SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF WESTCHESTER: COMMERCIAL DIVISION

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1 FILED: WESTCHESTER COUNTY CLERK 03/27/ :04 AM INDEX NO /2015 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 03/27/2015 LAW OFFICE OF JACK M. PLATT by Neal R. Platt Of Counsel 23 rd Floor 767 Third Avenue New York, New York (212) plattneal@gmail.com Attorney for Defendant Pasternak Wine Imports, Defendant/Counterclaim Plaintiff Pasternak Wine Imports LLC, and Defendant DBR (USA), Inc. s/h/a Domaines Barons de Rothschild SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF WESTCHESTER: COMMERCIAL DIVISION VIGNERONS DE LA MEDITERANEE, S.A., -against- Plaintiff, Index No /2015 PASTERNAK WINE IMPORTS, PASTERNAK WINE IMPORTS LLC, and DOMAINES BARONS DE ROTHSCHILD, Defendants, ANSWER, AFFIRMATIVE DEFENSES & COUNTERCLAIMS Electronically Filed PASTERNAK WINE IMPORTS LLC, Counterclaim Plaintiff, - against - VIGNERONS DE LA MEDITERRANEE, S.A. d/b/a VIGNERONS DE LA MEDITERANEE, S.A., Counterclaim Defendant, and RICHARD J. GENOVA, VINTAGE EPICURE LLC, LIZZ MEJIA, and BEVERAGE GROUP INTERNATIONAL, LLC d/b/a VAL D ORBIEU AMERICAS, USA, Additional Defendants on Counterclaims. Defendants PASTERNAK WINE IMPORTS, PASTERNAK WINE IMPORTS LLC (each of which may hereinafter be referred to as a Pasternak Defendant, and Page 1 of 29

2 together as the Pasternak Defendants ) and DBR (USA), INC., sued herein as DOMAINES BARONS DE ROTHSCHILD, by their undersigned attorney, allege the following as their Answer, Affirmative Defenses, and Counterclaims: ANSWER 1. Responding to the allegations contained in Paragraph 1 of Plaintiff s Complaint, Defendants affirmatively state that they believe that Plaintiff s name, when written in the English Language without French accents, is Vignerons de la Mediterranee, S.A., and otherwise deny knowledge or information sufficient to form a belief as to the truth or falsity of the allegations asserted in said paragraph. 2. Responding to the allegations contained in Paragraph 2 of Plaintiff s Complaint, Defendants affirmatively state that Pasternak Wine Imports : (a) (b) was the name of a now-inactive general partnership organized and existing under the laws of the State of Connecticut, which at one time maintained its principal place of business at 777 West Putnam Avenue, Greenwich, Connecticut (hereinafter, Pasternak GP or the Inactive Connecticut Partnership ); and is presently the assumed name, pursuant to certificate duly filed in the Office of the Clerk of the County of Westchester, New York, of the successor in interest to the Inactive Connecticut Partnership, namely, Defendant Pasternak Wine Imports LLC (hereinafter, Pasternak LLC ), which is a limited liability company organized and existing under the laws of the State of New York, having a business address at 500 Mamaroneck Avenue, Harrison, New York For purposes of this pleading, Defendants will presume that Plaintiff s references to Pasternak Wine Imports and PWI were intended to denominate the Inactive Connecticut Partnership. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 3. Defendants deny the allegations contained in Paragraphs 3, 4, & 5 of Plaintiff s Complaint. Page 2 of 29

3 4. Responding to the allegations contained in Paragraph 6 of Plaintiff s Complaint, Defendants affirmatively state that Pasternak LLC is a limited liability company organized and existing under the laws of the State of New York, having a business address at 500 Mamaroneck Avenue, Harrison, New York 10528, but that Defendants have no knowledge or information concerning an entity by the name of Pasternak Wine Imposts [sic] LLC, as alleged by Plaintiff. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 5. Responding to the allegations contained in Paragraph 7 of Plaintiff s Complaint, Defendants affirmatively state that Pasternak LLC is a business which derives revenue from its business and activities within the State of New York. To the extent that Plaintiff characterizes such revenue as substantial without providing a definition of said term, said paragraph states a legal conclusion to which no response is required. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 6. Responding to the allegations contained in Paragraph 8 of Plaintiff s Complaint, Defendants affirmatively state that Pasternak LLC is a limited liability company organized and existing under the laws of the State of New York, having a business address at 500 Mamaroneck Avenue, Harrison, New York 10528, and, as such, is authorized to conduct business in the State of New York, and deny the remaining allegations contained in said paragraph. 7. Responding to the allegations contained in Paragraph 9 of Plaintiff s Complaint, Defendants affirmatively state that Pasternak LLC is a limited liability company that transacts business in the State of New York, and deny the remaining allegations contained in said paragraph. 8. Responding to the allegations contained in Paragraphs 10, 11, 12, 13, & 14 of Plaintiff s Complaint, Defendants affirmatively state that Defendant DBR (USA), Inc. ( DBR ), sued herein as Domaines Barons de Rothschild: (a) is, and at all relevant times has been, a corporation organized and existing under the laws of the State of Nevada, having its registered office at 6100 Neil Road, Suite 500, Reno, Nevada 89511; Page 3 of 29

4 (b) (c) (d) (e) formerly owned a thirty-five (35%) percent partnership interest in the Inactive Connecticut Partnership, and, since a date in 2012, has acquired one hundred (100%) percent of the limited liability company membership interests in Pasternak LLC; does not conduct, and at all relevant times has not conducted, business in the State of New York; does not derive, and at all relevant times has not derived, substantial revenue from its business and activities within the State of New York; and does not transact, and at all relevant times has not transacted, business within the State of New York. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 9. Responding to the allegations contained in Paragraph 15 of Plaintiff s Complaint, Defendants deny knowledge or information sufficient to form a belief as to the truth or falsity of the allegations asserted in said paragraph. 10. Defendants deny the allegations contained in Paragraph 16 of Plaintiff s Complaint. 11. Responding to the allegations contained in Paragraph 17 of Plaintiff s Complaint, Defendants affirmatively state that Defendant Pasternak LLC purchases imported wine and distributes it to licensed resellers in the United States, and deny the remaining allegations contained in said paragraph. 12. Defendants deny the allegations contained in Paragraphs 18 & 19 of Plaintiff s Complaint. 13. Responding to the allegations contained in Paragraph 20 of Plaintiff s Complaint, Defendants affirmatively state that Defendant Pasternak Wine Imports entered into a written agreement, styled Distribution Agreement, with Plaintiff and Martin Sinkoff Wines, Inc., dated August 17, 2001 (the Distribution Agreement ). The Page 4 of 29

5 Distribution Agreement speaks for itself. To the extent a further response may be required, Defendants deny knowledge or information sufficient to form a belief as to the truth or falsity of the allegations asserted in said paragraph. 14. Responding to the allegations contained in Paragraph 21 of Plaintiff s Complaint, Defendants affirmatively state that the Distribution Agreement speaks for itself. Said paragraph also fails to provide a definition of the word exclusively, without which no response may reasonably be framed. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 15. Responding to the allegations contained in Paragraphs 22, 23, & 24 of Plaintiff s Complaint, Defendants affirmatively state that the Distribution Agreement speaks for itself. To the extent a further response may be required, Defendants deny knowledge or information sufficient to form a belief as to the truth or falsity of the allegations asserted in said paragraph. 16. Responding to the allegations contained in Paragraph 25 of Plaintiff s Complaint, Defendants affirmatively state that, without objection by Plaintiff and with Plaintiff s full knowledge, Defendant Pasternak GP, as well as its successor Pasternak LLC, purchased from a company then affiliated, and then under common control, with Plaintiff, wines from the Pays d Oc region of France, and marketed, represented, and sold such wines in the Territory, as that term is defined in Section 1(b) of the Distribution Agreement. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 17. Responding to the allegations contained in Paragraph 26 of Plaintiff s Complaint, Defendants affirmatively state that Defendant Pasternak GP reorganized its business into a limited liability company organized and existing under the laws of the State of New York, namely Pasternak LLC, and that Plaintiff acceded to, and ratified, such reorganization by, among other things: (a) (b) continuing to do business with Pasternak LLC (as acknowledged by Plaintiff in Paragraph 50 of Plaintiff s Complaint) and to accept the benefit of operating under the Distribution Agreement; accepting and fulfilling purchase orders from Pasternak Wine Imports LLC ; Page 5 of 29

6 (c) (d) (e) invoicing Pasternak Wine Imports LLC for wines; accepting payment for such wines from Pasternak Wine Imports LLC ; and certifying by letter to the alcoholic beverage control authorities of several states of the United States: (i) that Pasternak Wine Imports of 500 Mamaroneck Avenue, Harrison, NY 10528, USA, was the sole importer/exclusive representative of these wines in the United States of America ; (ii) (iii) that the entity authorized to represent Plaintiff s wine brands in the United States was Pasternak Wine Imports LLC ; and that each letter was subject to the conditions listed in the contract signed by Pasternak Wine Import and Vignerons de la Mediterranee [sic] on the 17th August To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 18. Defendants deny the allegations contained in Paragraphs 27, 28, 29, 30, 31, & 32 of Plaintiff s Complaint. 19. Responding to the allegations contained in Paragraph 33 of Plaintiff s Complaint, formerly owned a thirty-five (35%) percent partnership interest in the Inactive Connecticut Partnership, and, since a date in 2012, has acquired one hundred (100%) percent of the limited liability company membership interests in Pasternak LLC. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 20. Defendants deny the allegations contained in Paragraphs 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, & 44 of Plaintiff s Complaint. Page 6 of 29

7 21. Responding to the allegations contained in Paragraph 45 of Plaintiff s Complaint, Defendants repeat and reallege their responses to each of Paragraphs 1 through 44 of Plaintiff s Complaint. 22. Responding to the allegations contained in Paragraph 46 of Plaintiff s Complaint, Defendants affirmatively state that the Distribution Agreement was valid when made. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 23. Defendants deny the allegations contained in Paragraphs 47, 48, & 49 of Plaintiff s Complaint. 24. Responding to the allegations contained in Paragraph 50 of Plaintiff s Complaint, Defendants admit that Plaintiff supplied certain wine products to Defendant Pasternak LLC and invoiced Defendant Pasternak LLC therefor, some of which invoices have been paid, and others of which remain unpaid and subject to valid claims and setoffs of Defendant Pasternak LLC, as further set forth in Defendants affirmative defenses and counterclaims, below. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 25. Defendants deny the allegations contained in Paragraphs 51, 52, & 53 of Plaintiff s Complaint. 26. Responding to the allegations contained in Paragraph 54 of Plaintiff s Complaint, Defendants repeat and reallege their responses to each of Paragraphs 1 through 53 of Plaintiff s Complaint. 27. Responding to the allegations contained in Paragraph 55 of Plaintiff s Complaint, Defendants affirmatively state that the Distribution Agreement speaks for itself. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 28. Defendants deny the allegations contained in Paragraphs 56, 57, 58, 59 & 60 of Plaintiff s Complaint. 29. Responding to the allegations contained in Paragraph 61 of Plaintiff s Complaint, Defendants repeat and reallege their responses to each of Paragraphs 1 through 60 of Plaintiff s Complaint. Page 7 of 29

8 30. Defendants deny the allegations contained in Paragraphs 62, 63, 64, & 65 of Plaintiff s Complaint. 31. Responding to the allegations contained in Paragraph 66 of Plaintiff s Complaint, Defendants repeat and reallege their responses to each of Paragraphs 1 through 65 of Plaintiff s Complaint. 32. Defendants deny the allegations contained in Paragraphs 67, 68, & 69 of Plaintiff s Complaint. 33. Responding to the allegations contained in Paragraph 70 of Plaintiff s Complaint, Defendants repeat and reallege their responses to each of Paragraphs 1 through 69 of Plaintiff s Complaint. 34. Defendants deny the allegations contained in Paragraphs 71, 72, 73, & 74 of Plaintiff s Complaint. 35. Responding to the allegations contained in Paragraph 75 of Plaintiff s Complaint, Defendants repeat and reallege their responses to each of Paragraphs 1 through 74 of Plaintiff s Complaint. 36. Responding to the allegations contained in Paragraph 76 of Plaintiff s Complaint, Defendants affirmatively state that the Distribution Agreement was valid when made. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 37. Defendants deny the allegations contained in Paragraphs 77, 78, 79, 80 & 81 of Plaintiff s Complaint. 38. Responding to the allegations contained in Paragraph 82 of Plaintiff s Complaint, Defendants repeat and reallege their responses to each of Paragraphs 1 through 81 of Plaintiff s Complaint. 39. Responding to the allegations contained in Paragraph 83 of Plaintiff s Complaint, Defendants affirmatively state that, without objection by Plaintiff and with Plaintiff s full knowledge, Defendant Pasternak GP, as well as its successor Pasternak LLC, purchased from a company then affiliated, and then under common control, with Plaintiff, wines from the Pays d Oc region of France, and marketed, Page 8 of 29

9 represented, and sold such wines in the Territory, as that term is defined in Section 1(b) of the Distribution Agreement. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 40. Defendants deny the allegations contained in Paragraphs 84 & 85 of Plaintiff s Complaint. 41. Responding to the allegations contained in Paragraph 86 of Plaintiff s Complaint, Defendants affirmatively state that, subsequent to Plaintiff s repudiations and breach of the Distribution Agreement, Defendant Pasternak LLC offset against amounts invoiced by Plaintiff certain reasonable charges and offsets, as well as damages suffered by said Defendant on account of Plaintiff s breach. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 42. Defendants deny the allegations contained in Paragraphs 87 & 88 of Plaintiff s Complaint. 43. Responding to the allegations contained in Paragraph 89 of Plaintiff s Complaint, Defendants repeat and reallege their responses to each of Paragraphs 1 through 88 of Plaintiff s Complaint. 44. Defendants deny the allegations contained in Paragraphs 90, 91, & 92 of Plaintiff s Complaint. 45. Responding to the allegations contained in Paragraph 93 of Plaintiff s Complaint, Defendants repeat and reallege their responses to each of Paragraphs 1 through 92 of Plaintiff s Complaint. 46. Defendants deny the allegations contained in Paragraphs 94, 95, 96, & 97 of Plaintiff s Complaint. 47. Responding to the allegations contained in Paragraph 98 of Plaintiff s Complaint, Defendants repeat and reallege their responses to each of Paragraphs 1 through 97 of Plaintiff s Complaint. Page 9 of 29

10 48. Responding to the allegations contained in Paragraph 99 of Plaintiff s Complaint, Defendants affirmatively state that Defendant Pasternak GP entered into the Distribution Agreement, which agreement speaks for itself. To the extent a further response may be required, Defendants deny knowledge or information sufficient to form a belief as to the truth or falsity of the allegations asserted in said paragraph. 49. Responding to the allegations contained in Paragraph 100 of Plaintiff s Complaint, Defendants affirmatively state that Defendant DBR was informed by Defendant Pasternak GP in the ordinary course of business that Defendant Pasternak GP had entered into a distributorship agreement with Plaintiff, and that Defendant Pasternak LLC had succeeded to the rights and obligations of Defendant Pasternak GP pursuant to such agreement. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 50. Defendants deny the allegations contained in Paragraphs 101, 102, 103, & 104 of Plaintiff s Complaint. 51. Responding to the allegations contained in Paragraph 105 of Plaintiff s Complaint, Defendants repeat and reallege their responses to each of Paragraphs 1 through 104 of Plaintiff s Complaint. 52. Responding to the allegations contained in Paragraph 106 of Plaintiff s Complaint, Defendants affirmatively state that, without objection by Plaintiff and with Plaintiff s full knowledge, Defendant Pasternak GP, as well as its successor Pasternak LLC, purchased from a company then affiliated, and then under common control, with Plaintiff, wines from the Pays d Oc region of France, and marketed, represented, and sold such wines in the Territory, as that term is defined in Section 1(b) of the Distribution Agreement. To the extent a further response may be required, Defendants deny the allegations asserted in said paragraph. 53. Defendants deny the allegations contained in Paragraphs 107, 108, 109, 110, & 111 of Plaintiff s Complaint. 54. Responding to the allegations contained in Paragraph 112 of Plaintiff s Complaint, Defendants repeat and reallege their responses to each of Paragraphs 1 through 111 of Plaintiff s Complaint. Page 10 of 29

11 55. Defendants deny the allegations contained in Paragraphs 113, 114, 115, 116, 117, 118, 119, & 120 of Plaintiff s Complaint. 56. Responding to the allegations contained in Paragraph 121 of Plaintiff s Complaint, Defendants repeat and reallege their responses to each of Paragraphs 1 through 120 of Plaintiff s Complaint. 57. Defendants deny the allegations contained in Paragraph 122, 123, & 124 of Plaintiff s Complaint. AFFIRMATIVE DEFENSES FIRST AFFIRMATIVE DEFENSE (Ineffective Service of Process) 58. Service of process in this action on each Defendant other than Defendant Pasternak LLC has failed to comply with the requirements of law, and is therefore ineffective. SECOND AFFIRMATIVE DEFENSE (Defective Summons) 59. Plaintiff s summons is defective in failing to state the address of Plaintiff s counsel upon which Defendants are required to serve responsive papers. THIRD AFFIRMATIVE DEFENSE (Acquiescence, Waiver, & Estoppel) 60. With full knowledge of all material facts, Plaintiff has acquiesced in conduct complained of in Plaintiff s complaint in numerous ways, including but not limited to the following: (a) entering into the Distributorship Agreement with Defendant Pasternak GP: (i) which agreement in no way prohibited Defendant Pasternak GP or its successor from Page 11 of 29

12 issuing ownership interests of any size to companies owning brands of wines, regardless whether such brands were to compete with Plaintiff s brands; (ii) with full knowledge that thirty-five (35%) percent of the equity of Defendant Pasternak GP was already owned by a company, some of whose principal shareholders owned brands of wines, and by Plaintiff s continuing to accept the benefits of such agreement until such time as Plaintiff wrongfully repudiated and breached such agreement on specious grounds; (b) acceding to, and ratifying the Inactive General Partnership s reorganization of its business into a limited liability company organized and existing under the laws of the State of New York, namely Pasternak LLC, by continuing to do business with Pasternak LLC (as acknowledged by Plaintiff in Paragraph 50 of Plaintiff s Complaint) and to accept the benefit of operating under the Distribution Agreement by; (i) (ii) (iii) (iv) accepting and fulfilling purchase orders from Pasternak Wine Imports LLC ; invoicing Pasternak Wine Imports LLC for wines; accepting payment for such wines from Pasternak Wine Imports LLC ; and certifying by letter to the alcoholic beverage control authorities of several states of the United States: (A) that Pasternak Wine Imports of 500 Mamaroneck Avenue, Harrison, NY 10528, USA, was Page 12 of 29

13 the sole importer/exclusive representative of these wines in the United States of America ; (B) that the entity authorized to represent Plaintiff s wine brands in the United States was Pasternak Wine Imports LLC ; and (C) (D) that each letter was subject to the conditions listed in the contract signed by Pasternak Wine Import and Vignerons de la Mediterranee [sic] on the 17th August 2001 ; and acquiescing in Pasternak GP s and Pasternak LLC s purchase from one or more companies affiliated with Plaintiff and operated by some or all of the people who operated Plaintiff, wines from the Pays d Oc region of France, and also in Pasternak GP s and Pasternak LLC s marketing, representing, and selling of such wines in the Territory, as that term is defined in Section 1(b) of the Distribution Agreement; and (c) without objection by Plaintiff and with Plaintiff s full knowledge, allowing Defendant Pasternak GP, as well as its successor Pasternak LLC, to purchase from a company then affiliated, and then under common control, with Plaintiff, wines from the Pays d Oc region of France, and to market, Page 13 of 29

14 represent, and sell such wines in the Territory, as that term is defined in Section 1(b) of the Distribution Agreement. 61. By numerous acts of commission and omission, Plaintiff has expressly and impliedly represented to the Pasternak Defendants and certain non-parties that Plaintiff acquiesced in the Pasternak Defendants conduct in the above respects, thereby inducing and causing the Pasternak Defendants and such non-parties to rely reasonably upon Plaintiff s such representations, in such manner that Plaintiff should not be heard to deny the accuracy of such representations in this action. 62. Plaintiff s claims are barred, in whole or in part, by the doctrine of acquiescence. 63. Plaintiff s claims are barred, in whole or in part, by the doctrine of estoppel. 64. Plaintiff s claims are barred, in whole or in part, by the doctrine of waiver. FOURTH AFFIRMATIVE DEFENSE (Account Stated; Pasternak LLC s Right of Setoff) 65. On or about August 15, 2013, Plaintiff and Pasternak LLC jointly agreed upon a statement of account liquidating amounts owed to and by Plaintiff, including all offsets and adjustments, as set forth in the Counterclaims below. 66. Plaintiff has failed to honor said statement of account, and should be foreclosed from obtaining a money judgment in excess of that set forth in Paragraph 113, below. 67. Defendant Pasternak LLC has a right to set off from any amounts owed to Plaintiff, amounts not less than those indicated in the chart set forth in Paragraph 113, below. FIFTH AFFIRMATIVE DEFENSE (Plaintiff s Repudiation and Breach) 68. Plaintiff repudiated and breached the Distribution Agreement, as more fully set forth in the Counterclaims, which precludes Plaintiff from relying upon any purported right under said agreement, including, but not limited to: Page 14 of 29

15 (a) (b) (c) (d) (e) Any right to terminate said agreement; Any right to arrange for the replacement of Defendant Pasternak LLC as Plaintiff s U.S. importer; Any right to demand Defendant Pasternak LLC s performance under said agreement; Any claim for indemnity or legal fees under said agreement; and Any purported limitation upon the right to damages available to Defendant Pasternak LLC under said agreement. 69. The Distribution Agreement is a contract for the sale of goods under Article 2 of the Uniform Commercial Code ( UCC ). 70. Plaintiff s delivery of goods at a time when it was in breach (or knew it soon would be in breach) of the Distribution Agreement and the implied covenant of good faith and fair dealing, rendered the goods non-conforming under various sections of the UCC, including but not limited to UCC 2-714, Comment Pursuant to UCC and other provisions of law, Defendant Pasternak LLC has acted as a reasonable purchaser whose seller, namely Plaintiff, has engaged in anticipatory repudiation of the agreement. 72. By repudiating the Distribution Agreement, Plaintiff has rendered impractical the resale of the goods by Defendant Pasternak LLC at its regular prices and to its regular customers, thus depriving Defendant Pasternak LLC of the benefit of its bargain. 73. Under UCC 2-607(2), any failure of effective rejection does not of itself impair any other remedy available to Defendant Pasternak LLC. Page 15 of 29

16 SIXTH AFFIRMATIVE DEFENSE (Plaintiff s Unclean Hands) 74. Plaintiff s repudiation and breach of the Distribution Agreement as more fully set forth in the Counterclaims alleged below, constitute unclean hands, precluding the relief demanded in Plaintiff s Complaint. SEVENTH AFFIRMATIVE DEFENSE (Failure to State a Cognizable Claim) 75. Each cause of action pleaded in Plaintiff s Complaint fails to state a cause of action upon which relief can be granted. COUNTERCLAIMS BRIEF STATEMENT OF COUNTERCLAIMS 76. The Counterclaims arise out of the unlawful termination of an exclusive importation arrangement pursuant to which the Pasternak Defendants, in sequence, imported wines from the Pays d Oc region of France of Plaintiff s brands into the United States for approximately twelve years, as well as tortious interference by Additional Defendants on Counterclaim Richard J. Genova, Vintage Epicure LLC, Lizz Mejia, and Beverage Group International, LLC d/b/a Val D Orbieu Americas, USA, in such contractual and business relationship. PARTIES Counterclaim Plaintiff 77. Counterclaim Plaintiff Pasternak Wine Imports LLC ( Counterclaim Plaintiff or Pasternak LLC ): (a) is a limited liability company organized and existing under the laws of the State of New York; Page 16 of 29

17 (b) (c) maintains its principal place of business at 500 Mamaroneck Avenue, Harrison, New York 10528; and generally does business in the State of New York under the assumed name Pasternak Wine Imports, pursuant to certificate duly filed in the Office of the Clerk of the County of Westchester, New York. Counterclaim Plaintiff s Predecessor 78. Counterclaim Plaintiff s predecessor in interest, namely, Pasternak Wine Imports was a general partnership organized and existing under the laws of the State of Connecticut, having its principal place of business at 500 Mamaroneck Avenue, Harrison, New York (the Inactive Connecticut Partnership or Pasternak GP ). 79. The general partners of the Inactive Connecticut Partnership were one Connecticut corporation, one New York corporation, and DBR (USA), Inc., a Defendant named in this action sued herein as Domaines Barons De Rothschild, which is a corporation organized and existing under the laws of the State of Nevada, having its registered office at 6100 Neil Road, Suite 500, Reno, Nevada Counterclaim Defendant 80. Counterclaim Defendant Vignerons de la Mediterranee, S.A. ( Vignerons ): (a) (b) (c) (d) is the named Plaintiff in this action: has misspelled its own name in the caption of this action as follows: Vignerons de la Mediteranee, S.A. ; misspelled its name in like manner in entering into the distributorship agreement with the Inactive Connecticut Partnership, as such agreement is further described at Paragraph 91, below; is a French corporation of a type known as a societé anonyme ; Page 17 of 29

18 (e) (f) maintains its principal place of business at12 Rue du Rec de Veyret, Narbonne, in the Republic of France; is, and at all relevant times has been, engaged in the distribution, marketing, and sale of wines from the Pays d Oc region of France under various brand names. 81. Additional Defendant on Counterclaim Richard J. Genova: (a) (b) (c) (d) is a natural person who is a citizen of the State of New York; maintains an address for the transaction of business at Vintage Epicure LLC, 1 Pleasant Avenue, Suite E, Port Washington, New York 11050; was formerly an employee of both Counterclaim Plaintiff and Pasternak GP; and is a current employee, member, or manager of Additional Defendant on Counterclaim Vintage Epicure LLC, as further described below. 82. Additional Defendant on Counterclaim Vintage Epicure LLC: (a) (b) (c) (d) is a limited liability company organized and existing under the laws of the State of New York; maintains an address for the transaction of business at 1 Pleasant Avenue, Suite E, Port Washington, New York 11050; is, and at all relevant times has been, engaged in the distribution, marketing, and sale of wines; is engaged in the sale of wines distributed by Counterclaim Defendant Vignerons; and Page 18 of 29

19 (e) operates a website which, on its Contacts page, bears the words: Visit Beverage Group International - our importer and compliance partner, where the words Beverage Group International are linked to a website operated by Additional Defendant on Counterclaim Beverage Group International, LLC d/b/a Val d Orbieu Americas, USA, further identified at Paragraph 84, below. 83. Additional Defendant on Counterclaim Lizz Mejia: (a) (b) (c) (d) (e) is a natural person who is a citizen of the State of New York; maintains an address for the transaction of business at Beverage Group International, LLC d/b/a Val d Orbieu Americas, USA, 120 North Main Street, Suite 502, New City, New York ; was formerly an employee of both Counterclaim Plaintiff and Pasternak GP; is a current employee, member, or manager of Additional Defendant on Counterclaim Beverage Group International, LLC d/b/a Val d Orbieu Americas, USA, as further described in Paragraph 84, below; is, and at all relevant times has been, engaged in the business of providing to suppliers of wine various wine-related services, including but not limited to clearance, logistical compliance, transportation, and warehousing; and (f) currently provides clearance, logistical compliance, transportation, and warehousing services to Counterclaim Defendant Vignerons in connection with wines distributed by Counterclaim Defendant Vignerons. Page 19 of 29

20 84. Additional Defendant on Counterclaim Beverage Group International, LLC d/b/a Val d Orbieu Americas, USA: (a) (b) (c) (d) (e) (f) is a limited liability company organized and existing under the laws of the State of New York; does all or a portion of its business under the assumed name Val d Orbieu Americas, USA ; maintains an address for the transaction of business at 120 North Main Street, Suite 502, New City, New York ; is, and at all relevant times has been, engaged in the business of the transportation and warehousing of wines, as well as other specialized services in connection with wines; is engaged in the sale of wines distributed by Counterclaim Defendant Vignerons; and operates a website which, on its About Us page, bears the words: You also can visit Vintage Epicure, our Sales and Marketing partner, where the words Vintage Epicure are linked to a website operated by Additional Defendant on Counterclaim Vintage Epicure LLC, further identified at Paragraph 82, above. VENUE 85. Westchester is the County in which Counterclaim Plaintiff resides. 86. Venue is proper in the County of Westchester pursuant to CPLR 501. Page 20 of 29

21 ALLEGATIONS COMMON TO ALL CAUSES OF ACTION Relationship Between Counterclaim Plaintiff and Counterclaim Defendant Vignerons 87. The business known as Pasternak Wine Imports has been a national importer of fine wines since From 1988 to June 1, 2007, the entity conducting such business under the name Pasternak Wine Imports was the entity identified as Pasternak GP in Paragraph 78, above. 89. From June 1, 2007 through the date of this pleading, the entity conducting such business under the name Pasternak Wine Imports has been the entity identified as Pasternak LLC in Paragraph 77, above. 90. In 2001 and since that time, Counterclaim Defendant Vignerons was engaged in the distribution, marketing, export, and sale of wines of certain brands originating in the Pays d Oc region of France. 91. On or about August 17, 2001, Pasternak entered into a certain Distribution Agreement with Counterclaim Defendant Vignerons, and Martin Sinkoff Wines, Inc. (the Distribution Agreement ), pursuant to which Pasternak GP was granted the exclusive right to import Defendant Vignerons wines from the Pays d Oc region of France into the United States upon stated terms and conditions. 92. Notwithstanding the terms of Section 14 of the Distribution Agreement, Counterclaim Defendant Vignerons acceded to, and ratified, the reorganization of Pasternak Wine Imports that took place on or about June 1, 2007 on numerous occasions by, including but not limited to: (a) (b) continuing to do business with Pasternak LLC (as acknowledged by Counterclaim Defendant Vignerons in Paragraph 50 of its Complaint) and to accept the benefit of operating under the Distribution Agreement; accepting and fulfilling purchase orders from Pasternak Wine Imports LLC ; Page 21 of 29

22 (c) (d) (e) invoicing Pasternak Wine Imports LLC for wines; accepting payment for such wines from Pasternak Wine Imports LLC ; and certifying by letter to the alcoholic beverage control authorities of several states of the United States: (i) that Pasternak Wine Imports of 500 Mamaroneck Avenue, Harrison, NY 10528, USA, was the sole importer/exclusive representative of these wines in the United States of America ; (ii) (iii) that the entity authorized to represent Counterclaim Defendant Vignerons wine brands in the United States was Pasternak Wine Imports LLC ; and that each letter was subject to the conditions listed in the contract signed by Pasternak Wine Import and Vignerons de la Mediterranee [sic] on the 17th August Counterclaim Defendant Vignerons Groundless and Unexcused Repudiation and Termination of the Distribution Agreement 93. Section 2(a) of the Distributorship Agreement provided that Counterclaim Plaintiff had the exclusive right to import and distribute Counterclaim Defendant Vignerons brands of wines into the Territory, as that term was defined in Section 1(b) of the Distribution Agreement. 94. Wines bearing the brand name VAL D ORBIEU were among Counterclaim Defendant Vignerons brands required to be sold exclusively to Counterclaim Plaintiff pursuant to the Distribution Agreement. Page 22 of 29

23 95. VAL D ORBIEU is the brand name of certain wines sold by Counterclaim Defendant. 96. The entity owning all or a substantial portion of Counterclaim Defendant Vignerons is known as Groupe Val d Orbieu. 97. Groupe Val d Orbieu is a French still wine cooperative. 98. Val d Orbieu is part of the official name of the entity owning all or a substantial portion of Counterclaim Defendant Vignerons. 99. For a foreign wine seller to import wines into the United States, such foreign wine seller is required to register its brands to a U.S. importer of record From the inception of the Distribution Agreement, the brands of Counterclaim Defendant Vignerons were registered to Counterclaim Plaintiff, which served as U.S. importer of record for such brands During the term of the Distribution Agreement, on or about February 12, 2013, and prior to any attempts by Counterclaim Defendant Vignerons to address with Counterclaim Plaintiff any perceived inadequacies of Counterclaim Plaintiff s representation of said Counterclaim Defendant Vignerons brands in the United States, Additional Defendant on Counterclaims Beverage Group International, LLC filed a certificate of assumed name in the Office of the Clerk of the County of Rockland, New York stating that Additional Defendant on Counterclaims Beverage Group International, LLC would be doing business under the name Val d Orbieu Americas, USA (the Val d Orbieu d/b/a Certificate ) Counterclaim Defendant Vignerons: (a) did not contemporaneously inform Counterclaim Plaintiff that: (i) Counterclaim Defendant Vignerons had authorized Additional Defendant on Counterclaims Beverage Group International to do business under the name Val d Orbieu Americas, USA ; nor that Page 23 of 29

24 (ii) Counterclaim Defendant Vignerons had authorized Additional Defendant on Counterclaims Beverage Group International to file the Val d Orbieu d/b/a Certificate; and (b) did not contemporaneously seek the consent of Counterclaim Plaintiff to: (i) Counterclaim Defendant Vignerons authorization of Additional Defendant on Counterclaims Beverage Group International to do business under the name Val d Orbieu Americas, USA ; or (ii) Counterclaim Defendant Vignerons authorizing Additional Defendant on Counterclaims Beverage Group International to file the Val d Orbieu d/b/a Certificate During the term of the Distribution Agreement, on or about March 29, 2013, and prior to any attempts by Counterclaim Defendant Vignerons to address with Counterclaim Plaintiff any perceived inadequacies of Counterclaim Plaintiff s representation of said Counterclaim Defendant Vignerons brands in the United States, Counterclaim Defendant Vignerons registered its brands to Additional Defendant on Counterclaims Beverage Group International, LLC d/b/a Val d Orbieu Americas, USA Counterclaim Defendant Vignerons did not contemporaneously inform Counterclaim Plaintiff that it had registered its brands to Additional Defendant on Counterclaims Beverage Group International, LLC d/b/a Val d Orbieu Americas, USA, nor did Counterclaim Defendant Vignerons seek the consent of Counterclaim Plaintiff to do so Upon information and belief, Counterclaim Defendant Vignerons had been urged to register its brands to Additional Defendant on Counterclaim Beverage Group International, LLC d/b/a Val d Orbieu Americas, USA: (a) by Additional Defendant on Counterclaim Lizz Mejia, whether acting on her own behalf or on behalf of Additional Page 24 of 29

25 Defendant on Counterclaim Beverage Group International, LLC d/b/a Val d Orbieu Americas, USA; and (b) by Additional Defendant on Counterclaim Richard J. Genova, whether on his own behalf or acting on behalf of Additional Defendant on Counterclaim Vintage Epicure LLC The Distributorship Agreement remained in effect and, upon information and belief, except for Counterclaim Defendant Vignerons actions aforesaid, including but not limited to consenting to the filing of the Val d Orbieu d/b/a Certificate and the registration of its brands to Additional Defendant on Counterclaim Beverage Group International, LLC d/b/a Val d Orbieu Americas, USA, the parties to the Distributorship Agreement continued to operate in accordance with its terms until such time as Counterclaim Defendant Vignerons, notwithstanding that it had no valid grounds for termination, purported to terminate the Distribution Agreement in an undated letter, received by Counterclaim Plaintiff on or about June 10, Upon information and belief, Counterclaim Defendant Vignerons had been urged to repudiate and terminate the Distribution Agreement: (a) (b) by Additional Defendant on Counterclaim Lizz Mejia, whether on her own behalf or on behalf of Additional Defendant on Counterclaim Beverage Group International, LLC d/b/a Val d Orbieu Americas, USA; and by Additional Defendant on Counterclaim Richard J. Genova, whether on his own behalf or on behalf of Additional Defendant on Counterclaim Vintage Epicure LLC Upon those occasions when the Additional Defendants on Counterclaim urged Counterclaim Defendant Vignerons to register its brands to the Additional Defendants on Counterclaim and to repudiate and terminate the Distribution Agreement, Additional Defendants on Counterclaim: (a) had knowledge of the essential character and binding nature of the Distribution Agreement; Page 25 of 29

26 (b) (c) knew that the Distribution Agreement remained in effect, and that there were no valid grounds for its repudiation and termination by Counterclaim Defendant Vignerons; and urged such actions upon Counterclaim Defendant Vignerons to advance the pecuniary gain of the Additional Defendants on Counterclaim, without excuse or privilege. FIRST COUNTERCLAIM Against Counterclaim Defendant Vignerons (Breach and Repudiation of Contract & Implied Covenant of Good Faith and Fair Dealing) 109. Counterclaim Plaintiff repeats and realleges each allegation set forth in Paragraphs 76 through 108, above By the acts stated above, Counterclaim Defendant Vignerons has repudiated and breached both the express terms of the Distribution Agreement and the covenant of good faith and fair dealing implied in that agreement as a matter of law As a result of Counterclaim Defendant Vignerons aforesaid breaches of contract and the covenant of good faith and fair dealing, Counterclaim Plaintiff has suffered damages in an amount not less than $2,212,272. SECOND COUNTERCLAIM Against Counterclaim Defendant Vignerons (Account Stated; Counterclaim Plaintiff s Right of Setoff) 112. Counterclaim Plaintiff repeats and realleges each allegation set forth in Paragraphs 76 through 108, above On or about August 15, 2013, Counterclaim Plaintiff and Counterclaim Defendant Vignerons jointly agreed upon a statement of account, liquidating amounts owed to and by Counterclaim Plaintiff, including all offsets and adjustments, as follows: Page 26 of 29

27 Party Owing Money For Amount Owed Counterclaim Plaintiff Unpaid Invoices $649, Counterclaim Defendant Vignerons Counterclaim Defendant Vignerons Promotional billbacks ($236,065.16) Inventory Buyback ($64,376.88) Counterclaim Defendant Vignerons Storage fees (through Nov. 30, 2013 ($3,758.00) Counterclaim Defendant Vignerons Separation Fee ($200,000.00) Net Owed to Counterclaim Defendant Vignerons $145, Counterclaim Defendant Vignerons has failed to honor said statement of account, and is foreclosed from obtaining a money judgment in excess of that set forth in the chart in Paragraph 113, above Counterclaim Plaintiff has a right to set off against any amounts owed to Counterclaim Defendant Vignerons, amounts not less than those indicated in the chart in Paragraph 113, above. THIRD COUNTERCLAIM Against Additional Defendants on Counterclaim Richard J. Genova, Vintage Epicure LLC, Lizz Mejia, and Beverage Group International, LLC d/b/a Val d Orbieu Americas, USA (Tortious Interference with Contractual and Business Relations) 116. Counterclaim Plaintiff repeats and realleges each allegation set forth in Paragraphs 76 through 108, above Additional Defendants on Counterclaim induced said breach(es) by Counterclaim Defendant Vignerons for the purpose of causing Counterclaim Defendant Vignerons to remove Counterclaim Plaintiff as sole U.S. importer of Counterclaim Defendant Vignerons brands into the United States, and causing Additional Defendants Page 27 of 29

28 on Counterclaim to replace Counterclaim Plaintiff in that capacity, and for no proper purpose By means of Additional Defendants on Counterclaim s tortious interference with contractual and business relations between Counterclaim Plaintiff and Counterclaim Defendant Vignerons, Counterclaim Defendant Vignerons was induced to terminate the Distribution Agreement wrongfully, and to enter into a new agreement with Additional Defendants on Counterclaim to act as the U.S. importer of Counterclaim Defendant Vignerons brands of wine into the United States, in place of Counterclaim Plaintiff As a result of Counterclaim Defendant Vignerons aforesaid breaches of contract and the covenant of good faith and fair dealing, and Additional Defendants on Counterclaim s tortious interference with contractual and business relations between Counterclaim Plaintiff and Counterclaim Defendant Vignerons, Counterclaim Plaintiff has suffered damages in an amount not less than $2,212, By the acts stated above, Additional Defendants on Counterclaim have also intentionally and/or recklessly damaged the commercial reputation of Counterclaim Plaintiff in various ways, including but not limited to, by falsely stating or implying that Counterclaim Plaintiff was in breach of the Distribution Agreement, or was an unworthy importer. WHEREFORE: RELIEF REQUESTED ON PLAINTIFF S CLAIMS Dismissal of Claims (a) Defendants respectfully request judgment dismissing Plaintiff s claims in their entirety, together with interest, plus the costs, disbursements, and attorneys fees of this action; and Additional Available Relief (b) such other and further relief as this Court may deem just and proper; and Page 28 of 29

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