A lawyer’s motion for reconsideration of an order to pay opposing counsel’s legal fees in a fractious franchise dispute was one motion too many, according to a federal judge.

Issuing an admonishment to Clifton solo Michael Curran on Dec. 23, District Judge William Martini found that the plaintiff’s lawyer violated Rule 11 of the Federal Rules of Civil Procedure by repeatedly using motions and appeals to raise new arguments inappropriately and reiterate arguments that had already been rejected.