The following excerpt is from Ozorowski v. Pawloski, 207 Misc. 407 (N.Y. Dist. Ct. 1955):
An attorney at common law was protected by two kinds of liens, a retaining lien on all papers in his possession and a charging lien on the fund or judgment recovered through his efforts. The charging lien "was a device invented by the courts for the protection of attorneys against the knavery of their clients, by disabling clients from receiving the fruits of recoveries without paying for the valuable services by which the recoveries were obtained." (Goodrich v. McDonald, 112 N.Y. 157, 163.)
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