[brief] PRELIMINARY STATEMENT  Plaintiff [...] ([...] or Plaintiff) filed an application with the trial court for an award of attorneys’ fees incurred in connection with post-judgment efforts spanning an approximate six-year period.  By way of a judgment, dated June 29, 2023, the trial court effectively rubber-stamped that application by awarding every penny of the $3,570,3557.50 sought by [...].  In doing so, the trial court ignored the New Jersey Supreme Court’s repeated admonishments not to passively accept the submissions of counsel in fee applications.  Indeed, numerous opinions of the New Jersey Supreme Court and this Court have made unmistakably clear that fee applications must be subjected to a very high level of critical analysis and scrutiny.  Here, the trial court fell far short of meeting that elevated standard.  The trial court did not meaningfully engage in the required calculation of a proper lodestar comprised of a reasonable number of hours multiplied by a reasonable hourly rate.  Rather, the trial court approved every minute of the 5,485.1 hours of legal work included in the fee application and approved [...]’s counsels’ rates in full – which ranged as high as $825 per hour and averaged almost $700 per hour for the four firm partners that performed roughly 94% of the subject services – despite those rates being multiples of the average rate in New Jersey.  No reductions to the fee request were applied whatsoever.  In fact, the trial court awarded Plaintiff fees in connection with motions brought by Plaintiff that the same trial court denied based on an obvious lack of merit.  The nature of this omnibus fee application in and of itself should never have been countenanced by the trial court.  [...] and his counsel sought payment for 5,485.1 hours of fees vaguely relating to “execution and collection efforts” (but supposedly not the same efforts for which [...] had already been awarded a total of $2,721,804.14 in attorneys’ fees/costs) covering more than six years of post-judgment proceedings, two years of which the reviewing trial court judge, the Honorable [...], P.J.Ch. did not even oversee.  Under these circumstances, no critical analysis was possible and the fee application should have been denied for that reason alone.  Indeed, the trial court judge who originally oversaw this matter, the Honorable [...] P. Contillo, P.J.Ch. (ret.), denied [...]’s two prior applications, respectively filed in 2017 and 2018, in which [...] likewise sought all fees relating to general execution and collection efforts.  Judge Contillo found there was no legal basis to generally award fees for collection efforts and instructed [...] that if he wanted to re-apply for such an award, he needed to first provide a basis connecting the specific collection efforts to an entitlement to awarded fees and then, once that was established, submit a proposed quantification of the applicable fees.  [...], however, chose not to follow that orderly process mandated by Judge Contillo.  Instead, [...] waited four years and then resubmitted a massive, unreviewable “global” fee application, seeking payment of his fees at substantially increased rates, which was erroneously granted by Judge Jerejian.  For these reasons and those set forth in more detail herein, the trial court erred and it is respectfully requested that this Court reverse those errors.