Here is an Appellate Division, Second Department case in which plaintiff is the law firm seeking fees after matrimonial work and defendant is the client.  Parola, Gross & Marino, P.C. v Susskind
2007 NY Slip Op 06850 ; Decided on September 18, 2007 ; Appellate Division, Second Department

Here, the client could not link up mistakes and damages.  "Here, the counterclaims failed to allege any material facts giving rise to a cognizable claim for legal malpractice (see Hartman v Morganstern, 28 AD3d 423). To establish a counterclaim to recover damages for legal malpractice, the defendant is required to show that the plaintiff failed to exercise the care, skill, and diligence commonly possessed and exercised by a member of the legal profession, that the plaintiff’s negligence was a proximate cause of the loss sustained, that the defendant incurred actual damages as a result of the plaintiff’s actions or inaction, and that but for the plaintiff’s negligence, the defendant would have prevailed in the underlying action or would not have sustained any damages ( see Arnav Indus., Inc. Retirement Trust v Brown, Raysman, Millstein, Felder & Steiner, 96 NY2d 300; Pistilli v Gandin, 10 AD3d 353, 354). Here, the defendant’s counterclaims merely set forth conclusory allegations of negligence on the part of the plaintiff and wholly failed to allege any actual damages that he sustained as a result of the plaintiff’s alleged negligence. "