Berkadia Real Estate Advisors LLC v. Wadlund

District Court, D. Arizona·Decided June 10, 2024·No. 4:22-cv-00049·Unknown

Opinion

1 WO 2 3 4 5

9 Berkadia Real Estate Advisors LLC, No. CV-22-00049-TUC-CKJ

10 Plaintiff, ORDER

11 v.

12 Arthur R Wadlund, et al.,

13 Defendants. 14 Arthur R Wadlund, et al.,

15 Plaintiffs,

16 v.

17 Berkadia Real Estate Advisors LLC,

18 Defendant.

20 The following has been disclosed to the Court: “Plaintiff, Berkadia Real Estate 21 Advisors LLC, a private non-governmental party, . . . is an indirect subsidiary of Berkshire 22 Hathaway, Inc. (Berkshire) and Jefferies Financial Group Inc., both of which are publicly- 23 traded companies,” (Corporate Disclosure (Doc. 6) at 2), Berkshire is a “parent 24 corporation” of Berkadia for recusal purposes (Supp. Rule 26(f) Report (Doc. 70) at 2), 25 and was more recently described as “a 50/50 joint venture between Berkshire and Jefferies 26 Financial Group, Inc. (“Jeffries”),” (Ds Resp. P MPSJ, SOF ¶ 1 (Doc. 244-1) at 2). Based 27 on this last disclosure the Court asked for additional information to enable it to determine 28 whether Berkshire has a controlling interest in Berkadia because the Court holds stock in 1 Berkshire. (Order (Doc. 262)). 2 As noted by Plaintiff: “Any justice, judge, or magistrate judge of the United States 3 shall disqualify [herself] in any proceeding in which [her] impartiality might reasonably be 4 questioned.” 28 U.S.C. § 455(a). 28 U.S.C.A. § 455 (West) A judge “shall also disqualify 5 [herself]” if the judge “knows that [she], individually or as a fiduciary, . . . , has a financial 6 interest in the subject matter in controversy or in a party to the proceeding, or any other 7 interest that could be substantially affected by the outcome of the proceeding.” 28 U.S.C. 8 § 455(b)(4) (emphasis added to relevant part). “‘[F]inancial interest” means ownership of 9 a legal or equitable interest, however small.” 28 U.S.C. § 455(d)(4). 10 “No justice, judge, or magistrate judge shall accept from the parties to the 11 proceeding a waiver of any ground for disqualification enumerated in subsection (b),” 12 which includes disqualification based on a financial interest. “Where the ground for 13 disqualification arises only under subsection (a), waiver may be accepted provided it is 14 preceded by a full disclosure on the record of the basis for disqualification.” 28 U.S.C. § 15 455(e). 16 February 2024, the Committee of Codes of Conduct issued Advisory Opinion 57 17 for Cannon 3(C)(1)(c) of the Code of Conduct for United States Judges, which tracks the 18 rules set forth in 28 U.S.C. § 455. 19 Advisory Opinion 57 provides that “[i]f a parent corporation owns all or a majority 20 of stock in a subsidiary that is a party, the Committee advises that a judge who owns stock 21 in the parent then has a financial interest in the subsidiary, requiring recusal.” The issue is 22 less clear where the parent holds less than a majority interest—then, the owner of stock in 23 a parent corporation has a financial interest in a subsidiary that the parent controls. “When 24 a corporation does not own all or a majority of stock in a party, the judge should determine 25 whether the corporation has control of the party, and a presumption of control arises with 26 the 10% disclosure requirement in the Federal Rules. Fed. R. Civ. P. Rule 7.1. “Whether 27 that presumption may be rebutted or not depends on other indicia of control, such as board 28 representation or wide dispersion of the remainder of the stock, which are relevant to the 1 influence wielded by a 10% interest. . . .When a judge concludes that a party is controlled 2 by a corporation in which the judge owns stock, the judge must recuse.” (P Brief (Doc. 3 263) at 5-6 (quoting Advisory Opinion 57)). 4 Rule 7.1, Fed. R. Civ. P., requires parties to disclose any publicly held corporation 5 owning 10% or more of its stock. Drawn from Rule 26.1 of the Fed. R. App. P., it functions 6 “to assist judges in making a determination of whether they have any interests in any of a 7 party's related corporate entities that would disqualify the judges from hearing the appeal.” 8 Donoff v. Delta Air Lines, Inc., No. 18-81258-CV, 2020 WL 3268500, at *2 (Fla. Feb. 4, 9 2020) (quoting Advisory Committee Notes to Rule 26.1). As previous explained to the 10 parties, the Defendants’ Response to Plaintiff’s Motion for Partial Summary Judgment 11 reflected the “more than 10 %” benchmark exists in this case and prompted the Court’s 12 inquiry into whether Berkshire has a controlling interest in Berkadia for the purpose of 13 considering whether recusal is mandatory under 28 U.S.C. § 455(b)(4). 14 In response to the Court’s inquiry, the Plaintiff explains that “Berkadia is a 15 subsidiary of Berkshire. Berkshire, through other wholly-owned intermediate companies, 16 ultimately owns 50% of Berkadia,” (P Brief (Doc. 263) at 2), with the following ownership 17 structure: 1) Berkshire owns BH Columbia Inc.; 2) BH Columbia Inc. owns Columbia 18 Insurance Company; 3) Columbia Insurance Company owns 50% of Berkadia Commercial 19 Mortgage Holding LLC; 4) the other 50% of Berkadia Commercial Mortgage Holding LLC 20 is owned by LUK Servicing, which is owned by Jefferies US Holding LLC, which is in 21 turn owned by Jefferies Financial Group Inc. Id. at 4-5. 22 “Berkshire appoints two of [Berkadia’s] Managers and Jefferies appoints the other 23 two Managers. The Board of Managers confers authority on officers who control 24 Berkadia’s day-to-day business activities. As an equally owned joint venture, there is no 25 mechanism for making decisions where Berkshire and Jefferies do not agree on a single 26 course of action.” Id. at 6. 27 Plaintiff did not provide information regarding Berkshire’s overall portfolio but the 28 Court’s review of public documents reflects approximately 70 sub-companies, none of 1 which includes Berkadia. Berkshire Hathaway Inc., berkshirehathaway.com/subs/sublinks. 2 html. Reportedly, the top stocks owned by Berkshire include Apple ($1.49.9 billion); Bank 3 of America ($40.6 billion); American Express ($36.8 billion); Coca-Cola ($25.2 billion); 4 Chevron ($20 billion) Occidental Petroleum ($15.7 billion); Kraft Heinz ($11.7 billion); 5 Moody’s ($ 10.2 billion); Mitsubishi ($7.8 billion), and Chubb ($7.1 billion). The Motley 6 Fool, https://www.fool.com/investing/how-to-invest/famous-investors/warren-buffett- 7 investments/stocks-owned/. It has a net worth of $885.45 billion as of June 6, 2024. Stock 8 Analysis, https://stockanalysis.com/stocks/brk.b/market-cap/. 9 Plaintiff provided a copy of the Court’s financial disclosures for January 1, 2021 10 through December 31, 2021, which reflect she has no interest in Berkshire. This is because 11 the Court acquired stock in Berkshire on June 28, 2022. The purchase was made as part of 12 a routine portfolio transaction and not requested by the Court. The Court made this and its 13 full financial disclosures for 2022 in May 2023. The Berkshire stock makes up 14 approximately 2 percent of the Court’s financial investments. The key inquiry, however, is 15 not the size of the Court’s financial interest, but the size of the impact on that interest. 16 (Advisory Opinion 69.) Berkshire is not a party to this proceeding, and the impact of this 17 proceeding will be on Berkadia, not Berkshire.

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Berkadia Real Estate Advisors LLC v. Wadlund, (D. Ariz. 2024).

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