07-27-09 ARNOLD P. FEROLITO V. PARK HILL ASSOCIATION and PAGANO
COMPANY
A-4985-07T1
The appeal is from an award of fees and costs for frivolous
litigation entered against a party pursuant to N.J.S.A. 2A:15-
59.1. We address the scope of a prevailing party's obligations
to give notice pursuant to Rule l:4-8 and to prove that the
litigant, who was represented by counsel, acted in bad faith.
Richard Sadowski
Assistant Editor
