Narendra Lakhani v. Anil Patel, 321 A.3d 818

The case arose from complex business disputes over hotel ownership and operations, resulting in a final judgment against Anil and Manish Patel and the appointment of a Receiver to enforce collection efforts.
The Superior Court appointed a Special Adjudicator to manage discovery disputes due to the complexity of the litigation and judicial resource constraints.
John Calzaretto, an attorney for a law firm formerly representing the Patels, petitioned the court to quash a subpoena seeking his firm's bank records; he was not a party to the main litigation.
The Special Adjudicator charged Calzaretto $3,000 as his share of the $9,000 fee for handling the dispute, reasoning that participation in the motion practice sufficed for fee allocation under Rule 4:41-2.
The trial court upheld the Special Adjudicator's allocation without elaborating on its legal or factual basis; Calzaretto appealed.

Issue	Calzaretto's Argument	Receiver's Argument	Held
May a nonparty movant to quash a subpoena be charged fees of a Special Adjudicator under Rule 4:41-2?	Rule 4:41-2 limits fee liability to parties to the litigation; Calzaretto was only a nonparty movant.	Calzaretto was a party to the motion practice and thus liable under the rule; court’s discretionary authority applies.	No; only parties to the underlying litigation can be charged under Rule 4:41-2; order reversed.

In re Est. of Hope, 390 N.J. Super. 533 (App. Div. 2007) (trial court's allocation of special adjudicator's fees reviewed for abuse of discretion)
Little v. KIA Motors Am., Inc., 425 N.J. Super. 82 (App. Div. 2012) (limited deference to the legal conclusions of a special adjudicator; appellate review focuses on trial court decision)
Robertelli v. N.J. Off. of Att'y Ethics, 224 N.J. 470 (2016) (court rules are interpreted using the same approach as statutes, focusing first on plain language)
DiProspero v. Penn, 183 N.J. 477 (2005) (interpretation should not undermine the broader statutory or regulatory scheme)