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VOL. 2 NO. 142 DECISIONS RELEASED AUGUST 5, 1994 ATTORNEY/CLIENT 04-2-3902 Suzanne Cooper et al. v. Budd, Larner, Gross, Rosenbaum, Greenberg & Sade, P.C. at al., App. Div. (7 pp.) Where defendant law firm conceded that plaintiffs did not need an expert to establish defendant’s negligence in failing to file the client’s medical malpractice complaint before the statute of limitations expired, trial court erred in requiring expert testimony to establish that negligence was the proximate cause of damages. AUTOMOBILES 05-2-3903 State v. Joseph J. Crescente, Jr., App. Div. (6 pp.) Driving-under-the-influence conviction reversed where Breathalyzer Model 900 results were tainted by the presence of hand-held radio transmitters near site where defendant was being tested. INSURANCE 23-2-3094 Susan Taylor-Segan v. Ganesh P. Rajagopal, App. Div. (9 pp.) New Jersey’s “deemer” statute, N.J.S.A. 17:28-1.4, providing that nonresident auto owners are subject to the N.J. verbal threshold, does not unconstitutionally deprive Pennsylvania resident, who paid for full tort coverage under her own auto policy, of the right to sue for pain and suffering. CRIMINAL LAW AND PROCEDURE 14-2-3905 State v. Julio Hernandez, App. Div. (6 pp.) Neither attempted extortion nor official misconduct involve per se crimes of violence that would support the imposition of Violent Crimes Compensation Board penalties.

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