
Construction and workplace liability under Labor Law §§ 200, 240, and 241.
Duty to defend, exclusions, additional insured status, and coverage disputes.
Contractual and common-law risk transfer, defense, and allocation issues.
Preservation, standards of review, and appellate strategy in New York courts.
CPLR motion practice, pleadings, discovery disputes, and procedural rulings.
Credibility issues, exaggeration, inconsistent claims, and defense tools.
Admissibility, expert affidavits, foundation, and evidentiary standards.
Premises liability, motor vehicle accidents, medical causation, damages, and defense strategies in New York personal injury litigation.
Jury selection, motions in limine, witness preparation, and trial tactics.
Using technology and AI responsibly to improve legal analysis and workflow.





Matthew Lerner’s recent appellate and trial results.

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✉️ mlerner@gerberciano.com
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