Nostrame v. Santiago, A-40 September Term 2011; Supreme Court; opinion by Hoens, J.; decided March 11, 2013. On certification to the Appellate Division, 420 N.J. Super. 427 (App. Div. 2011). [Sat below: Judge Parrillo, Yannotti and Skillman in the Appellate Division; Judge O'Connor in the Law Division.] DDS No. 04-1-9272 [32 pp.]

In this appeal, the court considers three issues: whether, and under what circumstances, an attorney might have a cause of action against a successor attorney for tortious interference with an attorney-client relationship; the factual and procedural predicates required for assertion of and prosecution of such a claim; and whether plaintiff should have been afforded the opportunity to file an amended complaint or to pursue discovery to uncover evidence of wrongdoing.