AJ Ruiz Consultoria Empresarial S.A. v. Colorado Investment Holdings, LLC

CourtUnited States Bankruptcy Court, S.D. Florida.
DecidedSeptember 25, 2025
Docket23-01118
StatusUnknown

This text of AJ Ruiz Consultoria Empresarial S.A. v. Colorado Investment Holdings, LLC (AJ Ruiz Consultoria Empresarial S.A. v. Colorado Investment Holdings, LLC) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, S.D. Florida. primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
AJ Ruiz Consultoria Empresarial S.A. v. Colorado Investment Holdings, LLC, (Fla. 2025).

Opinion

ey * AO OS aR’ if * □ iD 8 Ss 74 □□□ a Ways A swillikg & \ om Ai eb Sa pisruct OF oe ORDERED in the Southern District of Florida on September 25, 2025.

Mindy A. Mora, Judge United States Bankruptcy Court

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA In re: Case No.: 23-11719-MAM Tinto Holding Ltda., Chapter 15 Debtor. / Deloitte Touche Tohmatsu Consultores Adv. Proc. No.: 23-01118-MAM Ltda. and AJ Ruiz Consultoria Empresarial S.A., Plaintiffs,

Colorado Investment Holdings, LLC, J&F Investimentos $.A., JJMB Participacées Ltda., WWMB Participacées Ltda., Joesley Mendonca Batista, Wesley Mendonga Batista, and JBS, S.A., Defendants. / MEMORANDUM OPINION AND ORDER DISMISSING ADVERSARY PROCEEDING This proceeding perhaps should not have been filed, but it was. Over the course

of almost two years, the Court has given the plaintiff, AJ Ruiz Consultoria Empresarial S.A., every benefit of the doubt, providing access to justice and comity to a foreign representative. Even so, the procedural obstacles are too great and the

due process concerns too significant. Equity plays a role, but the true stumbling block here is lack of connection: lack of assets within the United States, lack of purposeful connection to the selected forum, and lack of necessary parties. Too many essential requirements are missing to justify retention of this adversary proceeding in this Court. BACKGROUND

I. Parties and Claims

This proceeding involves events that transpired mostly in Brazil. AJ Ruiz acts on behalf of Tinto, a Brazilian-based entity.1 All defendants2 except one are Brazilian nationals or Brazilian-based entities. The lone U.S.-based party is defendant Colorado Investment Holdings, LLC, a Delaware business entity. No entity has a principal place of business within the Southern District of Florida. The case involves no U.S. individuals. This chart summarizes the parties’ identities and nationalities: Full Name Short Nationality and Name Identity AJ Ruiz AJ Ruiz Brazilian judicial Consultoria administrator and Empresarial S.A.

1 The Court will describe the plaintiff as Tinto in the balance of this opinion for ease of reference. 2 To avoid confusion with the defined term “Brazilian Defendants”, this Opinion refers to all defendants collectively by the uncapitalized term “defendants” and avoids use of a capital “D” for individual defendants. foreign representative of Tinto Tinto Holding Ltda. Tinto Brazilian agribusiness holding entity J&F Investimentos, J&F Brazilian business S.A. entity JJMB Participações JJMB Brazilian business Ltda. entity WWMB WWMB Brazilian business Participações Ltda. entity Joesley Mendonça Joesley3 Brazilian individual Batista Wesley Mendonça Wesley Brazilian individual Batista JBS, S.A. JBS Brazilian business entity Colorado CIH Delaware entity Investment Holdings LLC

J&F, JJMB, WWMB, Joesley, and Wesley form the litigation group identified in this proceeding as the “Brazilian Defendants”.4 Joesley and Wesley are members of a Brazilian family (the Batista family) that owns interests in J&F, JJMB, WWMB, and CIH. Those entities in turn hold interests in entities that, through a network of other business entities, own a percentage of interests in JBS (another defendant in this proceeding).5 None of the defendants directly holds 100% of the interests in JBS. Tinto asserts a total of 7 claims. This chart summarizes the claims, the source of law, and defendants for each claim:

3 The use of given names is for efficiency and parallels the nomenclature the parties adopted in their filings. No disrespect is intended. 4 The Brazilian Defendants shared counsel, while JBS and CIH retained their own counsel. All defendants pursued the same litigation strategy, with each defendant incorporating by reference pleadings filed by other defendants. 5 Second Am. Compl., ECF No. 190 at ¶ 69, pdf p. 23 (Tinto’s diagram of alleged corporate structure). Claim Description Source of Law Defendants 1 Unjust Enrichment NY state All except JBS 2 Aiding and Abetting Breach of NY state All except JBS Fiduciary Duty 3 Action to Declare Absolute Brazil Joesley Nullity of a Transaction Wesley CIH 4 Action to Declare Void Brazil Joesley Transaction Wesley CIH 5 Transfer of Establishment Brazil All except JBS 6 Piercing of the Corporate Veil Brazil All 7 Compensation for the Damages Brazil All except JBS Caused by the Illicit Acts

As is immediately apparent from a review of the two charts, Tinto primarily asserts claims under Brazilian law against Brazilian defendants, with the notable exception of CIH. Synthesizing the two charts into one emphasizes this aspect. Claim Source Defendants’ of Law Nationality 1 NY state Brazil (except CIH) 2 NY state Brazil (except CIH) 3 Brazil Brazil (except CIH) 4 Brazil Brazil (except CIH) 5 Brazil Brazil (except CIH) 6 Brazil Brazil (except CIH) 7 Brazil Brazil (except CIH)

Another simple way to view the landscape is that CIH serves as the “anchor defendant” for all claims asserted in this United States bankruptcy court. There are no bankruptcy-specific claims, no federal question claims, and no claims under local state (Florida) law. A $1,500 retainer held by a Miami law firm provides the only notable link to this federal geographic district.6 II. Additional Background

The full story that AJ Ruiz asserts on behalf of Tinto is complicated, and the Court does not attempt a detailed retelling here. The Court accepts all allegations in the Second Amended Complaint (ECF No. 190) (“Complaint”) as true and summarizes only the most salient details. Tinto is an insolvent Brazilian entity. Tinto contends that a series of share- transfer agreements involving some of the defendants contributed to Tinto’s financial

decline. A brief recap of the share-transfer agreements’ history follows. Over fifteen years ago, JBS and another Brazilian entity, Bertin S.A. (not a party to this proceeding), announced their intent to merge.7 To facilitate the merger, JBS and Bertin S.A. entered into a series of agreements that redistributed ownership interests in other Brazilian business entities. Recounting the story becomes more complicated at this point because Tinto alleges that the “true” merger process was not the one documented in public filings,

and that the actual terms of the “true” merger remain unknown. What is known is that Tinto executed a third share-transfer agreement with J&F and JBS in Brazil

6 The Court previously granted recognition of Tinto’s Brazilian insolvency proceeding as a foreign main proceeding. ECF No. 8 in Case No. 23-11719; see generally Al Zawawi v. Diss (In re Al Zawawi), 97 F.4th 1244 (11th Cir. 2024) (holding that debtor eligibility under 11 U.S.C. § 109 is not a prerequisite for recognition of a foreign proceeding). 7 Second Am. Compl. (hereinafter abbreviated as “Compl.”, consistent with use of the defined term “Complaint” in the Opinion text), ECF No. 190 at ¶ 30, pdf p. 10. over ten years ago, and that Joesley and Wesley acted as guarantors for that transaction.8 Seven months later, the same parties revised their prior agreement, resulting in the “Revised Third Share-Transfer Agreement” (RTSA). The RTSA

produced a revised percentage of holdings in various entities.9 All share-transfer agreements, including the RTSA, were executed in Brazil.10 The hidden purpose of the RTSA, according to the Complaint, was to provide the Batista family with a windfall acquisition of undervalued assets in the form of ownership interests in Bertin S.A. This transfer allegedly strengthened business ties between the Batistas and the Bertins (another Brazilian family, none of whom are

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AJ Ruiz Consultoria Empresarial S.A. v. Colorado Investment Holdings, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aj-ruiz-consultoria-empresarial-sa-v-colorado-investment-holdings-llc-flsb-2025.