4588, LLC v. Lex Alexandria Holdings, LLC

CourtCourt of Appeals of Kentucky
DecidedMay 25, 2023
Docket2022 CA 000847
StatusUnknown

This text of 4588, LLC v. Lex Alexandria Holdings, LLC (4588, LLC v. Lex Alexandria Holdings, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
4588, LLC v. Lex Alexandria Holdings, LLC, (Ky. Ct. App. 2023).

Opinion

RENDERED: MAY 26, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2022-CA-0847-MR

4588, LLC APPELLANT

APPEAL FROM FAYETTE CIRCUIT COURT v. HONORABLE KIMBERLY N. BUNNELL, JUDGE ACTION NO. 22-CI-00045

LEX ALEXANDRIA HOLDINGS, LLC AND NATIONAL TITLE COMPANY APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; KAREM AND MCNEILL, JUDGES.

KAREM, JUDGE: 4588, LLC (“4588”) appeals from the Fayette Circuit Court’s

orders granting a declaration of rights, summary judgment, and attorney’s fees to

Lex Alexandria Holdings, LLC (“LAH”). At issue is whether the trial court

correctly determined that 4588 is required to pay earnest money as liquidated damages to LAH after terminating a real estate purchase contract. Upon careful

review, we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

On April 6, 2021, 4588 entered into a Purchase and Sale Agreement

(“the Agreement”) to buy the Crystal Garden Apartments (“the Property”), located

in Lexington, Kentucky, from LAH. The Agreement designated Matthew Snyder

as the broker for the sale and National Title Company (“NTC”) as the escrow

agent. The closing date was scheduled for July 5, 2021.

Under the terms of the Agreement, the sale price of the property was

$7.48 million. The Agreement required 4588 to deposit $50,000 with NTC as

Earnest Money to be credited against the purchase price of the Property upon the

closing of the transaction. If 4588 failed to complete the purchase or otherwise

defaulted on its obligations under the Agreement, LAH was entitled to receive the

Earnest Money as liquidated damages. 4588 did in fact deposit the $50,000

Earnest Money with NTC.

The Agreement provided 4588 with the right to conduct a due

diligence investigation of the Property until the Due Diligence Date of May 6,

2021.1 4588 was given until 5:00 p.m. on that date to:

1 The Agreement specified that the deadline was thirty days after the effective date, which was April 6, 2021, the date the Agreement was executed.

-2- (i) obtain and review a soil analysis of the Property; (ii) obtain and review reports, perform analyses, and otherwise inspect the Property related to the existence of Hazardous Substances . . . and compliance with Environmental laws; (iii) obtain and review such drawings, feasibility or market studies, site plans, construction or grading plans and specifications as Purchaser may commission; (iv) confirm that the Property is in a physical, mechanical and structural condition acceptable to Purchaser; (v) inspect the Property for building code violations; . . . (vii) perform such other inspections, tests or studies as Purchaser deems appropriate.

(Emphasis supplied.)

If at any time prior to 5:00 p.m. on that date 4588 was “not satisfied,

in its sole discretion” with the results of its investigation, it had the option of

delivering notice to LAH that it had decided not to purchase the Property and it

was thereafter “entitled to the immediate return of the Earnest Money.”

The Agreement further provided that it could be “amended, modified

or superseded only by a written instrument signed by all of the parties” and that

“[n]o party shall be deemed to have waived compliance by another party of any

provision of this Agreement unless such waiver is contained in a written

instrument signed by the waiving party[.]”

On May 14, 2021, after the Due Diligence Date had passed, Snyder,

4588’s property broker, emailed a Property Condition Assessment Report (“PCA

Report”) on the Property to Ed Babenco, a member of LAH. The report, which

-3- was dated May 6, 2021, was prepared by Criterium Engineers for Shlomi Fatal,

4588’s Construction Manager. It was based in part on a walk-through of the

Property performed on April 19-20, 2021. The Report stated that there were

numerous roof leaks and water entry issues at the Property, with water intrusion at

several of the units, roof leakage at the ceiling of at least one unit and mold on

walls within the units. LAH subsequently placed tarps over the areas of water

intrusion.

Upon the release of the PCA Report, LAH and 4588 negotiated a

reduction of the purchase price of the Property by $75,000 and an extension of the

closing date to September 6, 2021. These terms were memorialized in the First

Amendment to the Agreement, dated June 8, 2021. The First Amendment stated

that “[t]he Purchaser acknowledges that the Due Diligence Date in section 3.2.1 of

the Agreement has passed, and that the Purchaser has not terminated the

Agreement.” It further provided that “[e]xcept as amended herein, the Agreement

and all terms and provisions thereof remain in full force and effect.” Although it is

not expressly stated in the First Amendment, the parties do not dispute that the

price reduction and extension of the closing date were in exchange for 4588’s

acceptance of the Property in its “as-is” condition.

The Agreement was amended on two more occasions. On August 25,

2021, LAH and 4588 entered into a Second Amendment to the Agreement, in

-4- which 4588 agreed to deposit an additional $100,000 with NTC as additional

Earnest Money, bringing the total Earnest Money amount to $150,000. The

Second Amendment provided that:

the entire Earnest Money Deposit shall be applied to the Purchase Price at Closing, but shall be non-refundable to Purchaser and shall be released to Seller in the event Purchaser does not close on the purchase of the Property in accordance with the Agreement for any reason other than a default by Seller.

The Purchaser acknowledges that the Due Diligence Date in section 3.2.1. of the Agreement has passed, the financing contingency contained in section 3.3 of the Agreement has passed, the Financing Contingency Date and Extended Financing Contingency Date in section 3.3 of the Agreement have also passed and that Purchaser has not terminated the Agreement.

4588 did not, however, deposit the additional $100,000 with NTC.

On September 20, 2021, LAH and 4588 entered into a Third

Amendment to the Agreement. The Third Amendment ratified the First and

Second Amendments and extended the closing date to December 4, 2021. In

exchange for the extension of the closing date, 4588 agreed to deposit another

$100,000 as additional Earnest Money with NTC. 4588 did deposit the $100,000.

Under the terms of the Agreement and the three Amendments, the total Earnest

Money required was now $250,000, of which 4588 deposited a total of $150,000

with NTC. The Third Amendment contained identical language to the Second

Amendment regarding the passing of the Due Diligence Date.

-5- On October 5, 2021, approximately two months before the new

closing date, the Division of Code Enforcement of the Lexington-Fayette Urban

County Government issued a Notice of Violation for the Property, finding that it

required (1) electrical repair, (2) replacement of broken or missing face plates, (3)

carpet cleaning, (4) HVAC maintenance and repair, and (5) replacement of roof

covering that was leaking, rotted, worn, missing or otherwise deteriorated, and

repair and/or removal of plaster and drywall that was damaged or moldy.

4588 did not complete its purchase of the Property on December 4,

2021, the closing date specified in the Third Amendment. Two days later, LAH

received a letter from 4588 terminating the Agreement. The letter did not state a

reason for the termination.

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4588, LLC v. Lex Alexandria Holdings, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/4588-llc-v-lex-alexandria-holdings-llc-kyctapp-2023.