Sussman v. Grado

Herbert Sussman (plaintiff), needing a turnover order to enforce a judgment against a debtor's two bank accounts, hired independent paralegal Marcia Grado (defendant), a certificate-program graduate with 13 years of experience who worked without attorney supervision. Although Grado admitted she did not know how to draft a turnover order, she accepted the assignment for a $45 fee, consulted three attorneys unfamiliar with the document, and then prepared and submitted it herself based on her general knowledge of similar court filings; the Sheriff's Department found the papers deficient, causing Sussman's enforcement effort to fail, and he sued Grado for the value of his lost judgment and the fee he had paid her.