1. where the gross negligence of the counsel deprives the client of due process of law; 2. when the application of the rule will result in the 3. outright deprivation of client's liberty or propert...
6. The Lighthouse Defendants are subject to personal jurisdiction in this judicial district because they purposely availed themselves of the laws and protections of the United States and the state of New York by, among other things, knowingly directing funds to be invested with New York-based ...