Judiciary Law 487 does not have special pleading requirements as does Fraud.  It has not in the past been subject to CPLR 3016.  It is not a species of Fraud…it is the common law.  However, courts are general not friendly to JL 487 and find a plethora of ways to dismiss.  Betz v Blatt
2014 NY Slip Op 02554 [116 AD3d 813]  April 16, 2014  Appellate Division, Second Department is one such example. 

It’s an estate matter in which the first executor looted the estate and suffered a surcharge of more than $1 million.  When executor 2 comes into play, a legal malpractice case is started against the attorney for executor 1.  It falters.  The JL 487 claim is dismissed on pleading grounds.  Its the 15th cause of action.

"The Supreme Court properly dismissed the second and seventh causes of action, which alleged breach of fiduciary duty, the third, eighth, and thirteenth causes of action, which alleged fraud and breach of trust, and the fourth and ninth causes of action, which sought disgorgement and restitution of attorneys’ fees, which were all based on the same facts as the causes of action to recover damages for legal malpractice, and did not allege distinct causes of action (see Putnam County Temple & Jewish Ctr., Inc. v Rhinebeck Sav. Bank, 87 AD3d 1118, 1120 [2011] Weiss v Manfredi, 83 NY2d 974, 977 [1994] Financial Servs. Veh. Trust v Saad, 72 AD3d 1019, 1021 [2010] Mahler v Campagna, 60 AD3d 1009, 1012 [2009]). Likewise, the court properly dismissed the third, fifth, eighth, tenth, thirteenth, and fifteenth causes of action, since they were not pleaded with the requisite degree of particularity (see CPLR 3016 [b] Eurycleia Partners, LP v Seward & Kissel, LLP, 12 NY3d 553, 559 [2009] Parekh v Cain, 96 AD3d 812, 816-817 [2012] Putnam County Temple & Jewish Ctr., Inc. v Rhinebeck Sav. Bank, 87 AD3d at 1120)."