Hello all, I have a personal injury matter (MVA) in New York where the client passed away after retaining our firm. A petition was filed in Suffolk Surrogate's Court for limited letters of administration (appointing his niece). This action is still pending and limited letters have not been issued. The SOL is coming up to file the S&C in the personal injury matter (tolling wouldn't apply since it's been more than a year since the client's death). In order to preserve our case, we filed a S&C, with the niece as the proposed administrator. Defense counsel has now filed a motion to dismiss based on lack of standing (since she's not appointed yet). Does anyone know what to do in this situation? Any help would be greatly appreciated. Thank you. -Nick DeFraia