Coral Capital Solutions LLC v. Disrupt Social, LLC

District Court, S.D. New York·Decided December 10, 2024·No. 1:24-cv-03940·Unknown

Opinion

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Re: Coral Capital Solutions, LLC (“Coral”) v. Disrupt Social, LLC (“Disrupt”) Dear Judge Subramanian: Plaintiff, Coral, is a financing company located in New York City that specializes in factoring accounts receivable. Coral’s website identifies three members as comprising its management team: Rishi Kumar, Einat Steklov, and James Bertie. /d. Disrupt is a digital marketing company founded by Defendant, Evan Bloomberg. Disrupt’s customers have included well-known brands such as CBS Interactive and Yahoo!. Coral alleges that it entered into a factoring agreement with Disrupt, which was personally guaranteed by Evan Bloomberg, pursuant to which Coral would purchase and prepay for Disrupt’s receivables. Coral alleges that Disrupt, solely by and through Evan Bloomberg, knowingly submitted receivables to Coral that it knew did not actually exist. By and through its 101 paragraph Second Amended Complaint, Coral asserts six counts, including fraudulent inducement. (ECF 55 at {[47-101). The amount at issue in this Action is significant. Coral seeks more than $1.6 million in actual damages, as well as punitive damages and reimbursement of its fees and costs. (ECF 55 at 954). During the parties’ relationship, Nazema Zaman-Kamrudeen, who remains employed by Coral, served as Mr. Bloomberg’s principal and primary contact at Coral.! Mr. Bloomberg regularly exchanged email and other communications exclusively with Ms. Zaman - Kamrudeen. In its initial disclosures, Coral identified “Nazema Zaman” as an “Account Executive” and an “individual likely to have discoverable information. See (Ex. 1). Cora identified three additional individuals, James Berti, Rishi Kumar, Einat Steklov. Jd. In its interrogatory responses, Coral identified Ms. Zaman-Kamrudeen as a person possessing relevant information: “Nazema Zaman, Account Executive at Coral Capital Solutions, LLC, dealt directly with Defendants’ sold and assigned accounts receivable, the payments made on said

1! Coral Capital incorrectly states that Mr. Bertie with Mr. Bloomberg’s principal contact. That is not correct for the entire period of time after the subject agreement was executed.

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accounts receivable, the monies due and owing to Plaintiff, Defendant Bloomberg, and has knowledge of the facts supporting Plaintiff's claims.” See (Ex. 2). Coral correctly notes that when Disrupt served a deposition subpoena for Ms. Zaman- Kamrudeen’s deposition, Coral objected on the proffered basis that Ms. Zaman-Kamrudeen is not a member of Coral’s management. See (Ex.3). In that November 12, 2024, email transmission ofa letter, titled, “Letter of Rejection to SB and AM,” Coral’s attorney stated: “If you want to depose Mr. Kamrudden, you will have to issue a subpoena. Please be advised, again, that as previously stated, if you do subpoena Ms. Kamrudden, we will move to quash any such subpoena.” (Id.)4 As noted, on November 8, 2024, Coral’s counsel likewise emailed, “If you subpoena Nazema, please be advised we will move to quash. See (Ex. 4). Thus, Coral firmly elected to file its motion regardless of whether a check was provided or otherwise. Disrupt respectfully disagrees that the deposition notice to an “account executive” was not proper. Courts in this district generally consider five factors to determine whether an individual is a managing agent of a corporate party: “1) whether the individual is invested with general powers allowing him to exercise judgment and discretion in corporate matters; 2) whether the individual can be relied upon to give testimony, at his employer's request, in response to the demands of the examining party; 3) whether any person or persons are employed by the corporate employer in positions of higher authority than the individual designated in the area regarding which the information is sought by the examination; 4) the general responsibilities of the individual respecting the matters involved in the litigation; and 5) whether the individual can be expected to identify with the interests of the corporation.” See, e.g., Sugarhill Records, Ltd. b. Motown Record Corp., 105 F.R.D. 166, 170 (S.D.N.Y. 1985) (internal quotation marks, citation, and emphasis omitted). Coral is a small company, with eight employees (according to Linked.in). As such, the various parties necessarily have several roles. Ms. Nazem was Mr. Bloomberg’s primary contact, through which she received and provided information and provided guidance on instruction on what he was to do. Coral’s counsel has stated that it represents Ms. Nazem and that she remains employed, meaning she can certainly be requested to provide testimony at Coral’s request. Ms. Nazem is going to be asked about her direct communications with Mr. Bloomberg that took place between only her and Mr. Bloomberg, meaning she is uniquely suited to provide such testimony. Ms. Nazem’s responsibilities were tantamount to the relationship at issue. And, given Ms. Nazem’s continued employment ina small company, she can be expected to identify with Coral’s interests. Rather than waste time and money litigating the validity of the subject deposition notice, as requested by Coral’s counsel, on November 22, 2024, Disrupt personally served Ms. Zaman with the subpoena attached as exhibit 1 to the letter motion (the “Subpoena’”). Because Coral’s counsel had previously insisted that Mr. Bloomberg’s (now completed) deposition be taken at its Manhattan office, the Subpoena calls for Ms. Zaman-Kamrudeen,

2 It seems odd to Disrupt and its counsel that Coral Capital would insist on having one of its employees personally served by a process server, although it is unfortunately not surprising in light of the interactions that Disrupt has repeatedly encountered with Coral Capital’s attorneys in this Action.

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Sugarhill Records Ltd. v. Motown Record Corp.
105 F.R.D. 166 (S.D. New York, 1985)