Comprehensive litigation is a decision made before the first filing.

IThe method

“Comprehensive” is a word every firm uses. I mean something specific by it. A comprehensive representation takes the whole case, not the part of it that is convenient: every count in the indictment, every claim the facts support, every forum the law allows, and every stage from the first motion through the verdict and the appeal. The decision is made at the start, because it shapes everything that follows: how the complaint or the answer is drafted, which motions are filed, how discovery is run, and whether the other side believes, from the first day, that the case will be tried.

Three refusals follow from it.

• No compromise on the merits.

  A claim is dropped because it is weak, never because fighting it is expensive or the opponent is irritated by it. A conviction is appealed because there are grounds, not because the appeal is likely to be comfortable.

• No deference to the other side’s pocket.

  The Department of Justice, a federal agency, a wealthy adversary with a national firm behind it: the resources on the other side change the work. They do not change the posture, and they do not change the price of the case to my client.

• No fear of trial.

  A case prepared to be tried settles on the client’s terms. When it does not settle, it is tried. The other side learns early which kind of case it is in.

To the end

A case is finished when a court has decided it, not when one side is tired of it. That is why the appeal in Gasperini was taken after an acquittal on every felony: the one count that remained had not yet been decided by a court of appeals, and a client is owed the final answer, whatever it turns out to be. The same holds in civil cases. A trial is the only procedure that finds facts under oath, before a neutral, subject to cross-examination; everything before it is argument about what the facts would show. A motion withdrawn, a complaint dismissed by the party who filed it, a dispute dropped on the eve of a ruling: each leaves the question open, and an open question is not finality. My clients come to court for a finding of what happened and a judgment on it. The method commits to getting them both, however long it takes, and whichever side would prefer that the question never be answered.

Where cases are decided

A courtroom is the only place where a claim is tested. It is where a witness speaks under oath and is cross-examined, where a document is authenticated before it is believed, where a party who asserts a fact must prove it and a party who denies one must answer it, and where a neutral decides. Nothing else does that work. A newspaper reports; it does not find facts. A press release answers to no one. A post on social media, however many people it is written for, is not evidence, not a pleading and not a ruling. It is a statement, and like every statement made outside the courtroom it can be put to its author later, under oath, in the one place where it has to be defended. My clients’ cases are tried where cases are tried. What is said about them elsewhere is noted, kept, and brought along. This page is no exception: it describes a method, and it says nothing about any pending matter that the docket does not.

When the money runs out

Most litigation does not end with a judgment. It ends when one side can no longer pay for it, and the settlement that follows reflects the balance of the bank accounts rather than the merits. A well-funded opponent knows this and plans for it: the extensions, the motions and the volume of paper are not always meant to win; sometimes they are meant to cost. A comprehensive representation has to answer that too, or everything above is a slogan. In Gasperini, the client’s funds were exhausted after the first hearings. The seven-day trial, the sentencing and the Second Circuit appeal went forward regardless, at no cost to him. Jimenez v. Mullin is pro bono from the first filing. I do not promise that to every client, and I do not take every case. But once a case is taken, it is not the other side’s budget, or the exhaustion of my client’s, that decides when it ends.

IICivil cases, on either side of the caption

I take civil and commercial cases as plaintiff and as defendant, and the method is the same from either chair. What changes is only the first filing.

When the client is sued, the first filing is a motion to dismiss that is briefed to end the case, not to postpone it. The test of such a motion is what the other side does with it. A plaintiff who answers it by asking for leave to amend, or by swearing to new facts in his opposition, has told the court something about that pleading. Held to his earlier words, motion after motion, a plaintiff whose story moves tends to lose it; the Commercial Division case below is what that looks like over two rounds. If the case survives the motion, the answer carries the counterclaims: every claim my client holds against the party who sued goes on the record then, so that the plaintiff understands that it has opened a case, not merely brought one.

When the client has been wronged, the complaint pleads the whole dispute. The claim for money is pleaded, and so is the claim for a declaration of who owns what, the claim that carries attorney’s fees under the statute or the contract, and the claim against the individual as well as the entity. A complaint that pleads only the comfortable claims invites a settlement on the other side’s terms. A complaint that pleads all of them sets the terms.

The forum is chosen, not accepted. A party who sues first has not chosen the forum for good. If it abandons its own case, the question of where the dispute is heard is open again, and my clients answer it with a complaint of their own, built to be tried.

The opponent’s balance sheet is its problem. A well-funded party buys more paper, more extensions and more lawyers on the signature block. It does not buy a different record, and discovery is where the record is made. An opponent’s budget does not shrink my client’s case, and it does not raise my fee.

The trial: United States v. Gasperini

In 2017 an Italian citizen, arrested in Amsterdam and extradited to Brooklyn, stood trial in the Eastern District of New York on a five-count indictment: computer intrusion with intent to defraud and for financial gain, wire fraud conspiracy, wire fraud, and money laundering. The Wall Street Journal previewed it as the first click-fraud trial in the United States and reported an exposure of up to seventy years in prison. The prosecution was the United States Attorney’s Office. The defense was my office.

A comprehensive defense meant contesting every piece of the government’s case rather than negotiating around it. Before trial, a motion to dismiss for want of a sufficient connection to the United States, which I described to the Journal as “government overreaching to civil matters abroad.” A motion to suppress evidence gathered in violation of the Stored Communications Act. A challenge to the authentication of screenshots from the Internet Archive. Then seven days of jury trial on all five counts. The jury acquitted on every felony. It convicted on a single lesser-included misdemeanor, computer intrusion under 18 U.S.C. § 1030(a)(2)(C).

The appeal on the misdemeanor

A client acquitted of every felony has, by most measures, won. The comprehensive method does not stop there. The misdemeanor went to the Second Circuit on three principal grounds: that the statute of conviction is unconstitutionally vague, that the Stored Communications Act evidence should have been suppressed, and that the Wayback Machine screenshots were wrongly admitted. I argued the appeal on June 6, 2018. On July 2, 2018 the court affirmed, in a published opinion that is now widely cited on the admissibility of Internet Archive evidence in the federal courts.

We did not prevail on the appeal. I say so plainly, because this page is about method, not a highlight reel. The remaining count was taken as far as the law allowed, exactly as the felony counts had been. That is what the client was promised at the first meeting, and it is what he received.

United States v. Gasperini, 894 F.3d 482 (2d Cir. 2018), affirming No. 1:16-cr-00441 (E.D.N.Y.).

The defense: Huskanovic v. Armenti

In January 2024 a plaintiff sued three defendants in the Commercial Division of the New York Supreme Court. He claimed to have been, under an oral agreement, the fifty-percent owner of a Manhattan tour company for ten years, during which he had drawn no salary, received no distribution and seen no tax document. He pleaded eleven causes of action and demanded $4.5 million in damages. I represented two of the three defendants: the founder’s sister, and the travel company the plaintiff said had been formed as a “subsidiary” to divert the money.

The comprehensive response to a complaint like that is not an answer followed by two years of discovery. It is a motion to dismiss, and then another one, each holding the plaintiff to what he had already sworn. On the first motion he retreated. His counsel conceded in open court that he “was never an actual owner” of the travel company and that, as to my clients, “we know we have little to no evidence there.” The court dismissed from the bench, called the theory “a little chaotic,” and allowed one amended pleading, with a warning that the next one would be measured against the documents and against a motion for sanctions.

The amended complaint arrived with a new explanation for the ten silent years. The second motions showed that explanation to be wrong as a matter of law and of the plaintiff’s own conduct. His opposition abandoned it and offered two further theories, one of them a signed contract that had appeared in neither verified complaint and that he could not produce. By the time of argument the court was describing the case as “a distinctly moving target” and “a compelling story in search of a legal theory.”

By decision and order of December 23, 2025, my clients’ motion was granted in its entirety and every claim against them was dismissed. The remaining defendant’s motion was granted as to every cause of action but one. A plaintiff who changes his story is answered, each time, with the record of what he said before. That is slow, unglamorous work. It is also the only thing that ends a case like this without paying for it.

Huskanovic v. Armenti, Index No. 650244/2024 (Sup. Ct. N.Y. County, Commercial Division, Dec. 23, 2025). The record is public on NYSCEF.

The class action: Jimenez v. Mullin

The plaintiff is a Connecticut police detective and Army veteran. He is a United States citizen. His wife is in Brazil. The petition that would let her wait for her immigrant visa in the United States, the K-3 petition, had sat unadjudicated at USCIS since August 2025, well past the agency’s own published processing times, when the suit was filed.

The conventional response is a single mandamus petition for a single file. It gets one man his decision and leaves the practice that produced the delay intact for everyone behind him. The comprehensive response is different. The complaint pleads his individual claims under the Administrative Procedure Act and the mandamus statute. By amended complaint and a motion for class certification filed on October 19, 2026, it also asks the court to certify a Rule 23(b)(2) class and to set aside the government’s practice of administratively closing K-3 petitions once the underlying spousal petition is approved, and its refusal to sell premium processing to families while it sells it to employers.

The defendants are the federal immigration agencies and the officials who run them. The plaintiff’s counsel is one lawyer. The government’s response to the amended complaint and to the certification motion is due on December 14, 2026.

Jimenez v. Mullin, No. 3:26-cv-01384 (D. Conn.). Pending; the docket is public.

VIWhat this means in practice

A criminal jury trial, a commercial defense in the New York Commercial Division and a class action against the federal government have little in common. In each, the scope of the representation was set by the case, not by the budget of the other side or by the path of least resistance. For a client, that translates into a short list of commitments.

• Plaintiff or defendant.Civil and commercial cases on either side of the caption, individuals and companies, against private parties and against the government.
• One lawyer, start to finish.No leveraged pyramid. The person who wrote the motion argues it, takes the depositions, and tries the case.
• The whole case pleaded.Every claim the facts support goes into the complaint, including the ones that are harder to plead and prove.
• The forum chosen, not accepted.Where the case is heard is a decision, made early and defended, whether my client is the first to file or the one who was sued.
• Motions as the case, not as delay.A motion to dismiss, to suppress, or to certify a class is filed to change the case. It is briefed to be won, not to buy time.
• Trial and appeal budgeted from day one.A case is prepared as if it will be tried, and an adverse ruling is prepared as if it will be appealed. Both usually prove unnecessary. Both are sometimes needed.
• A straight answer on prospects.Including when the answer is that an appeal was lost. A client who is told the truth about the record can make real decisions about it.

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