Zaref v. Berk & Michaels, P.C

In Zaref v. Berk & Michaels, P.C., 192 AD2d 346 (1st Dept. 1993), the court reiterated that "the continuous representation must be in connection with the particular transaction which is the subject of the action", and declined to apply the doctrine even through the defendant attorneys subsequently provided services to the plaintiffs by preparing tax returns, making investment decisions, and obtaining mortgages and insurance.