Zipporah is a member of the Professional Liability Department where she focuses her practice on the defense of attorneys, accountants, insurance producers, corporate directors and officers, and financial institutions, among other clients. She previously served as a law clerk at our firm and most recently served as an attorney at the U.S. Equal Employment Opportunity Commission (EEOC).
Further, Zipporah completed a service year with the Jesuit Volunteer Corps., working at the Center for Community Alternatives, where she provided employment services to those who were formerly incarcerated. Upon concluding her service year, she served as a Pro Bono Case Manager at Philadelphia VIP, connecting low-income Philadelphians to volunteer attorneys for civil law matters.
After working for Philly VIP, Zipporah attended Delaware Law School where she received her Juris Doctorate. She currently serves on the Board of Directors at Spectrum Health Services, Inc., a Federally Qualified Health Center (FQHC).
Zipporah is admitted to practice in the District of Columbia and the state of New Jersey.
Thought Leadership
Case Law Alerts
U.S. Bankruptcy Court Upholds State Court Decisions
April 1, 2026
On March 10, 2025, the United States Bankruptcy Court, District of New Jersey, reinforced the decisions of the state court and its power to issue final judgments, including sanctions through the dismissal of the adversarial complaint. After years of complex litigation, the state court issued economic sanctions against the plaintiff for multiple offenses, including frivolous litigation and violations of sealing orders. These sanctions included attorney’s fees. The plaintiff failed to pay the sanctions, and they were subsequently entered as judgments, and then recorded as liens on her property. The current action arose after the plaintiff sold the property and noticed the recorded liens, despite the previous court notices. The plaintiff filed an adversary complaint in federal bankruptcy court seeking, a “judicial determination that the lien was fraudulent in origin and of no legal effect,” and sued the attorneys and their firms from the underlying state court matter. All defendants filed a motion to dismiss based on several bases, including: “(1) the Debtor lacks standing to bring the claims asserted in the Complaint; (2) the claims are barred by the Rooker-Feldman doctrine; (3) the claims are barred by collateral estoppel, res judicata, and the entire controversy doctrine; (4) the Complaint fails to state a cause of action; (5) the claims are barred by litigation privilege; (6) the Complaint improperly seeks an advisory opinion.” The court granted the motions to dismiss for multiple reasons. First, the court agreed that the plaintiff did not have standing to pursue a cause of action after the appointment of a trustee. Secondly, the court found that the claims were barred by the Rooker-Feldman doctrine because she sought to have the bankruptcy court rule that judgments entered by the state courts were invalid. The court found that they lacked the jurisdiction to consider the sanctions and their legitimacy under Rooker Feldman. Subsequentially, the court dismissed the matter because it was already litigated in state court, therefore issue preclusion barred the relitigating of the issue. Additionally, it was determined that the plaintiff failed to state a claim because she made conclusory statements, but did not make factual allegations to support the claims. Lastly, the court dismissed the plaintiff’s claim because it was impermissible for federal courts to give advisory opinions based on the hypothetical statement of facts.
Legal Updates for Lawyers' Professional Liability
New Jersey Defines When Attorneys Owe Duties to Non-Client
March 1, 2026
Christakos v. Boyadjis, 262 N.J. 447 (2026) When does an attorney owe a non-client a duty of care? And when can that non-client bring forth an action for legal malpractice? Christakos v. Boyadjis, 262 N.J. 447 (2026), undertakes these questions and considers the appropriate standard. In the present matter, the plaintiffs brought suit against the attorney that prepared the wills of their two family members, alleging legal malpractice. The two plaintiffs were the sister-in-law and niece to the decedents. The decedents were brothers and, in 2003, they executed mirror image wills, along with completing powers of attorney (POA) documents in 2001. As a result of these documents, the plaintiffs stood to inherit part of the estate, and one plaintiff was attorney-in-fact under the POA. However, the plaintiffs had no knowledge of this or the testamentary documents. In 2017, the brothers sought to make changes to their wills, expressing a strong desire to disinherit their nephew and nieces, wanting to leave their estate to their church and local community members that were supporting them in their advanced age. In 2018, their health began to decline, and the attorney made the final changes to their wills. The will for the first brother was completed in January 2018, leaving everything to the surviving brother, and the alternative residuary was to be split equally between two neighbors, their church, and then their sister-in-law, which is one of the plaintiffs. The other brother was not competent to execute the will and continued to have cognitive decline. This brother executed his will on April 7, 2018, after a home health aide determined that he was in a lucid state and had testamentary capacity. A few days letter, that brother was confirmed to be incompetent and needed a legal guardian appointed. Both brothers died in 2018, and the niece filed two caveats, challenging both wills among other probate actions. In 2020, the plaintiffs sued the attorney for legal malpractice, breach of fiduciary duty, and other claims, arguing that the attorney owed them a duty of care because they were beneficiaries to the brothers' estate. After years of motion practice and appeals, the Supreme Court of New Jersey expressly adopted the provisions of Section 51 of the Restatement (Third) of the Law Governing Lawyers to determine when a lawyer owes a duty of care to a non-client. In doing so, the court determined that the standard hinges upon reliance and clear, convincing evidence of intention.
