LEVINE, Justice.
Penny Selland commenced a divorce action against Larry Selland. In response to the summons and complaint, Larry filed a third-party complaint for damages arising from the allegedly unauthorized practice of law by Donna Bard and Diane Zainhofsky, certified domestic violence advocates, who had assisted Penny in an adult abuse proceeding which was the subject of a previous appeal to this Court. See Selland v. Selland,
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