Bradshaw v. Maiden

2018 NCBC 44
CourtNorth Carolina Business Court
DecidedMay 9, 2018
Docket14-CVS-14445
StatusPublished

This text of 2018 NCBC 44 (Bradshaw v. Maiden) is published on Counsel Stack Legal Research, covering North Carolina Business Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bradshaw v. Maiden, 2018 NCBC 44 (N.C. Super. Ct. 2018).

Opinion

Bradshaw v. Maiden, 2018 NCBC 44.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION MECKLENBURG COUNTY 14 CVS 14445

JAMES W. BRADSHAW; CARLA O. BRADSHAW; RESORT RETAIL ASSOCIATES, INC.; E.C. BROADFOOT; CHRISTINA DUNN CHANDRA; THOMAS F. EGAN; CHARLES EGGERT; MARK P. GARSIDE; DR. JAMES J. GREEN, JR.; ROBERT K. GRUNEWALD; RONALD HOLMES; DAVID LAUCK; CURT W. LEMKAU, JR.; EVAN MIDDLETON; JOSHUA M. NELSON; CHRISTIAN C. NUGENT; REGINA H. PAKRADOONI, as Executrix of the Estate of PETER B. PAKRADOONI, deceased; FORD PERRY; MARCELLO G. PORCELLI; ADAN RENDON; RICHARD H. STEVENSON; PAUL STOKES; LAWRENCE J. THEIL; R. MITCHELL WICKHAM; WILLIAM ORDER AND OPINION ON H. WILLIAMSON, III; WILLIAM K. WRIGHT, JR.; ALEX M. WOLF; PLAINTIFFS’ MOTION FOR CHAFFIN FAMILY LIMITED SANCTIONS PARTNERSHIP; and SOLARIS CAPITAL LLC,

Plaintiffs,

v.

STEPHEN E. MAIDEN; MAIDEN CAPITAL, LLC; and SS&C TECHNOLOGIES, INC.; successor by merger to SS&C FUND ADMINISTRATION SERVICES, LLC (a/k/a SS&C FUND SERVICES),

Defendants.

SS&C TECHNOLOGIES, INC.; successor by merger to SS&C FUND ADMINISTRATION SERVICES, LLC, Third-Party Plaintiff, v.

MAIDEN CAPITAL OPPORTUNITY FUND, LP,

Third-Party Defendant.

1. THIS MATTER is before the Court upon Plaintiffs’ Motion for Sanctions

Against Defendant SS&C Technologies, Inc. Pursuant to N.C. R. Civ. P. 37 (the

“Motion”) in the above-captioned case. Having considered the Motion, the arguments

of counsel at the September 22, 2017 hearing on the Motion, and the briefs in support

of and in opposition to the Motion, the Court hereby GRANTS the Motion, ENTERS

the following FINDINGS OF FACT and CONCLUSIONS OF LAW, and ORDERS

as follows.

Lewis & Roberts, PLLC, by Gary V. Mauney and James A. Roberts, III, for Plaintiffs James W. Bradshaw, Carla O. Bradshaw, Resort Retail Associates, Inc., E.C. Broadfoot, Christina Dunn Chandra, Thomas F. Egan, Charles Eggert, Mark P. Garside, Dr. James J. Green, Jr., Robert K. Grunewald, Ronald Holmes, David Lauck, Curt W. Lemkau, Jr., Evan Middleton, Joshua M. Nelson, Christian C. Nugent, Regina H. Pakradooni, as Executrix of the Estate of Peter B. Pakradooni, deceased, Ford Perry, Marcello G. Porcelli, Adan Rendon, Richard H. Stevenson, Paul Stokes, Lawrence J. Theil, R. Mitchell Wickham, William H. Williamson, III, William K. Wright, Jr., Alex M. Wolf, Chaffin Family Limited Partnership, and Solaris Capital, LLC.

Alston & Bird, LLP, by Ryan P. Ethridge, Michael A. Kaeding, and Jessica P. Corley, for Defendant SS&C Technologies, Inc.

Bledsoe, Judge.

I.

FINDINGS OF FACT

2. The Court has previously discussed the claims and allegations involved in

this action in the Court’s Order and Opinion on SS&C’s Motion to Dismiss, reported at Bradshaw v. Maiden, 2015 NCBC LEXIS 80 (N.C. Super. Ct. Aug. 10, 2015) (the

“Motion to Dismiss Opinion”). This case arises from an alleged multi-million dollar

“Ponzi scheme” run by Defendant Stephen A. Maiden (“Maiden”) through a hedge

fund titled the Maiden Capital Opportunity Fund, LP (the “Fund”). Defendant SS&C

Technologies, Inc. (“SS&C”) was the Fund’s administrator from approximately 2007

through the Fund’s collapse in 2013. Plaintiffs were investors in the Fund.

3. Plaintiffs’ allegations against SS&C center on SS&C’s performance of its

administrative duties. To give three examples, Plaintiffs contend that SS&C did not

follow standard GAAP procedures, did not obtain reasonable documentation to verify

the accuracy of information provided to SS&C by Maiden, and continued issuing

capital statements to Plaintiffs despite SS&C’s knowledge of record inaccuracies.

Bradshaw, 2015 NCBC LEXIS 80, at *16, *22–23. As a result of these practices,

Plaintiffs allege that SS&C communicated false information to Plaintiffs and caused

Plaintiffs to suffer financial loss by allowing Maiden’s Ponzi scheme to continue

unnoticed. Id. at *9–10.

4. In an effort to discover relevant information about the policies and

procedures SS&C had in place while it was administering the Fund, Plaintiffs served

SS&C with Plaintiffs’ First Set of Interrogatories and First Requests for Production

of Documents (the “Requests for Production”) on August 21, 2015. Of those requests,

Requests 20–22 and 35 sought the following:

20. All writings, recordings, and photographs that relate or refer to SSC’s policies, standards, and practices from 2006 to 2015 with respect to hedge fund administration. 21. All writings, recordings, and photographs that relate or refer to SSC’s policies, standards, and practices from 2006 to 2015 that apply to SSC’s accounting work for hedge funds.

22. All writings, recordings, and photographs that relate or refer to SSC’s policies, standards, and practices from 2006 to 2015 that apply to SSC’s record keeping for hedge funds.

....

35. All writings, recordings, and photographs that relate or refer to SSC’s policies, procedures, and standards from 2006 to 2015 for entering into administrative and/or accounting engagements with hedge funds.

(Pls.’ Br. Supp. Mot. Sanctions Ex. 2, at 8–9, 11, ECF No. 128.2.)

5. In response to Plaintiffs’ Requests for Production, SS&C agreed to produce

all the documents SS&C contended it had that “relate[d] directly to its work for the

Fund.” (Mem. Law Opp’n Pls.’ Mot. Compel Disc. Def. 12, ECF No. 68.) SS&C

objected to Plaintiffs’ Requests 20–22 and 35, however, arguing that these requests

were vague, unduly burdensome, overly broad, and not reasonably limited in

temporal scope. (Mem. Law Opp’n Pls.’ Mot. Compel Disc. Def. Ex. 2, at 31–35, 46–

48 [hereinafter “Answers to Requests”], ECF No. 71.) In addition, SS&C contended

that Requests 20–22 and 35 were not relevant to any remaining claims or defenses in

the case as a result of the Court’s Motion to Dismiss Opinion. (Answers to Requests

31–35, 46–48.)

6. The Motion to Dismiss Opinion altered the course of this case in several

ways. Plaintiffs brought claims against SS&C for breach of fiduciary duty, aiding

and abetting common law fraud, gross negligence, grossly negligent

misrepresentation, aiding and abetting constructive fraud, violation of N.C. Gen. Stat. § 78A-52(c)(2), civil conspiracy, and punitive damages. Bradshaw, 2015 NCBC

LEXIS 80, at *10. With respect to Plaintiffs’ claim for breach of fiduciary duty, the

Court concluded that SS&C’s duties were limited under North Carolina law to the

duties SS&C was obligated to perform under the agreement between SS&C and the

Fund. Id. at *36. Consequently, and because Plaintiffs had failed to plead that

Plaintiffs reposed confidence in SS&C or that SS&C had occupied a position of

dominance over Plaintiffs, no fiduciary duty existed between SS&C and Plaintiffs.

Id. Accordingly, the Court dismissed Plaintiffs’ claim for breach of fiduciary duty.

Id. The Court also dismissed, for unrelated reasons, Plaintiffs’ claim for aiding and

abetting common law fraud. Id. at *38.

7. With respect to Plaintiffs’ claim for gross negligence, the Court concluded

SS&C’s motion to dismiss should be denied in a limited capacity:

[T]he Court concludes that SS&C’s Motion to Dismiss Plaintiffs’ gross negligence claim . . .

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Bluebook (online)
2018 NCBC 44, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bradshaw-v-maiden-ncbizct-2018.