In which McNamee responds to Lewis's opposition to Motion to Dismiss:

October 09, 2012    McNamee Memorandum of Law in Opposition to Defendants' Cross-Motion for Change of Venue and Reply Memorandum of Law in Further Support of Plaintiff's Motion for Summary Judgment

June 09, 2011    Settlement signed; state pays LFF $71,690.28

June 10, 2011    Privitera calls to collect outstanding legal fees of $298,141.56

In which former Farm Counsel in APA matter, John J. Privitera, seeks payment of his firm’s legal bills of $298,141.56, plus interest:

April 17, 2012      MacNamee files Summons & Complaint against Lewises & Lewis Family Farm

In which Lewis denies legally sufficient cause of action and asserts defense of res judicata on ground that issue of reasonable value of attorneys’ fees was previously determined by Supreme Court of Essex County:

May 3, 2012      Lewis Answer

In which Privitera requests court to award summary judgment arguing no substantial issue of triable fact:

July 13, 2012     McNamee files Notice of Motion for Summary Judgement:

Notice of Motion   

Privitera Affidavit   

Exhibit A: MLTW Summons & Complaint   

Exhibit B: Lewis Answer   Exhibit C: Copy of Lewis Family Farm check to MLTW for portion of legal fees

Exhibit D: Affidavit of SBL in support of Farm's application for fees (Article 86) in underlying action

Exhibit E: Second Affidavit of SBL in support of Farm's application for fees (Article 86) in underlying action

Exhibit F: Email dated 5.2.09 JJP-SBL-JJP  

Exhibit G: Email dated 7.29.09 JJP-SBL  

Exhibit H: Email dated 9.2.09 JJP-SBL

Exhibit I: Email dated 10.15.09 JJP-SBL

Exhibit J: Email dated 10.17.09 SBL-JJP

Exhibit K: Email dated 3.8.10 K. Hill - SBL attaching fee statement

Exhibit L: Email dated 10.8.10 JJP-SBL

Exhibit M: Email dated 11.1.10 JJP-SBL

Exhibit N: Email dated 12.8.10 JJP-SBL

Exhibit O: Decision of Judge Meyer dated 2.3.10, establishing Farm's right to fees under Article 86 - amount to be determined

Exhibit P: Decision of Judge Meyer dated 11.17.10, awarding Farm $71,690.28

Exhibit Q: Email dated 6.30.11 JJP - M.Baillie

Exhibit R: Total McNamee invoices from Dec 31, 2007-June 30, 201 (Large download- 133 pages, 15.6 mb)

   

In which Lewis argues Summary Judgment should be denied as premature, cannot be granted due to existence of triable issues relating to Lewis’s objection to invoices and equitable considerations, and in any case, doctrine of preclusion should operate to bar plaintiff from re-litigating the issue of attorney fees:

Sept 17, 2012    Lewis files Motion to Change Venue and Opposition to Motion for Summary Judgment:

Lewis Memo of Law   

Lewis Affidavit   

Exhibit A: Letter dated 7.22.09 JJP –SBL   

Exhibit B: Exhibit B Screen shot of Appeals page on LFF website  

Exhibit C: Liptak NYT article dated 8.27.07 'With the Bench Cozied up to the Bar, the Lawyers Can't Lose'

Exhibit D: Lecture by Second Circuit Court Judge Dennis Jacobs , 'The Secret Life of Judges'

Exhibit E: Professor Barton article in Alabama Law Review, ‘Do Judges Systematically Favor the Interests of the Legal Profession’

Exhibit F: Articles in Press-Republican, Post-Star, Denton Publications covering settlement negotiations

Exhibit G: Email dated 7.9.11 SBL-JJP & attached letter from JJP -SBL

Exhibit H: Email dated 10.30.11 SBL - JJP & attached letter from JJP-SBL

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