Kamal v. Pressler, Felt & Warshaw, LLP

CourtDistrict Court, S.D. New York
DecidedMarch 25, 2025
Docket1:23-cv-10487
StatusUnknown

This text of Kamal v. Pressler, Felt & Warshaw, LLP (Kamal v. Pressler, Felt & Warshaw, LLP) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kamal v. Pressler, Felt & Warshaw, LLP, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT D DO AC TE # : F ILED: 3/25/2 025 SOUTHERN DISTRICT OF NEW YORK ANNETTE O. KAMAL and HANY M. KAMAL, individually, and on behalf of all others similarly situated, Plaintiffs, 1:23-cv-10487-MKV -against- OPINION & ORDER GRANTING MOTION TO DISMISS PRESSLER, FELT & WARSHAW, LLP and LVNV FUNDING LLC, Defendants. MARY KAY VYSKOCIL, United States District Judge: Plaintiffs Annette O. Kamal and Hany M. Kamal filed a complaint against Defendants Pressler, Felt & Warshaw, LLP (“Pressler”), and LVNV Funding LLC (“LVNV”) asserting claims on behalf of Plaintiffs and others similarly situated under the Fair Debt Collection Practices Act, 15 U.S.C. §§ 1692 et seq. (“FDCPA”), the Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C. §§ 1961-1968 (“RICO”), and the New York Consumer Fraud Act, NYGBL §§ 349, et seq. (“GBL”), arising from the allegedly defective service and subsequent fraudulent default judgment rendered against them in an action in New Jersey state court captioned, LVNV Funding LLC, Successor in Interest [Citibank, N.A. (AT&T), Original Creditor] v. Annette O. Kamal, No. MON-DC-009195-22 (the “Collection Action”). This case is in essence a collateral attack on the state court proceeding. Defendants move to dismiss the operative amended complaint for lack of standing pursuant to Rule 12(b)(1) of the Federal Rules of Civil Procedure, for lack of personal jurisdiction pursuant to Rule 12(b)(2), for failure to state a claim and under the doctrines of res judicata and collateral estoppel pursuant to Rule 12(b)(6), and because the claims are barred by the abstention doctrines of Rooker-Feldman and Colorado River. For the reasons below, the motion to dismiss is GRANTED. FACTUAL BACKGROUND1 Defendant Pressler, Felt & Warshaw, LLP (“Pressler”) is a law firm that has filed

thousands of consumer credit actions, or debt collection actions, throughout New York, New Jersey, and Pennsylvania on behalf of buyers of debt. FAC ¶¶ 2, 52. Pressler represents LVNV, an investor in domestic and international debt, in most of the debt collection lawsuits it brings. FAC ¶¶ 2–3. The vast majority of these lawsuits result in default judgments in favor of LVNV. FAC ¶ 3.2 Nearly a decade ago, the Consumer Financial Protection Bureau instituted a $1 million penalty against Pressler’s predecessor, Pressler & Pressler LLP, and its two principal partners Sheldon Pressler and Gerard Felt. for their role in filing deceptive debt collection lawsuits on behalf of a debt buyer, New Century Financial Service, Inc. FAC ¶ 4. Pressler & Pressler later reorganized as Pressler, Felt & Warshaw LLP, one of the defendants here. FAC ¶ 4. According to

Plaintiffs, Defendants practice “sewer service” by filing lawsuits to collect purchased debt, and failing properly to serve the summons and complaint, and then filing fraudulent affidavits of service to achieve default judgments. FAC ¶¶ 6–7. After Defendants obtain default judgments, they seek to enforce them by restraining bank accounts, garnishing wages, or threatening to seize personal property. FAC ¶ 8.

1 The facts as stated herein are drawn from Plaintiff’s First Amended Complaint [ECF No. 21] (“FAC”), and for purposes of this motion, are accepted as true. See Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Some of the facts asserted in this section are contrary to findings in a prior opinion in the Collection Action. The Court addresses this issue later in the opinion. 2 Pressler is a New Jersey Limited Liability Partnership with a principal place of business in Morris County, New Jersey and LVNV Funding, LLC is a Delaware Limited Liability Company with a principal place of business in New Castle County, Delaware. FAC ¶¶ 17–18 In February 2023, LVNV brought a lawsuit through its attorneys at Pressler against Plaintiff Annette Kamal in Superior Court of New Jersey (the “Collection Action”). FAC ¶ 55. Pressler affirmed that it had sent a copy of the summons and complaint to Annette Kamal via U.S. mail to an address in New Jersey (the “New Jersey address”) and affirmed that service was proper.

FAC ¶ 57. Hany and Annette Kamal are a married couple who have lived in New York County since 1968. FAC ¶¶ 14, 54, 56. Annette is 91 and Hany is 83. FAC ¶ 54. Hany and Annette Kamal allege that they have never been residents of New Jersey and were never served with a summons and complaint in the Collection Action. FAC ¶ 56. They allege that Pressler had “no reasonable basis for claiming valid service would be, could be, or was actually achieved by mailing documents to the New Jersey address.” FAC ¶ 57. When Annette Kamal did not appear in the Collection Action, Defendants obtained a default judgment against her. FAC ¶ 58; [ECF No. 26 (“DiCicco Decl.”) Ex. G (“Default Judgment”)]. Plaintiffs allege the motion for a default judgment and the resulting default judgment

also were not properly served. FAC ¶ 58. Defendants sought to enforce the judgment by attaching Annette’s personal account at her NYC Chase Bank account. FAC ¶ 58. This is how Annette and Hany Kamal became aware of the judgment in the Collection Action. FAC ¶ 58. Several months after the Collection Action was commenced, Plaintiff filed this action bringing claims against Pressler and LVNV. [ECF No. 1 (“Compl.”)]. Plaintiffs allege that about a month later Pressler learned Annette Kamal did not and never had resided in New Jersey, rendering false its affidavits of service. FAC ¶ 59. On December 11, 2023, Pressler advised the New Jersey Court that Plaintiff’s “address provided on the writ for the defendant is no longer valid as the defendant has relocated,” and called Kamal’s New York City address her “new home address,” suggesting that the New Jersey address was valid at the time of service. FAC ¶ 59 (emphasis added); [ECF No. 32 (“Kamal Decl.”) Ex. B (“Address Change Notice”)].3 Rather than notifying the New Jersey Court that Annette Kamal had never lived at the New Jersey address and seeking to have the judgment set aside, Pressler and LVNV asked the Court for leave to serve the

default judgment on Annette Kamal at her New York residence. FAC ¶ 59; Address Change Notice. In March 2024, while briefing on Defendants’ motion to dismiss was ongoing in this action, the New Jersey Court granted Annette Kamal’s motion to vacate the Default Judgment in the Collection Action. Kamal Decl. Ex. C (“Vacating Order”). The New Jersey Court held that “the Court is convinced that Defendant was not properly served with notice of the legal proceeding.” Id. at 6. However, soon after, the New Jersey Court held that Annette Kamal’s attorney—one of the attorneys who represents Plaintiffs here—had committed unauthorized practice of law by filing the motion to vacate and thus granted a motion filed by LVNV to reconsider the Vacating Order. [ECF No. 33 (“DiCicco Aff.”) Ex. 2 (“LVNV Mot. for Reconsideration”)]; [ECF No. 35

(“Defendants’ Supp. Letter”), Ex. A]. The New Jersey Court allowed Annette sixty days to file a proper motion to vacate. Defendants’ Supp. Letter Ex. A. In July 2024, the New Jersey Court denied Annette Kamal’s second motion to vacate. [ECF No. 35, Ex. A (“July Order”)]. In doing so, the Court applied New Jersey Rule of Court 4:50-1 which sets out several permitted reasons for relieving a party from a final judgment including that “the judgment or order is void[.]” The Court ruled that the Default Judgment was not void based on ineffective service. Id. at 5–6. In fact, the Court affirmatively found that “[s]ervice was

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Parklane Hosiery Co. v. Shore
439 U.S. 322 (Supreme Court, 1979)
Burger King Corp. v. Rudzewicz
471 U.S. 462 (Supreme Court, 1985)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Chloé v. Queen Bee of Beverly Hills, LLC
616 F.3d 158 (Second Circuit, 2010)
Hess v. Cohen & Slamowitz, LLP
637 F.3d 117 (Second Circuit, 2011)
Penachio v. Benedict
461 F. App'x 4 (Second Circuit, 2012)
Natalia Makarova v. United States
201 F.3d 110 (Second Circuit, 2000)
Isabella Ferrelli v. River Manor Health Care Center
323 F.3d 196 (Second Circuit, 2003)
Gabriele v. American Home Mortgage Servicing, Inc.
503 F. App'x 89 (Second Circuit, 2012)
MacDermid, Inc. v. Deiter
702 F.3d 725 (Second Circuit, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Kamal v. Pressler, Felt & Warshaw, LLP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kamal-v-pressler-felt-warshaw-llp-nysd-2025.