JTRE 242 Lafayette LLC v. BSK Group USA Ltd.

2024 NY Slip Op 33718(U)
CourtNew York Supreme Court, New York County
DecidedOctober 21, 2024
DocketIndex No. 153747/2021
StatusUnpublished

This text of 2024 NY Slip Op 33718(U) (JTRE 242 Lafayette LLC v. BSK Group USA Ltd.) 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
JTRE 242 Lafayette LLC v. BSK Group USA Ltd., 2024 NY Slip Op 33718(U) (N.Y. Super. Ct. 2024).

Opinion

JTRE 242 Lafayette LLC v BSK Group USA Ltd. 2024 NY Slip Op 33718(U) October 21, 2024 Supreme Court, New York County Docket Number: Index No. 153747/2021 Judge: Alexander M. Tisch 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. 153747/2021 NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 10/21/2024

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. ALEXANDER M. TISCH PART 18 Justice ---------------------------------------------------------------------------------X INDEX NO. 153747/2021 JTRE 242 LAFAYETTE LLC, MOTION DATE 08/16/2023 Plaintiff, MOTION SEQ. NO. 002 - V -

BSK GROUP USA LIMITED D/B/A MATT & NAT, VIA DECISION + ORDER ON VEGAN LTD. MOTION Defendant. ·----------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 002) 37, 38, 39, 40, 41, 42,43 , 44,45, 46,47, 48,49, 50, 51, 52 , 53, 54, 55, 56, 57, 58, 59,60 , 61 , 62, 63,64, 65, 66,67,68,69, 70, 71 , 72, 73 were read on this motion to/for VACATE - DECISION/ORDER/JUDGMENT/AWARD.

According to the complaint, plaintiff JTRE 242 Lafayette LLC leased the commercial

unit at 242-244 Lafayette Street, Unit 1S (the Premises) to defendant BSK Group USA Limited

d/b/a Matt & Nat (Tenant). Defendant Via Vegan Ltd., a Canadian company, executed a

guaranty for the Tenant's obligations under the lease. Tenant stopped paying rent in April 2020,

during the COVID-19 pandemic. Neither Tenant nor Via Vegan paid the plaintiff the

outstanding rents or other amounts due under the lease agreement. Plaintiff brought this suit.

Defendants failed to answer. In a Decision and Order dated March 31, 2022, this Court granted

plaintiffs unopposed motion for default judgment against both defendants and directed the Clerk

of the Court to enter judgment against them (NYSCEF Doc. No. 29).

In this motion, Via Vegan moves to vacate the default judgment and dismiss the

complaint against it for lack of personal jurisdiction due to lack of proper service. As a Canadian

entity, Via Vegan claims it should have been served pursuant to the Hague Convention, and the

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Affidavit of Service (NYSCEF Doc. No. 3) does not evidence service in compliance with the

requirements of the Hague Convention, such as translating the documents into French or

compliance with the local laws regarding service in Quebec. Nor, according to Via Vegan, was

service adequate pursuant to the CPLR, as the documents were delivered to Ms. Mastrangelo in

its office, who is not in one of the categories of authorized recipients enumerated in CPLR

31 l(a)(l).

Plaintiff contends the guaranty signed by Via Vegan included a consent to the jurisdiction

of this Court and argues Via Vegan was well aware of this litigation long before filing this

motion, as plaintiff mailed courtesy copies to its corporate offices and to its attorneys, and as Via

Vegan engaged in settlement discussions about satisfying the judgment in this case in September

2022, almost a full year before filing its motion to vacate. Plaintiff also explains it served Via

Vegan at its corporate offices in Montreal (see Affidavits of Service, Exhibit B to Affidavit of

David Ettedgui, NYSCEF Doc. No. 47). Plaintiff argues the consent to jurisdiction abrogates

Via Vegan's objections to service and jurisdiction. Plaintiff relies on A(fred E. Mann Living Tr.

v ETIRC Aviation S.a.r.l., (78 AD3d 137 [1st Dept 2010]) for the premise that a contractual

waiver of objections to jurisdiction and for service of process are binding. The Alfred E. Mann

Living Trust court held that the requirements of the Hague Convention could be waived by

contract. However, that court also noted those defendants explicitly waived their rights to

personal service of process, not only objections to jurisdiction (id. at 138-39). The guaranty at

issue here does not explicitly waive service.

It appears plaintiff attempted service on Via Vegan pursuant to the Hague Convention,

Article 10(b), rather than Article 5. Article 10(b) allows "judicial officers, officials or other

competent persons of the State of origin to effect service of judicial documents directly through

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the judicial officers, officials or other competent persons of the State of destination." Service

here was performed by a bailiff, which is an appropriate person (Sign(fy N. Am. Corp. v Axis

Light. Inc., 19CV5516 (DLC), 2019 WL 4994288, at *2 [SDNY Oct. 8, 2019]. The documents

were not translated into French, but that is not required for service pursuant to Article 10 (id.).

Article 10 permits service "by leaving the document in the care of a person who appears to be in

a position to give it to an officer or director or an agent of the legal person."

The affidavit of service describes Ms. Mastrangelo (her name was misspelled on the

affidavit of service) as an "ADMINISTRATIVE ASSISTANT and an authorized agent" of Via

Vegan. Via Vegan denies Mastrangelo was an agent or an administrative assistant, but does not

deny she was in a position to hand the papers to an officer, director, or agent of the company.

Via Vegan argues that the service was, nonetheless, ineffective and invalid, because Mastrangelo

never actually provided the summons and complaint to any officer, director, or agent of Via

Vegan. Via Vegan relies of the affirmation of Canadian attorney Michael Hollander (NYSCEF

Doc. No. 40) for his opinion that service is ineffective if the recipient does not actually give the

documents to an officer, director, or agent (id. at ii 10-11 ).

Hollander's affirmation relies on Genest v Bedard, 2019 QCCQ 2944, which was

attached to movant's papers in reply (Exhibit 2 to Affirmation of Laura E. Longobardi, NYSCEF

Doc. No. 60). Hollander's reliance is misplaced. The Genest case is distinguishable. There, the

papers had been served by handing them to individuals who did not work for Facebook Canada,

the target of the Request for Disclosure of Documents in that case. That court concluded that,

while service of the claim on Face book Canada was legal and valid, it was not shown to be

effective beyond a reasonable doubt, the elevated standard for a contempt proceeding, and that,

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in fact, service had been attempted on the wrong entity, as the demand should have been served

on Facebook Inc., not Facebook Canada.

Hollander also relies on 9277-3522 Quebec Inc. v GR Suspension Inc. (2011 QCCQ 424),

in which the recipient of service did not hand the documents to an officer, director, or agent of

the entity and the documents were not subsequently located after a search. Hollander explains

that, under these circumstances, the party who was served but never actually received the

documents may have the judgment against it revoked. In 9277-3522 Quebec Inc. (attached as

Exhibit l to Longobardi Aff., NYSCEF Doc. No. 59), the Canadian court considered whether the

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Related

Alfred E. Mann Living Trust v. ETIRC Aviation S.A.R.L.
78 A.D.3d 137 (Appellate Division of the Supreme Court of New York, 2010)

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Bluebook (online)
2024 NY Slip Op 33718(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/jtre-242-lafayette-llc-v-bsk-group-usa-ltd-nysupctnewyork-2024.