of a few Closings & Depositions
volunteers who would like $60 half day/ $120 full day
to play or who can help plan Non – Member Prices
a day that will be fun for $75 half day/ $135 full day
everyone together with raising scholarship monies. We must have advance notice for closings and
Please contact either Steve Lowe or Robyn Lefcourt. depositions. A small fee will be charged for
Robyn @ 845-359-2149 any telephone usage, faxes and copies.
Please call (845) 634-2149 in advance for rental
INDIVIDUAL PART RULES ARE
AVAILABLE AT THE NYLJ AND AT
THE SURROGATE CLERKS’ OFFICE
IN THE COURTHOUSE. THE HARD
COPY IS AVAILABLE AT THE BAR MY CLIENTS LEND
ASSOCIATION OFFICE. PLEASE CALL PRIVATE, SHORT TERM,
LESLIE @ 845-634-2149 IF YOU NEED COMMERCIAL MORTGAGE
A COPY. MONEY
ALAN SNIDER, ESQ.
800 CENTRAL PARK AVENUE
ANYONE LOOKING TO SHARE A WESTLAW SUITE 204
SCARSDALE, NY 10583
IF SO, LET ME KNOW. PHONE (914) 472-1956
CALL LESLIE @ 845-634-2149
PERMIT NO. 5683
We’re on the web
Best Employment Practices for Law Firms - January 8, 2009 6:00 p.m.- 9:00 p.m. $ 75.00
Landlord Tenant Update - January 26, 2009 6:00 p.m.- 9:00 p.m. $ 75.00
Litigating and Settling Cases March 2, 2009 6:00 p.m.- 9:00 p.m. $ 75.00
**Kosher Meals are dependant on the delivery service available from the caterer. All kosher meals must be ordered in
advance and require an extra charge of $10.00. Call the Association to place an order for a kosher meal. Please give us at
least one weeks notice.
Credit is not given for partial attendance.
Make sure your blue evaluation forms are completed and turned in to CLE Coordinator to receive your certificate.
If you pre-pay but are unable to attend the seminar you will be refunded the full amount only upon advance notice
(3:00 P.M. the day of the seminar) of your non attendance.