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Comments Off on Pecuniary Damages Rule Applied to Malpractice in Criminal Cases
By Lazar Emanuel [Originally published in NYPRR September 2002] In Wolkstein v. Morgenstern [713 N.Y.S.2d 171 (App. Div. 1st Dept. 2000)], the First Department promulgated a simple and clear rule in all civil cases: Except in cases of conduct “so...