.

Aaron provides legal counsel to attorneys, accountants, real estate agents, home inspectors, home appraisers, insurance brokers, and other professionals. Aaron has strong experience representing insurance brokers throughout Pennsylvania and Delaware, including complex claims involving issues concerning duty of care, policy interpretation, whether alternative policies were available, and claims with nuanced statute of limitations issues. He handles a variety of claims including, but not limited to, legal and accounting malpractice, wrongful use of civil process, commercial litigation, negligence, breach of contract, municipal liability, and civil rights matters.  Aaron is also experienced in consumer financial services litigation and compliance, particularly representing attorneys and agencies in debt collection practices.

Outside of his professional liability practice, Aaron is also an experienced litigator, defending clients in matters involving premises liability, land use, automobile liability, intellectual property and employment law.

Aaron is a 1987 graduate of Millersville University. Following graduation, he taught grades six through eight in the School District of Philadelphia for 12 years. During that time, he earned a Master's Degree in Education from Temple University. While teaching, Aaron attended evening classes at the Beasley School of Law at Temple University where he made the Dean's List and earned honors in Trial Advocacy and Research and Writing. Aaron began his legal career as an associate with a Blue Bell, Pennsylvania law firm, where he primarily focused on defending Pennsylvania municipalities in areas of civil rights law, premises liability, land use and automobile liability.

Aaron has received an AV® Preeminent™ rating by the Martindale Hubbell.

    • Temple University Beasley School of Law (J.D., 2003)
    • Temple University (M.A., 1995)
      • El. Ed.
    • Millersville University of Pennsylvania (B.A., 1987)
    • Pennsylvania, 2003
    • U.S. District Court Eastern District of Pennsylvania, 2006
    • U.S. District Court Middle District of Pennsylvania, 2016
    • Delaware, 2020
    • U.S. District Court District of Delaware, 2021
    • Top Lawyer, Legal Malpractice, Delaware Today (November 2024)
    • AV® Preeminent™ by Martindale-Hubbell®
    • Claims & Litigation Management Alliance (CLM)
    • Philadelphia Bar Association
    • Professional Liability Defense Federation
    • Proving a Case Within a Case in Legal Malpractice Actions, PLDF Annual Meeting, September 2018
    • Developments in Lawyer Liability in Pennsylvania & New Jersey, client seminar, March 2017 
    • Professional Liability - Issues for Attorneys, client seminar, June 2016
    • Virtual Law Office and Interstate Practice of Law, National Business Institute, April 2015
    • Aaron has been invited to speak to the Pennsylvania Institute of Certified Public Accountants as well as the Pennsylvania Home Inspector Association. Aaron has also given presentations to insurance companies concerning developments in legal malpractice law.
    • "LPL Claims Without Privity: Support for a Bright Line Rule", Professional Liability Defense Quarterly, Fall 2018
    • "Proving The 'Case-Within-A-Case' Standard," For The Defense, April 2018
    • "Demonstrative Evidence at Trial", Pennsylvania Civil Trial Practice, 2017, 2018, Reviewing Author 
    • "Common Evidentiary Issues at Trial", Pennsylvania Civil Trial Practice, 2017, 2018
    • "Responsive Pleadings", Pennsylvania Civil Pre-Trial Practice, 2017, 2018, Reviewing Author
    • Pennsylvania Legal Malpractice Handbook, 2017 Edition, 2019 Edition, Published by Marshall Dennehey Warner Coleman & Goggin, Co-author 
    • "Pennsylvania Supreme Court Rejects Constitutional Challenge to the Dragonetti Act," Defense Digest, Vol. 23, No. 2, June 2017
    • "An Argument Against Imposing Liability Against Attorneys for Aiding and Abetting Their Client's Breach of Fiduciary Duty Under Pennsylvania Law," Defense Digest, Vol. 17, No. 4, December 2011
    • "Former Phillies Tyler Green Thrown a Curve on Appeal for Legal Fees," Defense Digest, September 2007
    • "Medical Malpractice Plaintiff's Motion for Relief from Judgment of Non Pros Lacks Merit," Defense Digest, March 2007
    • Regular contributor to MDWC&G Case Law Alerts.
    • Successfully obtained dismissal of claims brought derivatively and directly by a corporation, including aiding and abetting breach of fiduciary duty and tortious interference with contract. The claims were brought against our client, an out of state attorney who previously represented the corporation and its former director. The Court granted the attorney’s Motion to Dismiss, concluding that the plaintiffs failed to sufficiently allege facts that would confer personal jurisdiction over the attorney under a conspiracy theory.
    • Successfully obtained dismissal of wrongful use of civil proceedings claims brought against our clients, two attorneys who were alleged to have wrongfully prosecuted a professional negligence claim against the plaintiff, a real estate agent. The plaintiff would not accept any settlement that was less than policy limits. After five years of litigation, the Court granted the attorney defendants’ summary judgment motion, concluding that the plaintiff failed to adduce facts that would reflect that the attorneys prosecuted the for obtaining dismissal of wrongful use of civil proceedings claims brought against our clients, two attorneys who were alleged to have wrongfully prosecuted a professional negligence claim against the plaintiff, a real estate agent. The plaintiff would not accept any settlement that was less than policy limits. After five years of litigation, the Court granted the attorney defendants’ summary judgment motion, concluding that the plaintiff failed to adduce facts that would reflect that the attorneys prosecuted the underlying action in a grossly negligent manner, or without probable cause. The Court also held that the plaintiff was unable to demonstrate that the underlying lawsuit was prosecuted for an improper purpose.
    • Successfully defended a home inspector before the Delaware Division of Professional Regulation. The Claimants sought disciplinary action against our client in connection with his inspection of their home. We were able to persuade the Division that the complained of defects at the property were not subject to inspection because they were not visible at the time of inspection. The Division weighed all concerns involved in the matter and on November 1, 2023, it concluded that the facts did not reflect a violation of the laws, rules, and regulations that governed the activities of the licensed professional.
    • A unanimous jury found in favor of our clients, a lawyer and his law firm in a legal malpractice case arising out of the lawyer’s drafting of a postnuptial agreement. The postnuptial agreement was invalidated by a family court judge, causing the husband to lose approximately $1.2 million as part of a subsequent property separation agreement. The jury considered testimony from the plaintiff’s ex-wife which reflected that she had signed the agreement under duress and concluded that the plaintiff could not demonstrate that the postnuptial agreement was invalidated as a result of anything the lawyer did.
    • Plaintiff claimed that estate attorneys misinterpreted stock restriction agreement causing Plaintiff's husband's estate to lose in excess of $1 million.  Court held that agreement was properly interpreted by attorneys
    • Attorney prosecuted civil rights claim on behalf of mother of son who was shot and killed by a Philadelphia police officer while unarmed and posing no threat to the officer.  Mother of decedent served as administrator of estate and retained proceeds of settlement.  Decedent allegedly had two children who should have received the proceeds.  Attorney sued by children's mother on their behalf. Plaintiff's minor children made $1 million settlement demand  just prior to the court's dismissal of the claims. 
    • Plaintiff claimed that his attorney failed to properly prosecute his workers' compensation claim causing his benefits to be discontinued.  Plaintiff's claims dismissed by way of summary judgment motion.
    • Buyers of real property sued real estate agent for seller, claiming misrepresentations regarding use of the property.  Claims dismissed by way of summary judgment motion.
    • Success in getting a number of legal malpractice cases dismissed promptly by way of preliminary objections. In such cases, the Plaintiff failed to allege facts that, even if true, could yield liability as to our client.
    • Success in getting a number of legal malpractice cases dismissed upon the filing of motions for non pros as a result of opposing counsel's failure to comply with the Pennsylvania Rules of Civil Procedure.
    • Summary judgment and motions to dismiss granted on behalf of a number of clients. In one recent case, the plaintiff claimed that our attorney client was liable to him for wrongful use of civil proceedings and was seeking in excess of $3 million in damages. Upon the filing of a Motion for Summary Judgment, the court dismissed our client, finding no liability whatsoever.
    • Success in defending clients at arbitration hearings and bench trials, including cases involving alleged home inspector liability and insurance subrogation claims.

Results

One Month – 4 Outstanding Results! Aaron Moore Obtained Four Successful Results on Behalf of Clients in the Span of One Month

Defense verdict on behalf of a real estate broker and agent. The plaintiffs, homebuyers, claimed that the sellers’ broker and agent were liable to them for the value of fixtures that were taken by the sellers when they vacated the property, which were alleged to have been included in the sale. At a bench trial, the judge determined that neither the broker nor the agent could be held liable to the plaintiffs because the representations regarding what was included in the sale were made by the sellers. Supreme Court affirmance of dismissal of a complex legal malpractice lawsuit. Aaron and Carol Vanderwoude obtained a Delaware Supreme Court affirmance of the trial court’s dismissal of a complex legal malpractice claim. The plaintiffs, seven affiliated companies and their owners in the business of developing property, had been sued by their bank for defaulting on multiple lines of credit. The bank filed multiple lawsuits against the property developers, claiming approximately $7 million in damages, plus attorneys’ fees, which were recoverable pursuant to the terms of the promissory notes. The property developers retained our client to defend the lawsuits, asserting that the amounts claimed to be owed to the bank were significantly overstated. Our client vigorously defended the bank’s underlying lawsuits. Ultimately, the property developers settled the bank’s lawsuits for the entire amount owed, plus interest and the bank’s legal fees. The developers argued that its attorneys should have advised them to settle the bank’s claims after the lawsuits were commenced and that, if they had done so, they would not have had to pay the bank’s legal fees, our client’s legal fees, or expert witness fees, or the additional interest on the loan. The property developers also claimed that not settling with the bank earlier caused them lost business opportunities valued at nearly $1 million. The plaintiffs’ legal malpractice claims were dismissed because their expert witness, a Maryland attorney with no business litigation experience, was not qualified to serve as an expert and because their damages claims were speculative. Motion to dismiss in complex matter involving claims of fraud, misappropriation of trade secrets, tortious interference with contractual relations, and piercing the corporate veil. The plaintiff, an investment fund, had purchased a business that was controlled and primarily owned by our client. The business ultimately went bankrupt, and the plaintiff claimed that the purchase was premised upon misrepresentation by our client. The plaintiff maintained that jurisdiction in Delaware was proper pursuant to the Asset Purchase Agreement. The District Court was persuaded by arguments reflecting that it lacked personal jurisdiction over our client, a citizen of Canada, even though he signed the Asset Purchase Agreement which included language conferring jurisdiction over claims arising from the sale in Delaware. The court agreed that our client did not sign the agreement in his individual capacity, and the plaintiff’s piercing the corporate veil allegations were insufficient to confer personal jurisdiction. Dismissal of an unjust enrichment claim. Obtained dismissal of an unjust enrichment claim brought by a condominium unit owner against the attorneys who represented her condominium association. The unit owner claimed that the law firm was liable to her for unjust enrichment in connection with legal fees it received from the association for legal services provided in efforts to collect on past due assessments owed by the unit owner. Pursuant to the association’s governing documents, the charges were passed on to the unit owner. The court agreed that the fees that were paid to our client by the condominium association were properly earned.

Unanimous Appellate Decision Preserves Defense Win in Legal Malpractice Suit

We successfully defended an appeal from a jury verdict previously secured by members of our Lawyers’ Professional Liability Department in favor of the firm’s client in a legal malpractice case. The plaintiffs initially asserted multiple tort claims and a claim under the Unfair Trade Practices and Consumer Protection Law, which were dismissed by the trial court upon partial grant of the defense’s motion for judgment on the pleadings. The case proceeded to trial on a remaining breach of contract claim, resulting in a defense verdict. On appeal, the plaintiffs challenged the trial court’s rulings on both the motion for judgment on the pleadings and a motion in limine related to evidentiary exclusions. The Pennsylvania Superior Court unanimously affirmed the trial court’s rulings, holding that the tort claims were time-barred and that the plaintiffs had waived their evidentiary argument by failing to properly develop it in their appellate brief.

Thought Leadership

Legal Updates for Lawyers' Professional Liability

Delaware Superior Court Clarifies Pleading Standard for Legal Malpractice Claims

July 29, 2026

In the matter of Edelstein v. Kirschner, No. N25C-09-018 FJJ, 2026 Del. Super. LEXIS 45, at *1 (Super. Ct. Jan. 29, 2026), the plaintiff law firm sued its former client for unpaid legal fees in the amount of $4,399.35. The former client asserted a counterclaim alleging legal malpractice. More, specifically, the former client claimed that his lawyer committed malpractice be recommending that he settle an underlying lawsuit by entering into a stipulated judgment for an excessive amount with interest that was accruing at “an outlandish” interest rate. The law firm moved to dismiss the counterclaim on the basis that its former client had not alleged facts reflecting that he could prove the case within the case. That is, facts reflecting that his attorneys caused him to lose the underlying case. The Superior Court held that while a legal malpractice plaintiff in cases arising from underlying litigation must prove the case within the case to survive a summary judgment motion, he does not need to plead facts reflecting as much in order to survive a motion to dismiss. While this case addresses the pleading requirements of a legal malpractice case in Delaware, it also serves as reminder that chasing unpaid legal fees from a former client can often give rise to a legal malpractice counterclaim. Attorneys seeking to collect unpaid legal fees should ensure that the fees they seek are for a significant amount, which would be recoverable if a judgment is obtained. Otherwise, the effort could backfire.

Case Law Alerts

Delaware Superior Court Addresses Continuous Representation Doctrine in Legal Malpractice Case—But Was It Really Applied?

January 1, 2026

In what the court stated was a matter of first impression, the Delaware Superior Court applied the “continuous representation doctrine” in a legal malpractice case. In this case, the plaintiff claimed that his attorneys did not take any meaningful action to prosecute his underlying lawsuit and failed to sufficiently communicate with him. The court dismissed the underlying action sua sponte for failure to prosecute. The plaintiff maintained he first learned that his underlying claims had been dismissed by the Superior Court 18 months after the dismissal. He then commenced his legal malpractice action more than three years after the dismissal. The defendant attorneys moved to dismiss the malpractice claims based on Delaware’s three-year statute of limitations, which, under the occurrence rule, began to accrue at the time of dismissal of the underlying action. The court held that the continuous representation doctrine was applicable because the “cause of action conceivably accrued at some point after the court dismissed the underlying suit” because the attorneys failed to take efforts to reopen the judgment. It appears that the Delaware Superior Court has conflated the “continuous representation doctrine” with the concept of continued negligence. There are some jurisdictions that recognize the continuous representation doctrine, which provides that a legal malpractice cause of action accrues at the end of the underlying representation, irrespective of when the negligence occurred during the representation. Delaware, however, follows the “occurrence rule,” which, in the absence of equitable tolling, provides that a cause of action accrues at the time of the alleged negligence. Here the court properly concluded that the cause of action could be deemed to have accrued after the dismissal of the underlying claims if the plaintiff could demonstrate continued negligence after the dismissal. The court’s use of the phrase “continuous representation doctrine,” however, could lead to confusion as to whether that doctrine is actually applicable in Delaware. The court entertained a motion for re-argument and issued a second opinion, where it made clear that the plaintiff’s claims were not time barred because of allegations of continued negligence. The second opinion did not reference the “continuous representation doctrine”; however, it did not specifically clarify that the doctrine was not applicable.

Firm Highlights

Thought Leadership

Florida Supreme Court Rules Florida Statute §627.70152 Does not Apply Retroactively

In a decision that resolves years of appellate uncertainty and confirms that insurers and insureds alike can rely on the legal framework in place when a policy is issued, the Supreme Court of Florida last week found that Florida Statute §627.70152, which involves an insured’s requirement to provide an insurer with pre-suit notice before filing a suit, cannot be applied retroactively. In Universal Property & Casualty Insurance Company v. Hughes, the Court was presented with the issue of whether the statutory pre-suit notice requirement applied retroactively and whether it would apply to a breach of contract of an insurance policy that was issued before the statute went into effect. Before the Court was an appeal from a homeowner, Ms. Hughes, who sued her insurance carrier, Universal Property & Casualty Insurance Company (Universal) for breach of contract under an insurance policy that was in effect from April 24, 2019 through April 24, 2020. During the policy period, Ms. Hughes suffered a loss and, on May 29, 2019, made a claim for water damage. The carrier investigated the loss and issued payment; Ms. Hughes disputed the payment, finding the amount insufficient for repairs. On July 1, 2021, Florida Statute §627.70152 went into effect, which required insureds to provide notice of intent to initiate litigation against the carrier prior to filing a lawsuit; if an insured filed the lawsuit without complying with §627.70152, a court must dismiss the case without prejudice. On August 4, 2021, Ms. Hughes filed her lawsuit against Universal for breach of contract. Universal moved to dismiss based on her failure to comply with §627.70152. Ms. Hughes contended the notice requirement could not be applied retroactively. The trial court disagreed and dismissed the lawsuit without prejudice, and Ms. Hughes appealed. During the appeal, the Fourth District Court of Appeal, in Cole v. Universal Property & Casualty, 363 So. 3d 1089 (Fla. 4th DCA 2023), ruled that Florida Statute §627.70152 did apply retroactively to policies issued before the effective date of §627.70152. However, the Sixth District Court agreed with Ms. Hughes and overturned the trial court’s ruling, finding the statute could not retroactively apply to policies issued prior to the statute effective date. Thereafter, the other district courts weighed in, with the Third District Court agreeing with the Fourth District Court, and the First, Second and Fifth District Courts agreeing with the Sixth District Court. In resolving the conflict amongst the district courts, the Supreme Court advised “as a general rule, ‘the statute in effect at the time an insurance contract is executed governs substantive issues arising in connection with that contract.’ Hassen v. State Farm Mut. Auto. Ins. Co., 674 So. 2d 106, 108 (Fla. 1996). The Court applied the two-step test when deciding whether a statute has retroactive application: “First, the Court must ascertain whether the Legislature intended for the statute to apply retroactively. Second, if such an intent is clearly expressed, the Court must determine whether retroactive application would violate any constitutional principles.” Menendez v. Progressive Exp. Ins. Co., 35 So. 3d 873, 877 (Fla. 2010). In analyzing the Legislature’s intent, the Court must determine whether the Legislature has manifested a clear command for retroactivity in the statutory text.  In review of the statutory text, the Court found nothing in the language of the statute to indicate that the phrase “all suits” was serving another purpose of expanding its reach to suits based on policies that both predate and postdate the enactment of the statute. Buis v. Universal Prop. & Cas. Ins. Co., 394 So. 3d 738, 741 (Fla. 2d DCA 2024). Further, the Court noted the statute has an effective date, which has long been considered to be evidence against retroactive application of a statute. The Court concluded that, on its face, no provision of §627.70152 speaks to application of the statute to insurance policies issued before the statute’s effective date and therefore, the Legislature did not clearly command retroactivity of the statute to include insurance policies issued prior to the enactment of the statute. The Court briefly reviewed Universal’s argument that the presuit notice requirement was procedural, not substantive, and therefore should be applied retroactively; however, the Court agreed with the Sixth District Court’s finding that, in its entirety, §627.70152 transformed an insured’s ability to sue an insurance company under a property insurance policy and an insurer’s obligations to respond to and pay insurance claims, thus making the requirement a substantive change. The Court thereby upheld the decision of the Sixth District and disapproved the decision of the Fourth District in Cole.

Thought Leadership

The Tolling Trap: Filing Alone Will Not Toll the Statute Without Good-Faith Service

The Eastern District of Pennsylvania recently reinforced a critical limitation on bad faith claims, holding that a timely filing alone will not preserve a cause of action absent a good-faith effort to serve the original process. The plaintiff had presented a claim for underinsured motorist benefits to his auto insurer. The insurer evaluated the claim and determined that the plaintiff’s accident-related damages did not exceed the bodily injury liability insurance limits of the at-fault driver and denied his claim. Among other claims, the plaintiff sought to present a claim for insurance bad faith under 42 Pa. C.S.A. § 8371, to which a two year statute of limitation applies. He first filed a praecipe for writ of summons before the expiration of the statute of limitation. However, the plaintiff did not attempt to serve the praecipe or writ until after the statute of limitations had expired. Additionally, the service failed as the plaintiff had mailed the original process to an incorrect address. Despite receipt of the Postal Service’s failure to deliver the original process, the plaintiff did not attempt to re-serve the writ. Two months later, the plaintiff filed a complaint and then successfully served that complaint. The insurer sought to dismiss the plaintiff’s bad faith claim as time-barred by the statute of limitations. The district court agreed. Though the plaintiff had filed a praecipe for a writ of summons prior to the expiration of the statute of limitations, the statute is only tolled if there is a good faith effort to serve that original process. In this case, the court determined that the plaintiff had failed to perform a “good faith effort to serve the original process”. Additionally, though the filing and service of a complaint can serve as alternative original process when the lawsuit is commenced by the filing of a praecipe for a writ of summons, the plaintiff filed his complaint after the statute of limitations had expired. The plaintiff’s bad faith claim was therefore determined to be barred by the statute of limitations and dismissed by the court, with prejudice. A key takeaway for the defense is not to assume that the statute of limitations has been successfully tolled by a plaintiff merely because a praecipe for a writ of summons or complaint has been filed prior to the expiration of the statute. A filed complaint or writ is only part of the equation. The defense should carefully review the docket and filings to confirm that the plaintiff also performed the requisite good faith effort to serve that original process. A thorough review of the docket may reveal that the plaintiff failed to make the good-faith service efforts necessary to toll the statute of limitations.

Thought Leadership

Commonwealth Court Reaffirms the Constitutionality of Act 111's IRE Provisions

In this case, the claimant sustained a work injury of January 6, 1994, which was acknowledged by Notice of Compensation Payable (NCP). After the claimant’s receipt of 104 weeks of temporary total disability benefits, the employer filed a Request for an Impairment Rating Examination (IRE). The IRE was performed in May 2023 and the IRE physician found that the claimant had a 5% whole person impairment, under the AMA Guides. The employer filed a Petition based on the IRE results, and the Petition was granted by the WCJ. During litigation, the claimant argued that the IRE provisions of Act 111 (Section 306(a.3) of the Act) were not applicable to her injury, since it predated June 24, 1996, the date Act 57 went into effect, and that the IRE provisions were unconstitutional. The Workers’ Compensation Judge (WCJ)) granted the Petition and the Board affirmed. On appeal to the Commonwealth Court, the claimant argued that Act 111 violated the nondelegation doctrine and that its retroactive application to the claimant’s injury was unconstitutional. The court rejected the arguments on the basis that they had already found the same arguments without merit in multiple, prior cases. The court also addressed an argument made by the claimant that Act 111 was procedurally defective under the Pennsylvania Constitution because it was only considered on two days in each House after having undergone amendments and reassignments. The court noted that the Pennsylvania Constitution requires every bill to be considered on three different days in each House. The claimant maintained that, according to the legislative history, the bill did not receive three separate days of consideration from each House when it was assigned a new bill number. The court pointed out, however, that the bill number, H.B. 1840 remained constant and was considered on three occasions by the House. Further, the court concluded that minor amendments to the bill were germane to its original subject, which was to modify the Act’s IRE process, in accordance with Protz II.