Citibank, N.A. v. Friedman

CourtDistrict Court, E.D. New York
DecidedAugust 15, 2024
Docket1:23-cv-02420
StatusUnknown

This text of Citibank, N.A. v. Friedman (Citibank, N.A. v. Friedman) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Citibank, N.A. v. Friedman, (E.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK CITIBANK, N.A., MEMORANDUM & ORDER Plaintiff, 23-CV-02420 (NGG) (RML) -~against- SHULEM FRIEDMAN and MIRIAM FRIEDMAN, Ci efenddatts. NICHOLAS G. GARAUFIS, United States District Judge. Plaintiff Citibank, N.A. (“Citibank” or “Plaintiff’) brings several claims against Defendants Shulem and Miriam Friedman (“Fried- mans” or “Defendants”) for allegedly pursuing a fraudulent scheme to misuse and overcharge nine personal credit accounts with Citibank. (See Am. Compl. (Dkt. 16) § 8-10, 19-24.) Citi- bank seeks to recover $1,738,035.63 in damages from the Defendants’ alleged overcharging scheme and asserts claims for (i) fraudulent misrepresentation; (ii) false pretenses; (iii) actual fraud with respect to misrepresentations and fraudulent conduct; (iv) civil conspiracy; (v) breach of contract; and (vi) unjust en- richment. (See generally id.) Defendants move to dismiss Plaintiffs Amended Complaint in its entirety under Federal Rule of Civil Procedure 12(b)}(6) for failure to state a claim. (See Not. of Mot. (Dkt. 20); Defs.’ Mot. to Dismiss (“Mot,”) (Dkt. 20-5).) For the following reasons, the Defendants’ motion is GRANTED in part and DENIED in part. I. BACKGROUND! Defendants Shulem and Miriam Friedman opened nine credit card accounts (the “Credit Accounts”) with Plaintiff Citibank. The following facts are taken from the Amended Complaint and, for the purposes of this motion to dismiss, are assumed to be true. See Ark. Pub.

(See Am. Compl. { 8.) Upon opening these accounts, Defendants, through Citibank’s credit agreements, agreed to use the accounts only for consumer purposes, to pay all amounts due, make monthly minimum payments, and not use their accounts for un- lawful transactions. (id. {{ 29, 31, 33.) They also agreed to a total credit limit on all accounts of $184,000. (Am. Compl. { 34; see also Credit Agreements at 2.) Initially, Defendants “were good customers;” they honored their credit agreements and made timely payments on their Credit Accounts for consumer goods. (Am. Compl. § 9.) After several years, however, Defendants un- dertook a fraudulent scheme to “drastically increase and swiftly charge up the balances of their Credit Agreements before Citi- bank could identify their illicit manipulations.” @d. { 10.) This resulted in overcharged amounts, totaling over $1,738,035.63 across all nine Credit Accounts. (Id.} Specifically, Defendants used their Credit Accounts to make large purchases, including some in excess of $50,000, at eyewear com- panies, as well as for shipping and related business expenses, at times in excess of $15,000. (id. {{ 11-14.) To obtain excess credit above authorized limits and to avoid default in doing so, Defend- ants used four primary mechanisms to carry out their fraudulent scheme. Ud. § 24.) First, Defendants disputed the large transaction charges made on their Citibank Credit Accounts, triggering Citibank to automati- cally apply a conditional credit in the amount of the disputed transaction on the relevant Credit Account pending investigation

Emps. Ret. Sys. v. Bristol-Myers Squibb Co., 28 F.4th 343, 349 (2d Cir, 2022). The Amended Complaint is also deemed to include documents in- corporated in it by reference and that are “integral.” Chambers v. Time Warner, Inc., 282 F.3d 147, 152-53 (2d Cir. 2002), The court considers the exhibits that Defendant submitted with its motion—the Citibank credit card agreements and notices of account closures—to be integral to the Complaint. (See Ex. B to Cwibeker Decl. (“Credit Agreements”) (Dkt. 20- 3); Ex. C to Cwibeker Decl. (“Notices of Account Closures”) (Dkt. 20-4).)

of the dispute. (Id. { 24(a).) When Citibank applied the condi- tional credit, the disputed transaction was no longer reflected against the Defendants’ credit limit, thereby allowing Defendants to continue spending on the account in excess of their credit limit. id.) Citibank alleges that Defendants disputed charges aimed at obtaining extensions of credit in excess of their credit limit on 66 known occasions, resulting in a fraudulent credit ex- tension of $2,480,184.69. Cid.) The second mechanism by which Defendants carried out their fraudulent scheme was to file false payment disputes with their banks after submitting payments to their Credit Accounts. (Id. { 24(b).) Here, Defendants made payments to their Credit Ac- counts using their accounts at different banks, including a $149,157.53 payment using their Valley National Bank account and a $67,425.40 payment using their JP Morgan Chase account, and then disputed those same payments with the Defendants’ paying banks. (Id.) By first making the payment to Citibank, De- fendants obtained additional borrowing capability under their Credit Accounts. When they later disputed the payments with the payor banks, this triggered the payor banks to recall the initial payment, allowing Defendants to also re-use the same funds with their payor banks. Citibank asserts that Defendants disputed pay- ments with payor banks on four known occasions. (id.) Third, on 115 known occasions, Defendants used false or fraud- ulent account numbers to submit large payments on their Credit Account balances. (Id. § 24(c).} All the payments were returned on or after June 7, 2018, as Citibank was unable to process any payments because the account numbers listed on each payment did not exist or were not owned by Defendants. (Id.) Finally, on at least eight occasions, Defendants submitted their false payments right before the billing cycle causing the Credit Accounts to reflect a zero amount owed for the period, even though the payments were ultimately rejected. (id. { 24(d).) This

additional mechanism allowed Defendants to manipulate the timing of their fraudulent payments to prevent Defendants’ ac- counts “from being flagged as in default for failure to make monthly payments, and prevent collection.” fd.) As a result of the fraudulent scheme, Citibank commenced this action by filing a complaint in this district on March 29, 2023 and asserting causes of action for (1) fraudulent misrepresentation; (2) false pretenses; (3) actual fraud — misrepresentation; (4) ac- tual fraud — fraudulent conduct; (5) civil conspiracy; (6) breach of contract; and (7) unjust enrichment. (See generally Complaint (Dkt. 1).} Plaintiff shortly thereafter amended its complaint, rais- ing all of its previous causes of action, but adding additional allegations as support. (See generally Am. Compl.) Defendants’ motion to dismiss was fully briefed on January 12, 2024. (See Scheduling Order (Dkt. 19); see also Mot.; PL’s Opp. to Mot. (“Opp.”) (Dkt. 20-6); Defs.’ Reply (“Reply”) (Dkt. 20-7).) Il. LEGAL STANDARD To survive a Rule 12(b)(6) motion to dismiss, “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl Corp. v. Twombly, 550 U.S. 544, 570 (2007)).? “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the miscon- duct alleged.” Id. A complaint must contain facts that do more than present a “sheer possibility that a defendant has acted un- lawfully.” Id. In deciding a motion to dismiss, the court accepts all factual allegations in the complaint as true and draws all rea- sonable inferences in the plaintiffs favor. See Fink v. Time Warner

2 When quoting cases, unless otherwise noted, all citations and internal quotation marks are omitted, and all alterations are adopted.

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