Uncertainty in the First Department
Generally speaking, there has been a stark split between the First and Second Departments over the standard for a Judiciary Law § 487 claim. In the First Department there was a requirement of a “chronic and extreme pattern of legal delinquency” and in the Second Department a single egregious incident of deceit was sufficient. Amtrust N. Am., Inc. v Pavloff 2021 NY Slip Op 31062(U) April 2, 2021 Supreme Court, New York County Docket Number:…