MEMORANDUM & ORDER
KATZ, Senior District Judge.
Before the court are plaintiff's motion for partial summary judgment on defendant's counterclaims and defendant's motion for sanctions and for partial summary judgment.
I. Background
Plaintiff Jeffrey M. Brown Associates, Inc. (JMB) provides construction management services. In 1994 and 1995, JMB entered into three contracts with three different owners to construct Caldor department...
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