In the Matter of Liquidation of Midland Ins. Co. (71 AD3d 221, 893 N.Y.S.2d 31 [1st Dept 2010] ) , the Appellate Division, First Department, added that, under this doctrine, "parties and their privies are precluded from relitigating an issue decided in an ongoing proceeding where there previously was a full and fair opportunity to address the issue" and that "privity is established where the interests of the nonparty can be said to have been represented in the prior proceedings." Id. at 225.