With the Memorial Day holiday, as we see on many holidays, people will travel.  Whether it’s vacation or quick visits to friends and family, major holidays like this one are when the greatest number of people travel from here to there.

The number of travelers choosing to drive may be particularly high this Memorial Day when compared to past Memorial Day holidays.  Lower gas prices combined with a general “fatigue” for flying from higher fares, new baggage fees, long security lines and increased flight delays have the AAA predicting that 89% of all travelers (31.2 million overall) will choose the automobile as their primary mode of travel this Memorial Day. This is up slightly from prior years.

When I was 16 and first started driving, I remember my parents always saying “drive safe”.  People say it to each other all the time prior to getting into a car.  It always struck me as a kind of useless thing to say, as if I would have not driven safely had you not made a specific request to the contrary.

Despite the fact that “be careful” and “drive safe” might seem to be simple common sense advice, it’s actually still helpful to hear it.  Certainly, it can’t hurt.  So,  this is our “drive safe” message to friends, family and clients and some specific things to keep in mind  if/when you head out in your car over the holiday weekend.

1.  Avoid alcohol.  Alcohol and driving is always a bad mix.  According to NHTSA statistics, on average somewhere between 35-45% of driving fatalities during our biggest holiday periods are alcohol related.  While we will never know what percentage of overall drivers on the road are intoxicated, it’s likely to be significantly lower than 35-45%.  To think that such a high percentage of fatalities are alcohol related is indeed a sobering thought.  Every day, nearly 30 people in the U.S. die in a motor-vehicle crash involving an alcohol-impaired driver.  This is all well documented and there’s not a whole lot more to say about it. Don’t drink and drive.

2.  Avoid driving during peak danger periods or be particularly careful when you do.  According to the Insurance Institute for Highway Safety, between 9 pm and 6 am is the big danger zone where a much higher percentage of drivers on the road may be under the influence than compared to daytime hours.

3.  Check that your tires are properly inflated, windshields are clear, wipers, lights and other equipment are all good and ready to go.  Adjust your seat, mirrors and climate controls before putting the car in gear.

4.  If you stop your car even briefly, never leave children or pets unattended.

5.  To stay alert on your trip, get plenty of rest before you leave and keep yourself hydrated by bringing water with you.

6.  Don’t speed − it gives you less time to react and increases the severity of an accident.  Don’t put yourself in a position where you have to rush.  Build time into your schedule to stop for food and run any other errands that need to be completed.

7.  No distracted driving.  Make sure you are hands free with your cell phone and GPS.  No eating a sandwich, drinking coffee, combing your hair or applying makeup.  Keep all of your attention on driving at all times.  Some estimates have almost 80% of accidents related to distractions.

8.  Be aware of what others around you are doing and always expect the unexpected.  Practice defensive driving and give yourself time to react. Keep a 2-5 second cushion between you and the car in front of you and 5-10 seconds if the weather is bad.  Rule of thumb is generally one car length distance from the car in front of you for every 10mph you are driving (four car lengths for 40mph, five for 50mph, etc).

9.  Secure cargo that may move around while the vehicle is in motion. Don’t attempt to retrieve items that fall to the floor. Have items needed within easy reach, such as toll fares, EZ Pass tags, water bottles, etc.

10. Wear your seat belt. Make sure all passengers are buckled up every time you get in the car. Make sure children are in age-appropriate safety seats.

Have a great weekend and be safe.  As always, if you have any questions or need help with something, feel free to contact us.

Scott Feifer

§ 1174. Overtaking and passing school bus. (a) The driver of a vehicle
upon a public highway, street or private road upon meeting or overtaking
from either direction any school bus marked and equipped as provided in
subdivision twenty of section three hundred seventy-five of this chapter
which has stopped on the public highway, street or private road for the
purpose of receiving or discharging any passengers, or which has stopped
because a school bus in front of it has stopped to receive or discharge
any passengers, shall stop the vehicle before reaching such school bus
when there is in operation on said school bus a red visual signal as
specified in subdivision twenty of section three hundred seventy-five of
this chapter and said driver shall not proceed until such school bus
resumes motion, or until signaled by the driver or a police officer to
proceed. For the purposes of this section, and in addition to the
provisions of section one hundred thirty-four of this chapter, the term
“public highway” shall mean any area used for the parking of motor
vehicles or used as a driveway located on the grounds of a school or of
a board of cooperative educational services facility or any area used as
a means of access to and egress from such school or facility.

A conviction for this violation puts five (5) points on your NY license or record.

If you’ve been issued a ticket for failure to stop for a school bus answerable to a local court, you’ll most likely pursue a plea bargain and a negotiated reduction of the charge before you schedule a trial on the merits.  If you do end up taking the case to trial, or you’ve been issued the ticket at the TVB (in NYC) where there is no negotiation and all cases go to trial, here are the most basic take aways from the statute:

• This ticket can be written anytime, anywhere.  School grounds or off school grounds (various field trips), private or public roadway, before, during or after school hours.  It is always in effect.
• Approaches from front and rear, left and right are all covered.   There’s also no provision that you be adjacent to the school bus.  A technical reading of the law would require a vehicle in the most western southbound lane of Broadway in NYC to stop for a school bus 6 lanes and one median away in the most eastern northbound lane.
• You are required to stop when passengers are getting on or off a school bus AND the school bus flashing red lights are illuminated.
• The bus in question must be a school bus as defined by the Vehicle and Traffic Law § 375(20).
• You may not pass just because the lights are off or passengers seem to be finished getting on or off.  You must wait until waived on by the driver or the bus starts in motion again.

Of course this is an important law.  Children’s safety is always a priority.  Unfortunately, the nature of this violation can sometimes lead to overly aggressive enforcement.  We’ve worked with many people who have argued that they were issued a ticket for this violation despite passengers not getting on or off the bus or just before the red lights were ever illuminated or were otherwise adamant that they did not commit a violation.  We’ve had clients tell us the issuing officer implied that he or she was indeed aggressively enforcing because of prior complaints from the school or parents.   Also unfortunate is the fact that this over agressive enforcement can sometimes carry over to a plea negotiation or hearing where a Prosecutor or Judge is slightly more weary of negotiating with or ruling in favor of someone charged with this particular violation.

Submitted by Scott Feifer

Distracted driving is any activity that diverts a person’s attention away from the task of driving.  Using cell phones and other electronic devices, adjusting various settings for the car or radio or navigation system, eating, drinking, shaving, disciplining your kids in the back…all are examples of common distractions while driving.

Distracted driving is a real issue.  Distraction should be considered an “impairment” of one’s ability to drive no less dangerous than the conventional drug and alcohol impairment.

Shouldn’t need traffic laws to tell you this isn’t safe.

Some distracted driving statistics to consider:

• In 2011, more than 3,300 people were killed and 387,000 were injured in crashes attributed to distracted driving (AAA).
• 72% of AAA members support a ban on the use of all cell phones (hand-held and hands-free) while driving except for emergency situations.
• 11 percent of all drivers younger than 20 involved in fatal crashes were reportedly distracted when the accident occurred. (Pew research)
• 40 percent of all American teens say they have been in a car when the driver used a cell phone in a way that put people in danger.
• Drivers who do not go hands free are more likely (four times more likely) to sustain injuries in a crash. (Monash University)
• Text messaging increases the chance of a crash by 23 times when compared to driving without distraction.  Average text takes drivers eyes off the road for 4.6 seconds which, at 55mph, means about a football field worth of driving essentially blind. (Virginia Tech. Transportation Institute)

Not much else to say.  Put the devices away and distractions aside and keep your eyes on the road.

By Scott Feifer

Currently, moving violation traffic tickets which will be handled by this court are handled by the Suffolk County TVB. At the TVB, there is no plea bargaining. All challenged tickets proceed to trial where the outcome is either all (win, case dismissed) or nothing (guilty as charged). We’re expecting the new court to allow plea bargaining and negotiation similar to all the other village, town, city and county courts throughout NY.

Cases which are still open and were originally answerable to the Suffolk TVB will be transferred to the new SCTPVA.

Everyone at this point is saying the right things about the new court. It is designed to open fully staffed, operate efficiently and help motorists avoid long lines and waits that motorists expect at state agencies like the DMV. Ultimately, there are plans to give motorists access to their case information online.

I know no one wants to receive a traffic ticket in Suffolk and no one is going to be excited about a traffic ticket just because it’s in a new court. However, as far as traffic tickets go, I’m hoping this court is a win-win for the County and for the motorists responding to summonses.

SCTPVA
H. Lee Dennison Building, Ground Floor, North Entrance
100 Veterans Memorial Highway
Hauppauge, NY 11788

By Scott Feifer

A larger percentage of the people I consult with tell me that they did nothing wrong and have a particular explanation for why they were issued a ticket. It was a trap, it was quota-driven at the end of the month, the officer created a hazard, I have out of state plates, it’s because I’m driving a Mercedes or it’s because I’m driving a cab…

I won’t say that people are making excuses or unwilling to take responsibility. I think people genuinely think these things are true in many cases. Moreover, I can’t say that the conversations I have with people are necessarily representative of the overall population of people who have been issued traffic tickets. I speak to the portion of people who are considering fighting and potentially hiring an attorney. I don’t get to speak to those who just admit guilt and pay the ticket so I don’t know what these people may have to say about their particular incident.

At very least I can say for sure that plenty of people who get traffic tickets feel there may have been some ulterior motive, not an actually traffic violation, behind the issuance of their ticket.

Here are some very quick thoughts on three particular types of “bad tickets” and ulterior motives for issuing them I hear mentioned by clients and potential clients. The ticket was issued because of who I am and/or the car I drive, the ticket was issued because it was the end of the month (quota) and the speed trap ticket.

1. Did I just get this ticket simply because I’m rich (driving a Porsche)…or maybe because I’m obviously not rich and won’t fight too hard (taxi), because I’m from out of state, etc? Would an officer write a ticket that had no basis in reality? Do you think lawyers over-bill clients? Do doctors prescribe medicine because a sales rep gave them Jets tickets? Do waiters urinate in soup? There are definitely some bad apples in every bunch so everything is possible. That said, it’s hard to picture too many officers literally pulling people over for absolutely no reason other than who they appear to be or where they are from. On the other hand, what about an officer who observes 100 cars speeding on a stretch and only has time to pick out five or six to issue tickets? How does the officer choose which ones to pick? It’s reasonable to assume that some bias and profiling does enter this decision making, but if the person pulled over was indeed speeding we still can’t technically call it a “bad ticket”. All in all, it’s considerably more likely one may be pulled over in partbecause of the car they are driving or some similar factor than it is to be pulled over and issued a ticket based only on such factors.

2. I don’t think there are strict quotas. It’s unlikely that an officer is ever in a position where writing three more tickets before the end of the month gets the job done but only two more and he risks facing some discipline. Officers are sent out on traffic patrol and I’m sure there is some general sense of what is reasonable productivity based on the length of their tour and the location of patrol. There may be some prodding if an officer seems unmotivated to issue summonses but it seems hard to believe there is some exact minimum number per officer per month that needs to be reached. Perhaps an undeserved or bad ticket may be issued here and there just after such prodding from a superior officer, but I’ve always been slightly skeptical of the very specific monthly quota claims that some seem convinced exist.

3. Speed traps? In some cases, officers are at locations popularly referred to as speed traps because it’s simply a place where a lot of people tend to speed. In such cases it’s no “trap”–it’s just a location in need of speed enforcement. On the other hand, some officers sit at locations that just doesn’t seem fair. A 50 mph highway goes down to 35 mph about a quarter mile prior to a toll plaza and an officer pulls you over doing 55 right after that 35 mph sign. You are still nowhere near the toll and you are driving at a very natural speed for that highway and you’ve just come out of a higher zone. Perhaps this can be considered a trap. While the trap may indeed seem unfair, technically no one “trapped” anyone into doing anything nor is it a “bad” ticket. The officer caught you exceeding the speed limit and he just sees it as clever place to sit and do his job.

I think all in all many of the so called “bad” tickets may not actually technically be so “bad”. They may be unlucky or you may feel singled out or perhaps the officer could have issued a warning or perhaps there was no dangerous situation created by your action or perhaps the sign was new or everyone else does it or the speed limit was too low for that stretch of road… As accurate as those claims may be in some cases, none of them actually adress the real issue–did you technically commit a traffic violation? There may be some truly “bad” tickets written by officers but a close honest look at most cases will show there are probably a lot fewer than people think there are.

Good/bad tickets aside, the procedure for fighting a traffic ticket is the same for every ticket ranging from the most to least deserved. If you have been charged with something and wish to avoid the points and other liabilities that come with a conviction, there’s always a way to try to do something about it. Courts which are negotiable are negotiable even with those who blatantly committed the violation at hand and courts which force traffic hearings (the TVB) require the same evidence from officers regardless of the true underlying reason for the ticket.

By Scott Feifer

New York City endured a different type of scandal in its traffic courts last year.  In New York City all types of traffic tickets including speeding tickets and red light tickets are fought in the Traffic Violation Bureau or TVB.  The TVB is the arm of the Department of Motor Vehicles responsible for adjudicating these matters.  The scandal involved NYPD police officers making tickets disappear for friends, family, business associates and the politically connected.  This is essentially the other side of coin from what is happening now in Philadelphia, with the officers engaging in these behaviors instead of the judges.

The upshot of these scandals, at least in terms of its affect on what its like to be a summonsed motorist fighting your case at the New York City traffic courts, is that it makes an already unpleasant situation that much worse.  At the TVB, a motorist could always find in their judge an unsympathetic and disinterested ear to ignore their defense and rubber stamp the conviction.  The indictment of the police officers last year has had the effect of making the police officer’s scared to lose a case for fear of reprisals within the Department.  Internal Affairs is crawling over the TVB offices in all Boroughs of New York City monitoring win rates, admonishing officer’s for losing cases and even docking officer’s hard earned vacation time.  It was even reported in the New York Post, quoting an unnamed officer, that he would be willing to lie under oath to secure a conviction to protect himself from  Police Department punishment for losing a case.  As an attorney who represents motorists in these traffic cases, I watch unrepresented motorists banging their heads in disbelief at the treatment they endure at the hands of the police and the agency responsible for dispensing justice.  One benefit of hiring an attorney can be to prevent some of the egregious injustices that might befall an unrepresented motorist. Just last week it was reported that Judge Brian Levine from the Staten Island TVB was formally reprimanded, not for his mind-boggling conviction rate and vicious penalties he dispenses, but rather for simply being rude and disrespectful to the motorists whose cases he presides over.

I do not mean to suggest that hiring an attorney is a panacea against shabby treatment at the TVB.  Nor can we guarantee that we will even win your case, although we do have a lot of success and give our clients the best chance to win that they  are going to have.  As the  rules and procedures continue to tighten at the TVB in reaction to these various scandals, at least our law office  can seek to prevent those rules from tightening around our clients necks.

By Matthew Greenberg

Typically, the “target” plea bargain is a reduction to a parking violation or other local ordinance.  The “win-win” here is that the local court collects their fine money and the motorist walks away with nothing reported to the DMV (no points, conviction or insurance ramifications at all).

Cuomo’s proposal seeks to end this type of deal on speeding tickets issued for driving 21+ mph over the speed limit.  Moreover, he looks to add an additional $80 fee when such a plea bargain is negotiated to compensate for the state surcharge that would have been paid had the case ended with a conviction for a traditional moving violations.

The $80 additional surcharge is what it is.  DMV has come up with new surcharges and increased existing charges consistently over the years.  There’s really no surprise with this type of thing.  It may not be fair, it may be just another “tax” on motorists, but it doesn’t materially alter the way traffic tickets are routinely defended.  In fact, it alters nothing–new and increased fees are very much business as usual.

The proposal to limit plea bargaining and interfere in the court process and prosecutor-defense negotiation was was more troubling on it’s face.  However, while the very first news reports offered headlines like “Cuomo seeks to end plea bargaining on speeds”, we now know this was a little too general.  The proposal isn’t quite that sweeping.  Specifically we are talking about only the following subset of speeding tickets issued:

• Speeding tickets outside of NYC and the Traffic Violations Bureau (there’s never any negotiation or plea bargaining at all there)
• Speeding tickets issued for 21+ over the speed limit
• Speeding tickets answerable in courts/counties that in the first place would even entertain a plea reduction of a 21+ speed to a non-moving violation (not all courts allow this even without the proposal)

Moreover, the proposal doesn’t set forth eliminating plea bargains on such tickets.  Instead, it requires plea bargains on such speeding violations to be reduced to some “point carrying” violation.

So the downside to motorists issued tickets under this umbrella is potentially having to accept a two point non-speeding violation instead of a not on your record at all non-moving violation.

In most cases, this will still be a fair deal worth accepting and that will be the end of the matter.

I do however have three main problems with this proposal:

1.  This was included as part of the budget to help compensate for the money NYS loses for every ticket negotiated down to a non-moving violation.  However, I feel there is potentially an unfair burden place on local courts and prosecutors.  While this may not touch every speeding ticket issued in NYS, ultimately some higher percentage of cases will go to trial as a result of slightly lesser deals on certain tickets in certain courts.  The local towns and counties are the ones who will end up having to pay for this and the fact that this potential burden has been completely ignored by NYS is wrong.

2.  Too many quotes like this one from Morris Peters, a spokesman for the governor’s budget division:  “The point of this is public safety”.  The argument is that letting these individuals issued speeding tickets for 21+ over the limit off the hook without any mark on their license is a big danger where convicting them for a two point or similar lesser  moving violation will somehow make the roads safer.  Can we please just drop the “safety” argument here?  You are adding new surcharges and included all this as part of the BUDGET.  Clearly, this is an economic move.  Don’t insult our intelligence by proposing to hit drivers up for more money, points, potential insurance, etc. but that it’s ok “because it’s good for you”

3.  I don’t like legislative control of plea bargains like this.  I understand it wouldn’t be the first time sentencing was controlled by legislation (mandatory sentencing, repeat offender laws), but these are speeding tickets.  While those other guidelines really are mostly driven by safety and concern for the public, this is purely economic.  Changing how individuals are prosecuted simply because you are losing out on a little money isn’t a good enough reason to make the change.

By Scott Feifer

This laissez faire attitude toward punishing drivers charged with a speeding ticket is not shared by our elected officials in Albany. Governor Cuomo, in his recently unveiled budget proposal is asking the legislature to approve new surcharges for those convicted of traffic infractions and is trying to make it harder to fight these infractions in court. The budget, if passed, would mandate new restrictions on plea bargaining, making it harder for New Yorkers to come to an acceptable resolution on their speeding tickets. Aside from presenting an attack from the executive and legislative branches of government on a traditional prerogative of the judicial system (not unlike mandatory sentencing guidelines), the effect of this on New Yorkers will prove truly costly on our already overtaxed population. The state already nickel and dimes its citizens with outrageous fees and taxes on most all aspects of commerce in New York. This measure is solely proposed to raise additional dollars for the state that Cuomo feels the state loses out on when drivers and their traffic court attorneys reduce speeding tickets to lesser infractions. This blatant cash grab isn’t even couched in public safety terms as its sole purpose is to generate income for the state instead of the local municipalities who at present get to keep the money generated from these plea deals.

This proposed measure is also likely to inundate the small courts around New York State that adjudicate the hundreds of thousands of speeding tickets that are issued each year. The only way these courts function efficiently is to allow motorists and attorneys the opportunity to reduce the charges that they face. Most of the local town courts are very small, with limited budgets, personnel and court hours. Some of them are even in the judge’s private homes . Attorneys such as myself in the absence of the ability to gain favorable results through negotiation will be forced to conduct trials in order to protect our clients rights and save them from the problems attendant with speeding ticket convictions. These trials will overwhelm these courts with matters that would otherwise never have been a problem. Governor Cuomo’s initiative is an example of blatant overreach on the part of the executive, a cash grab and ultimately detrimental to the citizens of New York. Lets hope the legislature rejects this folly.

By Matthew Greenberg

Here’s our list…what NOT to do while driving during the holidays.

1. Drink before driving. It’s pretty much at the top of any what NOT to do while driving list.

2. Speed or commit other ordinary traffic violations. Yes this is common sense but it’s here as a reminder that there will be increased enforcement during the holidays. Between looking for drunk drivers and attempting to recoup some of the revenue lost to the hurricane, let’s just say that while the weather outside is frightful, the opportunity for officers to issue a large volume of tickets is delightful.

3. Engage in distracted driving. Calling to wish someone happy holidays, excessively using your GPS to figure out how to get to or from that holiday party, last minute holiday party makeup application, eating fruitcake…Whatever you’re tempted to do other than pay attention while driving, just don’t do it.

4. Wear a Santa suit while driving. You’re just asking someone to pull you over, even if it’s only out of curiousity.

5. Dress as Baby New Year while driving. If an officer was potentially curious about Santa, he will definitely be curious about an adult in a diaper.

6. Do not expect normal traffic patterns or driver actions. “Sunday driving” is a real thing. I see it on the LIE every weekend. Where regular commuters understand how to merge at certain spots or otherwise react, people off their regularly beaten path tend to make last minute lane changes, suddenly slow down, etc. If a typical Sunday has drivers out of their comfort zone, holidays can take it to a whole other level. Always expect the unexpected while driving, especially during peak holiday travel times.

7. Do not rely on your regular gas station to be open. Christmas and Christmas Eve, New Years Day and Eve…if you roll up to your ordinary filling spot on fumes, you may have an issue. Just stay gassed up moreso than usual.

8. Do not ignore the hazards of driving in bad weather. This is the time of year for ice and snow on our roads. Statistically speaking, rain will cause a higher volume of accidents than snow and ice because snow and ice generally scare more people into staying home and off the roads when compared to rain. That said, people tend to brave ice and snow when they need/want to get somewhere over the holidays. If you believe you must be on the road and the winter weather is bad, be very very careful.

9. If that new John Travolta / Olivia Newton John duet “I Think You Might Like It” comes on the radio, you must turn it off immediately. Trust me.

Do NOT listen while driving…or ever!

10. While driving, please don’t spend too much time pondering these year end lists. Most are blog fillers for an otherwise slow time of year. Think instead about anything and everything good you have happening in your life and try to drive into 2013 with some positive momentum.

Happy Everything.

Scott Feifer

NYC Speeding Ticket Lawyer Goal No. 1:  Case Dismissed

In a TVB system with no plea bargaining, we’re forced to proceed to trial on every case.  The outcome of a trial is either going to be we win (case dismissed–no points, fine, or evidence of the ticket on your driving record) or we lose (guilty as charged, points and fines and surcharges as prescribed by law).

Our number once goal with speeding tickets issued in NYC is to find a way to get the ticket thrown out in it’s entirety.  Sometimes we get lucky, but as TVB in general cracks down on the easy wins (officer fails to show more than once, officer loses his notes, tickets get lost in the system) the lucky wins become  fewer and further between.  More often dismissals come from using our experience and knowledge with respect to TVB trials and fighting a ticket at the TVB in general.

NYC Speeding Ticket Lawyer Goal No. 2 (IF POSSIBLE):  Reduction to the next lower speeding category.

There are five speeding categories:  0-10mph over the limit (three points), 11-20 over (four points), 21-30 over (six points), 31-40 over (eight points), 41+ over (11 points).  In certain cases, it is possible at the TVB to slide down a lower category.

This is not a plea bargain.  It’s technically an amendment of the original speed to a different speed based on the officer’s testimony.  For example, if a motorist is charged with driving 71mph in a 50mph zone, a speeding ticket lawyer in a NYC TVB office may be able to turn the ticket into a 70 in a 50.

A few notes on these reductions:

-Every judge has different rules with respect to this.  Not all will do it, they have different procedures for when and how the request is made and some are willing to go down only one or two mph and no more.  The officer’s “visual estimation” is an important part of this procedure as is the officer’s “tolerance” (how close his visual estimations are on average to actual speed traveled).  This is not something you can just walk into court and request.  It is imperative that your speeding lawyer understands how each judge in the particular TVB court handles these situations and where it may or may not be an option to consider.

-No judge can move down more than five mph.  The TVB won’t allow it.

-In some cases, we do NOT want to pursue this.  For example, clients on the verge of losing their license even if convicted of a lesser speed.  We also do not want to request it if we think we have a good chance to get the ticket dismissed outright at the hearing or on appeal.

-A case is no longer appealable if this motion to amend is granted.  It’s essentially admitting to driving the lesser speed.  Again, a lawyer should only pursue this where a guilty finding on the original charge seemed certain and an appeal was just short of guaranteed to be useless anyway.

-Certain reductions like this can be very helpful.  The example above of 71 to 70 could save two points and $300 in assessment charges.

_________________

That’s it with NYC speeding tickets.  If it’s not dismissed or reduced one category lower, unfortunately you’ve been found guilty as charged.  That can happen even if you’re working with the best NYC speeding ticket lawyers.  I would never list it as one of our “goals”, but it is possible.  As always, we can’t guarantee results.  We can only guarantee that we will do everything possible to achieve a favorable outcome in every case and that we will honestly assess someone’s chances of success during their initial consultation.

Scott Feifer