Rxmedical Dynamics Llc, Charlotte Wray, Frank Cerasoli v. Lani Adler Esq.

Plaintiffs are seeking a trial de novo in connection with an arbitration award, dated

on or about June 20, 2019, obtained in their absence. A copy of that award is attached to this

Complaint as Ex. A. In an email dated on or about June 20, 2019, the same day as the award, Ms.

Elizabeth Biberman, the Program Administrator for the Joint Committee on Fee Disputes and

Conciliation, acknowledged that “the client” i.e., Plaintiffs, were “disadvantaged” by the

arbitration, in that the Plaintiffs “could not attend and I was unable to confirm that the date was going

forward before I left town.” A copy of that email is attached to this Complaint as Ex. B.

In connection with the arbitration, Defendant demanded that Plaintiffs pay some

$48,841.79 in purported overdue fees, but those fees, if due at all (and Plaintiffs dispute that any

fees are due whatsoever), are due to Ms. Adler’s former firm, Fensterstock & Partners LLP

(“Fensterstock”), and not to Ms. Adler. A copy of the Fensterstock engagement letter agreement

is attached to this Complaint as Ex. C. Regardless, as previously stated, Plaintiffs owe no fees to

Causes of Action

COUNT I Declaratory Judgment – No Fees Due to Adler

COUNT II Declaratory Judgment – Unreasonable, Unnecessary, Excessive, and Unauthorized Legal Fees