CHRISTOPHER RYAN VS. THE RIDGE AT BACK BROOK, LLC (L-0447-13, HUNTERDON COUNTY AND STATEWIDE), A-4831-15T3

Christopher Ryan joined The Ridge at Back Brook (a private golf club LLC) in 2002, paid a $90,000 refundable membership deposit conditioned on the club reaching "full membership," later increased from 275 to 295 members.
In 2003 Ryan loaned the club $25,000 via a promissory note that likewise deferred repayment until the club reached full membership.
Ryan attempted to resign in 2010; the club placed him on an "intent to resign" list because full membership was not attained and retained his deposit and deferred loan repayment.
Ryan sued in 2013 claiming breach of the implied covenant of good faith and fair dealing, alleging the club had no business incentive to reach full membership; the club counterclaimed for unpaid membership fees.
Pretrial, the court denied Ryan’s request for the club’s internal financial records but ordered other discovery; after a jury trial, the jury found for the club and awarded the club $47,201.47 on its counterclaim.
The membership agreement contained a unilateral fee-shifting clause (member who sues and loses pays the club’s fees); the promissory note had no fee-shifting clause. The trial court awarded fees to the club but reduced the claim by ~27% including a 5% reduction for work relating solely to the promissory note.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused discretion in awarding contractual attorneys' fees and the amount awarded	Ryan argued the award was excessive, that fees for defending the promissory note (which lacks fee-shifting) should be excluded, and that counsel time should have been more junior/segregated	Club argued the membership agreement permits fee-shifting; overlap of claims made segregation impractical; experienced counsel was reasonable	Court affirmed: applied deferential review, found no abuse of discretion; reductions made by trial court reasonable (including 5% for note work and other cuts)
Whether trial court erred by denying pretrial discovery of the club's internal financial records (LLC)	Ryan argued financial records were necessary to prove the club’s motive and ability regarding full membership, and to support his claim	Club asserted proprietary/confidential interest as a privately-held LLC outweighs disclosure; other discovery was provided	Court affirmed: trial judge reasonably balanced broad discovery against LLC privacy interests and permitted other relevant discovery; no abuse of discretion

North Bergen Rex Transp., Inc. v. Trailer Leasing Co., 158 N.J. 561 (contractual fee-shifting enforced but construed strictly)
Cmty. Realty Mgmt., Inc. v. Harris, 155 N.J. 212 (principles on contractual fee-shifting)
McGuire v. City of Jersey City, 125 N.J. 310 (courts disfavor awards of attorneys' fees)
Rendine v. Pantzer, 141 N.J. 292 (deferential standard of review for fee determinations)
Packard-Bamberger & Co. v. Collier, 167 N.J. 427 (deference to trial courts on fee awards)
Walker v. Giuffre, 209 N.J. 124 (trial court abuses discretion when it misapplies fee-calculation methodology)
Litton Industries, Inc. v. IMO Industries, Inc., 200 N.J. 372 (upholding percentage lodestar reductions in overlapping-claims contexts)
Pomerantz Paper Corp. v. New Cmty. Corp., 207 N.J. 344 (deference to discovery rulings)
Jenkins v. Rainner, 69 N.J. 50 (scope of civil discovery is presumptively broad)
Herman v. Sunshine Chem. Specialties, Inc., 133 N.J. 329 (recognizing confidentiality interests of privately held companies over internal records)