Palm Court, Inc. v. Durham

29 Fla. Supp. 2d 14
CourtCircuit Court for the Judicial Circuits of Florida
DecidedMarch 28, 1988
DocketCase Nos. 86-9123 (CL) F and 86-3885 (CL) F
StatusPublished

This text of 29 Fla. Supp. 2d 14 (Palm Court, Inc. v. Durham) is published on Counsel Stack Legal Research, covering Circuit Court for the Judicial Circuits of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Palm Court, Inc. v. Durham, 29 Fla. Supp. 2d 14 (Fla. Super. Ct. 1988).

Opinion

OPINION OF THE COURT

DANIEL T. K. HURLEY, Circuit Judge.

MEMORANDUM OPINION

THIS CASE was tried before the court in a five-week bench trial. Gerald Richman, Esq. and Michael Hanzman, Esq. represented the investors-unit owners (the “unit owners”); William Hoppe, Esq., Angela Hoppe, Esq. and James Crabtree, Esq., represented Palm Court, Inc. and its principals (“PCI”).

[15]*15 THE “FIRST WAVE”

Before setting forth the court’s findings of fact and conclusions of law, a word is in order about the present posture of the case. This action began when PIC filed a complaint to foreclose sixty-six notes and mortgages which it claimed to have received during the sale and purchase of sixty-six condominium units in the Palm Court Hotel in Palm Beach, Florida. The unit owners counterclaimed for recission, contending that the hotel interests were securities which had been sold in violation of state and federal law.

As the case progressed, it expanded and took on a whirlpool-like quality. Attendance at hearings grew as new parties with batteries of lawyers were swept into the litigation malestrom. Early on, the parties stipulated to a “first wave” proceeding to resolve the claims between PCI and the unit owners. Later, the focus was limited to securities issues.

A pretrial conference was held shortly before trial. There, the court granted a motion to sever and reduce the number of unit owners in the “first wave” to ten. For a time, Carteret Savings and Loan Association (“Carteret”) also was a party in the “first wave.” During trial, however, it reached a settlement with the unit owners and all claims were dismissed.

Prior to trial the court ruled that recission and foreclosure are equitable actions, triable to the court. Thus, PCI’s motion for a jury trial on these issues was denied. Trial exhibits are cited in this opinions as follows: Unit Owners . . . “UO # — Palm Court Inc. . . . “PCI # — and Carteret. . . “C # — ”.

Based upon the credible testimony and evidence presented, the court makes the following

FINDINGS OF FACT

I. The Concept

Carl Sax came to Florida in the mid-1970s to work as a developer/ syndicator. Previously, he had worked with an established New York law firm where he did securities work and provided corporate representation for the firm’s multi-national clients. Development and syndication, according to Sax, are related but distinct endeavors. Development entails the orchestration of a construction project. Syndication, on the other hand, involves the acquisition of property and the sale of interests in the property via a private placement memorandum. Usually [16]*16the interests take the form of limited partnerships with substantial tax-oriented benefits, i.e., tax shelters.

By 1984 Sax had been involved in several projects in southern Palm Beach County. As a result, he had a working relationship with at least two local lending institutions. Carteret Savings and Loan Association regarded him as “one of its premier borrowers.” Robert V. Giggs, the chairman and chief executive officer of Southern Floridabanc, described him as “a good client.”

It was about this time, 1984, that Sax heard about the Royal Park Hotel in Palm Beach. This sixty-six-room, mostly-frame structure, located on Cocoanut Row near Worth Avenue, had been built in the ’20s and, for a time, had served as a gambling casino. But now the glitter was gone. The building was old and in disrepair. It had all but ceased to function as a hotel, operating more as a guest house to accommodate the owner’s extended family. Paying guests were occasionally accepted to maintain the hotel’s liquor license. But the hotel’s business reputation was nonexistent; it had no advance bookings and no standing guest list. Nevertheless, Sax perceived that the property had investment potential.

In late 1984 and 1985, the federal tax laws were in a state of flux. The continued availability of the investment tax credit for limited partnerships was in doubt. Therefore, syndicators were looking at new forms of ownership to provide investment opportunities with enhanced tax benefits. The “condominium-hotel” seemed the perfect answer. It enabled an investor to purchase a hotel room as a condominium unit and then, by executing a rental management agreement, to place the unit in a rental pool under the supervision of a hotel operator or agent. This arrangement allowed the investor/unit owner to take an investment tax credit during the first year of ownership plus the usual deductions associated with property ownership. Moreover, because the property housed a functioning business, the unit owner could anticipate an eventual participation in the profits.

II. THE OFFERING

The hotel interests were offered for sale through a prospectus or private placement memorandum (“PPM”) which was drafted by PCI’s securities counsel, Sparber, Shevin, Shapo, Heilbronner & Book (“Sparber Shevin”). Steven Sonberg, the lead attorney and principal contact at Sparber Shevin, testified that Carl Sax was personally involved in a “significant way” in the preparation of the PPM. According to Son-berg, it was Sax who decided what should be included and excluded from the PPM.

See, e. g. UO #29.

[17]*17 PART ONE, REPRESENTATIONS IN THE PPM

(A) WORKING CAPITAL

Page 22 of the PPM contains a listing entitled, “Use of Sales Proceeds.” It indicates that PCI anticipated receiving $13,900,000 in total proceeds from the sale of the sixty-six condominium units in the Palm Court Hotel. It also indicates that $75,000 of the proceeds would be allocated for “Hotel Working Capital.” Footnote #3 to the chart, which appears on page 23 of the PPM states, “To the extent costs are greater than the amount indicated, PCI’s profit will be decreased.”

William T. Hurst, the vice president for operations of Py-Vavra Development Company offered this definition of a hotel’s working capital: “In conventional hotel accounting working capital refers to several different items, including funds to make change from, house banks like petty cash, and to cash checks on property; salaries and wages for some period of two to eight weeks; and general immediately available cash to carry you through the waiting time, the float on accounts receivable, and the peaks and valleys of seasonal hotel operations. It’s sort of like cash-on-hand for immediate day-to-day operating purposes.” Depo., at 49.

On December 31, 1985, when the hotel was turned over to the unit owners, the working capital fund contained no more than five or six thousand dollars.

The lack of working capital resulted from PCI’s contention at the closing that it had experienced cost overruns in three areas: (1) nonconsumable supplies ($9,268.97); (2) start up expenses ($43,840.47); and (3) hotel working capital ($30,813.37). These alleged overruns totaled $83,922.81. See UO #64. PCI asserted that the cost overruns inured to the unit owners’ benefit and, consequently, demanded reimbursement in the sum of $84,000. Louis Hautzig, who attending the closing as the authorized representative of P-V Hotels, Inc., the unit owners’ designated agent to operate the hotel, signed what has become known as the “transfer letter,” acknowledging the $84,000 debt. See UO #66.

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29 Fla. Supp. 2d 14, Counsel Stack Legal Research, https://law.counselstack.com/opinion/palm-court-inc-v-durham-flacirct-1988.