Time Chart of Potential Mistakes: Notices, Service and Answer


  • Municipal prior notice
  • Agency prior notice
  • Correct agency or municipality to serve- HHC, City, State
  • Private requirements- Insurers, contract requirements
  • Conditions precedent
  • Exhaustion of prior remedies
  • Affidavits to include
  • Motions for leave, requirements of affidavit, reasonable excuse, meritorious cause of action, knowledge of municipality
  • Index number for the motion, may not be used for the complaint
  • Serving by necessary method, whether certified or in person


  • You are responsible for acts of process server
  • Numerous issues of obtaining jurisdiction over the person
  • File proof of service- no longer required, but good practice
  • Communication with client reporting successful service
  • Time period for service


  • Default and the time in which to bring a default
  • Bring motion to dismiss on lack of personal jurisdiction within applicable time limit
  • Reply to Cross-claims is necessary
  • Anything not specifically denied or dealt with is admitted
  • Must include all your counterclaims
  • Must include all affirmative defenses
  • Extensions should be in writing
  • Third-party practice necessary now

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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!

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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...

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