As discussed previously on this blog, New Jersey law often precludes recovery by a non-client against an attorney. Aside from wills, courts have also created an exception when an attorney owed a duty to a non-client by virtue of being aware of something the non-client could not have found out. Davin, L.L.C. v. Daham v. Kress et al., 329 N.J. Super. 54 (NJ Super. App. 2000) is a case with a complex set of facts, and two legal malpractice actions. The attorneys being sued were Ahmad Daham's attorneys as well as the attorneys who represented Kress.