An appeals panel in Manhattan last week ruled that an attorney who failed to comply with a court rule covering retainer agreements and who was discharged by his client can nevertheless recover the value of services provided to the client.

The Appellate Division, 1st Department’s unanimous ruling in Nabi v. Sells, 1378, 1378A, narrowed a lower court ruling that would have permitted the lawyer, Derek S. Sells, who had not complied with the 2002 court requirement that clients be given retainer letters, to recover on the terms outlined in an agreement he claimed he had with Massod Nabi.

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