In court, an LLC needs an Attorney

Tom Swartz of New York Legal Update alerted me to this recent development in LLC law:  A New York court has decided that a  New York LLC needs to be represented by an attorney in court.  See his post on the topic and for case information

Pursuant to CPLR 321(a), "a party, other than one specified in section 1201 of this chapter, may
prosecute or defend  a  civil  action  in  person  or  by attorney, except that a corporation or voluntary association shall appear by attorney . . .. 

Until recently, no one knew if this provision also applied to limited liability companies.  Now a court has held that it does.