Eloquence Corp. v. Elba Jewelry Servs., LLC

2025 NY Slip Op 31182(U)
CourtNew York Supreme Court, New York County
DecidedApril 8, 2025
DocketIndex No. 654526/2022
StatusUnpublished

This text of 2025 NY Slip Op 31182(U) (Eloquence Corp. v. Elba Jewelry Servs., LLC) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Eloquence Corp. v. Elba Jewelry Servs., LLC, 2025 NY Slip Op 31182(U) (N.Y. Super. Ct. 2025).

Opinion

Eloquence Corp. v Elba Jewelry Servs., LLC 2025 NY Slip Op 31182(U) April 8, 2025 Supreme Court, New York County Docket Number: Index No. 654526/2022 Judge: Lyle E. Frank Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 654526/2022 NYSCEF DOC. NO. 72 RECEIVED NYSCEF: 04/08/2025

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. LYLE E. FRANK PART 11M Justice ---------------------------------------------------------------------------------X INDEX NO. 654526/2022 ELOQUENCE CORPORATION MOTION DATE 12/02/2024 Plaintiff, MOTION SEQ. NO. 003 -v- ELBA JEWELRY SERVICES, LLC, DECISION + ORDER ON MOTION Defendant. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 003) 66, 67, 68, 69, 70, 71 were read on this motion to/for REARGUMENT/RECONSIDERATION .

Upon the foregoing documents, plaintiff’s motion is granted.

Background

Eloquence Corporation (“Plaintiff”) is a diamond manufacturer and wholesale distributor

who began in 2010 to sell loose diamonds to Elba Jewelry Services, LLC d/b/a Sophia Fiori

(“Elba”). Elba’s principal officer and owner, Bernard Bachoura (“Bachoura”), made what

Plaintiff alleges are false and misleading representations regarding Elba’s financial status in

order to induce Plaintiff to enter into a consignment agreement in 2015. Plaintiff also alleges that

Elba failed to pay multiple invoices for loose diamonds. While in the process of negotiating

payment options regarding the monies owed, Plaintiff alleges that Bachoura was “secretly in the

process of shifting all of Elba’s assets to related entities under the same ownership, leaving Elba

an empty shell which cannot pay its liabilities.” These other entities are Fiori Diamonds LLC

(“Fiori”) and Elba Jewelry Design Center LLC (“New Elba”, collectively with Fiori, Bachoura,

and Elba “Defendants”).

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Plaintiff brought the underlying proceeding in November of 2022, with claims for breach

of contract, fraud, and others. Under a theory of successor liability, Plaintiff in their sixth cause

of action alleged that Fiori and New Elba were responsible for the debts and liabilities of Elba.

Defendants brought a motion to dismiss the second through sixth causes of action for failure to

state a cause of action. In an order dated October 2024 (the “October Order”), this Court

dismissed the complaint in its entirety as to Bachoura, New Elba, and Fiori, and dismissed the

third through sixth causes of action as against Elba. Plaintiff brings the present motion to renew

and reargue. Defendants oppose.

Standard of Review

CPLR § 2221(d) allows for a party to make a motion to reargue if it is “identified

specifically as such” and requires that it be based “upon matters of fact or law allegedly

overlooked or misapprehended by the court in determining the prior motion but shall not include

any matters of fact not offered on the prior motion.”

Discussion

In the October Order, this Court held that the complaint did not, as a matter of law, state a

claim for successor liability because “there are no allegations that Elba is dissolved and no

longer conducting business and that the other two entities acquired any assets of Elba.” Plaintiff

moves to reargue the issue of successor liability, on the grounds that this Court misapprehended

the law. Specifically, Plaintiff argues that 1) a successor liability claim is adequately pled when it

is alleged that the predecessor entity is an empty shell and formal dissolution is not required; and

2) allegations that substantially all assets were transferred to the successor entities is sufficient to

survive a motion to dismiss. Defendants oppose, arguing that a claim for successor liability

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requires a showing that the former entity no longer exists, and that Fiori and New Elba did not

assume Elba’s liabilities. For the reasons that follow, the motion is granted.

Formal Dissolution Is Not Required for Successor Liability

The first issue is whether a technical dissolution of the predecessor entity is required in

order to state a valid claim for successor liability. In 1983, the Court of Appeals held that under

the mere continuation doctrine, “the predecessor corporation must be extinguished.” Schumacher

v. Richards Shear Co., 59 N.Y.2d 239, 245 (1983). But a line of cases since have allowed for a

claim for successor liability on a de facto merger theory to stand when it is alleged that the

predecessor company has been left a “mere shell.” Fitzgerald v. Fahnestock & Co., 286 A.D.2d

573, 575 (1st Dept. 2001); see also Holme v. Global Mins. & Metals Corp., 63 A.D.3d 417, 418

(1st Dept. 2009); Radium2 Capital, LLC v. Xtreme Natl. Maintenance Corp., 202 A.D.3d 638,

639 (1st Dept. 2022).

The case law, it should be noted, on this point is muddled. It appears that where, as is the

case here, a complaint alleges that a predecessor company was rendered a mere shell by the

transfer of assets to the successor company, this is sufficient to survive a motion to dismiss

despite the lack of formal dissolution. The recent line of cases support successor liability on a de

facto merger theory even without a legal dissolution. But, as discussed above, the Court of

Appeals appears in 1983 to have required formal dissolution for the mere continuation doctrine.

The mere continuation doctrine and the de facto merger doctrine are often considered “so similar

that they may be considered a single exception.” Matter of TBA Global, LLC v. Fidus Partners,

LLC, 132 A.D.3d 195, 211 n. 17 (1st Dept. 2015). The recent line of ‘mere shell’ cases and

Schumacher can be reconciled as regards a formal dissolution requirement by an understanding

that regardless of the similarities between the two theories, formal dissolution is not required

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under the de facto merger theory. See also Tap Holdings, LLC v. Orix Fin. Corp., 109 A.D.3d

167, 176 (1st Dept. 2013) (holding that the mere continuation doctrine can apply when the

predecessor entity still exists but is “effectively extinguished”). Therefore, here, the lack of

pleading of a formal dissolution is not required for successor liability under the de facto merger

theory.

The Asset Transfer Was Sufficiently Pled

The second issue is whether the complaint adequately alleges that assets were transferred

from Elba to Fiori and New Elba. The complaint alleges several times that Elba transferred all of

its assets to the successor entities, including “goodwill, trade names, customer lists, and lists of

suppliers.” The complaint also alleges facts relating to the advertising of Fiori and New Elba as

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Related

Matter of TBA Global, LLC v. Fidus Partners, LLC
132 A.D.3d 195 (Appellate Division of the Supreme Court of New York, 2015)
Schumacher v. Richards Shear Co.
451 N.E.2d 195 (New York Court of Appeals, 1983)
Holme v. Global Minerals & Metals Corp.
63 A.D.3d 417 (Appellate Division of the Supreme Court of New York, 2009)
Fitzgerald v. Fahnestock & Co.
286 A.D.2d 573 (Appellate Division of the Supreme Court of New York, 2001)
Polanco v. Durgaj
159 N.Y.S.3d 837 (Appellate Division of the Supreme Court of New York, 2022)

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Bluebook (online)
2025 NY Slip Op 31182(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/eloquence-corp-v-elba-jewelry-servs-llc-nysupctnewyork-2025.