M. COHEN AND SONS, INC. v. PLATTE RIVER INSURANCE COMPANY

CourtDistrict Court, D. New Jersey
DecidedJuly 7, 2025
Docket3:20-cv-02149
StatusUnknown

This text of M. COHEN AND SONS, INC. v. PLATTE RIVER INSURANCE COMPANY (M. COHEN AND SONS, INC. v. PLATTE RIVER INSURANCE COMPANY) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
M. COHEN AND SONS, INC. v. PLATTE RIVER INSURANCE COMPANY, (D.N.J. 2025).

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

M. COHEN AND SONS, INC.,

Plaintiff, Civil Action No. 20-2149 (ZNQ) (RLS) v. OPINION PLATTE RIVER INSURANCE COMPANY,

Defendant,

ALLEN COHEN, et al., Counterclaim Defendants.

QURAISHI, District Judge THIS MATTER comes before the Court upon a Report and Recommendation that granted Defendant/Counterclaim-Plaintiff Platte River Insurance Company’s (“Platte River”) Motion to Strike (“Motion to Strike,” ECF No. 268) and recommended striking a portion of the Nineteenth Affirmative Defense asserting fraud. (ECF No. 295.) Plaintiff/Counterclaim-Defendant M. Cohen & Sons, Inc. (“MCS”) and Counterclaim Defendants Allen Cohen, Susan Cohen, Eileen Cohen, Ronald Cohen, Barbara Cohen, Samuel Cohen, Janet Cohen, H.R. Reed Road, L.P., Penmawr, L.P., H.R. Sarasota LLC, and Penmawr FLA, LLC (collectively, the “MCS Defendants”) filed an objection to the Report and Recommendation. (“Objection,” ECF No. 300.) Platte River filed a Response to the Objection. (“Response,” ECF No. 302.) The Court has carefully considered the parties’ submissions and decides the Motion without oral argument pursuant to Federal Rule of Civil Procedure 78 and Local Civil Rule 78.1. For the reasons set forth below, the Court will ADOPT the Report and Recommendation in its entirety. I. BACKGROUND AND PROCEDURAL HISTORY The Court assumes the parties’ familiarity with the underlying facts and procedural history and only recites those facts necessary to decide the instant motion. For a comprehensive review

of the factual and procedural history, reference is made to the underlying decision from the Honorable Rukhsanah L. Singh, U.S.M.J. (the “Magistrate Judge”). M. Cohen & Sons, Inc. v. Platte River Ins. Co., Civ. No. 20-2149, 2024 WL 1773619, at *1 (D.N.J. Mar. 25, 2024). (“Opinion,” ECF No. 295.) The parties to this matter are contractors, subcontractors, and an insurance company who entered into a General Indemnity Agreement (“GIA”) for a construction project where Platte River served as MCS’s surety and agreed to provide bonds for MCS’ projects. (“Second Amended Complaint (“SAC”),” ECF No. 183, ¶¶ 17–19.) Pursuant to the GIA, MCS agreed to indemnify Platte River for losses incurred on any bonds issued. (Id. ¶ 20.) W.S. Cumby, Inc. (“Cumby”) is

the general contractor and party to a 2018 construction contract in Princeton, New Jersey, with MCS. (Id. ¶ 26.) On October 26, 2018, MCS secured a performance bond issued by Platte River in the amount of $3,508,849 with respect to the Princeton construction project. (Id. ¶ 22.) After performance, MCS alleges that Cumby breached the construction agreement, which, in turn, meant that Platte River was not required to act under the performance bond. (Id. ¶¶ 36–44.) In June 2019, Cumby notified Platte River that it was considering whether to submit a claim under the performance bond, which it ultimately did in November 2019. (Id. ¶ 66.) Unrelated, in July 2019, Platte River reviewed MCS’s books and records, using a consultant, Forcon International (“Forcon”), because MCS requested another performance bond for another project. (Id. ¶ 68.) MCS alleges that despite being financially strong, Platte River refused to issue new bonds, in part because of Cumby’s pending claim. (Id. ¶ 71.) Ultimately, after Cumby formally filed its claim, Platte River and Cumby entered into a tender agreement, whereby Platte River agreed to pay Cumby $3,400,000.45 and obtained an assignment of Cumby’s claims against MCS. (Id. ¶¶ 170– 172.) As a result of the above, MCS filed this action.

The relevant procedural history, as set forth in the Magistrate Judge’s Opinion, is reproduced below: On February 27, 2020, MCS filed this action against Platte River alleging claims for: (1) breach of the performance bond; (2) breach of the implied covenant of good faith and fair dealing; (3) a declaratory judgment; and (4) tortious interference with contractual relations. (See generally ECF No. 1). On June 15, 2020, MCS filed its First Amended Complaint (“FAC”), naming Cumby as a Defendant and adding a fifth count alleging a violation of the Defend Trade Secrets Act (“DTSA”), 18 U.S.C. §§ 1836 et seq. (See generally ECF No. 24).

On July 6, 2020, Platte River filed its Answer and Counterclaims against the MCS Defendants, asserting claims for specific performance of the General Indemnity Agreement, breach of the General Indemnity Agreement, common law indemnity, and recovery of attorneys’ fees pursuant to the General Indemnity Agreement (the “Counterclaims”). (ECF No. 37). On August 10, 2020, the MCS Defendants filed their Answer to the Counterclaims, asserting eighteen Affirmative Defenses, none of which involved fraud. (ECF No. 53).

Following substantial discovery and a contested motion for leave to amend, with the Court’s leave, MCS filed a Second Amended Complaint (“SAC”) on November 9, 2022. (ECF No. 179; see also ECF No. 183 (public SAC)). Platte River filed its Answer and Counterclaims in response to the SAC on June 23, 2023. (ECF No. 255). Platte River did not amend its Counterclaims in response to the SAC. (See ECF No. 255). On July 21, 2023, the MCS Defendants filed their Answer, Affirmative Defenses, and Jury Demand in response to the Counterclaims. (ECF No. 262). Without having sought prior leave to do so, the MCS [Defendants] added a new affirmative defense not previously asserted through their Nineteenth Affirmative Defense, which asserts that “Platte River’s Counterclaims are barred by its bad faith and fraud.” (ECF No. 262 at 19).

(Opinion at 5–6.) The issue before the Magistrate Judge was whether to grant or deny Platte River’s Motion to Strike the MCS Defendants’ Nineteenth Affirmative Defense of fraud.1 (ECF No. 268.) In a well-reasoned and thoughtful decision, the Magistrate Judge recommended granting the Motion to Strike because the allegations pertaining to the affirmative defense of fraud in the SAC failed to “rise to the level of meeting the particularized pleading standard of Rule 9(b).” (Opinion at 11–12.) Specifically, the Court found that the SAC did not identify who made the representations, to whom they were made, and simply “lack[ed] any precision or some measure of substantiation to support a fraud allegation as required by Rule 9(b).” (Id. at 12 (quotation marks omitted).) The Magistrate Judge further found that allowing the affirmative defense of fraud to proceed would unduly prejudice Platte River because it came three years after the original counterclaims and after factual discovery had been substantially completed. (Id. at 13.) The Magistrate Judge also recommended that the MCS Defendants’ alternative request for leave to amend its Answer and Affirmative Defenses to the Counterclaims be denied. (Id. at 13–14.)2 The MCS Defendants filed a timely objection to the Report and Recommendation. II. LEGAL STANDARD When a magistrate judge addresses motions that are considered “dispositive,” a magistrate judge will submit a Report and Recommendation to the district court. 28 U.S.C. § 636(b)(1)(A);

1 The nature of the fraud defense is, in essence, that Platte River’s investigation of the bond claim by Cumby was “a sham” or not “bona fide” and that Platte River misrepresented the status of its investigation. 2 The Magistrate Judge conducted a review of whether leave to amend would have been granted in the first instance had it been properly sought.

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

Related

Frederico v. Home Depot
507 F.3d 188 (Third Circuit, 2007)
United States v. Lightman
988 F. Supp. 448 (D. New Jersey, 1997)
Dewey v. VOLKSWAGEN AG
558 F. Supp. 2d 505 (D. New Jersey, 2008)
Tyco Fire Products LP v. Victaulic Co.
777 F. Supp. 2d 893 (E.D. Pennsylvania, 2011)
Gasperini v. Center for Humanities, Inc.
518 U.S. 415 (Supreme Court, 1996)
Bruno, D., Aplts. v. Erie Insurance
106 A.3d 48 (Supreme Court of Pennsylvania, 2014)
Giles v. Phelan, Hallinan & Schmieg, L.L.P.
901 F. Supp. 2d 509 (D. New Jersey, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
M. COHEN AND SONS, INC. v. PLATTE RIVER INSURANCE COMPANY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/m-cohen-and-sons-inc-v-platte-river-insurance-company-njd-2025.