- Court
- New York Supreme Court, Appellate Division, Second Department
- Case
- Matter of Taylor
- Date
- June 3, 2026
- Slip Op. No.
- 2026 NY Slip Op 03445
Background
The Grievance Committee for the Tenth Judicial District commenced disciplinary proceedings against respondent Daivery Gerard Taylor, admitted to the bar in 1995, as a companion proceeding to Matter of Silverman. Taylor was the other partner in Silverman and Taylor, PLLC, and the second signatory on the firm’s attorney escrow account at Citibank. The verified petition alleged the identical four charges of misconduct relating to the same escrow account deficiencies.
The charges arose from the same facts: between January 2017 and April 2019, five disbursements totaling $25,777.35 were made without sufficient correlating funds, and subsequent audits revealed shortages of $21,182.30 (April 2021) and $30,366.41 (December 2021) against required balances for 21 client matters. A joint hearing was conducted, and the Special Referee sustained all four charges against Taylor as well.
Holding
The Appellate Division, Second Department, confirmed the Special Referee’s report sustaining all four charges against Taylor. Like his partner Silverman, Taylor admitted to all factual allegations and did not challenge the Special Referee’s findings. He requested that any sanction be limited to public censure. The Court imposed discipline based on the same pattern of escrow account mismanagement and record-keeping failures that supported the charges against his partner.
Takeaways
This companion case to Matter of Silverman drives home the principle that both signatories on a firm escrow account bear independent responsibility for its proper management. Taylor’s status as the second partner did not diminish his obligations under Rule 1.15(a) of the Rules of Professional Conduct. Every attorney with signatory authority on an escrow account is independently required to ensure adequate funds are maintained, transactions are properly recorded, and accounts are regularly reconciled. The identical charges against both partners demonstrate that disciplinary authorities will pursue all responsible attorneys, not just the managing partner.
Why It Matters
This case, read together with Matter of Silverman, sends a clear message to law firms of all sizes: escrow account obligations are personal and non-delegable. A partner cannot avoid disciplinary responsibility by claiming that the other partner managed the account or directed the problematic disbursements. Both attorneys with signatory authority faced the same four charges and the same disciplinary consequences. Law firms should implement dual-control procedures, mandatory reconciliation schedules, and internal audit mechanisms to prevent the kind of systemic escrow failures that led to these parallel proceedings. The cases also highlight the importance of seeking compliance guidance proactively rather than waiting for a grievance committee investigation.