Writing Skills Unsurpassed
Congratulations to Erin Stalzer on her motion to dismiss victory! This was a potentially high exposure case involving the UCC and medical malpractice claims arising from our clients purportedly negligent retail, distribution and placement of a contaminated chemoport which caused a “cascade of events”, including the decedent’s development of Stevens-Johnson Syndrome/ Toxic Epidermal Necrolysis and resultant wrongful death months later. Erin proactively moved for a grant of dismissal pursuant to CPLR §3211(a)(5) and (7) prior to party depositions, and artfully drafted her papers in a manner that precluded plaintiff from asserting any realistic opposing continuous treatment argument. Despite obtaining multiple adjournments from the Court, plaintiff’s counsel was ultimately unable to even submit an opposition. Please join us in congratulating Erin on her creative and proactive representation, and success on behalf of our clients.