LOVATO v. NIXON PEABODY LLP

CourtUnited States Bankruptcy Court, D. Nevada
DecidedSeptember 22, 2022
Docket21-05072
StatusUnknown

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

Bluebook
LOVATO v. NIXON PEABODY LLP, (Nev. 2022).

Opinion

& SOX (2). Honorable Gary Spraker oth United States Bankruptcy Jud nited States Bankruptcy Judge eee Entered on Docket September 22, 2022 NITED STATES BANKRUPTCY COGRE □□ DISTRICT OF NEVADA In re: Lead Case No.: 19-50102-gs DOUBLE JUMP, INC., Chapter 7 Debtor(s). Substantively Consolidated With: 19-50130-gs_| DC Solar Solutions, Inc. Affects: 19-50131-gs_ | DC Solar Distribution, Inc. X__DC Solar Solutions, Inc. 19-50135-gs | DC Solar Freedom, Inc. X DC Solar Distribution, Inc. X DC Solar Freedom, Inc. Double Jump, Inc. Adv. Proc. No.: 21-05072-gs CHRISTINA W. LOVATO, Hearing Date Plaintiff(s), Date: June 3, 2022 Time: 9:30 a.m. Vv. NIXON PEABODY LLP, Defendant(s).

MEMORANDUM DECISION ON DEFENDANT’S MOTION TO DISMISS Plaintiff Christina Lovato, chapter 7 trustee for the substantively consolidated bankruptcy estates (Trustee), sues Nixon Peabody LLP (Nixon) for professional malpractice, breach of fiduciary duty, aiding and abetting the breach of fiduciary duty, to recover fraudulent transfers, and to deny its proof of claim. Nixon seeks partial dismissal of these claims on the theories of in pari delicto and mootness. Motion to Dismiss Counts I-IV and VIII of the Complaint (Adv. ECF No. 43) (Motion to Dismiss). It contends that the debtors were just as, if not more, culpable for

the wrongdoing at the heart of the complaint, and thus are barred from recovering against Nixon. The Trustee has opposed the Motion to Dismiss (Adv. ECF No. 84) (Opposition), arguing that in pari delicto is inapplicable to her claims. She further contends that even if it did apply, dismissing her claims at the pleading stage is premature. For the reasons stated below, this court will enter an order denying the Motion to Dismiss in part as to counts I-IV. In light of Nixon’s withdrawal of its proof of claim, the court will grant the Motion to Dismiss as to count VIII of the Complaint because the relief requested by the Trustee is moot. Facts DC Solar Solutions, Inc. (Solutions) would manufacture the MSGs then sell the MSGs to buyers, usually investment funds. Enticed by federal investment tax credits generated from the purchase, use, and ultimate depreciation of the MSGs, buyers would make a down payment of $45,000.00 on a $150,000.00 purchase price. The remainder of the purchase price was wrapped into a twenty-year note obligation payable to Solutions. These note payments were to be funded by leasing the MSGs to third parties. The buyers leased the MSGs to DC Solar Distribution, Inc. (Distribution), who, in turn, would sublease their MSGs to third parties. The sublease payments were to be used to pay the buyers’ note obligations to Solutions. DC Solar Freedom, Inc. (Freedom) was established in 2014 to market the MSGs and generate additional revenue by placing them in public spaces in a socially conscious way. The Trustee alleges that the debtors’ founder and executive Jeff Carpoff used the debtors to perpetrate a Ponzi scheme. The Trustee alleges that Solutions sold, and Distribution leased, far more MSGs than actually existed. This necessarily meant that Distribution was subleasing MSGs that did not exist and were not actually generating payments on those subleases. Instead, the trustee alleges that Carpoff sent new purchase monies paid to Solutions by new buyers/funds to Distribution to cover the accruing sublease payments owed to existing prior buyers/funds. These funds were then recycled back to Solutions. The complaint also alleges that Carpoff used the debtors to fund a lavish lifestyle for himself, furthering the illusion that the debtors were profitable. Based on this scheme, the Trustee alleges that the debtors were insolvent at all material times. Between 2010 and 2018, Nixon provided legal advice on tax issues to Solutions and Distribution, as well as to non-debtors Solarmore Investment Services, Inc., Solarmore Management Services, Inc. and Halo Management Services, LLC. Each of these non-debtors were managing members of certain investment funds that purchased the MSGs (Funds).1 Under the debtors’ business model, the primary benefit to the buyers/funds was the tax credits they received for owning the MSGs. Among other things, Nixon assisted Solutions and Distribution with the tax advantaged transactions, including preparation of tax opinion letters provided at the close of purchase, which served as Nixon’s endorsement of those transactions. Included in the tax opinion letters were representations about the business structure, such as the use of lease revenue by the buyers/funds to pay Solutions and the leasing of MSGs to end users. As the years progressed, Carpoff’s alleged Ponzi scheme began to unravel. The Trustee alleges: After a particular DC Solar senior executive discovered that certain other DC Solar insiders were committing wrongdoing, he left DC Solar’s employ. This person discussed with another former DC Solar employee about how to stop the wrongdoing, and both took active steps to do so. At least one of them became a “whistleblower” with federal law enforcement, resulting in the Raid. Complaint, Adv. ECF No. 1, pp. 7:27-8:3. Federal law enforcement raided the debtors’ California headquarters on December 18, 2018. The Trustee contends that after the raid, the debtors were accused of operating a Ponzi scheme, and subsequently made certain changes to their corporate structure. Most significantly, they appointed Daniel Briggs, then-president of Freedom, as president of Solutions and Distribution, and retained GlassRatner Advisory & Capital Group, LLC to act as chief

1 According to the Complaint (defined below), “The buyers were typically tax-equity funds, 99% owned by a financial investor seeking federal investment tax credits… After five years, ownership of the buyer would be (largely) transferred from the investor to the managing member, an entity affiliated with or controlled by Carpoff.” Complaint, Adv. ECF No. 1, p. 5:8- 15. restructuring officer. Ultimately, the debtors filed for bankruptcy between January 31, 2019 and February 5, 2019. Post-petition, the Trustee sought and obtained an order substantively consolidating the debtors’ bankruptcy cases under the Double Jump, Inc. bankruptcy. As for Carpoff, he has entered into a plea agreement in the federal criminal action against him brought in the Eastern District of California and is serving a prison sentence for his role in the alleged Ponzi scheme. On March 4, 2019, Nixon filed proof of claim no. 34-1 in Solutions’ bankruptcy case, seeking $111,223.95 for pre-petition legal services. On October 25, 2021, the Trustee commenced this proceeding against Nixon. The Trustee’s allegations are rooted in the pre- petition tax advice Nixon provided to Solutions and Distribution from 2010 to 2018. The Trustee’s detailed complaint (Complaint) alleges causes of action for: (I) professional malpractice; (II) breach of fiduciary duty; (III) aiding and abetting breach of fiduciary duty; (IV) co-conspirator to breach of fiduciary duty; (V) constructive fraudulent transfer and (VI and VII) avoidance of fraudulent transfers, seeking to recover legal fees paid to Nixon; and (VIII) disallowance of Nixon’s proof of claim. Nixon responded to the Trustee’s Complaint with, among other motions and requests, the Motion to Dismiss. According to Nixon, the Trustee stands in the shoes of Solutions and Distribution and cannot recover from Nixon for its alleged role in Carpoff’s alleged Ponzi scheme. Nixon also contends that count VIII objecting to its proof of claim should be dismissed as moot because it intended to withdraw that claim.2 In her Opposition, the Trustee contends that the in pari delicto defense is inapplicable to the Complaint as a matter of law because Nixon benefitted from Carpoff’s wrongdoing.

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Bluebook (online)
LOVATO v. NIXON PEABODY LLP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lovato-v-nixon-peabody-llp-nvb-2022.