Giarratano v. Ramirez

CourtUnited States Bankruptcy Court, W.D. Texas
DecidedOctober 2, 2025
Docket24-01069
StatusUnknown

This text of Giarratano v. Ramirez (Giarratano v. Ramirez) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, W.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Giarratano v. Ramirez, (Tex. 2025).

Opinion

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Dated: October 02, 2025. Clete GC. CHRISTOPHER G. BRADLEY UNITED STATES BANKRUPTCY JUDGE

IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION In re: LAURENCE MICHAEL : Case No. 24-11109-cgb RAMIREZ AND LEAN RANDELL WORTMAN : Chapter 7 Debtors. GARY GIARRATANO, § Plaintiff, § § Vv. § LAURENCE RAMIREZ A/K/A § LAURENCE LEFORTUNE, LEAN § WORTMAN A/K/A LEANN § LEFORTUNE, FFTX HOLDING, § LLC, FORTUNATE g Adv. No. 24-01069-cgb FOUNDATIONS, LLC, FFTX § HOLDING, LLC-6107P, § PROTECTED SERIES, FFTX § HOLDING, LLC-6206F2, § PROTECTED SERIES, 202311WY- § 04, LLC, 2021 TX02, LLC, AND § 2021 TX-05, LLC, § Defendants. §

MEMORANDUM OPINION ON DISCHARGEABILITY OF DEBTS

Introduction

In this opinion, the Court holds that the debts owed by the debtor-defendants should be discharged. The debtor-defendants have not been shown to have incurred a debt to the plaintiff by committing fraud or willful or malicious injury, and they have not been shown to have misused the entity-defendants such that the veil should be pierced or the entities should be treated as alter egos of the debtors. The Court holds that two of the entity defendants, FFTX Holding, LLC – 6107P, Protected Series and FFTX Holding LLC – 6206F2, Protected Series, breached their contracts to make certain payments to the plaintiff. The Court will consider damages and attorney’s fees for that breach in due course.

Jurisdiction and Authority

The Court has authority to adjudicate this matter pursuant to the District Court’s Standing Order of Reference.1 It is related to the main bankruptcy case, In re Ramirez.2 The Court has jurisdiction over this matter under 28 U.S.C. §§ 157(b)(2), (c)(2), and 1334(b). All parties filed statements consenting to the Court’s authority to enter a final judgment in this adversary proceeding.3

Factual Background

This case emerges from a real estate deal gone bad. Debtor-defendants Laurence Ramirez and LeAn Wortman, known as Laurence and LeAn LeFortune, got married after meeting at a real estate investment seminar. The pair’s real estate investment business was initially focused on remodeling residential properties, but eventually, they shifted their business model to new construction. Typically, the LeFortunes would buy a lot, tear down any existing homes, and build multiple new homes on the lot. At first, the business was focused on building homes to sell, but as a result of the shifting real estate market and interest rates after the COVID-19 pandemic, they switched to short-term rental projects.

1 Order of Reference of Bankruptcy Cases and Proceedings (W.D. Tex. Oct. 4, 2013). 2 Case No. 24-11109 (Bankr. W.D. Tex.). 3 ECF Nos. 12, 15, 115. The LeFortunes’ investment model typically worked as follows: once they had identified a property, they would acquire a construction loan. They would form a new LLC for each property.4 Then, LeAn would reach out to potential investors acting in her capacity as manager of the new LLC.5 Upon investing, the investor would receive a membership interest in the LLC. The investor would sign an agreement with the LLC that obligated the LLC to pay monthly interest payments on the investment. The investor was expected to co-guarantee a loan on the property so that the construction loan could be rolled into a mortgage with a more favorable interest rate.6 The property would be placed into the LLC once this refinancing took place.7

In early 2023, the LeFortunes approached Gary Giarratano about investing in two new builds that would be used as short-term rentals in East Austin: three units on a lot located on Palm Circle and another home located on part of a lot on Felix Avenue (the LeFortunes’ enterprise was separately working on the second part of this lot). Mr. Giarratano invested $200,000 in the Palm Circle project and $100,000 in the Felix Avenue project with the debtors’ business enterprise. The proposed investments are described in a pitch deck at Plaintiff’s Exhibit 19. In brief, Giarratano was to invest cash and serve as “co-guarantor” on new long-term loans that were to be procured on each project to “take out” existing, higher interest rate construction loans.8 The debtors, through their various entities, were to develop and run the properties as income-producing short-term rentals.9 Each investment was to be “secured” by a membership (ownership) interest in an LLC that would be the “owning entity” of each property. There would be sizable bank loans constituting roughly 75% of the value of the homes at the time of purchase,10 which would obviously hold a prior position in each project’s capital structure.

4 ECF No. 91 at 215:18. 5 Id. at 215:14–15. 6 ECF No. 90 at 100:7–17; 101:22–102:4. 7 See, e.g., ECF No. 91 at 235:9–16; 238:13–16; 240:1–4. 8 ECF No. 90 at 100:20–101:8; 104:23–105:2. 9 See Pl.’s Ex. 18. 10 According to the pitch deck, the Felix Avenue property was worth $572,000 and the loan was $429,000. The Palm Circle property was valued at $1,465,000 with a loan of $1,100,000. Pl.’s Ex. 19. As with many real estate investments, the project was manifestly very risky. In light of this, as well as his agreement to provide a guarantee, Mr. Giarratano agreed to receive “above market” returns of 14% APR: $14,000 per year for the Felix Avenue property and $28,000 per year for the Palm Circle property.11 Even in the pitch deck, which of course one would expect to err on the side of optimism, the excess cash flow projected to make these payments to Mr. Giarratano is remarkably tight: the estimated annual profits were $18,925 for the Felix Avenue property and $29,455 for the Palm Circle property.12 Notably, if you subtract the payment to Mr. Giarratano from the pitch deck estimates for each property, the margin is very thin. In other words, if anything went less well than expected (which of course is common in real estate development projects), or if the market did not continue to thrive (which of course is common given the volatility of real estate) it was always going to be difficult to make all of the promised payments to Mr. Giarratano. This is evident from the pitch deck itself.

Entity defendant “FFTX Holding, LLC – 6107P, Protected Series” was to own the Palm Circle home, and entity defendant “FFTX Holding LLC – 6206F2, Protected Series” was to own the Felix Avenue home. Mr. Giarratano signed a membership agreement with each respective entity outlining the interest payments he was to receive. Prior to signing and investing, Mr. Giarratano was also provided with documentation that stated that the properties were “to be contributed” to the entities (language that, importantly, indicated to all that the properties had not yet in fact been contributed). Mr. Giarratano wire transferred his investment on March 3, 2023.

The relationship between Mr. Giarratano and the LeFortunes quickly soured. The May 2023 interest check was sent out late.13 The LeFortunes failed to timely provide statements and other financial information to Mr. Giarratano.14 For his part, Mr. Giarratano did not provide his financial information to the broker who was to handle the refinancing of the loans on the properties. Because of the lack of guarantee, it became difficult to roll the construction loan on each property into a

11 Id.; Pl.’s Ex. 18. 12 Pl.’s Ex. 19. 13 Pl.’s Ex. 50. 14 E.g., Pl.’s Ex. 48. long-term loan with favorable terms.15 Consequently, the properties were never able to become profitable short-term rentals.

In July of 2023, the Felix Avenue property was sold without Mr. Giarratano’s knowledge or consent.16 In an effort to mitigate damages, the LeFortunes purportedly transferred Mr.

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Giarratano v. Ramirez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/giarratano-v-ramirez-txwb-2025.