Optimal Strategic U.S. Equity Ltd. v. SPV OSUS Ltd.

CourtNew York Supreme Court
DecidedMarch 6, 2017
Docket2017 NYSlipOp 50284(U)
StatusPublished

This text of Optimal Strategic U.S. Equity Ltd. v. SPV OSUS Ltd. (Optimal Strategic U.S. Equity Ltd. v. SPV OSUS Ltd.) is published on Counsel Stack Legal Research, covering New York Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Optimal Strategic U.S. Equity Ltd. v. SPV OSUS Ltd., (N.Y. Super. Ct. 2017).

Opinion



Optimal Strategic U.S. Equity Ltd., Plaintiff,

against

SPV OSUS Ltd., Defendant.




653693/2014

Hunton & Williams LLP, New York City (Shawn Patrick Regan, Joseph J. Saltarelli, Samuel A. Danon, and Gustavo J. Membiela) and Smith, Buss & Jacobs, LLP, Yonkers, New York (John J. Malley) for plaintiff Optimal Strategic U.S. Equity Ltd.

Yetter Coleman LLP, Houston, Texas (R. Paul Yetter, Collin J. Cox, James E. Zucker, Autry W. Ross, and Elizabeth A. Wyman) and Law Office of Matthew C. Heerde, New York City (Matthew C. Heerde) for defendant SPV OSUS Ltd.
Saliann Scarpulla, J.

Motion sequence nos. 007 and 008 are consolidated for disposition. In motion sequence no. 007, plaintiff Optimal Strategic U.S. Equity Ltd. ("OSUS") moves, pursuant to CPLR 3212, for summary judgment on its claim for a declaration of the rights of the parties pursuant to a written assignment of claim the ("Assignment of Claim") dated May 6, 2011. Defendant SPV OSUS Ltd. ("SPV") also moves (seq. no. 008) for summary judgment in its favor.

Several years after the execution of the Assignment of Claim, a dispute arose between the parties regarding the scope of the rights that OSUS assigned to SPV. The sole issue before me is whether, in assigning to SPV its allowed claim in the liquidation proceeding of Bernard L. Madoff Investment Securities, LLC ("BLMIS") OSUS also assigned to SPV the right to sue certain third parties, such as OSUS's service providers. Both sides argue that the language of the assignment is unambiguous, rendering the matter ripe for summary judgment.



Background

OSUS is a trading company owned by Optimal Multiadvisors, Ltd. ("OML"), which is a Bahamian multi-portfolio investment company. All of OML's shares are [*2]owned by Optimal Investment Services, S.A. ("OIS"), a Swiss société anonyme, which is an indirect wholly-owned subsidiary of Banco Santander, S.A., a Spanish banking association ("Santander"). OIS also acted as a service provider to OSUS, having been appointed its investment manager. Other service providers included HSBC Institutional Trust Services (Ireland) Limited (HSBC Custodian), HSBC Securities (Ireland) Limited (HSBC Administrator), PricewaterhouseCoopers Ireland, and KB Associates. Substantially all of OSUS's assets were invested with an account at BLMIS.

Following the December 2008 collapse of BLMIS, Irving Picard was appointed the trustee of BLMIS's liquidation. The trustee demanded that OSUS return more than $151 million that it had redeemed out of its BLMIS account within the 90-day preference period. On May 22, 2009, OSUS settled the trustee's preference claim by agreeing to turn over 85% of the amount demanded in return for the trustee allowing OSUS's claim against BLMIS in the amount of $1,540,141,277.60, reduced from $2.9 billion (the "Allowed Claim").

After the settlement of the preference action and allowance of its claim, OSUS began to receive interest from distressed debt investors in purchasing the Allowed Claim. At the same time, because it was apparent that it would take several years for the trustee to close the liquidation proceedings, some OSUS investors expressed an interest in liquidating their position in OSUS. In November 2010, the Bankruptcy Court issued an order providing that an allowed claim could be assigned to a third party, but only in its entirety. This meant that OSUS could not sell off portions of its $1.5 billion Allowed Claim. SPV was created to bypass the Bankruptcy Court's order that a claim could only be assigned in its entirety.

On May 5, 2011, SPV was established as a "special purpose vehicle" under Bahamian law,[FN1] whereby investors in OSUS could convert their OSUS shares into shares of SPV, which the investors could either hold or sell. The transaction involved several steps. First, the entire Allowed Claim was assigned to SPV, in consideration of which OSUS received all of SPV's shares and SPV became a 100% subsidiary of OSUS. The directors of OML (who were the same directors of OSUS) comprised the initial board of directors of SPV.

Second, OSUS shareholders wishing to dispose of their interests in the Allowed Claim would redeem their OSUS shares in return for shares in SPV, representing the investor's pro rata share of the allowed claim. Upon completing the transaction, the former OSUS shareholders, now SPV shareholders, owned their pro rata share of the allowed claim as personal property (in the form of SPV shares), and were free to either keep the shares or sell them to third-party investors at auction.

On May 6, 2011, concurrent with the creation of SPV, the parties executed the Assignment of Claim, pursuant to which OSUS assigned to SPV the Allowed Claim and certain other rights. Section 1 of the Assignment of Claim defines the rights transferred [*3]thereunder, and provides, in pertinent part, that OSUS assigned to SPV:

"(a) an undivided 100% interest (the "Purchased Claim") in Assignor's right, title, and interest in and to the allowed claim filed by Assignor (the "Proof of Claim") in the proceedings under the Securities Investor Protection Act of 1970 in the United States Bankruptcy Court for the Southern District of New York, (the "Court"), concerning Bernard L. Madoff Investment Securities, LLC (in liquidation) ("Debtor"), Case No. 08-01789 (BRL) (the "Proceedings"),
(b) all rights and benefits of Assignor related to the Purchased Claim, including (i) any right to receive cash, securities, instruments, interest, penalties, fees or other property that may be paid or distributed with respect to the Purchased Claim, (ii) any action or claim (including any 'claim' as defined in 11 U.S.C. § 101 (5)) of any nature whatsoever, whether against the Debtor or any other party, arising out of or in connection with the Purchased Claim, (iii) voting rights, but only to the extent related to the Purchased Claim,
(c) all rights of Assignor under paragraph 13 of the [May 22, 2009 settlement agreement with the trustee],
(d) any other rights, action or claim arising out of the Assignor's investment in Debtor including, but not limited to, any claim the Assignor may have with respect to any current or future victim remission proceedings developed by the United States Department of Justice and
(e) any and all proceeds of any of the foregoing (collectively, as described in clauses (a), (b), (c), (d) and (e) the "Transferred Rights")."

(Cmplt., Ex. A [emphasis in original]).[FN2] Attached to the Assignment of Claim as Schedule 1 is a document entitled "Transfer of Allowed Claim" that was to be filed with the trustee. This form attaches a one-page document, also entitled "Assignment," which provides, in pertinent part, that SPV was assigned the Allowed Claim "together with any affirmative claims of the Assignor against third parties" (id.). Section 2.1 of the Assignment of Claim refers to these two documents as the "Transfer Form." However, Section 2.1 also states that "[n]othing in the Transfer Form shall supersede or alter the transactions contemplated by or the rights created under this Assignment" (id.).

On May 11, 2011, OIS organized, on OML's behalf, an auction for those interested in selling their SPV shares.

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

Related

Northern Assurance Co. of America v. EDP Floors, Inc.
533 A.2d 682 (Court of Appeals of Maryland, 1987)
Vermont Teddy Bear Co. v. 538 Madison Realty Co.
807 N.E.2d 876 (New York Court of Appeals, 2004)
Reiss v. Financial Performance Corp.
764 N.E.2d 958 (New York Court of Appeals, 2001)
Fox v. Hirschfeld
157 A.D. 364 (Appellate Division of the Supreme Court of New York, 1913)
NML Capital v. Republic of Argentina
952 N.E.2d 482 (New York Court of Appeals, 2011)
Rudman v. Cowles Communications, Inc.
280 N.E.2d 867 (New York Court of Appeals, 1972)
Chimart Associates v. Paul
489 N.E.2d 231 (New York Court of Appeals, 1986)
W.W.W. Associates, Inc. v. Giancontieri
566 N.E.2d 639 (New York Court of Appeals, 1990)
Cornhusker Farms, Inc. v. Hunts Point Cooperative Market, Inc.
2 A.D.3d 201 (Appellate Division of the Supreme Court of New York, 2003)
Aetna Casualty & Surety Co. v. Liberty Mutual Insurance
91 A.D.2d 317 (Appellate Division of the Supreme Court of New York, 1983)

Cite This Page — Counsel Stack

Bluebook (online)
Optimal Strategic U.S. Equity Ltd. v. SPV OSUS Ltd., Counsel Stack Legal Research, https://law.counselstack.com/opinion/optimal-strategic-us-equity-ltd-v-spv-osus-ltd-nysupct-2017.