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Volume 1 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 President Glenn W. Kelleher President Elect 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 Lawrence Codispoti 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: Larry Gantt 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’ Catherine Miklitsch 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 Page 1-2 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 Memorial Service & and instructed their attorney to disapprove the contract. Although the attorney had no Condolences objections to the contract, he disapproved it, at this clients’ direction. Page 4-5 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 2008 by: Judah S. Shapiro, Esq. contract with the Erks was signed and cancelled, the Morans sued the Erks for breach of Page 6 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 FYI 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 FYI provision to void a purchase contract for any reason whatsoever. The reason will not be Page 14 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 case. 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. The lesson? 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 professional. 4. Examine my self. What are my strengths? What are my weaknesses? What do I wish to keep? What do I wish to change? 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 the past. 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. Contact us: 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 To Honorable Catherine Miklitsch On the passing of her husband Ray O’Connell 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 In the 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 settlement. NEED HELP WITH YOUR COMMERCIAL LITIGATION? CALL JUDAH S. SHAPIRO, ESQ. 845-634-8000 OVER TWENTY YEARS EXPERIENCE IN ALL ASPECTS OF STATE & FEDERAL PRACTICES ♦ FREE INITIAL CONSULTATION ON ALL COMMERCIAL AND PROCEDURAL MATTERS ♦ BIG FIRM EXPERIENCE ♦ PERSONAL ATTENTION HAPPY TO BRAINSTORM WITH MY FELLOW BAR MEMBERS JUDAH S. SHAPIRO, ESQ. 151 NORTH MAIN STREET-4TH FLOOR 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 BAR ASSOCIATION 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 Cost: Judges: gratis RCWBA members: $25 BRIAN K. CONDON, ESQ. Non-Members: :$40 Formerly of Condon & Resnick RSVP: IS PLEASED TO ANNOUNCE Kathleen Goodfellow THE ESTABLISHMENT OF HIS PRIVATE PRACTICE (973) 820-2144 CONDON & ASSOCIATES, PLLC email@example.com 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., New York (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 Management Resources is a full service company comprised of licensed professional investigators that assist attorneys in researching and preparing their cases. We specialize in both civil and criminal investigations. Civil Investigations Personal injury, Wrongful death, Discrimination, Retaliation and Harassment cases. Criminal Investigations Homicide investigations, Crime scene examination, Eyewitness identification, DUI and DWI, Unsolved crimes/suspicious deaths, Civil Rights Violations, Witness statements Certified Criminal Defense Investigators Licensed in New York by the Department of State & in New Jersey by the Division of State Police 800- 490-2267 www.managementresourcesny.com PAGE 9 VOLUME 1 Rockland Attorneys Can Expect More from Hudson Valley Bank 254 South New Main Street, New City Services Designed by Attorneys for Attorneys ♦ Local Decision Making ♦ Access to Senior Management ● Attorney Operating Accounts ● Streamlined Attorney Trust & IOLA Accounts ● Messenger Service for Deposit Pick-up ● Late Day Wires ● Partner & Firm Lines of Credit ● Commercial Mortgages & Residential Loans ● Equipment Leasing Services ● Trust & Investment Services ● Exceptional Personal Service & Attention Contact our Legal Services Group at (845) 521-7014 or visit www.hudsonvalleybank.com Find out why over 1,000 law firms bank with Hudson Valley! Joseph Ruhl Larry McElroen First Senior Vice President Vice President firstname.lastname@example.org email@example.com Hudson Valley Bank is an independently owned local bank with $2 billion in assets, serving the metropolitan area with 27 branches located in Westchester, Rockland, the Bronx, Manhattan, Queens and Brooklyn NY, and Fairfield County, CT. VOLUME 1 PAGE 11 ACCURATE INVESTIGATIONS, LLP Michael Zall Assigned Counsel Cases, Interviews & Statements, Notary, Process Service, Skip Tracing, DMV Records Attorney Civil and Criminal Many Resources for Your Needs 120 North Main Street Tel: (845) 634-2463 Suite 203 Fax: (845) 634-7710 New City, NY 10956 Email: frankalessio.com Two Yorkshire Drive Professionally Licensed PATENTS Suffern, New York10901 & Bonded Private Investigation Service TRADEMARKS Tel# (845) 357-6800 COPYRIGHTS Fax# (845) 357-4616 I AM LOOKING FOR JIM FITZGERALD’S FILES IF YOU HAVE ANY INFO PLEASE CALL BEN SELIG 845-942-2222 OUR PRO BONO STAR FOR THE MONTH: GOT BABY NEWS? YOUR NAME COULD BE HERE! GRIEVANCE DISCIPLINARY LAW (914) 682-0037 ALL ASSIGNED COUNSEL PANEL MEMBERS PLEASE NOTE : RICHARD E. GRAYSON ATTORNEY AT LAW 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. www.richardgraysonesq.com PAGE 12 VOLUME 1 COMMITTEE CALENDAR CLE CALENDAR PLEASE NOTE: THE SEMINAR SCHEDULED FOR FEBRUARY 10, 2009 WILL BE RESCHEDULED TO A LATER DATE AT THE REQUEST OF THE DISTRICT ATTORNEYS OFFICE 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 Level: Transitional/Non-Transitional 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 Cost: $75.00 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 FINDING WITNESSES BUILDING DEPARTMENT RECORDS HAVE YOU MADE YOUR NEW YEARS COURT FILINGS & RETREIVAL RESOLUTION YET? Serving Rockland, Hudson Valley & NYC HERE ARE SOME TIPS: Hilly Minzer Retired Court Officer ♦MORE COMMITTEE PARTICIPATION 33 Years Court Experience ♦ MORE INVOLVEMENT IN THE Phone / Fax (845) 354-9805 ASSOCIATION Cell (914) 260-2866 ♦ 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 Broker 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 E-Mail: firstname.lastname@example.org 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 SURROGATE WALSH’S 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 SUBSCRIPTION? SCARSDALE, NY 10583 IF SO, LET ME KNOW. PHONE (914) 472-1956 CALL LESLIE @ 845-634-2149 US POSTAGE NON-PROFIT ORG PAID MONSEY, NY PERMIT NO. 5683 We’re on the web www.rocklandbar.org Name(s)_________________________________________Updated E-mail____________________________ 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.
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