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In 2023 we wrote about Judiciary Law §487, summing up its history. The most recent New York Court of Appeals JL §487 case had been Bill Birds, Inc. v. Stein Law Firm, P.C., 35 N.Y.3d 173, 178 (2020), where the court stated: “As reflected in our decisions in Looff and Amalfitano, the purpose of Judiciary Law §487 is to safeguard an attorney’s special obligation of honesty and fair dealing in the course of a litigation….”