Brandt v. Siam Commercial Bank Pub. Co. Ltd.

CourtSuperior Court of Maine
DecidedFebruary 8, 2002
DocketCUMcv-01-222
StatusUnpublished

This text of Brandt v. Siam Commercial Bank Pub. Co. Ltd. (Brandt v. Siam Commercial Bank Pub. Co. Ltd.) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brandt v. Siam Commercial Bank Pub. Co. Ltd., (Me. Super. Ct. 2002).

Opinion

STATE OF MAINE JHELEE LS 3s SUPERIOR COURT CUMBERLAND, ss. CURR AS A Ses CIVIL ACTION DOCKET NO. CV-(1-222

ro. ot fas AN 1- . Pep og G 03 Al td? REC CM — 3 fei 4 0a WILLIAM A. BRANDT, JR., poy

Plaintiff

Vv. ORDER ON PLAINTIFF'S MOTION TO DISMISS COUNTERCLAIMS AND MOTION FOR SANCTIONS; DEFENDANTS’ MOTION TO REMOVE PLAINTIFF AS ASSIGNEE FOR THE BENEFIT OF CREDITORS

SIAM COMMERCIAL BANK PUBLIC DONALD L. GAPRRECHT

COMPANY LIMITED, NEW YORK LAM LIDSARY AGENCY, et al.,

Defendants FEB 14 2002

Plaintiff William Brandt (“Brandt”) filed a motion to dismiss the iam sumer 1 Bank and Siam Commercial Bank Public Company Limited, New York Agency (collectively “Siam”); and a motion for sanctions. Siam filed a motion to remove Brandt as the assignee for the benefit of creditors. Upon review of the motions, opposition, and

the applicable law, the motion to dismiss will be granted, the motion for sanctions

will be denied, and the motion to remove Brandt as the assignee will be denied.

BACKGROUND

Three related entities, Avian Farms, Inc., Avian Farms (USA), Inc., and

Avian Data Communications, Inc. (collectively “Avian”) became’ financially troubled. In order to resolve the finances of these three entities, Avian proposed to the various creditors a settlement solution whereby the plaintiff would be the assignee and would distribute the assets of the three entities. The creditors were given the option to accept the assignment. After some correspondence with Brandt, Siam accepted the assignment. In the course of evaluating the assets and obligations of Avian, Brandt determined that consolidating and liquidating the assets of the

three entities was the best method of satisfying the outstanding obligations.” In

order to obtain court approval of the consolidation, Brandt filed the present declaratory judgment action and requested a determination that he was permitted to

so act.

asserted two counterclaims - breach of fiduciary duty (Count I) and fraud (Count II). The crux of Siam’s argument is twofold: first, that the mere attempt by Brandt to consolidate the assets and debts is a breach of fiduciary duty because it would result in some creditors receiving more at the expense of others; and second, Brandt had induced Siam’s acceptance of the assignment by representing that he would attempt to keep the estates separate. In addition, Siam has filed a motion to remove Brandt as the assignee.

Brandt asserts that any breach of fiduciary duty claim is premature because

Brandt has not yet consolidated the estates, but rather has only turned to the court to

1 The decision was made, as alleged by Brandt, because the management of Avian did not respect the separateness of the entities, and the finances of the three

entities were intermingled. discover whether he can consolidate the estates. Furthermore, Brandt argues that under the assignment agreement, which was accepted by Siam, Brandt specifically has the right to bring a declaratory judgment action, and in all correspondence Brandt explicitly reserved the right to consolidate the estates. Brandt argues that Siam cannot point to a misrepresentation, or even assuming a misrepresentation, cannot point to a cognizable injury, and therefore the fraud claim must also be dismissed. Asserting that the counterclaims are baseless, Brandt also requests the imposition of sanctions. Finally, Brandt opposes Siam’s motion to remove him as

assignee.

DISCUSSION The motion to dismiss tests the sufficiency of a counterclaim. Heber v.

Lucerne-in-Maine Village Corp., 2000 ME 137, J 7, 755 A.2d 1064, 1066. In ruling on

UY awaeminal

a motion to dismiss, the court “examine[s} the complaint in the light most favorable to the [claimant] to determine whether it sets forth elements of a cause of action or alleges facts that would entitle the [claimant] to relief pursuant to some legal

theory.” Id. (citations omitted).

I. Breach of Fiduciary Duty Under Section B.8 of the assignment agreement (Exhibit A to the plaintiff's Amended Complaint p. 6), Brandt has “the right to petition the state or federal

courts of the State of Maine for a declaratory judgment or such other relief as [Brandt] may deem necessary if, in his opinion, said action is desirable in connection with any dispute or claim arising hereunder.” This is a broad grant of discretion to the assignee, which was accepted by Siam. Siam now complains that the present declaratory judgment action is on an inappropriate topic because the assignee cannot consolidate the assigned estates. However, Brandt brought the declaratory action to determine whether he has the authority to consolidate the estates, and thus must have concluded the “action [was] desirable in connection with [a] dispute” arising under the assignment agreement. Accordingly, in the counterclaim for breach of

fiduciary duty, Siam has failed to state a claim for which relief can be granted.

Il. Fraud Brandt would be liable for fraud or deceit if he: (1) made a false representation

(2) of a material fact (3) with knowledge of its falsity or in reckless disregard of

refrain from acting in reliance upon it, and (5) Siam justifiably relied upon the

representation as true and acted upon the false representation to its damage. Francis

v. Stinson, 2000 ME 173, { 38, 760 A.2d 209. Siam relies solely on the correspondence between Siam and Brandt, included

in Siam’s Answer and Counterclaims as exhibits C - F,* to support its contention of a

2 “When a complaint’s factual allegations are expressly linked to - and admittedly dependent upon - a document (the authenticity of which is not: challenged), then the court can review it upon a motion to dismiss.” Alternative Energy, Inc. v. St. Paul Fire and Marine Insurance Co., 267 F.3d 30, 34 (1st Cir. 2001) (citation and quotation omitted). Here, the documents were attached to Siam’s

4 misrepresentation. Siam points to Brandt’s representations that he was attempting to maintain separate estates, and alleges that in fact Brandt never intended to maintain separate estates. Siam asserts that Brandt intended to consolidate the estates, but represented otherwise to induce Siam’s acceptance of the assignment agreement.

In the letters sent by Brandt to Siam, exhibits D and F, Brandt writes, “the Assignee and his representatives are finding assets to have been commingled, ‘possibly to the point that separate attribution may not be possible,” and “the Assignee reserves the right to seek substantive consolidation of the estates, should evidence suggest that is appropriate and in the best interest of the creditors of the estates.” In context, any “representation” made in these letters that Brandt would try to maintain separate estates was significantly conditional and tentative. In

addition, Brandt disclaimed any commitment to separate the estates. Therefore, the

serious doubt. However, even if the court accepts the existence of a misrepresentation and the existence of justifiable reliance, Siam’s counterclaim for fraud is not ripe. “ae

Ripeness is determined with a view to the “fitness of the issues for judicial decision

and the hardship to the parties of withholding court consideration.” Lincoln House

inc. v. Dupre, 903 F.2d 845, 847 (1st Cir. 1990) (internal quotations omitted). In

counterclaim, and therefore are properly considered by the court in ruling on the motion to dismiss.

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Related

Lincoln House, Inc. v. Paul W. Dupre
903 F.2d 845 (First Circuit, 1990)
Francis v. Stinson
2000 ME 173 (Supreme Judicial Court of Maine, 2000)
Heber v. Lucerne-In-Maine Village Corp.
2000 ME 137 (Supreme Judicial Court of Maine, 2000)
Jourdain v. Dineen
527 A.2d 1304 (Supreme Judicial Court of Maine, 1987)

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