The motions by both plaintiffs and their counsel (SGA) for awards of attorneys' fees and expenses against additional defendants should have been granted pursuant to the common fund doctrine, and SGA's award against additional defendants in index No. 650163/14 should be based on the total $3.5 million recovery allocable to the independent limited partners, not solely on the portion of this recovery ($1 million) that purportedly is attributable to SGA's efforts alone.
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