Time Chart of Potential Mistakes: Judgment, Notice of Appeal, Appeal, and End of the Relationship


  • You should prepare
  • Correct interest
  • Use of special verdicts in judgment
  • Timely filing of judgment increases interest
  • File notice of appeal from judgment if necessary
  • Prompt payment of judgment per CPLR
  • Cite all unappealed motions if necessary

Notice of Appeal

  • Time limits can not be waived
  • Measure date carefully
  • File with Clerk and opponent
  • RADI necessary in 2d Dept.
  • Craft to appeal only that which you need to appeal
  • Watch for Cross-appeal
  • Be sure to serve document with notice of entry


  • Timely perfection
  • Make motion early if necessary
  • Highly technical rules about included items, pages, printing, service
  • Recite post trial motions
  • Advise client about time limits, costs, likelihood of success, downside if any
  • Letter requesting oral argument, discussion with opponent
  • Form to be filed in Court on day of argument

End of the Relationship

  • Rules about holding files at end of relationship
  • Liens: charging, retention, quantum meruit, contingency
  • Rules about selection of compensation when representation is terminated
  • Retention of files for 7 years
  • Communication often heads off complaints
  • Ethical rules re: Disciplinary complaints

Client Reviews

I was referred to Andrew Bluestone by another legal professional for a consultation on a specific subject. He called back promptly, gave concrete answers to my questions and provided an informed opinion on the matter. Highly professional!

Kamen A.

I contacted Andrew to inquire about a potential action against my attorney for professional negligence. He returned my call the same day and was very helpful in walking me through my options and making a recommendation for how I should handle my situation. Very professional, knowledgeable, and...

Jason M.

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  2. 2 Unique Personalized Service
  3. 3 Dedicated Representation
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