In Harmon v. Huntington Hospital, 163 Misc 2d. 150 (Sup.Ct., N.Y.Co. 1994) the plaintiff was representing himself. Justice Stanley Sklar noted in Harmon that the Legislature found the intent of CPLR 3012-a was to "deter the commencement of frivolous cases" brought by attorneys on behalf of their clients. (163 Misc 2d. at 151 citing L 1986, ch 266 1.) He also noted that the Legislature, while not explicitly discussing its reasoning for excluding pro se plaintiffs from the requirement to file a Certificate of Merit, did not appear concerned with pro se plaintiffs bringing frivolous lawsuits. Rather, the statute "was aimed at reducing frivolous suits commenced by attorneys on behalf of their clients." (163 Misc 2d. at 151.)