NJSBA Family Law Section

I had represented a client (as attorney #2) in a divorce action and successfully moved to be relieved as counsel.  Client owes me a tidy sum. Client obtained another attorney but Attorney #3 just bailed too.  Client is now pro se and divorce trial will be scheduled within the next 2-3 months. 
I already provided client with required arbitration notice. 
I am getting ready to file a petition for an attorney's lien (client will be receiving a significant amount of money from spouse and I want to make sure that some of that comes to me). 
I've reviewed the statute and case law but am not sure what kind of pleading a "petition" is -
Is it like a Notice of Motion that is supported by my Certification or more like a Complaint with the "Whereas" clauses containing requests for relief such as
1- Determining amount ​owed
2- Establishing schedule for further proceedings
3- Pending the court's determination following a plenary hearing on my claim, imposing interim restraints on the payment to client of a fixed amount (no more than the balance owed to me) of assets that will be payable to the client by spouse.  
Any assistance is greatly appreciated.

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Lisa M. Radell, Esq.
207 South Main Street
Cape May Court House, NJ 08210
Phone (609) 465-9910
Fax (609) 465-9920
E-Mail [email protected]
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Original Message------

I had represented a client (as attorney #2) in a divorce action and successfully moved to be relieved as counsel.  Client owes me a tidy sum. Client obtained another attorney but Attorney #3 just bailed too.  Client is now pro se and divorce trial will be scheduled within the next 2-3 months. 
I already provided client with required arbitration notice. 
I am getting ready to file a petition for an attorney's lien (client will be receiving a significant amount of money from spouse and I want to make sure that some of that comes to me). 
I've reviewed the statute and case law but am not sure what kind of pleading a "petition" is -
Is it like a Notice of Motion that is supported by my Certification or more like a Complaint with the "Whereas" clauses containing requests for relief such as
1- Determining amount ​owed
2- Establishing schedule for further proceedings
3- Pending the court's determination following a plenary hearing on my claim, imposing interim restraints on the payment to client of a fixed amount (no more than the balance owed to me) of assets that will be payable to the client by spouse.  
Any assistance is greatly appreciated.

------------------------------
Lisa M. Radell, Esq.
207 South Main Street
Cape May Court House, NJ 08210
Phone (609) 465-9910
Fax (609) 465-9920
E-Mail [email protected]
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