Common questions of law and fact warranting consolidation include: Kern's entitlement to share in fees derived from the "referral list" of cases set forth in his agreement with SSSB upon joining that firm; the amount of that entitlement; the amount of the fees realized by Schiff from referral list cases; and the amount of referral list fees already paid by Schiff to SSSB. As the motion court succinctly put it: "both actions concern a dispute over legal fees from cases arising...
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