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ROTH LAW FIRM, PLLC v. SANDS

4687N, 602323/07.

82 A.D.3d 675 (2011)

920 N.Y.S.2d 72

ROTH LAW FIRM, PLLC, Respondent, v. STEVEN BRETT SANDS et al., Appellants.

Appellate Division of the Supreme Court of New York, First Department.

Decided March 31, 2011.

Plaintiff's failure to comply with the letter of engagement rule (22 NYCRR 1215.1) does not preclude it from seeking recovery of legal fees under such theories as services rendered, quantum meruit, and account stated (see Miller v Nadler, 60 A.D.3d 499 [2009]).

Plaintiff failed to establish its entitlement to recovery based on an account stated. Its invoices were addressed to a variety of entities and individuals; in...

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