Lerner v. Laufer

During her divorce mediation, Lynne Lerner (plaintiff) was referred to divorce attorney William Laufer (defendant), who provided a letter clearly stating he hadn't performed financial due diligence and couldn't advise on whether the proposed settlement's terms (giving her $500,000 and 15 percent of stock worth over $3 million, in exchange for waiving the remaining 85 percent) were fair compared to a potential trial recovery, explicitly limiting his role to reviewing the agreement itself; Lynne signed the letter, reviewed the agreement with Laufer, and executed it. She later signed Laufer's standard retainer agreement (listing broader services including financial due diligence), and Laufer suggested some amendments before the final judgment was entered. Five years later, Lynne sued Laufer for malpractice, claiming his limitation letter didn't validly restrict his representation and that his suggested amendments exceeded whatever limits existed; the trial court dismissed the suit, and Lynne appealed.