Mark A. Scheinfeld v. Charles M. Cushing

CourtCourt of Appeals of Georgia
DecidedJuly 16, 2013
DocketA13A0820
StatusPublished

This text of Mark A. Scheinfeld v. Charles M. Cushing (Mark A. Scheinfeld v. Charles M. Cushing) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mark A. Scheinfeld v. Charles M. Cushing, (Ga. Ct. App. 2013).

Opinion

SECOND DIVISION BARNES, P. J., MILLER, and RAY, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules/

July 16, 2013

In the Court of Appeals of Georgia A13A0736. CUSHING v. COHEN et al. A13A0820. SCHEINFELD et al. v. CUSHING.

BARNES, Presiding Judge.

These two cases involve different plaintiffs and opposing trial court rulings but

the same defendants and the same three financial instruments. The issue in both

appeals is whether these instruments were securities under Georgia law or simply

investments in a common venture. The plaintiffs contend that the investments were

unregistered securities and that they are entitled to the return of the money they

invested. The defendants contend that the investments were simply real estate

development loans for which the plaintiffs must bear the loss. For the reasons that

follow, we conclude that the financial instruments at issue here are securities under

the Georgia Securities Act of 1973, OCGA § 10-5-1 et seq. The plaintiffs in both of these cases sued attorney Charles M. Cushing,

Palmetto Capital Corporation, and Mary Alice Ruben, as the executor of James

Ruben’s estate, as trustee and beneficiary of the James Ruben Jr. Trust, and

individually. They alleged that the financial instruments they purchased that were

related to three real estate development loans were unregistered securities, and sought

the return of their investments.

In Case No. A13A0736, the trial judge determined that the financial

instruments were securities under the Georgia Securities Act of 1973. Cushing

appeals the trial judge’s grant of summary judgment to the plaintiffs on the securities

issue and other rulings related to the statute of limitations, tolling, release, breach of

fiduciary duty, and derivative claims. In Case No. A13A0820, a different trial judge

held that the financial instruments were not securities but simply commercial loans.

Those plaintiffs appeal the trial court’s grant of summary judgment to Cushing on the

securities issue.

“On appeal from the grant or denial of a motion for summary judgment, we

conduct a de novo review of the law and evidence, viewing the evidence in the light

most favorable to the nonmovant, to determine whether a genuine issue of material

fact exists and whether the moving party was entitled to judgment as a matter of law.”

2 (Citation omitted.) Golden Atlanta Site Dev. v. Tilson, 299 Ga. App. 646, 649 (2) (683

SE2d 166) (2009).

So viewed, the record establishes that in the 1990s, James Ruben began putting

together real estate development loans that were made up of contributions from a

number of people. Initially the borrowers issued promissory notes and security deeds

that named every investor, but as the deals became larger with more investors, Ruben

hired the law firm of Cushing and Morris to incorporate Palmetto Capital Corporation

in 1993. Ruben could then have the borrowers issue the notes and deeds to Palmetto,

and when the loan was paid off Ruben would not have to obtain each investor’s

signature to cancel the deeds to secure debt.

James Ruben, Charles Cushing, and another attorney at the firm were the

original three shareholders, but Cushing and the other attorney sold their interest in

the corporation to Mary Alice Ruben in August 1998. Cushing was Palmetto’s

secretary and registered agent from 2003 to 2008. The corporation minutes reflect that

Palmetto’s board of directors repeatedly authorized Cushing in his capacity “as

general counsel, vice-president of the Corporation” to execute documents necessary

to complete transactions. In June 2003, Cushing executed an “incumbency certificate”

3 verifying his title and other corporate documentation for the benefit of a real estate

buyer and title company.

Ruben reviewed 20 to 40 investment deals before finding one “he would even

think twice about.” When Ruben found a deal he was interested in, he asked some of

his more sophisticated investors to look at the property and perform other due

diligence, for which they received a fee.1 Ruben would then talk to the potential

borrower, and if they reached an agreement, Ruben emailed details of the proposal

to his list of investors and invited them to participate. His messages would include

details about the property that would secure the loan, the identity of the borrower, and

the terms of the loan.

Once Ruben had a sufficient number of subscribers to meet his monetary goal,

he would direct them to send their investment to the law firm, which held the funds

in escrow, prepared the closing documentation, then closed the deal. The borrowers

gave Palmetto promissory notes and security deeds to the real property purchased

with the loans, and Palmetto in turn issued unsecured promissory notes to the

1 Ruben was diagnosed with ALS in 1995 and became progressively disabled physically until his death in 2007. He thus relied on other people to research some aspects of the deals he identified as interesting.

4 investors. Ruben received up to three percent of the total loan for putting the deals

together and Palmetto received one percent for servicing the loans.

The developers generally made monthly interest-only payments to Palmetto for

two or three years and then repaid the principle in a balloon payment. Palmetto paid

the investors their proportionate share of the monthly payments and sent the investors

monthly email updates about the projects. The investors received their principle back

when the developers made a balloon payment at the end of the loan period.

In 2003, a financial advisor for one of the investors asked Ruben whether the

promissory notes were actually securities. In response to questions from Ruben,

Cushing hired an expert in securities law to obtain a legal opinion about whether

these investments were securities under state and federal law. The expert concluded

that it was “highly likely that a court would deems these loan participations to be

securities.” He further opined that, because Ruben was a corporate officer, his

transactions were illegal because he was paying himself commissions but was not

registered as a securities dealer or salesperson under OCGA § 10-5-2 (25).

In response to the expert’s opinion that these financial transactions were

securities, Ruben advised Cushing that he would not make any more loans until the

security issue was settled and asked what Palmetto could do to become compliant

5 with securities laws. Cushing prepared a “Securities Analysis” memo, advising Ruben

that, while Palmetto could seek to qualify for a “private placement” exemption from

securities laws, the fees the investors paid to Palmetto might affect the company’s

ability to qualify for such an exemption. He also advised Ruben that the fees he and

Palmetto received would “run afoul” of the registration requirements for a securities

salesperson and broker, concluding that the structure of the deals presented

insurmountable problems in any attempt to obtain an exemption from securities

registration requirements.

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