For the doctrine to apply, the representation must be specifically related to the subject matter underlying the malpractice claim, and there must be a mutual understanding of need for further services in connection with that same subject matter. A vague ongoing representation is insufficient to invoke the doctrine.
Davis v. Cohen & Gresser, LLP, NY Slip Op 02542 (1st Dep't April 12, 2018)
Here is the decision.
