[brief] **THE TRIAL COURT ERRED IN DISMISSING THE NINTH COUNT THROUGH THE ELEVENTH COUNT OF PLAINTIFFS’ COMPLAINT FOR LEGAL MALPRACTICE AGAINST [...] (183a)**  The Ninth Count through the Eleventh Count of Plaintiffs’ Amended Complaint allege legal malpractice against [...].  The legal malpractice alleged in said Counts arises solely from Plaintiffs’ newly discovered evidence and newly discovered claim in the 2015 Action that [...] was Sole Member of [...] and controlled and operated [...] as a sham entity.  The legal malpractice claimed against [...] arises solely from [...]’s failure to advise Plaintiffs of said facts during the course of his representation.  None of these facts nor claims were alleged in the complaint that was dismissed against [...] in the 2015 Action, as said facts were discovered in the course of the 2015 Action following said dismissal.  The Trial Court’s sole basis for dismissing said Counts against [...] was expressed by the Trial Court as follows:  To the extent these Counts are based on the same factual predicates underlying the legal malpractice claims asserted in the 2015 case, they are clearly barred by the Law of the Case Doctrine, as the legal malpractice claims asserted in that case were dismissed with prejudice by the Court…  Neither the Trial Court nor the opposition briefs explain how claims that are entirely new, arising out of the discovery that [...] was Sole Member of [...] and controlled and operated [...] as a sham entity – facts and claims which were not pled before the dismissal of the complaint against [...] in the 2015 Action, since they were unknown by Plaintiffs at the time – could possibly be “based on the same factual predicates underlying the legal malpractice claims asserted in the 2015 case. ”  The new legal malpractice claims against [...] were not and could not have been known or pled prior to the dismissal of the previous claims, because they arise solely out of [...]’s ownership of [...] and control and operation of [...] as a sham entity, which are facts that could not have been known and were not previously known or alleged at the time of the original complaint in the 2015 Action.  The new legal malpractice claims against [...] have absolutely no connection to the prior, dismissed legal malpractice claims, and share absolutely no factual predicates.  Instead, the prior dismissed claims, as [...] so forcefully argued and [...] held, were all legal malpractice claims arising out of [...]’s legal work on behalf of Plaintiffs with respect to the transaction.  The new legal malpractice claims against [...], on the other hand, are solely supported by the previously unknown and unknowable fact that [...] was the Sole Member of [...] and controlled and operated [...] as a sham entity, and therefore committed malpractice by failing to advise Plaintiffs of these facts.  It is self-evident that the previously dismissed claim for legal malpractice in the 2015 Action had absolutely none of the factual predicates of the legal malpractice claim in the Amended Complaint in this matter, and for obvious reason: Plaintiffs did not know and could not have known at the time of the filing of the complaint in the 2015 Action that [...] was Sole Member of [...] and controlled and operated [...] as a sham entity.  These facts only emerged during the course of discovery in the 2015 Action, after the dismissal of Plaintiffs’ prior claims.  For the Trial Court to state that the present legal malpractice claims against [...], predicated solely on the discovery of [...]’s ownership of [...] and operation of [...] as a sham entity, have the “same factual predicates” as Plaintiffs’ previously dismissed legal malpractice claim which did not and could not have alleged any of these predicate facts because they were unknown, is a confounding error that must be reversed.