You want to sue your attorney, and the security guard downstairs won’t let the process server up.  The process server goes there several times, and fails to get upstairs.  What is one to do?

Miller v Friedman  2013 NY Slip Op 30282(U)  January 29, 2013  Supreme Court, New York County Docket Number: 400833/12  Judge: Joan A. Madden gives one answer.  You should go to the judge, via motion, early on, and ask for expedient service or some other relief.

"In the affidavit of service, Tracy Harris states that on April 16, 17 and 18, 2012, she attempted to deliver the summons and complaint to defendants at their place of business at 217 Broadway, Suite 401, New York, New York, and on each day she spoke to the security officer at the building, Willie Bernard, who told her “defendants were not available,” and he “would not allow me access upstairs.” Ms. Harris further states that on April 18, 2011 ,“I served the parties listed below by mailing a true copy of the attached papers, enclosed and properly sealed in a prepaid envelope, via signature confirmation, next day, priority mail, which I then deposited in a official depository under the exclusive care and custody of the United States Postal Services within the State of New York addressed” to defendants at the 217 Broadway address.

Based on the affidavit of service, it is undisputed that defendants were served by mail alone, which is not sufficient to effectuate service on the individual defendant under CPLR 308 or the defendant law firm under CPLR 3 IO. The CPLR does not permit service by mail alone. Rather, mailing is just one component of personal service, which is required as a follow-up after the summons and complaint are either delivered to a person of suitable age and discretion at defendants’ actual place of business, or affixed to the door of defendants’ actual place of business. 

In opposing the motion, plaintiff requests that the court “use its discretion” pursuant to CPLR 308(5) to “permit service by mail or some other mode crafted by this Court, because there is no other mode of service available.” Plaintiff also requests that the court use its discretion to find that he “need not comply with the strict provisions of the CPLR,” due to his “physical and financial hardship” and the “impracticality of other modes of service.”

Under CPLR 308(5), the court is authorized to permit expedient service where a plaintiff demonstrates that it is “impracticable” to serve a defendant under existing statutory methods.
With respect to service on a natural person, a plaintiff need only establish that service cannot be
made under CPLR 308(1), (2) and (4).Dobkin v. Chapman, 21 NY2d 490,500 (1968)  Significantly, a showing of impracticability does not require plaintiff to establish actual prior attempts by each and every statutory method of service, or require proof of due diligence. Contimortgage Corp v. Isler, 48 AD3d 732,734 (2nd Dept 2008); Franklin v. Winard, 189 AD2d 717 (1” Dept 1993); Saulo v. Noumi, 119 AD2d 657 (2nd Dept 1986). The court is not persuaded that plaintiff has sufficiently shown that service is impracticable within the meaning of CPLR 308(5). Plaintiff states in his affidavit that defendant law firm is located in a office building “manned by a security guard that does not allow citizens access to the building if they do not have an appointment” and “if there is no response from the company after the security guard attempts to contact the company via telephone.”

Even though plaintiff has not established grounds for expedient service pursuant to CPLR 308(5), the court finds that plaintiff has made an adequate showing of good cause pursuant to CPLR 306-b for an extension of time to serve the summons and complaint on defendants. Henneberry v. Borstein, 91 AD3d 493 (1st Dept 2012). Plaintiff shall have 45 days from the date of this decision and order to properly effect service on defendants, and in the event he is unable to do so, the court will reconsider his request for expedient service."

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Andrew Lavoott Bluestone

Andrew Lavoott Bluestone has been an attorney for 40 years, with a career that spans criminal prosecution, civil litigation and appellate litigation. Mr. Bluestone became an Assistant District Attorney in Kings County in 1978, entered private practice in 1984 and in 1989 opened…

Andrew Lavoott Bluestone has been an attorney for 40 years, with a career that spans criminal prosecution, civil litigation and appellate litigation. Mr. Bluestone became an Assistant District Attorney in Kings County in 1978, entered private practice in 1984 and in 1989 opened his private law office and took his first legal malpractice case.

Since 1989, Bluestone has become a leader in the New York Plaintiff’s Legal Malpractice bar, handling a wide array of plaintiff’s legal malpractice cases arising from catastrophic personal injury, contracts, patents, commercial litigation, securities, matrimonial and custody issues, medical malpractice, insurance, product liability, real estate, landlord-tenant, foreclosures and has defended attorneys in a limited number of legal malpractice cases.

Bluestone also took an academic role in field, publishing the New York Attorney Malpractice Report from 2002-2004.  He started the “New York Attorney Malpractice Blog” in 2004, where he has published more than 4500 entries.

Mr. Bluestone has written 38 scholarly peer-reviewed articles concerning legal malpractice, many in the Outside Counsel column of the New York Law Journal. He has appeared as an Expert witness in multiple legal malpractice litigations.

Mr. Bluestone is an adjunct professor of law at St. John’s University College of Law, teaching Legal Malpractice.  Mr. Bluestone has argued legal malpractice cases in the Second Circuit, in the New York State Court of Appeals, each of the four New York Appellate Divisions, in all four of  the U.S. District Courts of New York and in Supreme Courts all over the state.  He has also been admitted pro haec vice in the states of Connecticut, New Jersey and Florida and was formally admitted to the US District Court of Connecticut and to its Bankruptcy Court all for legal malpractice matters. He has been retained by U.S. Trustees in legal malpractice cases from Bankruptcy Courts, and has represented municipalities, insurance companies, hedge funds, communications companies and international manufacturing firms. Mr. Bluestone regularly lectures in CLEs on legal malpractice.

Based upon his professional experience Bluestone was named a Diplomate and was Board Certified by the American Board of Professional Liability Attorneys in 2008 in Legal Malpractice. He remains Board Certified.  He was admitted to The Best Lawyers in America from 2012-2019.  He has been featured in Who’s Who in Law since 1993.

In the last years, Mr. Bluestone has been featured for two particularly noteworthy legal malpractice cases.  The first was a settlement of an $11.9 million dollar default legal malpractice case of Yeo v. Kasowitz, Benson, Torres & Friedman which was reported in the NYLJ on August 15, 2016. Most recently, Mr. Bluestone obtained a rare plaintiff’s verdict in a legal malpractice case on behalf of the City of White Plains v. Joseph Maria, reported in the NYLJ on February 14, 2017. It was the sole legal malpractice jury verdict in the State of New York for 2017.

Bluestone has been at the forefront of the development of legal malpractice principles and has contributed case law decisions, writing and lecturing which have been recognized by his peers.  He is regularly mentioned in academic writing, and his past cases are often cited in current legal malpractice decisions. He is recognized for his ample writings on Judiciary Law § 487, a 850 year old statute deriving from England which relates to attorney deceit.