A New York City Marshal carries out almost all the same tasks as Sheriffs…

Photo of toddler with sheriff's star illustrating article by Richard Klass Esq. about New York City marshal

In New York City, a City Marshal carries out almost all of the same tasks as Sheriffs…

In New York City, a City Marshal carries out almost all of the same tasks as Sheriffs, including evicting tenants, towing cars, seizing businesses and levying on bank accounts. However, unlike Sheriffs, City Marshals aren’t elected to office, aren’t government officers who get paid salaries, and make their income from fees and a percentage of moneys collected through their enforcement duties. Also, their jurisdiction extends only throughout the City of New York.

Entry of Judgment by the Creditor

A company in the business of making credit available to small businesses through the use of merchant service agreements entered into an agreement with a night club. As part of the agreement, it obtained a signed confession of judgment from the night club which, in the event of a default in repayment of the credit line, could be entered with the county clerk. At some point, the debtor defaulted under the agreement and the creditor entered the confession of judgment with the clerk of court. Once judgment was entered, the creditor issued an Execution to the City Marshal. An Execution is a document which directs the enforcement officer (Sheriff or Marshal) to attach and levy upon certain assets belonging to the judgment debtor in order to satisfy the judgment.

The New York City Marshal Levied upon the Debtor’s Out-of-State Bank Account.

The City Marshal levied upon the debtor’s bank account located far outside the City of New York, in Cincinnati, Ohio. The bank honored the levy, remitting the funds contained in the account to the City Marshal (which amounted to approximately half of the balance due on the judgment). In turn, the City Marshal remitted the net proceeds to the judgment creditor after deducting his levy and poundage fees.

The debtor filed a lawsuit against the City Marshal for both money damages for the amount withdrawn from its account and for punitive damages. The debtor claimed that the City Marshal acted outside of his jurisdiction by levying on the Ohio bank account. The City Marshal hired Richard A. Klass, Your Court Street Lawyer, to defend him against the lawsuit.

A City Marshal Is Subject to Reprimand

Article 16 of the New York City Civil Court Act governs City Marshals. Article 16 provides that the appellate courts may reprimand, censure, suspend or remove a City Marshal for cause through established, detailed procedures. Through delegation from the courts, the NYC Department of Investigation is charged with oversight of the City Marshals, including taking complaints, conducting investigations, and regulating their activities subject to court approval. Among the requirements for serving, a City Marshal must post a bond to answer for any violation of his duties.

Juxtaposed with the courts’ power of reprimand, City Marshals may also be held civilly liable for any damages caused by negligently executing a levy or warrant. See, Korsinsky v. Rose, 120 AD3d 1307 [2d Dept. 2014]. To establish a cause of action for negligence, however, a plaintiff must establish the existence of a duty on the defendant’s part, breach of that duty and damages. Specifically, a plaintiff suing a Marshal or Sheriff for wrongful execution must prove that he lacked or exceeded his authority while performing his duties and caused damage. While there are occasions that a judgment creditor may be held liable for conversion (under the principle of caveat creditor), an enforcement officer acting under an execution that was regular on its face and issued from a court of competent jurisdiction is protected by law. Ruckman v. Cowell, 1 NY 505 [1848].

Judgment Debtor Did Not Suffer Any Damages

In dismissing the case against the City Marshal, the judge focused on the issue of damages. In any negligence case, it is critical that the plaintiff-injured party prove that it was damaged as a result of the defendant’s acts. In this case, the judgment debtor could not establish that it sustained any damages as a result of the City Marshal’s levy on the out-of-state bank; there was no dispute that the moneys collected from the debtor’s bank account were properly applied towards partial satisfaction of the judgment. The judge held that the lawsuit was “a blatant attempt to avoid having to pay its bill (i.e. having the Marshal pay the money that Plaintiff owes the Judgment Creditor) and under the transparent guide of this action against the Marshal (which would in effect amount to a sanction of the Marshal).”

The court found that, by vesting authority with the appellate courts over City Marshals, the legislature did not create a private remedy where one was never intended. Since there exists both a forum and mechanism for addressing any alleged abuses of authority by City Marshals, the court would not entertain a lawsuit, especially where the City Marshal seemingly executed on a facially-valid confession of judgment. See, Bam Bam Entertainment LLC v. Pagnotta, [Sup. Kings 4/11/18], New York Law Journal, April 19, 2018. (Bam Bam Entertainment LLC v. Pagnotta decision/order available here in PDF format.)

Richard A. Klass, Esq.

Richard A. Klass, Esq., maintains a law firm engaged in civil litigation at 16 Court Street, 28th Floor, Brooklyn, New York. He may be reached at (718) COURT●ST or RichKlass@courtstreetlaw.com with any questions.

Prior results do not guarantee a similar outcome.

©2018 Richard A. Klass.
Image at top of page: Getty Images

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Service to the New York Bar Association: Klass awarded

Emily Franchina poses with Richard Klass for a photo as he is awarded plaque for his service as Chair, New York State Bar Association, General Practice Section 2014-2015.

For Service to the New York State Bar Association

Emily Franchina, Esq. presents Richard Klass, Esq. with an award for his service as Chair, New York State Bar Association, General Practice Section 2014-2015.
 

Appointment to Grievance Committee: Richard Klass

Richard A. Klass, has been appointed to serve a 4-year term on the Grievance Committee for the Appellate Division Second Department for the Second, Eleventh and Thirteenth Judicial Districts.

Members of the Grievance Committee serve to maintain the honesty, integrity and professional competence of the legal profession and protect the general public by enforcing the Rules of Professional Conduct.


R. A. Klass
Your Court Street Lawyer

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A Man’s House is (Not Always) His Castle

Neuschwanstein Castle, in Bavaria, Germany, which looks similar to Cinderella's castle in Disney World, used to illustrate both an e-book and an article by Richard Klass with titles such as " A Man’s Home Is (Not Always) His Castle: RPAPL 881 License to Enter Neighbor’s Property. "

A New York City college bought an old garage on a residential street with the intention of eventually tearing it down and using the vacant lot in the development of a 17-story building. The owner of the adjacent apartment building was more than glad to have the college demolish the garage, which had become an eyesore. In order to demolish the garage, however, the college needed to enter the adjacent property to erect bridge scaffolding around the apartment building. But the college offered little protection to the owner other than promising to pay for any damage it might cause to the apartment building during the demolition.

Alleging that the apartment building owner refused to consent, the college brought a petition for a court order to allow its contractor to enter upon the adjacent property to erect the scaffolding. The adjacent apartment building owner retained Richard A. Klass, Esq., Your Court Street Lawyer, to oppose the petition and negotiate a license agreement with the college to grant access, but only upon meeting certain, reasonable conditions.

In the current economic and political climate in New York City, which encourages building more and more housing units for the multitudes, it is not surprising that current property owners are experiencing “growing pains.” Among those “growing pains” are the inconvenience and annoyance they experience when a developer buys land next to their property, seeking to build on that land, and needs to gain access to the neighboring property to do the work. Such access may be needed to move equipment, build up to the property line, or deliver material to the building site.

RPAPL 881 grants a license to enter property

New York law seeks to find middle ground between the property developer and the neighboring owner so that the developer may build its structure while the neighbor can be left relatively undisturbed. Real Property Actions and Proceedings Law (RPAPL) Section 881 provides as follows:

When an owner or lessee seeks to make improvements or repairs to real property so situated that such improvements or repairs cannot be made by the owner or lessee without entering the premises of an adjoining owner or his lessee, and permission so to enter has been refused, the owner or lessee seeking to make such improvements or repairs may commence a special proceeding for a license so to enter pursuant to article four of the civil practice law and rules. The petition and affidavits, if any, shall state the facts making such entry necessary and the date or dates on which entry is sought. Such license shall be granted by the court in an appropriate case upon such terms as justice requires. The licensee shall be liable to the adjoining owner or his lessee for actual damages occurring as a result of the entry.

Essentially, if a developer must gain access to the adjacent property, it must first make a request upon that property owner. If turned down, the developer can then file a petition to ask the court to grant a license to enter the premises for a reasonable period of time.

Courts apply a ‘balancing test’

The court must balance the competing interests of the parties and should grant the issuance of the license when necessary, under reasonable conditions, and where the inconvenience to the adjacent property owner is outweighed by the hardship of its neighbor if the license is refused. In Rosma Development LLC v. South, the court granted a developer a license to enter the adjacent property, recognizing that the developer’s property interests in completing its project (and as quickly as possible in order to avoid unnecessary delay and expense) outweighed the temporary inconvenience to the neighbor.

Provisions of a license agreement

Courts have held that reasonable conditions of a license agreement under RPAPL 881 may include:

  1. Providing the owner with the details and schedule of the work to be done;
  2. Conducting pre-construction inspections and monitoring for cracks, vibrations, and noise during construction;
  3. Paying the owner’s fees for engineers, attorney’s fees, and other expenses;
  4. Imposing penalties in the event of noncompliance with the license, including the failure to complete the work in a timely fashion;
  5. Taking steps after construction is complete to close up lot-line windows or resolve any structural wall issues; and
  6. Ensuring that an adequate liability insurance policy is in effect in the event that actual damages occur.

In resolving the college’s petition, the parties negotiated an extensive agreement that ultimately allowed the judge to approve the license to enter the adjoining property.

— by Richard A. Klass, Esq.

R. A. Klass
Your Court Street Lawyer

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Debt Collection Tips: Docketing a Judgment Lien

Once a Judgment has been entered in a court, there are various methods which may be utilized by the judgment creditor to collect the Judgment from the debtor.

Where the debtor owns real estate, a lien may be placed upon the property. This type of lien is referred to as a Judgment lien under Article 52 of the Civil Practice Law and Rules (CPLR).

The Judgment lien is placed upon real estate by the “docketing” of a Transcript of Judgment with the County Clerk’s Office.  Once the Judgment is docketed or registered, the judgment creditor may issue an Execution to the Sheriff to levy and sell the real estate, or merely leave the lien against the property until the debtor sells or transfers the property (at which time, the Judgment will likely be paid from the proceeds at closing).

If the Judgment was obtained in the Supreme Court of the county in which the property is located, no further action is required to docket the lien.

If the Judgment was obtained in another court (such as the New York City Civil Court, federal court, Family Court, or District Court), that court will issue, for a fee, a Transcript of Judgment with a raised seal, which Transcript of Judgment will then be filed with the County Clerk’s Office, at which point the lien will be effective.

If the debtor owns real estate in a county different from the one in which the Judgment was entered, a Transcript of Judgment should issue from the County Clerk’s Office in which the Judgment was entered and be filed with the County Clerk’s Office in which the property is located to effectuate the lien.

by Richard A. Klass, Esq.

R. A. Klass
Your Court Street Lawyer

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Debt Collection Tips: Executions

Once a Judgment has been obtained against a debtor, an “Execution” may issue to a Sheriff or Marshal. An Execution is a legal document which directs the Sheriff or Marshal to levy upon certain assets of the debtor.

There are three types of Executions:

1. Property Execution: issues against personal property of any nature belonging to the debtor, including bank accounts, cars, shares of stock, equipment, etc.

2. Real Property Execution: issues against real estate owned by the debtor, permitting the sale of the real estate at auction.

3. Income Execution: issues against a debtor’s wages, permitting the garnishment of the debtor’s salary or compensation.

Each county of New York State has a Sheriff, who performs the above functions. Within the City of New York, a City Marshal may be selected by the creditor in lieu of a Sheriff (except for real estate sales). Some creditors prefer using a City Marshal instead of a Sheriff because City Marshals are not City employees, but rather work strictly upon a percentage of the amount collected. The perception is that City Marshals have more incentive to work harder because of this fee structure.

According to statute, the Sheriff/Marshal is entitled to collect a levy fee and “poundage” of 5% from the debtor on top of the Judgment amount as a fee.

In some situations, the Sheriff cannot levy upon property, where there may be title issues relating to the ownership of the property, at which time further legal proceedings may be necessary.

— 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.


R. A. Klass
Your Court Street Lawyer

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Klass in the News: Yoko Ono Publicist Kip Kouri Injured at NYC Restaurant, Alleges Homophobic Harassment

By Andrew Hampp
Billboardbiz
July 25, 2014 6:00 PM EDT


Link to original article: Yoko Ono Publicist Kip Kouri Injured at NYC Restaurant, Alleges Homophobic Harassment

 

Kip Kouri, founder of Tell All Your Friends PR, is one of the most familiar and well-liked faces on the New York indie-rock circuit, repping everyone from Yoko Ono to Les Savy Fav to Guided By Voices to white-hot duo Sylvan Esso.

But a recent visit to Eataly, Mario Batali’s food emporium in New York’s Gramercy Park, ended in a violent altercation with the wait staff, leaving Kouri in stitches after allegedly being thrown through a plate glass window by a security guard. Kouri declined public comment while he sought legal counsel, but clients like Frenchkiss Records’ Syd Butler and Miniature Tigers began tweeting in Kouri’s defense, suggesting the incident was a hate crime and that a security guard used homophobic slurs against Kouri….

…Kouri declined comment, but deferred to his lawyer Richard Klass, who responded to Billboard in a statement: “Mr. Kouri vehemently denies the allegations made in the statement of Eataly’s representative. Mr. Kouri was at Eataly with his stepmother, sister and boyfriend, and a disagreement arose concerning the mishandling by Eataly of Mr. Kouri’s reservation. Mr. Kouri proceeded to leave the store after being harassed by Eataly’s staff, including being called homophobic slurs and enduring the staff’s homophobic hand gestures at him.

“As Mr. Kouri was exiting,” Klass continued, “three security guards became physical and began to push Mr. Kouri, his stepmother and sister, all the while calling him names. The security guards then tackled Mr. Kouri and threw him through a glass door, causing him to sustain serious injuries. Footage from Eataly’s security cameras were reviewed by the New York City Police Department and the investigation of the matter is pending.”

 

 

———–
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.


R. A. Klass
Your Court Street Lawyer

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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.


R. A. Klass
Your Court Street Lawyer

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Stone Cold

Adonis Mort, c. 1620 by Laurent de La Hyre (1606-1656). Photograph of Adonis Mort by Gautier Poupeau, 2011. Shows: Muscular young man, mostly nude, with red shaw draped on body, laying apparently motionless on the ground, with brown dog sitting near his feet.

The business idea was a good one: one partner, we’ll call him “Salesman,” was experienced in the stone business.

He would bring his knowledge and talents. The other partner, we’ll call him “Moneybags,” would bring his cash. Together, they would launch a business to import and distribute stone material from China. The plan was for Moneybags to invest money into the newly-formed corporation to be used to purchase the stone material, and Salesman was going to make profitable deals, moving the product to market through wholesalers.

In anticipation of launching the business, and in order to buy the stone material, Moneybags gave Salesman more than $250,000, a bit at a time. Every time Moneybags invested a chunk of money, Salesman gave him an “IOU” for the money. After a while, and after a series of exchanges which raised his suspicions, Moneybags became convinced that Salesman was diverting the seed money from the stone business and was using it instead for personal purposes. Thinking he had been defrauded, Moneybags began an action to recoup whatever he could of his original investment. The situation was dire and complicated, but it got worse. During this period, Salesman went on a business trip to Africa and died.

Substitution of wife/administrator as defendant

Before learning that Salesman had died, Moneybags had already brought a lawsuit against Salesman, through counsel other than Richard A. Klass, Your Court Street Lawyer, for breach of contract and embezzlement. After Salesman died, Moneybags’ lawsuit was “stayed” or stopped from proceeding. According to law, when a defendant dies, there is a stay of the legal proceeding until someone is appointed to represent the estate of the deceased. CPLR 1015 (“If a party dies and the claim for or against him is not thereby extinguished the court shall order substitution of the proper parties.”). Salesman’s widow was appointed as the administrator of his estate. At this point, Moneybags sought help from Richard A. Klass. The first step was to substitute the wife/administrator as the defendant in place of her deceased husband.

Elements of Fraud and Conversion

The next, important, step was to amend the Complaint in the action to include various causes of action, including fraud and conversion against the estate of the defendant. To allege fraud, the Complaint contained the essential elements that (a) Salesman made representations to Moneybags about investing the money into buying stone material; (b) those representations were false and misleading; (c) that Salesman made those representations knowingly and with the intent and purpose of inducing Moneybags to invest the money; (d) that Moneybags justifiably relied on those representations to his detriment; and (e) he sustained damages. The Complaint also alleged that Salesman wrongfully took and converted the investment moneys for his own purposes and in derogation of Moneybags’ rights.

Rights as a Shareholder in the Corporation

Aside from alleging that Salesman was a fraudster who diverted his investment moneys into his own pocket, Moneybags also pursued rights afforded to him as a shareholder in a New York State corporation. New York Business Corporation Law Section 717 states that “A director shall perform his duties as a director, including his duties as a member of any committee of the board upon which he may serve, in good faith and with that degree of care which an ordinarily prudent person in a like position would use under similar circumstances.” (Similarly, Business Corporation Law Section 715(h) provides “An officer shall perform his duties as an officer in good faith and with that degree of care which an ordinarily prudent person in a like position would use under similar circumstances.”)

Aiding and Abetting Breach of Fiduciary Duty

Unless some “bite” could be put into the Complaint to allege that the wife and son may have some personal liability, Moneybags realized he was nearly certain to lose his entire $250,000 investment. Richard A. Klass amended the Complaint to allege numerous causes of action against not only the estate of Salesman but also his wife/administrator of the estate and son, including fraud, conversion, constructive trust, accounting, breach of fiduciary duties, aiding and abetting breach of duties, and unjust enrichment. Under New York law, a claim for aiding and abetting breach of fiduciary duty consists of the following elements: (1) a breach of fiduciary duty, (2) that the defendant knowingly induced or participated in the breach, and (3) that the plaintiff suffered damages as a result of the breach. See, S&K Sales Co. v. Nike, Inc., 816 F2d 843 [2 Cir. 1987]. In this case, Moneybags alleged that the wife and son should be held liable to him, and not only Salesman’s estate.

The amendment of the Complaint to include numerous allegations against the several defendants pushed them to immediately settle the case for a substantial percentage of Moneybag’s initial investment.

by Richard A. Klass, Esq.

———–
copyr. 2013 Richard A. Klass, Esq.
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.

R. A. Klass
Your Court Street Lawyer

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