Jia Wang v. Coa 99 Hudson, LLC

CourtNew Jersey Superior Court Appellate Division
DecidedMarch 18, 2025
DocketA-3594-23
StatusUnpublished

This text of Jia Wang v. Coa 99 Hudson, LLC (Jia Wang v. Coa 99 Hudson, LLC) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jia Wang v. Coa 99 Hudson, LLC, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3594-23

JIA WANG and XIAODONG JIANG,

Plaintiffs-Respondents,

v.

COA 99 HUDSON, LLC, CHINA OVERSEAS AMERICA, INC., and THE MARKETING DIRECTORS, INC.,

Defendants-Appellants. ____________________________

Argued February 12, 2025 – Decided March 18, 2025

Before Judges Sumners and Bergman.

On appeal from the Superior Court of New Jersey, Law Division, Hudson County, Docket No. L-2296-23.

Patricia A. Lee argued the cause for appellants (Connell Foley LLP, attorneys; Leo J. Hurley, Jr., Patricia A. Lee, and Alexa C. Salcito, of counsel and on the briefs).

Keith N. Biebelberg argued the cause for respondents (Biebelberg & Martin LLC, attorneys; Keith N. Biebelberg, of counsel and on the brief). PER CURIAM

In this residential real estate sale, defendants appeal, on leave granted,

from an order denying their motion requesting: (1) summary disposition on the

enforceability of the parties' arbitration agreement; (2) staying all claims

pending completion of the American Arbitration Association (AAA) proceeding

pursuant to Rule 4:6-2(e), or, in the alternative; (3) to dismiss any remaining

claims of plaintiffs' pursuant Rule 4:6-2(e). After our de novo review, we

conclude the trial court engaged in an appropriate factual and legal analysis

supporting its denial of defendants' motion and invalidating the arbitration

clause in their agreement and, therefore, we affirm.

I.

In December 2017, the parties executed a Subscription and Purchase

Agreement (SPA) for plaintiffs to purchase condominium unit 1601 (the unit)

from defendants located at 99 Hudson Street in Jersey City. Pursuant to the

SPA, plaintiffs paid a deposit of $86,700 representing ten percent of the

purchase price to be held in escrow. Upon signing of the SPA, plaintiffs

received a digital copy of the public offering statement (POS).

The SPA provided that the contract "will be legally binding" after the

review period unless an attorney reviews and disapproves. Plaintiffs retained

A-3594-23 2 counsel to represent them concerning the SPA, POS and other issues

surrounding their purchase of the unit.

The SPA included Section 13, titled "ARBITRATION" (Arbitration

Provision), stating:

ARBITRATION: Buyer, on behalf of Buyer and all permanent residents of the Unit, including minor children, hereby agree that any and all disputes with Seller, Seller's parent company or their subsidiaries or affiliates arising out of the Unit, this Agreement, the Unit warranty, any other agreements, communications or dealings involving Buyer, or the construction or condition of the Unit including, but not limited to, disputes concerning breach of contract, express and implied warranties, personal injuries and/or illness, mold-related claims, representations and/or omissions by Seller, on-site and off-site conditions and all other torts and statutory causes of action ("Claims") shall be resolved by binding arbitration during the warranty period in accordance with the rules and procedures of Construction Arbitration Services, Inc. [(CAS)] or its successor or an equivalent organization selected by Seller. If CAS is unable to arbitrate a particular claim, then that claim shall be resolved by binding arbitration pursuant to the Construction Rules of Arbitration of the [AAA] or its successor or an equivalent organization selected by Seller. In addition, Buyer agrees that Buyer may not initiate any arbitration proceeding for any Claim(s) unless and until Buyer has first given Seller specific written notice of each claim (at 1500 Broadway, Suite 2301, New York, New York, 10036, Attn: Warranty Dispute Resolution) and given Seller a reasonable opportunity after such notice to cure any default, including the repair of the Unit, in accordance with the Unit warranty. The provisions of this section

A-3594-23 3 shall be governed by the provisions of the Federal Arbitration Act [(FAA)], 9 U.S.C. [§§ 1, et seq.] and shall survive settlement.

On November 15, 2021, defendants provided a letter to plaintiffs' counsel

reminding him that a certificate of occupancy was issued for the unit and

requested confirmation of plaintiffs' intention to close. Defendants' letter further

stated "[i]f we do not receive notice of your client's intent to proceed to closing

by December 15, 2021, seller will utilize the arbitration provision within the

[SPA] in order to collect liquidated damages."

On December 9, plaintiff Jai Wang contacted defendants by e-mail

informing them they were no longer represented by counsel and requested that

defendants contact her directly regarding the closing of the unit. Defendants

revised the November 15 letter re-addressing and emailing it to Wang that same

day.

For approximately eleven months from December 2021 to November

2022, Wang and defendants exchanged numerous communications concerning

closing on the unit. Throughout this period, Wang expressed her intent to

proceed with the closing but indicated difficulties with finding replacement

counsel and inquired about the "deadline" to close. Defendants informed her

the deadline was "as soon as possible as this unit has been able to close for some

A-3594-23 4 time." Defendants repeatedly informed plaintiffs that their failure to close may

result in them filing for arbitration.

Plaintiffs refused to close on the unit, claiming it was substantially smaller

than represented and advertised among other reasons. Based on plaintiffs'

refusal to close, on March 7, 2023, defendants filed a demand for arbitration

with AAA requesting a declaratory judgment as well as a claim for breach of

contract. Defendants demanded relief pursuant to the liquidated damages clause

in the SPA that entitled defendants to retain ten percent or the $86,700 held in

escrow due to plaintiffs' breach.

On March 27, plaintiffs filed an answer and counterclaim. The

counterclaim asserted breach of contract, breach of implied duty of good faith

and fair dealing, negligent/fraudulent misrepresentations/omissions, and sought

dismissal of the arbitration, a refund of plaintiffs' deposit, as well as an order

awarding costs and attorney's fees. The counterclaim also alleged that

defendants "materially breached the parties' contract by failing to disclose the

nature and extent of various substantial defects with the construction," including

"fail[ing] to disclose water damage to [the unit] in a timely manner and by

submitting an inconsistent incident report and estimate of repairs," . . . "defects

with the windows and the truthfulness of the representations as to the dimensions

A-3594-23 5 of the units." Plaintiffs also averred that "the building is presently the subject

of multiple multi-plaintiff and/or class action lawsuits which could have a

significant adverse financial impact on the [plaintiffs] by way of future

assessments or special assessments distributed among the unit owners. " The

answer also responded to paragraph 23 of defendants' demand asserting "the

meaning and significance of the arbitration provision was not explained to

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