American National Holding Corporation v. Emm Credit, LLC

CourtCourt of Appeals of Georgia
DecidedJuly 16, 2013
DocketA13A0166
StatusPublished

This text of American National Holding Corporation v. Emm Credit, LLC (American National Holding Corporation v. Emm Credit, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American National Holding Corporation v. Emm Credit, LLC, (Ga. Ct. App. 2013).

Opinion

FIRST DIVISION PHIPPS, C. J., ELLINGTON, P. J., and BRANCH, J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules/

July 16, 2013

In the Court of Appeals of Georgia A13A0166. AMERICAN NATIONAL HOLDING CORPORATION v. EMM CREDIT, LLC.

PHIPPS, Chief Judge.

In this interlocutory appeal, American National Holding, Inc. challenges

various pretrial rulings: (i) the denial of its motion for summary judgment on a

fraudulent transfer claim asserted against it; (ii) rulings resulting in a party

substitution; and (iii) the denial of its motion to preclude admission of certain

evidence at trial. For reasons discussed below, the summary judgment ruling is

reversed, the substitution rulings are affirmed, the evidentiary ruling is vacated, and

the case is remanded for proceedings not inconsistent with this opinion.

This litigation was commenced on November 14, 2003 by a California

company, NCOM, Inc. f/k/a Newcom, Inc. In its complaint, as amended, NCOM

alleged that one of its former directors, Alexander Remington, had entered into a plea agreement in September 2002, wherein he pled guilty in a federal court in California

to embezzling a specified sum of money from NCOM from 1996 through early 1999;

that in 2006, it (NCOM) had obtained in that court a monetary judgment (hereinafter

the “California Judgment”) for that amount against Remington, jointly and severally

with his domestic partner and a Georgia company (Micro Equipment Corporation) of

which Remington owned 95 percent of the stock.

NCOM sought in this litigation to recoup monies owed it under the California

Judgment. NCOM named as defendants Remington and several associated persons

and entities, including American National Holding Corporation. NCOM alleged that

Remington had used the embezzled funds to purchase real and personal properties,

which he then fraudulently transferred to the named persons and entities in order to

avoid collection upon the California Judgment. During the course of the litigation, as

we discuss below,1 EMM Credit, LLC was substituted for NCOM. Then, on the eve

of trial, American National was granted this interlocutory appeal, in which it

challenges various rulings.2

1 See Division 2, infra. 2 See OCGA § 5-6-34 (d) (pertinently providing that, on interlocutory appeal, “all judgments, rulings, or orders rendered in the case which are raised on appeal and which may affect the proceedings below shall be reviewed and determined by the

2 1. American National contends that the trial court erred in denying its motion

for summary judgment on a fraudulent transfer claim asserted against it, maintaining

that the claim is time-barred.

Specifically, EMM Credit sought to set aside a deed wherein Remington

transferred to American National certain real property located in Gwinnett County,

Georgia. Evidence showed that Remington purchased the property on April 18, 1996,

and that same day, transferred it to American National. That company had been

formed several years earlier with only Remington’s domestic partner and

Remington’s two brothers as its stockholders.

In its motion for summary judgment, American National argued that the filing

of the fraudulent transfer claim on November 14, 2003 was untimely. But the trial

court determined that genuine issues of material fact remained for a jury.

appellate court, without regard to the appealability of the judgment, ruling, or order standing alone”). Cf. Zekser v. Zekser, ___ Ga. ___ (2) (___ SE2d ____) (2013) (Case No. S13F0408, decided June 17, 2013) (holding that, in discretionary appeals, review is “limited to the errors actually enumerated in the application”).

3 The Uniform Fraudulent Transfer Act,3 governing this claim,4 sets forth the

applicable limitation period.5 The Act provides that a cause of action with respect to

a fraudulent transfer is extinguished unless brought “within four years after the

transfer was made or the obligation was incurred or, if later, within one year after the

transfer or obligation was or could reasonably have been discovered by the

claimant.”6

EMM Credit counters that a jury should be allowed to determine whether its

claim was extinguished under the Act. It sets forth in its brief that its corporate

representative stands

prepared to testify that he did not discover and should not have discovered the fraudulent transfer before November 14, 2002 [which was one year before the action was filed]. When [the representative] first

3 OCGA § 18-2-70 et seq. 4 Indeed, the complaint as amended alleged that Remington’s transfer of the property to “insider” American National violated OCGA § 18-2-74. ) See OCGA § 18-2-71 (7) (defining “insider” for purposes of the Uniform Fraudulent Transfers Act). 5 See Huggins v. Powell, 315 Ga. App. 599, 601-602 (1) (726 SE2d 730) (2012) (explaining that there is no vested right in a statute of limitation and that statutes addressing procedural and remedial rights such as statutes of limitation may be retroactively applied). 6 OCGA § 18-2-79 (1).

4 learned of the September 4, 2002 indictment of Remington, he was on the board of NCOM in California. As part of his responsibilities in that position, he began to investigate the facts as they came to light in the indictment and plea agreement. He also began to investigate the finances of Mr. Remington in order to identify what happened to the funds Remington had embezzled from NCOM and identify ways to reclaim those funds. His investigation ultimately led to the decision to file suit in the Central District Court of California on February 26, 2003. Even as of the date of filing of [that] suit, [the representative] had not learned of the involvement of [American National] in Mr. Remington’s affairs. Indeed, [American National] was not a defendant in the California federal suit. . . As [the representative] continued his investigation of Remington, he examined the Secretary of State and real estate records in Georgia. Later in 2003, [the representative] did discover the transfer of the subject property in Norcross, Georgia from Remington to [American National] and discovered Remington’s interest in [American National], and EMM then filed its Complaint less than one year after that date. For that reason, [the] statute of limitations defense will not succeed at trial.

Notwithstanding, the question presented to the trial court was whether, on

motion for summary judgment, the statute of limitation defense was meritorious.

[T]o prevail on a motion for summary judgment, the moving party must demonstrate that there is no genuine issue of material fact, so that the party is entitled to judgment as a matter of law. A defendant may do this by either presenting evidence negating an essential element of the plaintiff’s claims or establishing from the record an absence of evidence

5 to support such claims.

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American National Holding Corporation v. Emm Credit, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-national-holding-corporation-v-emm-credit-llc-gactapp-2013.