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PLAINTIFF ENTITLED TO SUMMARY JUDGMENT ON LABOR LAW 240(1) AND 240(6) CAUSES OF ACTION, HEAVY MOTORIZED PALLET JACK SLID ON WATER ON A DESCENDING RAMP.

The First Department, in a full-fledged opinion by Justice Saxe, determined plaintiff was entitled to summary judgment on his Labor Law 240(1) and 241(6) causes of action. Plaintiff was guiding a heavy motorized pallet jack carrying concrete blocks down a ramp to a lower level of the building under construction. The ramp was wet and the pallet jack slid, running over plaintiff’s foot. The fact that the load was not being hoisted or secured at the time of the accident did not preclude recovery. The pallet itself was deemed a safety device that failed in an elevation-related accident:

Plaintiff’s testimony here established that his accident was proximately caused by the combination of the traction-reducing water condition and the slope, which caused the heavy, loaded pallet jack to slide downhill while the breaking [sic] mechanism was rendered useless. The jack, with its built-in braking mechanism, failed to provide him adequate protection against the gravity-related risk inherent in transporting the heavy load down the water-covered ramp. Therefore, defendants failed “to provide adequate protection against” the risk that was created in part by the ” significant elevation differential'” of the ramp … . Landi v SDS William St., LLC, 2016 NY Slip Op 08340, 1st Dept 12-13-16

LABOR LAW-CONSTRUCTION LAW (PLAINTIFF ENTITLED TO SUMMARY JUDGMENT ON LABOR LAW 240(1) AND 240(6) CAUSES OF ACTION, HEAVY MOTORIZED PALLET JACK SLID ON WATER ON A DESCENDING RAMP)/PALLET JACK (LABOR LAW-CONSTRUCTION LAW, PLAINTIFF ENTITLED TO SUMMARY JUDGMENT ON LABOR LAW 240(1) AND 240(6) CAUSES OF ACTION, HEAVY MOTORIZED PALLET JACK SLID ON WATER ON A DESCENDING RAMP)

LABOR LAW 240(1) CAUSE OF ACTION PROPERLY DISMISSED, EVENT NOT RELATED TO THE FORCE OF GRAVITY.

The First Department determined summary judgment dismissing plaintiff’s Labor Law 240(1) cause of action was properly granted. Plaintiff was cutting a steel beam when it sprang up, striking him in the face. The event was not related to the force of gravity:

The Labor Law § 240(1) claim was correctly dismissed, because the record demonstrates that plaintiff’s injuries were not the result of a failure to provide proper protection against “the application of the force of gravity to an object or person” … , but rather the result of the propulsion of the vertical beam upward by “the kinetic energy of the sudden release of tensile stress in the [beam]” … . Quishpi v 80 WEA Owner, LLC, 2016 NY Slip Op 08324, 1st Dept 12-13-16

LABOR LAW-CONSTRUCTION LAW (LABOR LAW 240(1) CAUSE OF ACTION PROPERLY DISMISSED, EVENT NOT RELATED TO THE FORCE OF GRAVITY)

QUESTION OF FACT WHETHER DEFENDANT EXERCISED SUFFICIENT CONTROL OVER THE WORK TO BE LIABLE UNDER LABOR LAW 200 AS AN AGENT OF THE OWNER AND GENERAL CONTRACTOR.

The First Department determined there were questions of fact whether defendant (Premiere) exercised sufficient control over the work to be liable as an agent of the owner and general contractor pursuant to Labor Law 200. Plaintiff, who worked for the building where the work was being done, tripped over a worker’s tool bag which had been left in the vicinity of a staircase. The decision gives some insight into the level of control and supervision necessary for Labor Law 200 liability:

Given its responsibilities regarding the construction work – responsibilities that resemble those of a construction manager – there are issues of fact as to whether Premiere was a statutory agent of the owner and general contractor, i.e., whether it exercised general control over the work site … , rather than the exclusive control that it claims on appeal. Premiere CEO Grimes’s testimony supports plaintiff’s claim that Premiere exercised general control over the work site. Not only did Grimes hire and schedule the repair people and oversee the quality of their work, but he also interacted with construction teams on a day-to-day basis, told them if he was displeased with work, made decisions about the work, and reminded the teams to move materials around to insure clear access to apartments and stairways. He was authorized to shut down the job “if there was a dangerous or unsafe condition,” and before plaintiff’s injury he and the superintendent spoke with … workers about not leaving tools and construction dust in the common areas. From theses facts, a jury could find that Premiere exercised general control. Burgos v Premiere Props., Inc., 2016 NY Slip Op 08317, 1st Dept 12-13-16

 

LABOR LAW-CONSTRUCTION LAW (QUESTION OF FACT WHETHER DEFENDANT EXERCISED SUFFICIENT CONTROL OVER THE WORK TO BE LIABLE UNDER LABOR LAW 200 AS AN AGENT OF THE OWNER AND GENERAL CONTRACTOR)

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SIX YEAR STATUTE OF LIMITATIONS APPLIES TO FRAUD ACTIONS AGAINST DEFENDANT BANK RELATING TO THE SALE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES BROUGHT PURSUANT TO THE MARTIN ACT AND EXECUTIVE LAW 63.

The First Department, over an extensive dissent, determined that fraud-related actions against defendant Credit Suisse (stemming from the sale of residential mortgage-backed securities [RMBS]) were governed by the six-year, not three-year statute of limitations. The actions were brought pursuant to the Martin Act and Executive Law 63(12). Those statutes were deemed to have codified common law causes of action. Therefore the six-year statute (CPLR 213), not the three-year statute (CPLR 214) applies:

Where claims are “to recover upon a liability . . . created or imposed by statute” (CPLR 214[2]), and the liability, although akin to common-law causes, “would not exist but for [the] statute” … , the three-year statute of limitations of CPLR 214(2) applies … . In contrast, where a statute “merely codifies and affords new remedies for what in essence is a common-law … claim[,]” CPLR 214(2) does not apply and “the Statute of Limitations for the statutory claim is that for the common-law cause of action which the statute codified or implemented”(id. at 208).

In the complaint, the Attorney General alleges, inter alia, that defendants’ fraud was their failure to abide by their representations that they had carefully evaluated and would continue to monitor the quality of the loans underlying their RMBS, and that they would encourage loan originators to implement sound origination practices. Instead, defendants routinely ignored defects discovered in their due diligence reviews and did not seek to influence originators to utilize appropriate origination practices, choosing instead to misuse their quality control process to obtain significant monetary settlements from originators, which defendants improperly kept for themselves. People v Credit Suisse Sec. (USA) LLC, 2016 NY Slip Op 08339, 1st Dept 12-13-16

 

CIVIL PROCEDURE (SIX YEAR STATUTE OF LIMITATIONS APPLIES TO FRAUD ACTIONS AGAINST DEFENDANT BANK RELATING TO THE SALE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES BROUGHT PURSUANT TO THE MARTIN ACT AND EXECUTIVE LAW 63)/SECURITIES (SIX YEAR STATUTE OF LIMITATIONS APPLIES TO FRAUD ACTIONS AGAINST DEFENDANT BANK RELATING TO THE SALE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES BROUGHT PURSUANT TO THE MARTIN ACT AND EXECUTIVE LAW 63)/FRAUD (SIX YEAR STATUTE OF LIMITATIONS APPLIES TO FRAUD ACTIONS AGAINST DEFENDANT BANK RELATING TO THE SALE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES BROUGHT PURSUANT TO THE MARTIN ACT AND EXECUTIVE LAW 63)/CRIMINAL LAW (SECURITIES FRAUD, SIX YEAR STATUTE OF LIMITATIONS APPLIES TO FRAUD ACTIONS AGAINST DEFENDANT BANK RELATING TO THE SALE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES BROUGHT PURSUANT TO THE MARTIN ACT AND EXECUTIVE LAW 63)/EXECUTIVE LAW 63 (SIX YEAR STATUTE OF LIMITATIONS APPLIES TO FRAUD ACTIONS AGAINST DEFENDANT BANK RELATING TO THE SALE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES BROUGHT PURSUANT TO THE MARTIN ACT AND EXECUTIVE LAW 63)/MARTIN ACT (SIX YEAR STATUTE OF LIMITATIONS APPLIES TO FRAUD ACTIONS AGAINST DEFENDANT BANK RELATING TO THE SALE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES BROUGHT PURSUANT TO THE MARTIN ACT AND EXECUTIVE LAW 63)/STATUTE OF LIMITATION (SIX YEAR STATUTE OF LIMITATIONS APPLIES TO FRAUD ACTIONS AGAINST DEFENDANT BANK RELATING TO THE SALE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES BROUGHT PURSUANT TO THE MARTIN ACT AND EXECUTIVE LAW 63),RESIDENTIAL MORTGAGE-BACKED SECURITIES (SIX YEAR STATUTE OF LIMITATIONS APPLIES TO FRAUD ACTIONS AGAINST DEFENDANT BANK RELATING TO THE SALE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES BROUGHT PURSUANT TO THE MARTIN ACT AND EXECUTIVE LAW 63)

REDACTED DOCUMENTS AND A SEALED RECORD MUST BE UNREDACTED AND UNSEALED, CRITERIA AND PROCEDURE FOR REDACTION AND SEALING EXPLAINED.

The First Department, reversing Supreme Court, determined redacted documents filed in connection with one lawsuit, and the entirely sealed record of a second lawsuit should be fully disclosed and available to the media (the intervenors here):

This Court has previously held that there is a “broad presumption that the public is entitled to access to judicial proceedings and court records” … . The right of public access includes the right of the press to read and review court documents, unless those documents have been sealed pursuant to a statutory provision or by a properly issued sealing order. To allow them to assert their interests here, the proposed intervenors should be allowed to intervene in both actions for the limited purpose of obtaining access to court records … .

Furthermore, because confidentiality is the exception and not the rule … , “the party seeking to seal court records has the burden to demonstrate compelling circumstances to justify restricting public access” … . Having reviewed the record, we see no basis to seal the entire court record in the second action; therefore, we vacate the sealing order. It appears that the motion court sealed the second action because the parties stipulated to it. Before sealing, the motion court should have made its own written finding of good cause, as is required by the provisions of the Uniform Rules for Trial Courts (22 NYCRR) § 216.1(a) … . Maxim Inc. v Feifer, 2016 NY Slip Op 08319, 1st Dept 12-13-16

 

CIVIL PROCEDURE (REDACTED DOCUMENTS AND A SEALED RECORD MUST BE UNREDACTED AND UNSEALED, CRITERIA AND PROCEDURE FOR REDACTION AND SEALING EXPLAINED)/SEALING-REDACTION OF COURT RECORDS (CIVIL, REDACTED DOCUMENTS AND A SEALED RECORD MUST BE UNREDACTED AND UNSEALED, CRITERIA AND PROCEDURE FOR REDACTION AND SEALING EXPLAINED)

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JURY ONLY CONSIDERED THE TREATMENT OF PLAINTIFF’S LEG AFTER IT HAD BEEN INJURED BY A DRIVER, THE DRIVER WAS PROPERLY NOT INCLUDED IN THE MALPRACTICE VERDICT SHEET.

The First Department, over a dissent, determined the driver who caused the injury to plaintiff’s leg was properly excluded from the verdict sheet in this medical malpractice action. Only the treatment of the leg injury (amputation) was before the jury, not the original injury:

[T]he court [did not] err in denying defendants’ request to place the driver of the vehicle that struck plaintiff, who settled prior to institution of the instant action, on the verdict sheet. Defendants are subsequent tortfeasors, and the jury was correctly charged that its award was to be limited to the exacerbation of the original injury caused by malpractice … . Defendants’ argument that plaintiff’s original injury and subsequent amputation were indivisible is without merit, in that the experts testified as to what the condition of the leg would have been if it had been saved … . Defendants’ arguments concerning General Obligations Law § 15-108 are academic, given that the court reduced the judgment based upon the settlement received by the settling driver. Marin v New York City Health & Hosps. Corp., 2016 NY Slip Op 08294, 1st Dept 12-8-16

NEGLIGENCE (MEDICAL MALPRACTICE, JURY ONLY CONSIDERED THE TREATMENT OF PLAINTIFF’S LEG AFTER IT HAD BEEN INJURED BY A DRIVER, THE DRIVER WAS PROPERLY NOT INCLUDED IN THE MALPRACTICE VERDICT SHEET)/MEDICAL MALPRACTICE (JURY ONLY CONSIDERED THE TREATMENT OF PLAINTIFF’S LEG AFTER IT HAD BEEN INJURED BY A DRIVER, THE DRIVER WAS PROPERLY NOT INCLUDED IN THE MALPRACTICE VERDICT SHEET)

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STATEMENT BY UNIDENTIFIED BYSTANDER, AUDIBLE ON THE 911 CALL, ADMISSIBLE, EVIDENTIARY RULINGS ARE NOT SUBJECT TO THE LAW OF THE CASE DOCTRINE.

The First Department determined that a statement by an unidentified bystander, audible on the 911 call, was properly admitted as an excited utterance. The court noted that another judge, who became ill, had ruled the statement inadmissible. Because it was an evidentiary ruling, it was not subject to the law of the case doctrine:

The court providently admitted, as an excited utterance, the statement of an unidentified bystander, audible on the 911 call made by one of the victims, that implicated defendant. All of the circumstances — most significantly that the statement was made immediately after the shooting — established a strong likelihood that the declarant observed the shooting … .

Although a contrary ruling on the excited utterance issue had been made by a previous judge, who presided over part of jury selection but was unable to continue because of illness, this circumstance did not foreclose the successor judge’s ruling by operation of the law of the case doctrine. The ruling was evidentiary and did not fall within the ambit of that doctrine (see People v Evans , 94 NY2d 499 [2000]). Defendant does not dispute that this was the type of ruling that, under Evans , may be revisited by a successor judge in a retrial. We see no reason to apply a different rule where there are successive judges in the same trial … . People v Cummings, 2016 NY Slip Op 08298, 1st Dept 12-8-16

CRIMINAL LAW (STATEMENT BY UNIDENTIFIED BYSTANDER, AUDIBLE ON THE 911 CALL, ADMISSIBLE, EVIDENTIARY RULINGS ARE NOT SUBJECT TO THE LAW OF THE CASE DOCTRINE)/EVIDENCE (CRIMINAL LAW, STATEMENT BY UNIDENTIFIED BYSTANDER, AUDIBLE ON THE 911 CALL, ADMISSIBLE, EVIDENTIARY RULINGS ARE NOT SUBJECT TO THE LAW OF THE CASE DOCTRINE)/EXCITED UTTERANCE  (STATEMENT BY UNIDENTIFIED BYSTANDER, AUDIBLE ON THE 911 CALL, ADMISSIBLE, EVIDENTIARY RULINGS ARE NOT SUBJECT TO THE LAW OF THE CASE DOCTRINE)/HEARSAY (EXCITED UTTERANCE, STATEMENT BY UNIDENTIFIED BYSTANDER, AUDIBLE ON THE 911 CALL, ADMISSIBLE, EVIDENTIARY RULINGS ARE NOT SUBJECT TO THE LAW OF THE CASE DOCTRINE)/LAW OF THE CASE DOCTRINE (CRIMINAL LAW, STATEMENT BY UNIDENTIFIED BYSTANDER, AUDIBLE ON THE 911 CALL, ADMISSIBLE, EVIDENTIARY RULINGS ARE NOT SUBJECT TO THE LAW OF THE CASE DOCTRINE)/CIVIL PROCEDURE (CRIMINAL LAW, STATEMENT BY UNIDENTIFIED BYSTANDER, AUDIBLE ON THE 911 CALL, ADMISSIBLE, EVIDENTIARY RULINGS ARE NOT SUBJECT TO THE LAW OF THE CASE DOCTRINE)

FOR CAUSE CHALLENGE TO JUROR SHOULD HAVE BEEN GRANTED, TRIAL JUDGE DID NOT MAKE A SUFFICIENT INQUIRY WHEN THE JUROR EXPRESSED DOUBT SHE COULD BE FAIR.

The First Department, over a two-justice dissent, determined defense counsel’s “for cause” challenge to a juror (Ms. J) should have been granted. Two of the juror’s siblings had been the victims of serious crimes. Although the juror, at one point, indicated she could be fair, she subsequently expressed doubt and the trial judge did not make any further inquiry at that point:

 

While it is true that the trial judge in this case asked Ms. J. on October 5, 2011 whether the crimes suffered by her siblings would affect her ability to be fair, the judge did not repeat this inquiry the next day when Ms. J. repeated her belief that her siblings’ experience might affect her ability to be fair. Defense counsel’s general inquiry into whether Ms. J. would have difficulty returning a not guilty verdict if she had a reasonable doubt was insufficient to elicit an unequivocal assurance of her impartiality, as this questioning failed to confront the very issue she had raised: that her siblings’ experiences would affect her, thus making it less likely that she might have any reasonable doubt. Just as defense counsel’s venire-wide inquiry in Arnold did not directly address a prospective juror’s personal bias, in this case, defense counsel’s general inquiry about reasonable doubt did not directly address the concerns of bias raised by Ms. J. on October 6, 2011.

…[W]e [also] find that the totality of Ms. J.’s responses did not indicate that she could set aside what happened to her brother and sister. People v Small, 2016 NY Slip Op 08293, 1st Dept 12-8-16

 

CRIMINAL LAW (FOR CAUSE CHALLENGE TO JUROR SHOULD HAVE BEEN GRANTED, TRIAL JUDGE DID NOT MAKE A SUFFICIENT INQUIRY WHEN THE JUROR EXPRESSED DOUBT SHE COULD BE FAIR)/JURORS (CRIMINAL, FOR CAUSE CHALLENGE TO JUROR SHOULD HAVE BEEN GRANTED, TRIAL JUDGE DID NOT MAKE A SUFFICIENT INQUIRY WHEN THE JUROR EXPRESSED DOUBT SHE COULD BE FAIR)

 

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WRITTEN AGREEMENT REQUIREMENT IN POLICY FOR ADDITIONAL INSUREDS DID NOT REQUIRE AN EXECUTED AGREEMENT.

The First Department determined the “written agreement” requirement in an insurance policy did not mean a “signed agreement.” Here a purchase order required that the owner’s property manager, Newmark, be named as an additional insured. The purchase order did not have signature lines and was not signed. The court held the unsigned purchase order was a “written agreement” within the meaning of the policy language:

Defendant contends that Newmark and the owner are not additional insureds because the purchase order/agreement was unsigned. However, defendant’s policy merely requires a “written” contract, not a “signed” one. By contrast, in Cusumano v Extell Rock, LLC (86 AD3d 448 [1st Dept 2011]), the policy said, “The following are also an insured when you … have agreed, in writing, in a contract or agreement that another person or organization be added as an additional insured on your policy, provided the injury or damage occurs subsequent to the execution of the contract or agreement” … . As the motion court in Cusumano found, the insurer analogous to defendant in the case at bar “expressly included the word executed’ in[] its Policy, thereby requiring that any agreement by Regions to add a person/organization as an additional insured be memorialized in a signed contract” … . * * *

Under the circumstances, the court did not err by finding that the unsigned purchase order constituted a written contract for purposes of the additional insured endorsement … . Zurich Am. Ins. Co. v Endurance Am. Speciality Ins. Co., 2016 NY Slip Op 08313, 1st Dept 12-8-16

 

CONTRACT LAW (INSURANCE POLICY, WRITTEN AGREEMENT REQUIRED BY POLICY FOR ADDITIONAL INSUREDS DID NOT REQUIRE AN EXECUTED AGREEMENT)/INSURANCE LAW (WRITTEN AGREEMENT REQUIRED BY POLICY FOR ADDITIONAL INSUREDS DID NOT REQUIRE AN EXECUTED AGREEMENT)/ADDITIONAL INSUREDS (WRITTEN AGREEMENT REQUIRED BY POLICY FOR ADDITIONAL INSUREDS DID NOT REQUIRE AN EXECUTED AGREEMENT)

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EQUITABLE ESTOPPEL DOCTRINE ADEQUATELY PLED, LAW FIRM MAY BE PROHIBITED FROM ARGUING THE ASSIGNMENT IT DREW UP FOR PLAINTIFF DID NOT ASSIGN PLAINTIFF THE RIGHT TO BRING A MALPRACTICE ACTION AGAINST IT.

The First Department, reversing Supreme Court, determined plaintiff had adequately pled that the defendant law firm was equitably estopped from arguing an assignment, which was drawn up by the law firm, did not assign to plaintiff the right to bring a malpractice action against the law firm. The law firm had missed a deadline. Although the assignment could not be interpreted to include the malpractice claim, the equitable estoppel doctrine could be applied to prohibit the law firm from arguing the issue:

The motion court correctly found that the subject assignment, which merely transferred the assignor’s “entire right, title and interest in and to the [call] option contained in Paragraph 8 of” another contract, did not explicitly assign tort claims … . The assignment is not ambiguous; even if it were (and if we therefore considered parol evidence), an unexpressed understanding does not suffice … .

However, accepting plaintiff’s affidavit in opposition to defendants’ motion as true, we find that plaintiff sufficiently pleaded that defendants should be equitably estopped from arguing that the assignment did not assign tort claims. Contrary to defendants’ contention, estoppel can be based on silence as well as conduct … . Under these circumstances, where defendants drafted the assignment at a time when it represented … plaintiff, and that interpreting the assignment to exclude tort claims would mean that neither the assignor nor plaintiff, the assignee, would be able to sue defendants for malpractice for failing to exercise the call option in a timely manner, we find that the “special circumstances” exception to the privity requirement applies … . Deep Woods Holdings LLC v Pryor Cashman LLP, 2016 NY Slip Op 08156, 1st Dept 12-6-16

NEGLIGENCE (LEGAL MALPRACTICE, EQUITABLE ESTOPPEL DOCTRINE ADEQUATELY PLED, LAW FIRM MAY BE PROHIBITED FROM ARGUING THE ASSIGNMENT IT DREW UP FOR PLAINTIFF DID NOT ASSIGN PLAINTIFF THE RIGHT TO BRING A MALPRACTICE ACTION AGAINST IT)/LEGAL MALPRACTICE EQUITABLE ESTOPPEL DOCTRINE ADEQUATELY PLED, LAW FIRM MAY BE PROHIBITED FROM ARGUING THE ASSIGNMENT IT DREW UP FOR PLAINTIFF DID NOT ASSIGN PLAINTIFF THE RIGHT TO BRING A MALPRACTICE ACTION AGAINST IT)/CONTRACT LAW (ASSIGNMENT, EQUITABLE ESTOPPEL DOCTRINE ADEQUATELY PLED, LAW FIRM MAY BE PROHIBITED FROM ARGUING THE ASSIGNMENT IT DREW UP FOR PLAINTIFF DID NOT ASSIGN PLAINTIFF THE RIGHT TO BRING A MALPRACTICE ACTION AGAINST IT)/ASSIGNMENT (LEGAL MALPRACTICE, EQUITABLE ESTOPPEL DOCTRINE ADEQUATELY PLED, LAW FIRM MAY BE PROHIBITED FROM ARGUING THE ASSIGNMENT IT DREW UP FOR PLAINTIFF DID NOT ASSIGN PLAINTIFF THE RIGHT TO BRING A MALPRACTICE ACTION AGAINST IT)/ATTORNEYS (MALPRACTICE, EQUITABLE ESTOPPEL DOCTRINE ADEQUATELY PLED, LAW FIRM MAY BE PROHIBITED FROM ARGUING THE ASSIGNMENT IT DREW UP FOR PLAINTIFF DID NOT ASSIGN PLAINTIFF THE RIGHT TO BRING A MALPRACTICE ACTION AGAINST IT)/EQUITABLE ESTOPPEL (LEGAL MALPRACTICE, EQUITABLE ESTOPPEL DOCTRINE ADEQUATELY PLED, LAW FIRM MAY BE PROHIBITED FROM ARGUING THE ASSIGNMENT IT DREW UP FOR PLAINTIFF DID NOT ASSIGN PLAINTIFF THE RIGHT TO BRING A MALPRACTICE ACTION AGAINST IT)/CIVIL PROCEDURE (EQUITABLE ESTOPPEL DOCTRINE ADEQUATELY PLED, LAW FIRM MAY BE PROHIBITED FROM ARGUING THE ASSIGNMENT IT DREW UP FOR PLAINTIFF DID NOT ASSIGN PLAINTIFF THE RIGHT TO BRING A MALPRACTICE ACTION AGAINST IT)

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