Loray Master Tenant, LLC v. Foss N.C. Mill Credit 2014 Fund I, LLC

2021 NCBC 12
CourtNorth Carolina Business Court
DecidedFebruary 18, 2021
Docket19-CVS-1024
StatusPublished

This text of 2021 NCBC 12 (Loray Master Tenant, LLC v. Foss N.C. Mill Credit 2014 Fund I, LLC) is published on Counsel Stack Legal Research, covering North Carolina Business Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Loray Master Tenant, LLC v. Foss N.C. Mill Credit 2014 Fund I, LLC, 2021 NCBC 12 (N.C. Super. Ct. 2021).

Opinion

Loray Master Tenant, LLC v. Foss N.C. Mill Credit 2014 Fund I, LLC, 2021 NCBC 12.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION GASTON COUNTY 19 CVS 1024

LORAY MASTER TENANT, LLC, and JOSEPH LENIHAN,

Plaintiffs,

v. ORDER AND OPINION ON DEFENDANT GOVERNMENT FOSS N.C. MILL CREDIT 2014 EMPLOYEES INSURANCE FUND I, LLC; FOSS AND COMPANY, INC.; and COMPANY’S MOTION TO DISMISS GOVERNMENT EMPLOYEES INSURANCE COMPANY,

Defendants.

1. THIS MATTER is before the Court on Defendant Government Employees

Insurance Company’s (“GEICO”) Motion to Dismiss (the “Motion” or “Motion to

Dismiss”) pursuant to Rule 12(b)(6) of the North Carolina Rules of Civil Procedure

(“Rule(s)”). (ECF No. 14.)

2. This case arises from Defendant Foss N.C. Mill Credit 2014 Fund I, LLC’s

(“Foss 2014”) alleged failure to timely pay certain obligations in exchange for the right

to claim state and federal tax credits that Plaintiff Loray Master Tenant, LLC

(“Loray”) generated while developing historic property. Plaintiffs allege that GEICO,

an investor in Foss 2014, asserted domination and control over Foss 2014 and its

decision to delay required payments to Loray and thus should be held liable for Foss

2014’s alleged actions that underlie Plaintiffs’ claims.

3. Having considered the Motion, the related briefing, and the arguments of

counsel at the hearing on the Motion, the Court hereby GRANTS the Motion and

DISMISSES Plaintiffs’ claims against GEICO with prejudice. Rosenwood, Rose & Litwak, PLLC, by Nancy S. Litwak, Carl J. Burchette, Erik M. Rosenwood, and Ryan Michael Arnold, for Plaintiffs Loray Master Tenant, LLC and Joseph Lenihan.

Blanco Tackaberry & Matamoros, P.A., by Peter J. Juran and Chad A. Archer, for Defendants Foss N.C. Mill Credit 2014 Fund I, LLC and Foss and Company, Inc.

Williams Mullen, by Camden R. Webb and Lauren E. Fussell, for Defendant Government Employees Insurance Company.

Bledsoe, Chief Judge.

I.

FACTUAL BACKGROUND

4. The Court does not make findings of fact on a motion to dismiss under Rule

12(b)(6), reciting instead only those facts in the Amended Complaint relevant to the

Court’s determination of the Motion.

5. The Loray Mill (the “Mill”) is a large-scale urban revitalization and historic

preservation project located in Gastonia, North Carolina. (First Am. Compl.

[CORRECTED] ¶ 10 [hereinafter “Am. Compl.”], ECF No. 32.) 1 Loray is the

developer and managing member of Loray Mill Redevelopment, LLC, the entity that

owns the Mill. (Am. Compl. ¶ 11.)

6. The Mill was developed in part through the use of historic tax credits

granted by North Carolina and the federal government to developers who restore

historic buildings. (Am. Compl. ¶ 12.) Because developers cannot sell tax credits

outright under North Carolina law, Loray sought investors to make capital

1 The Court refers to the corrected version of the Amended Complaint filed on January 11,

2021 and located at ECF No. 32 for purposes of this Order and Opinion. contributions in exchange for the right to use the tax credits generated by the project.

(Am. Compl. ¶¶ 14–15.)

7. On or about March 27, 2013, Loray entered into an operating agreement

with various entities that agreed to become members of Loray and make investments

in the Mill in exchange for the right to claim the tax credits the Mill generated. (Am.

Compl. ¶ 16.) These investors included Chevron TCI, Inc. (“Chevron”), as well as Foss

2014 and Foss N.C. Mill Credit 2011 Fund I, LLC (“Foss 2011”), entities created by

Defendant Foss and Company, Inc. (“Foss”). (Am. Compl. ¶¶ 17–18.)

8. Pursuant to the operating agreement, Loray was to obtain loans to fund

construction of the Mill. (Am. Compl. ¶ 25.) When tax credits were generated, Loray

was to pass them through to Foss 2014 and the other Loray investors, which were to

then pass those credits on to customers. (Am. Compl. ¶ 25.) The customers, including

Foss 2014’s customer, GEICO, were then to make payments to Loray through the

investing entities. (Am. Compl. ¶ 25.)

9. To effectuate this plan, Loray borrowed $8,300,000 (the “Bridge Loan”) from

Central State Bank (“CSB”) in March 2013. (Am. Compl. ¶¶ 26–28.) According to

Plaintiffs, “it was understood by all parties that the Bridge Loan . . . would be paid

off via Defendants[.]” (Am. Compl. ¶ 27.)

10. In early March 2016, Loray notified Foss that payment was due in return

for the tax credits Foss 2014 had already received and passed through to GEICO.

(Am. Compl. ¶ 32.) On March 11, 2016, Foss suggested a new funding agreement

(the “Agreement”) that would allow Loray to pay off the Bridge Loan with investor payments. (Am. Compl. ¶ 34.) On March 22, 2016, Loray, Foss 2014, Foss 2011, and

CSB entered into the Agreement. (Am. Compl. ¶ 36.) The Agreement provided that

Foss 2014 would fund approximately $4,000,000 upon the signing of a settlement

agreement between Loray and its general contractor, with which Loray had an

ongoing dispute. (Am. Compl. ¶ 34.) Foss 2011 agreed to pay approximately

$3,000,000. (Am. Compl. ¶ 42.) The Agreement did not set any other conditions or

limitations on Foss 2014’s payment obligation. (Am. Compl. ¶ 34.)

11. On or about March 23, 2016, Foss 2011 wired the full amount it owed to

Loray, completing its obligation under the Agreement. (Am. Compl. ¶ 45.) However,

Foss 2014 failed to pay its capital contributions because, as Plaintiffs allege,

“G[EICO] was unwilling to fund its obligations.” (Am. Compl. ¶ 46.) In response, on

or about March 29, 2016, Loray requested an update on payment and confirmed that

it had entered into a settlement agreement with its general contractor the prior week,

partially resolving their dispute. (Am. Compl. ¶ 47; see Am. Compl. Ex. I.) Foss

responded that it was waiting for Foss 2014’s investor approval. (Am. Compl. ¶ 47.)

12. Foss 2014 then introduced a series of preconditions it required before it

would make its payment. According to Plaintiffs, GEICO was the driving force

behind these actions and caused Foss 2014 to “backpedal,” “first by trying to trick

[Loray] into rescinding or amending the fully enforceable [Agreement], and/or

beginning to invent preconditions to funding the capital account.” (Am. Compl. ¶ 48.)

13. First, Plaintiffs allege that on March 31, 2016, Foss claimed that the signed

Agreement contained an error, (Am. Compl. ¶ 50), and on April 1, 2016, Foss attempted to rescind the Agreement by circulating a revised contract that would have

“substantially changed” payment obligations, (Am. Compl. ¶ 49). Loray refused to

sign the revised document. (Am. Compl. ¶ 53.)

14. According to Plaintiffs, “Foss then pivoted to creating a series of roadblocks

and arbitrary conditions to funding, none of which were set forth in the [Agreement].”

(Am. Compl. ¶ 55.) On or about April 19, 2016, Foss indicated that Foss 2014’s

investor would not make its payment until the Mill was lien-free. (Am. Compl. ¶ 56.)

Loray worked through May and June to resolve all liens on the Mill filed by its

subcontractors. (Am. Compl. ¶ 59.) Foss then indicated that it needed a title

endorsement proving the Mill to be lien-free, which Loray obtained and forwarded to

Foss on or about June 21, 2016. (Am. Compl. ¶¶ 59–60.)

15. Next, Foss expressed concerns that Loray’s ongoing dispute with its general

contractor could result in a future lien. (Am. Compl.

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