An attorney violates § 487(1) by intentionally deceiving the court or any party. A claim premised on a statutory violation must be supported by a showing that the attorney intended to deceive, or engaged in a chronic and extreme pattern of legal delinquency. In order to make a prima facie showing of entitlement to summary judgment, an affidavit from someone with actual knowledge of the allegations is sufficient. The defendant is not required to submit an affidavit from a legal expert.
Koch v. Sheresky, Aronson & Mayefsky LLP, NY Slip Op 03178 (1st Dep't June 4, 2020)
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