In Lang v. State of New York (258 AD2d 165, 696 N.Y.S.2d 3) an attorney attempted to execute a judgment against her former client for unpaid legal fees for representation in a criminal case, on funds that her former client transferred to the State of New York to be paid as restitution for his criminal activity, which were being held in escrow pending the outcome of further criminal proceedings. The former client had pleaded guilty to grand larceny in the fourth degree, in connection with false billings for Medicaid reimbursement, and the plea provided, inter alia, for restitution of $500,000 to be paid prior to sentencing. The funds were turned over to the Attorney General to be held in escrow pending determination of the appeal of the judgment of conviction and denial of a motion to withdraw the plea. The Court of Appeals upheld the plea, but remitted the matter to Supreme Court for a hearing to determine the amount of restitution. (People v. Consalvo, 89 NY2d 140, [1996].) On remand, the hearing court in Consalvo denied an application to release the funds and ordered that the funds remain in escrow pending a final order of restitution.