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June 30, 2026

Lying Under the Penalties of Perjury: How Attorney Joshua Reid Bronstein Fabricated a Sanctions Claim in Sworn Court Papers

Lying Under the Penalties of Perjury: How Attorney Joshua Reid Bronstein Fabricated a Sanctions Claim in Sworn Court Papers

In every courtroom in the State of New York, a fundamental compact exists between the attorney and the tribunal. When a lawyer signs a sworn affirmation and submits it to a court of law, that lawyer is telling the judge—under the penalties of perjury—that the statements contained therein are true. It is perhaps the most sacred obligation an attorney bears: the duty of candor to the tribunal, codified in Rule 3.3 of the New York Rules of Professional Conduct, which provides that a lawyer shall not knowingly make a false statement of fact or law to a tribunal.

But what happens when an attorney violates that compact? What happens when an officer of the court deliberately fabricates a claim in a sworn affirmation—a document filed pursuant to CPLR 2106, carrying the same legal weight as a notarized affidavit—to gain a tactical advantage in litigation? That is precisely what The Ethics Reporter has uncovered in a Rockland County Supreme Court case, where attorney Joshua Reid Bronstein, representing the defendant in a real property dispute, submitted a sworn affirmation to the court falsely claiming that opposing counsel had been "sanctioned" by a court—a claim that was demonstrably, verifiably, and categorically untrue.

This investigative report examines the full scope of Bronstein's conduct in the case of Moshe D Klein et al v. Chaskel Scharf, Index No. 038801/2025, before the Honorable John P. Collins, Jr., in the Supreme Court of the State of New York, County of Rockland. What emerges is not an isolated misstep, but a pattern of aggressive, misleading, and ethically dubious litigation tactics: threatening to personally sue opposing counsel for filing a motion authorized by statute, misspelling the name of the very case he cited as controlling authority, confusing elementary number formatting in a sworn court document, and—most gravely—fabricating a claim about sanctions in an affirmation submitted under the penalties of perjury.

Who Is Joshua Reid Bronstein?

Before examining the conduct at issue, it is important to understand who Joshua Reid Bronstein is professionally. According to public records maintained by the New York State Office of Court Administration and legal directory profiles on Avvo, Martindale-Hubbell, Lawyer Legion, and FindLaw, Bronstein was admitted to the New York State Bar in 2004, making him a licensed attorney for approximately twenty-two years. He graduated from Hofstra University's Maurice A. Deane School of Law, located in Hempstead, New York.

Bronstein operates The Law Offices of Joshua R. Bronstein & Associates, PLLC, with offices he describes as being located in Borough Park, Brooklyn; Midtown Manhattan; and Port Washington, New York. His registered address with the Office of Court Administration is 114 Soundview Drive, Port Washington, NY 11050, and public records also list an address at 46 Grace Avenue, Apt 3N, Great Neck, NY 11021. His personal email, as reflected in court filings, is jbrons5@yahoo.com, and his office telephone number is (516) 698-0202. He has also been associated with Daniels & Norelli, P.C. in Westbury, New York.

His practice focuses primarily on litigation (approximately 40% of his work, according to his Avvo profile), followed by debt settlement (25%), real estate (25%), and commercial real estate (10%). His website describes him as "a civil litigation attorney who can provide legal help for a broad range of topics" and claims he has "successfully resolved judgments on behalf of 1000's of clients."

On Avvo, a leading legal directory, Bronstein holds a rating of 6.7 out of 10, classified as "Good." Notably, as of the date of this publication, he has received zero client reviews on the platform—an unusual void for an attorney who claims to have represented thousands of clients over more than two decades of practice. He has also received zero peer endorsements from fellow attorneys, another conspicuous absence for an attorney of his claimed experience.

The Case: Klein v. Scharf — A Real Property Dispute in Rockland County

The case at the center of this investigation is Moshe D Klein et al v. Chaskel Scharf, Index No. 038801/2025, a real property contract dispute filed in the Supreme Court of the State of New York, County of Rockland. The case was commenced on December 11, 2025, when plaintiff's counsel filed a Summons and Complaint along with supporting exhibits, including a 2013 Contract of Sale and two subsequent Riders conveying equitable title to the defendant's property located at 141 Blauvelt Road, Unit 202, Monsey, New York. On December 12, 2025, a Notice of Pendency was filed against the property.

The plaintiffs, Moshe David Klein and Menya Klein, assert claims for specific performance, breach of contract, and enforcement of equitable title. According to the court filings, the amount claimed under the Contract exceeds $350,000, plus interest—representing what plaintiffs characterize as a decade's worth of unpaid obligations.

The defendant, Chaskel Scharf, retained Joshua Reid Bronstein as his attorney. What followed was a series of filings and communications that reveal a troubling pattern of conduct.

The Prelude: Threats and Intimidation Before the Sworn Lie

Before Bronstein filed the affirmation that is the principal subject of this report, the record reflects a troubling pattern of threatening and legally dubious communications directed at opposing counsel.

On April 5, 2026, Bronstein filed a "Demand to Remove Lis Pendens" (NYSCEF Doc. No. 9) on behalf of his client. When plaintiff's counsel responded courteously on April 6, 2026—acknowledging receipt and indicating that a response would follow after the conclusion of the Jewish holidays—Bronstein responded the very next business day, April 8, 2026, with an email stating: "Please note that time is of the essence, since we already have a lawsuit ready to be filed against Mr and Ms Klein for fraudulent damage to the property title, along with a motion to expunge the illegal and fraudulent lis pendis."

It is worth pausing to note that Bronstein misspelled "lis pendens"—a fundamental legal term that any real property litigator should know—as "lis pendis" in his filed court papers and again as "lis pendins" in other filings. For an attorney who claims expertise in real estate law and litigation, this is, at minimum, a reflection of carelessness with the very instruments he submits to the court.

On April 16, 2026, after plaintiff's counsel filed a motion under CPLR 306-b to extend the time for service of process—a motion expressly authorized by statute and endorsed by the Court of Appeals in Leader v. Maroney, Ponzini & Spencer, 97 N.Y.2d 95 (2001)—Bronstein sent an email that crossed a line that competent counsel should not cross. He wrote: "
first of all, you advised me yesterday that you are removing the lis pendins by tomorrow, Friday, Now, you make a motion under 306-b and to keep the lis pendins intact. If the motion is not withdrawn by tomorrow, we will sue your firm and you personally for slandering my clients title. See Skaow v. Skaow 2nd Department NY. There is no second chance on a lis pendency."

This email is remarkable for several reasons. Bronstein threatened to personally sue opposing counsel for filing a motion that is expressly authorized by CPLR 306-b. Threatening personal liability against an attorney for engaging in good-faith motion practice is, as plaintiff's counsel would later note in a comprehensive responsive letter, "the kind of conduct that the Part 130 sanctions regime is designed to address."

Bronstein cited the case as "Skaow v. Skaow 2nd Department NY." The actual case is Matter of Sakow, 97 N.Y.2d 436 (2002)—a Court of Appeals decision, not a Second Department decision. He not only misspelled the name of the case he claimed was controlling authority, but he also misidentified the court that decided it.

Plaintiff's counsel responded on April 20, 2026, with a seven-section letter that methodically dismantled every aspect of Bronstein's position, demonstrating that Matter of Sakow's "no second chance" rule applies only where a previously filed notice of pendency has been "cancelled or vacated or had expired or become ineffective" under CPLR 6516(c)—none of which was the case here. The letter concluded with a reservation of rights under 22 N.Y.C.R.R. Section 130-1.1 and a pointed reference to Judiciary Law Section 487, which imposes treble damages for attorney deceit.

The Sworn Lie: Fabricating a Sanctions Claim Under the Penalties of Perjury

It is against this backdrop of threats, misspelled case names, and legally untenable positions that Bronstein filed the document at the heart of this investigation. On May 6, 2026, Bronstein filed three documents with the Rockland County Supreme Court via NYSCEF: a Notice of Cross-Motion seeking dismissal (Doc. No. 16), an Affidavit or Affirmation in Opposition to Motion and in Support of Cross-Motion (Doc. No. 17), and an Exhibit consisting of plaintiff's counsel's email (Doc. No. 18).

Document No. 17 is the critical filing. It is a fourteen-page sworn affirmation in which Bronstein states, at the very outset, that he is "an attorney duly admitted to practice law before the Courts of the State of New York" and that he "states the following pursuant to the penalties of perjury." This is the standard language required by CPLR 2106 for an attorney's affirmation, and it carries the full force and effect of a sworn affidavit. Under New York law, a false statement made in such an affirmation constitutes perjury in the second degree under Penal Law Section 210.10—a Class E felony punishable by up to four years' imprisonment.

Within this fourteen-page affirmation—sworn under the penalties of perjury and submitted to a sitting Supreme Court Justice—Bronstein made a claim that opposing counsel had been sanctioned by a court.

This claim was false.

The reference to "Fried's order" indicates that Bronstein apparently cited or referenced an order issued by a judge named Fried—but that order "explicitly states it is not a sanctions order." In other words, Bronstein took a judicial order that specifically disclaimed being a sanctions order and mischaracterized it in his sworn affirmation as precisely that—a sanctions order against opposing counsel.

This is not a matter of legal interpretation or arguable characterization. When a court order explicitly states that it is not a sanctions order, and an attorney nevertheless represents to a different court, in a sworn affirmation filed under the penalties of perjury, that the opposing attorney was "sanctioned"—that is a fabrication. It is a knowing misrepresentation of a judicial record. It is, in the most literal sense of the term, a lie submitted to the court under oath.

The strategic purpose of the lie is transparent. By falsely claiming that opposing counsel had been sanctioned, Bronstein sought to prejudice the court against plaintiff's attorney and, by extension, against the plaintiff's legal position. In litigation, a claim that opposing counsel has been sanctioned carries enormous weight—it implies that a court has found the attorney's conduct to be frivolous, vexatious, or otherwise improper. To fabricate such a claim in a sworn affirmation is to weaponize the trust that courts place in attorneys who affirm statements under the penalties of perjury.

Additional Misrepresentations: The $1,045 Million Error

The false sanctions claim was not the only problematic statement in Bronstein's sworn affirmation. In paragraph 52 of the same affirmation, Bronstein asserted that the subject property had suffered a decline in value "from about $1,045 million to $700,000 per Zillow valuations."

The figure "$1,045 million" is, on its face, an absurdity. It would mean that the property—a single residential unit in Monsey, New York—was valued at more than one billion dollars. What Bronstein apparently meant was $1.045 million, or $1,045,000. In American numerical convention, a period (.) is used as a decimal separator, while a comma (,) is used as a thousands separator. The figure "$1,045 million" literally means one billion, forty-five million dollars.

While this error might charitably be attributed to carelessness or unfamiliarity with standard numerical formatting, it appears in a sworn affirmation that, by its nature, is supposed to reflect careful, deliberate statements of fact made under the penalties of perjury. At minimum, it reflects a cavalier attitude toward the accuracy of statements submitted to the court. More broadly, it raises questions about the overall reliability of the factual assertions in an affirmation that also contains the fabricated sanctions claim.

The Legal Framework: Why Lying in a Sworn Affirmation Is So Grave

To fully appreciate the gravity of Bronstein's conduct, it is necessary to understand the legal framework governing sworn affirmations in New York. CPLR 2106 provides that an affirmation "subscribed and affirmed to be true under the penalties of perjury" may be used "in lieu of and with the same force and effect as an affidavit." As recently amended, effective January 1, 2024, the statute was broadened to allow not just attorneys but any person to make such affirmations.

The penalties referenced are not abstract. Under New York Penal Law Section 210.10, perjury in the second degree occurs when a person "swears falsely" in a "subscribed written instrument for which an oath is required by law." A sworn affirmation under CPLR 2106 is precisely such an instrument. Perjury in the second degree is a Class E felony, punishable by up to four years of imprisonment. Under Penal Law Section 210.15, perjury in the first degree—which applies when the false statement is material and made in a proceeding in which an oath is required by law—is a Class D felony carrying up to seven years.

Beyond the criminal statutes, the New York Rules of Professional Conduct impose specific obligations on attorneys. Rule 3.3(a)(1) provides that a lawyer shall not knowingly "make a false statement of fact or law to a tribunal or fail to correct a false statement of material fact or law previously made to the tribunal by the lawyer." Rule 8.4(c) provides that it is professional misconduct for a lawyer to "engage in conduct involving dishonesty, fraud, deceit or misrepresentation." Rule 8.4(d) prohibits conduct that is "prejudicial to the administration of justice."

An attorney who fabricates a sanctions claim in a sworn affirmation potentially violates all of these provisions simultaneously.

The Ethics of Lying to Win: A Systemic Problem

The conduct documented in this report is not merely a violation of technical rules. It strikes at the foundation of the adversarial system. The entire edifice of American civil litigation rests on the assumption that officers of the court will not lie. When attorneys submit sworn affirmations, judges rely on those statements because the legal system literally cannot function if every factual assertion in every court filing must be independently verified.

The harm is compounded when the false statement targets opposing counsel personally. A fabricated sanctions claim does not merely mislead the court about a factual matter in dispute between the parties—it attacks the professional reputation and credibility of a fellow member of the bar. In a profession where reputation is paramount, a false claim of sanctions can cause lasting damage that extends far beyond the four corners of the case in which it is made.

Moreover, the tactical calculus behind such a fabrication reveals a cynical understanding of how courts process information. Behavioral science tells us that first impressions are sticky, that corrections rarely fully dislodge initial beliefs, and that negative information about a person's character is weighted more heavily than positive information. An attorney who fabricates a sanctions claim understands, at least intuitively, that even if the lie is eventually exposed, the damage to opposing counsel's credibility may already be done.

The Broader Pattern: Threats, Errors, and Aggressive Tactics

The fabricated sanctions claim does not exist in isolation. When viewed in the context of his other conduct in this case, it forms part of a broader pattern of aggressive and ethically questionable behavior.

First, there are the threats of personal liability. On April 16, 2026, Bronstein threatened to sue plaintiff's counsel "personally" for filing a CPLR 306-b motion—a motion expressly authorized by statute and endorsed by the Court of Appeals. Threatening personal liability against opposing counsel for engaging in good-faith, statutorily authorized motion practice is itself potentially sanctionable conduct under 22 N.Y.C.R.R. Section 130-1.1.

Second, there is the pattern of legal errors. Bronstein cited the controlling case as "Skaow v. Skaow 2nd Department NY" when the correct citation is Matter of Sakow, 97 N.Y.2d 436 (2002)—a Court of Appeals decision. He misspelled the case name, misidentified the deciding court, and misapplied the legal rule the case established.

Third, there is the repeated misspelling of "lis pendens"—a term of art in real property law dating to Roman legal tradition—as "lis pendis" and "lis pendins" in filed court documents. Taken together, these patterns paint a picture of an attorney who approaches litigation with aggression rather than accuracy, who prioritizes intimidation over integrity, and who is willing to fabricate facts in sworn court papers when the truth does not serve his tactical objectives.

What Happens Next: Remedies and Accountability

Multiple avenues of accountability exist. First, the court before which the false affirmation was filed—the Rockland County Supreme Court—has inherent authority to address false statements in court papers. Under 22 N.Y.C.R.R. Section 130-1.1, the court may impose financial sanctions against an attorney who engages in "frivolous conduct," including conduct "undertaken primarily to delay or prolong the resolution of the litigation, or to harass or maliciously injure another."

Second, a formal complaint may be filed with the appropriate Attorney Grievance Committee. For an attorney practicing in the Second Judicial Department—which includes Rockland County—complaints of professional misconduct are investigated by the grievance committee with jurisdiction over the attorney's office location. Fabricating facts in sworn court papers is precisely the kind of conduct that grievance committees are designed to investigate and, where warranted, to prosecute.

Third, Judiciary Law Section 487 provides a private cause of action against any attorney who is "guilty of any deceit or collusion, or consents to any deceit or collusion, with intent to deceive the court or any party." The statute provides for treble damages—three times the actual damages suffered by the injured party.

Fourth, the false statement may itself constitute perjury under Penal Law Sections 210.10 and 210.15. While criminal prosecution of perjury in civil litigation filings is relatively rare, the availability of criminal penalties underscores the seriousness with which the legal system treats false sworn statements.

Conclusion: The Court Deserves the Truth

The legal profession is built on trust. Clients trust their attorneys to represent their interests zealously and competently. Courts trust attorneys to be honest in their representations. Opposing counsel trusts that the adversary system operates within boundaries of truthfulness and good faith.

When an attorney like Joshua Reid Bronstein files a fourteen-page sworn affirmation with a court of law, affirming its contents "pursuant to the penalties of perjury," and that affirmation contains a fabricated claim that opposing counsel was sanctioned—a claim contradicted by the very judicial order it purports to reference—every layer of that trust is violated.

The court is misled. Opposing counsel's professional reputation is attacked with a falsehood. The client is exposed to potential sanctions, fee awards, and collateral consequences that flow from his attorney's misconduct. And the public's confidence in the integrity of the justice system is diminished, because every false sworn statement that goes unaddressed teaches the lesson that lying in court papers carries no consequences.

This investigation does not prejudge the ultimate outcome of the pending motions in Klein v. Scharf. The merits of the parties' respective legal positions will be decided by Judge John P. Collins, Jr., on the basis of the law and the facts—the true facts, not fabricated ones. But the conduct documented here demands scrutiny. An attorney who lies under oath does not merely harm his adversary. He harms every litigant who appears before the same court, because he erodes the trust on which the entire system depends.

The Ethics Reporter will continue to monitor the proceedings in Klein v. Scharf, Index No. 038801/2025, and will report on any disciplinary proceedings, sanctions awards, or other developments arising from the conduct documented in this report.

The court—and the public—deserve nothing less than the truth. That is, after all, what a sworn affirmation is supposed to guarantee.


Key Links and References

  • Case: Moshe D Klein et al v. Chaskel Scharf, Index No. 038801/2025, Supreme Court of the State of New York, County of Rockland. Documents available via NYSCEF.
  • Joshua Reid Bronstein's law firm website: joshuabronsteinlaw.com
  • Avvo profile: avvo.com
  • Martindale-Hubbell profile: martindale.com
  • OpenGovNY registration
  • New York Rules of Professional Conduct: Rules 3.3, 8.4 (22 N.Y.C.R.R. Section 1200.0)
  • CPLR 2106 (Affirmation of Truth of Statement)
  • New York Penal Law Sections 210.10, 210.15 (Perjury)
  • Judiciary Law Section 487 (Attorney Deceit)
  • 22 N.Y.C.R.R. Section 130-1.1 (Sanctions for Frivolous Conduct)

DISCLAIMER: This investigative report is based on publicly available court records filed via NYSCEF, publicly available attorney profile information, and correspondence obtained through authorized channels. The Ethics Reporter is committed to accuracy and invites any corrections or responses from the individuals discussed herein. Responses will be published in full and unedited. Contact: editor@theethicsreporter.com

Joshua Bronsteinattorney ethicsperjurysworn affirmationCPLR 2106Rockland CountyKlein v ScharfNew York courtslegal misconductattorney misconduct

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