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New York courts have held that attorneys' fees may be properly awarded to include fees incurred in defending a counterclaim where the defense of the counterclaim and the prosecution of plaintiff's claim were ""inextricably intertwined"". Binghamton Precast & Supply v. A Servidone, Inc., 257 AD.2d 731, 682 N.Y.S.2d 719 (3d Dep't 1999). Cf. D'Angelo v. 1432 86th St. Realty Corp., 2008 NY Slip Op. 328670, 2008 NY Misc. LEXIS 10461 (N.Y. Sup. Ct., Kings Cty.)(holding that foreclosure action and counterclaim for an offset were not so inextricably intertwined as to warrant the recovery of attorneys' fees for all claims)."

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