Minkow v. Sanders

*598The documentary evidence conclusively disposed of plaintiffs legal malpractice claims (see Goshen v Mutual Life Ins. Co. of N.Y., 98 NY2d 314, 326 [2002]). The hearing court found that plaintiffs disobedience of the so-ordered stipulation directing her to transfer certain custodial accounts to her husband’s attorney to be placed in escrow or immediately liquidate the accounts and transfer the proceeds was willful. In light of such willful conduct, the motion court properly found that plaintiff— not her attorneys — was the proximate cause of her contempt adjudication and the resulting…