Reply Affirmation of Erica B. Garay, Esq. dated December 4, 2003.

Similar documents
SUPREME COURT - STATE OF NEW YORK IAS TERM PART 12 NASSAU COUNTY

- STATE OF NEW YORK IAS TERM PART 23 NASSAU COUNTY -- ORDER

Legnetti v Camp America 2011 NY Slip Op 33754(U) December 21, 2011 Sup Ct, Nassau County Docket Number: 1113/09 Judge: Antonio I.

IAS TERM, PART 28 NASSAU COUNTY

PRESENT: HONORABLE LEONARD B. AUSTIN Justice Motion R/D: Submission Date:

SUPREME COURT - STATE OF NEW YORK IAS TERM PART 14 NASSAU COUNTY

SUPREME COURT - STATE OF NEW YORK IAS TERM PART 12 NASSAU COUNTY

NEW YORK SUPREME COURT - QUEENS COUNTY

IAS Part 54. IAS Part 54. WHEREAS, The Leon Waldman Discretionary Trust (the "Trust"), as plaintiff,

NEW YORK SUPREME COURT - QUEENS COUNTY. x Index No /2008 OPTION ONE MORTGAGE CORPORATION. x Motion Seq. No. 1

Vasomedical, Inc. v Barron NY Slip Op 51015(U) Decided on June 30, Supreme Court, Nassau County. Destefano, J.

IAS TERM, PART 28 NASSAU COUNTY

Devlin v Mendes & Mount, LLP 2011 NY Slip Op 33823(U) July 1, 2011 Sup Ct, Queens County Docket Number: 31433/10 Judge: Denis J. Butler Cases posted

Present: HON. UTE WOLFF LALLY, Justice TRIAL/IAS, PART 17 NASSAU COUNTY SLENDER DELIGHT, INC. d/b/a S.D. Brands, Plaintiff(s), Defendant(s).

Abroon v Gurwin Home Care Agency, Inc NY Slip Op 31534(U) May 30, 2012 Supreme Court, Nassau County Docket Number: 22249/10 Judge: Roy S.

Robinson Brog Leinwand Greene Genovese & Gluck, P.C. v Basch 2017 NY Slip Op 30166(U) January 26, 2017 Supreme Court, New York County Docket Number:

Simpson v Alter 2011 NY Slip Op 31765(U) June 21, 2011 Supreme Court, Nassau County Docket Number: 11095/09 Judge: Thomas P. Phelan Republished from

Savings Deposit Ins. Fund of Turkey v SeaRock Holdings LLC 2019 NY Slip Op 30167(U) January 14, 2019 Supreme Court, New York Court Docket Number:

SUPREME COURT - STATE OF NEW YORK IAS TERM PART 16 NASSAU COUNTY. Justice LEONARD B. AUSTIN NO APPEARANCE ORDER

U.S. Bank, N.A. v Campbell 2015 NY Slip Op 30390(U) March 16, 2015 Supreme Court, Queens County Docket Number: 11601/2012 Judge: Robert J.

SUPREME COURT - STATE OF NEW YORK IAS TERM PART 14 NASSAU COUNTY

Pokuaa v Wellington Leasing Ltd. Partnership 2011 NY Slip Op 31580(U) June 2, 2011 Supreme Court, Queens County Docket Number: 9725/09 Judge: Howard

Matter of Verizon New England, Inc. v IDT Domestic Telecom, Inc NY Slip Op 32387(U) September 1, 2010 Supreme Court, New York County Docket

Sethi v Singh 2011 NY Slip Op 33814(U) July 18, 2011 Sup Ct, Queens County Docket Number: 4958/11 Judge: Howard G. Lane Cases posted with a "30000"

FILED: NEW YORK COUNTY CLERK 04/11/ :48 PM INDEX NO /2013 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 04/11/2017

Matter of Demetriou (Aliano) 2016 NY Slip Op 32031(U) June 29, 2016 Surrogate's Court, Nassau County Docket Number: C Judge: Margaret C.

Cohan v Movtady 2012 NY Slip Op 33256(U) January 24, 2012 Sup Ct, New York County Docket Number: 2845/11 Judge: Denise L. Sher Cases posted with a

Upon the following papers read on Defendant s motion seeking dismissal of the complaint:

Concepcion v JetBlue Airways Corp NY Slip Op 30474(U) March 30, 2015 Sup Ct, Queens County Docket Number: /2014 Judge: Robert J.

SUPREME COURT - STATE OF NEW YORK IAS TERM PART 18 NASSAU COUNTY. Justice LEONARD B. AUSTIN ORDER

SCQ'( Defendants. Plaintiff PRESENT: Motion RID: Submission Date: 10- Motion Sequence No. : 001/MOTD. - against - ORDER

Cadles of Grassy Meadow II, L.L.C. v Lapidus 2011 NY Slip Op 34159(U) October 5, 2011 Supreme Court, New York County Docket Number: /06 Judge:

Caeser v Harlem USA Stores, Inc NY Slip Op 30722(U) April 18, 2016 Supreme Court, New York County Docket Number: /2013 Judge: Anil C.

U.S. Bank Natl. Assn. v Bethelmie 2012 NY Slip Op 31773(U) June 29, 2012 Supreme Court, Queens County Docket Number: 15315/2009 Judge: Robert J.

Matter of Aoki 2016 NY Slip Op 31898(U) October 13, 2016 Surrogate's Court, New York County Docket Number: /E Judge: Rita M.

FILED: NEW YORK COUNTY CLERK 06/05/ :08 PM INDEX NO /2017 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/05/2017

FILED: NEW YORK COUNTY CLERK 07/06/ :19 PM INDEX NO /2017 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 07/06/2017

The following papers were read on Plaintiff s motion for summary judgment or alternatively to strike Defendants answer:

Upon the following papers read on Plaintiffs motion seeking leave to amend the complaint:

Lapsley-Cockett v Metropolitan Tr. Auth NY Slip Op 32550(U) September 29, 2014 Supreme Court, New York County Docket Number: /13 Judge:

FILED: NEW YORK COUNTY CLERK 09/15/ :14 PM INDEX NO /2014 NYSCEF DOC. NO. 67 RECEIVED NYSCEF: 09/15/2015

SUPREME COURT - ST ATE OF NEW YORK IAS TERM PART 12 NASSAU COUNTY. The following papers were read on Plaintiffs motion for summary

Upon reading and filing the affirmation of Lawrence E. Tofel, sworn to on the 5th

All other terms and conditions of the order dated July 11, 20J2 (a copy of which

Matter of Bethpage Fed. Credit Union v John 2011 NY Slip Op 31652(U) April 19, 2011 Supreme Court, Nassau County Docket Number: 20089/10 Judge:

Jobar Holding Corp. v Halio 2018 NY Slip Op 31982(U) August 14, 2018 Supreme Court, New York County Docket Number: /2017 Judge: Saliann

Drafting New York Civil-Ligation Documents: Part XXXI Subpoenas Continued

Dupiton v New York City Tr. Auth NY Slip Op 33234(U) November 26, 2018 Supreme Court, Queens County Docket Number: /2016 Judge: Ernest F.

SUPREME COURT-STATE OF NEW YORK

Bank of Am., N.A. v Sigo Mfr. L.L.C NY Slip Op 33538(U) January 12, 2011 Supreme Court, Albany County Docket Number: 7002/10 Judge: Joseph C.

At Part of the Supreme Court of the. of New York, at the Courthouse thereof, 60 PLAINTIFF, DEFENDANTS.

SUPREME COURT - STATE OF NEW YORK IAS TERM PART 23 NASSAU COUNTY ORDER

Plaintiffs motion for summary judgment as to its claim of contractual indemnification. is granted in the amount of

Matter of RBC Capital Mkts. Corp. v Bittner 2011 NY Slip Op 31231(U) May 9, 2011 Supreme Court, New York County Docket Number: /2008 Judge:

SUPREME COURT - STATE OF NEW YORK. HON. STEPHEN A. BUCARIA Justice

Desai v Azran 2010 NY Slip Op 31421(U) June 2, 2010 Supreme Court, Nassau County Docket Number: 12629/09 Judge: Randy Sue Marber Republished from New

Spallone v Spallone 2014 NY Slip Op 32412(U) September 11, 2014 Sup Ct, NY County Docket Number: /2013 Judge: Eileen A. Rakower Cases posted

SUPREME COURT STATE OF NEW YORK COUNTY OF NASSAU. PRESENT: HON. IRA B. WARSHAWSKY, Justice. TRIAL/IAS PART 7

Indo-Med Commodities, Inc. v Wisell 2014 NY Slip Op 33918(U) September 29, 2014 Supreme Court, Nassau County Docket Number: /14 Judge: F.

Neiditch v William Penn Life Ins. Co. of N.Y NY Slip Op 32757(U) April 24, 2015 Supreme Court, Nassau County Docket Number: /14 Judge:

Suffolk County Natl. Bank v Michael K. Lennon, Inc NY Slip Op 30193(U) January 10, 2014 Sup Ct, Suffolk County Docket Number: Judge:

Gonzalez v Schlau 2011 NY Slip Op 31048(U) April 12, 2011 Supreme Court, Queens County Docket Number: 8960/2009 Judge: Robert J. McDonald Republished

SUPREME COURT - STATE OF NEW YORK IAS TERM PART 18 NASSAU COUNTY

On Both Motions Affidavit of Norman Goldstein in Opposition as to Individual Defendants and supporting papers;

Approval of Settlement, Provisional Certification of the Settlement Class, Appointment of

Plaintiff INDE)( NO (Action No. 02)

COUNTY OF NASSAU. PRESENT: HON. IRA B. WARSHAWSKY, Justice. TRIAL/IAS PART 20. Plaintiff, Defendants.

withdraw as attorney for Plaintiff and on the Order to Show Cause brought on by

Matter of Mallin 2017 NY Slip Op 31133(U) May 17, 2017 Surrogate's Court, Nassau County Docket Number: Judge: Margaret C.

Gonzalez v 80 W. 170 Realty LLC 2018 NY Slip Op 33414(U) November 20, 2018 Supreme Court, Bronx County Docket Number: /2013 Judge: Doris M.

Merchant Cash & Capital, LLC v G&E Asian Am. Enter., Inc NY Slip Op 31592(U) July 29, 2016 Supreme Court, Nassau County Docket Number:

Shipyard Quarters Marina, LLC v New Hampshire Ins. Co NY Slip Op 30903(U) May 17, 2016 Supreme Court, New York County Docket Number:

Curran v 201 West 87th St., L.P NY Slip Op 33145(U) September 26, 2014 Supreme Court, Queens County Docket Number: 20305/12 Judge: Howard G.

Ruda v Lee 2012 NY Slip Op 32855(U) November 26, 2012 Sup Ct, Queens County Docket Number: 21833/2011 Judge: Robert J. McDonald Republished from New

Louissaint v DePaolo 2010 NY Slip Op 33138(U) October 27, 2010 Supreme Court, Queens County Docket Number: 18997/07 Judge: Howard G.

American Express Bank, FSB v Katshihtis 2013 NY Slip Op 30473(U) February 19, 2013 Supreme Court, Queens County Docket Number: 9833/2011 Judge:

FILED: WESTCHESTER COUNTY CLERK 04/28/ :35 PM INDEX NO /2017 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/28/2017

Platinum Rapid Funding Group Ltd. v VIP Limousine Servs., Inc NY Slip Op 31591(U) June 8, 2016 Supreme Court, Nassau County Docket Number:

Shi v Shaolin Temple 2011 NY Slip Op 33821(U) July 1, 2011 Sup Ct, Queens County Docket Number: 20167/09 Judge: Denis J. Butler Cases posted with a

SUPREME COURT - STATE OF NEW YORK IAS TERM PART 16 NASSAU COUNTY. Justice LEONARD B. AUSTIN ORDER

SUPREME COURT - STATE OF NEW YORK IAS TERM PART 16 NASSAU COUNTY. Justice

Present: HON. UTE WOLFF LALLY, Justice TRIAL/IAS, PART 17 NASSAU COUNTY HERCULES CORP., Plaintiff(s), Defendant(s).

Rutnik & Corr CPA's P.C. v Guptill Farms, Inc NY Slip Op 33554(U) March 25, 2014 Supreme Court, Saratoga County Docket Number: Judge:

Plaintiff, Randall Latona, moves by order to show cause for. an order appointing a temporary receiver for the assets and

Concord Assoc., L.P. v EPT Concord, LLC 2012 NY Slip Op 33799(U) February 8, 2012 Supreme Court, Sullivan County Docket Number: Judge:

Deerin v Ocean Rich Foods, LLC 2015 NY Slip Op 32747(U) August 6, 2015 Supreme Court, Nassau County Docket Number: Judge: Timothy S.

Upon the following papers read on Plaintiffs Motion seeking summary judgment in lieu of complaint: MEMORANDUM DECISION

In this matrimonial proceeding, defendant-wife seeks to have the court use its civil

American Tr. Ins. Co. v Batista 2016 NY Slip Op 30003(U) January 4, 2016 Supreme Court, New York County Docket Number: /2015 Judge: Eileen A.

Battiste v Mathis 2012 NY Slip Op 31082(U) April 9, 2012 Supreme Court, Queens County Docket Number: 7588/11 Judge: Howard G. Lane Republished from

Table of Contents. Notice of Intervention and CPLR 5704 Motion Att. A - Original notice of Motion Order to Show Cause...

Altop v TNT Petroleum, Inc NY Slip Op 32262(U) August 2, 2012 Supreme Court, Nassau County Docket Number: 4612/12 Judge: Stephen A.

UPON READING AND FILING of the accompanying Affidavit of Charyn Powers,

Matter of Kuts (Communicar, Inc.) 2013 NY Slip Op 32524(U) August 16, 2013 Supreme Court, Queens County Docket Number: 5892/13 Judge: Augustus C.

Ormandy v Georgiou 2010 NY Slip Op 32564(U) September 13, 2010 Supreme Court, Queens County Docket Number: 10196/08 Judge: Howard G.

SUPREME COURT - NASSAU COUNTY IAS PART 14 PART MATRIMONIAL RULES & PROCEDURES (revised 05/23/17)

Matter of Agnes Vaccaro Trust 2018 NY Slip Op 32625(U) September 24, 2018 Surrogate's Court, Nassau County Docket Number: /A Judge: Margaret

People v Mancuso NY Slip Op 50153(U) Decided on July 13, City Court Of Buffalo. Devlin, J.

Barneli & Cie SA v Dutch Book Fund SPC, Ltd NY Slip Op 33379(U) February 10, 2012 Supreme Court, New York County Docket Number: /08

Complex Strategies, Inc. v AA Ultrasound, Inc NY Slip Op 32723(U) October 11, 2016 Supreme Court, Nassau County Docket Number: Judge:

Transcription:

SUPREME COURT - STATE OF NEW YORK IAS TERM PART 19 NASSAU COUNTY INDEX NO. 11990-03 PRESENT: HONORABLE LEONARD B. AUSTIN Justice Motion R/D: 11-28-03 Submission Date: 12-5-03 Motion Sequence No.: 002,003,004/ X MOT D HARBOR FOOTWEAR GROUP, LTD., Petitioner, COUNSEL FOR PETITIONER Meyer, Suozzi, English & Klein, P.C. 1505 Kellum Place - against - Mineola, New York 11501 ASA TRADING, INC. Respondent. x COUNSEL FOR RESPONDENT Blank, Rome, Cominsky & McCauley, LLP 405 Lexington Avenue New York, New York 10174-0208 ORDER The following papers were read on Respondent s motion to quash an Information Subpoena and Plaintiff s cross-motion to compel a response to the Information Subpoena and to appoint a receiver: Notice of Motion dated November 3, 2003; Affidavit of Leonard D. Steinman sworn to on November 3, 2003; Petitioner s Memorandum of Law; Order to Show Cause dated December 3,2003; Affirmation of Erica B. Garay, Esq. dated November 21, 2003; Respondent s Memorandum of Law; Petitioner s Reply Memorandum of Law; Reply Affirmation of Erica B. Garay, Esq. dated December 4, 2003. Respondent ASA Trading, Inc. moves to quash the Information Subpoena served on it by Petitioner. Petitioner Harbor Footwear Group, Ltd. cross-moves for the

appointment of a receiver, pursuant to CPLR 5228 and to compel a response to the information Subpoena. BACKGROUND In June 2001, Petitioner Harbor Footwear Group, Ltd. ( Harbor ) and. Respondent ASA Trading, Inc. ( ASA ) - a California corporation - entered into a licensing agreement granting ASA the right to sell apparel under a trademark owned by Harbor. Among other things, the licensing agreement provided that any disputes arising out of the contract shall be submitted to and settled by arbitration consented to the jurisdiction of the Supreme Court, Nassau County and that the parties (Agreement,7 13). When ASA subsequently failed to pay royalties in accordance with the licensing contract, Harbor commenced an arbitration proceeding. During the arbitration process, but before the award was issued, Harbor moved for and secured a temporary restraining order pursuant to CPLR 7502 (c)freezing certain ASA bank accounts on deposit at a California branch of the China Trust Bank which also has a branch in New York. The temporary restraining order was later vacated by a so-ordered stipulation dated September 11, 2003. Pursuant to the stipulation, ASA agreed that it would not transfer, withdraw or dissipate its assets except to the extent that funds were utilized for payment of expenses arising in the ordinary course of business (Stipulation, 72). 2

After prevailing in the arbitration proceeding, Harbor moved for and obtained, confirmation of the $474,890.41 award which Harbor then entered in New York and domesticated in the State of California. Subsequently, on November 3,2003, Harbor served an Information Subpoena and Restraining Notice on the China Trust Bank. Harbor was allegedly informed on November 7, 2003, that the account had been reduced from $250,000.00 to $1,OOO.OO. Moreover, Harbor claims that it ascertained from a third-party which did business with ASA, that ASA had recently switched its bank accounts from China Trust to the East West Bank. Harbor s attorney advises that, in response, its local California counsel has served has served a writ of execution on East West Bank. By order to show cause dated December application for the appointment of a receiver over 3,2003, Harbor brings on the instant ASA sassets pursuant to CPLR 5228. Harbor argues that ASA has demonstrated that it intends to move its assets around so as to avoid the purpose of the information subpoena and restraining notice * * *. DISCUSSION A. Receiver Upon motion by a judgment creditor, the court may appoint a receiver to manage or sell property in which the judgment debtor has an interest for the purpose of satisfying an outstanding judgment. CPLR 5228 (a). See, Chlopecki v. Chlopecki, 296 A.D. 2d 640, 641 (3rd Dept. 2001). Siegel, New York Practice 3rd 512 at 835-836; and 54 N.Y. Jur. 2d Enforcement of Judgments 276. Notably, CPLR 5228 (a) requires 3

that the order of appointment shall specify the property to be received. The remedy will be denied where there is no property of the judgment debtor which is properly amenable to a receivership. (See, Berman v. Goldstein, 254 App. Div. 629 [4th Dept. 19381. See also, Gantz v. T.R.C. Holdina Corp., 259 A-D. 2d 663 [2nd Dept. 19991; 9B Carmody-Wait 2d, Enforcement of Judgments $j 64:448), or where the appointment would be effectively futile. Cf., Ulmann v. Thomas, 255 N.Y. 506, 513 (1931). Significantly, in determining whether the appointment of a receiver constitutes a provident exercise of discretion, courts have considered the alternative remedies available to the creditor * * likelihood of satisfaction* * *; [and] (2) the degree to which receivership will increase the *. I Chlopecki v. Chlopecki, supra at 641, quoting from, United States v Zitron, 1990 WL 13278 (SDNY). It is settled that [t]he appointment of a receiver pursuant to CPLR 5228 (subd. [a]), is entirely a matter of discretion. Drucker v. Drucker, 53 Misc2d 446, 447 (Sup. Ct., Queens Co.1967); and 11 Weinstein-Korn- Miller, New York Civil Practice, q 5228.04. Here, ASA alleges in opposition to the motion that it is a California corporation and that it owns no real or personal property in the State of New York over which a receiver could or should properly exercise control. Moreover, Harbor has domesticated the judgment in California, commenced enforcement proceedings there and has already served a writ of execution in connection with the East West Bank account - the principal - if not sole source of ASA s assets identified in Harbor s moving papers. 4

It also bears noting that ASA s principal denies any attempt to secrete assets and asserts that the reduction of funds in the China Trust account occurred after vacatur of the August 4 restraining order and was attributable to legitimate expenses incurred and paid in the ordinary course of business. It further contends that although it did switch banks from China Trust to the East West Bank, the change was made for legitimate business reasons and that, in any event, [n]o funds were transferred from the China Trust account to East West Bank at any time.harbor has not filed reply papers disputing these factual assertions. Nor has it identified the specific property which it anticipates will be amenable to the receivership in New York or demonstrated why the remedy is necessary or appropriate in light of its enforcement efforts already undertaken in California; where the debtor and its property are actually located. Under these circumstances, and upon the papers submitted, Harbor has not met its burden of establishing entitlement to the appointment of a receiver in New York. B. Information Subpoena The Information Subpoena served by Petitioner, however, must be enforced. While the parties submit competing contentions with regard to the validity of service of the Information Subpoena on Respondent by personal service and certified mail in California and by service on New York counsel, the Court is satisfied that the service requirements of CPLR 5224 (a) (3) have been met. See, e.g., Aquavella v. Equvision, &., 181 Misc. 2d 322 (Sup. Ct. Monroe Co. 1999), app. dim., 270 A.D. 2d 972 (4th Dept. 2000).

Index No. II 990-03 It is noted that the Information Subpoena requires only written responses under oath; not a personal appearance to give testimony. Thus, it is distinguishable from Siemens & Halskae, GmbH v. Gres, 37 A.D. 2d 768 (I Dept. 1971); and Israel Discount Bank, Ltd. v. P.S. Products Corp., 65 Misc. 2d 1002 (Sup. Ct. N.Y. CO. 1971). In those cases, as relied upon by Respondent, the subpoenas in question sought to compel the personal appearance of a foreign judgment debtor. See, Banco do Estado de Sao Paolo S.A. v. Mendes Junior Int l Co., 218 NYLJ 1011, p. 29, col. 4 (Sup. Ct., N.Y. Co. 1 l/24/97), where Justice Ramos held that a subpoena served pursuant to CPLR 5224 (a) (3) was not covered by the language of Judiciary Law 2 - b which requires a subpoena to compel the attendance of a person to give testimony be served in the same manner as a summons. See also, CPLR 2303. Respondent s reliance on DeLeonardis v. Subway Sandwich Shops, Inc., (219 NYLJ 59, p. 28, col. 3 [Sup. Ct. N.Y. Co., 3/30/98]) is also misplaced. In DeLeonardis, Justice Tompkins adopted the logic and reasoning of Justice Ramos in Banco do E&ado Sao Paolo but felt compelled to apply the holdings of Siemens & Halskae and Israel Discount Bank and thus quash the subpoena before him. Here, ASA, by virtue of its agreement to arbitrate in Nassau County under the supervision of this Court and pursuant to the laws of New York, cannot properly claim that compliance with the Information Subpoena is improper. Accordingly, Respondent s motion to quash the Information Subpoena must be 6

denied and Petitioner s cross-motion to enforce it granted. Accordingly, it is, ORDERED, that the cross-motion of Petitioner Harbor Footwear Group, Ltd for the appointment of a receiver pursuant to CPLR 5228 is denied; and it is further, ORDERED, that Respondent s motion to quash the Information Subpoena dated October 21, 2003 is denied and Petitioner s cross-motion to compel a response thereto is granted; and it is further, ORDERED, that Respondent ASA Trading Inc. shall respond to said Information Subpoena within twenty (20) days of service of a copy of this Order with Notice of Entry. This constitutes the decision and order of the Co Dated: Mineola, NY January 20,2004 c &g&, Hon. LEONARD B. AUSTIN, J.S.C. EN%- 7