Patterson Belknap Webb & Tyler LLP v. HoganWillig, PLLC

2025 NY Slip Op 31728(U)
CourtNew York Supreme Court, New York County
DecidedMay 12, 2025
DocketIndex No. 655006/2022
StatusUnpublished

This text of 2025 NY Slip Op 31728(U) (Patterson Belknap Webb & Tyler LLP v. HoganWillig, PLLC) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Patterson Belknap Webb & Tyler LLP v. HoganWillig, PLLC, 2025 NY Slip Op 31728(U) (N.Y. Super. Ct. 2025).

Opinion

Patterson Belknap Webb & Tyler LLP v HoganWillig, PLLC 2025 NY Slip Op 31728(U) May 12, 2025 Supreme Court, New York County Docket Number: Index No. 655006/2022 Judge: Arlene P. Bluth Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 655006/2022 NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 05/12/2025

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. ARLENE P. BLUTH PART 14 Justice ---------------------------------------------------------------------------------X INDEX NO. 655006/2022 PATTERSON BELKNAP WEBB & TYLER LLP MOTION DATE 05/09/2025 Plaintiff, MOTION SEQ. NO. 004 -v- HOGANWILLIG, PLLC, DECISION + ORDER ON MOTION Defendant. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 004) 65, 66, 67, 68, 69, 70, 71, 72, 73, 77, 78, 79, 80, 81, 82, 83, 84, 85 were read on this motion to/for DISMISS DEFENSE .

Plaintiff’s motion to dismiss certain affirmative defenses is granted as described below.

Background

Plaintiff brings this case as part of an effort to collect on a judgment it secured against

non-party Barbara Stewart. Plaintiff represented Ms. Stewart and, when she failed to pay legal

fees, commenced a separate action to recover these fees. It obtained a judgment in 2013 against

Ms. Stewart and alleges that no part of it was ever paid. Plaintiff contends it is now due over $3.5

million.

Plaintiff insists that it then issued various restraining notices to Ms. Stewart and her

financial institutions. However, plaintiff does not claim it served a restraining notice on

defendant. It claims that it took a deposition of Ms. Stewart in 2016 in which she claimed that

her only asset that could be used to satisfy plaintiff’s judgment was a property in Bermuda. Ms.

Stewart asserted that although she was awarded certain jewelry in connection with her divorce 655006/2022 PATTERSON BELKNAP WEBB & TYLER LLP vs. HOGANWILLIG, PLLC Page 1 of 7 Motion No. 004

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proceeding, her former daughter-in-law had misappropriated these items, including a diamond

ring. It contends that a few months after giving the above testimony (in August 2016), Ms.

Stewart sold the diamond ring (with the assistance of her then lawyer, non-party David Marcus)

for $2.375 million (it was a 24.79 carat diamond ring). Plaintiff alleges that the proceeds of the

sale were deposited into a bank account controlled by Mr. Marcus’ firm.

Plaintiff contends that Mr. Marcus’s firm (“M&C”) transferred about $630,000 out of the

account to pay off debts that Ms. Stewart allegedly owed to M&C and another attorney, and then

transferred the remaining portion of the proceeds to three escrow accounts for Ms. Stewart’s

benefit. Plaintiff alleges that in December 2017, Ms. Stewart entered into a retainer agreement

with defendant which included a retainer fee of $625,000 (this money was transferred by M&C

to defendant). Another retainer agreement was entered into between M&C and Ms. Stewart for

over $750,000. Taken together, these actions exhausted the bulk of remaining proceeds from the

sale of the ring.

In this motion, plaintiff seeks to dismiss defendant’s sixth, seventh, tenth, eleventh,

thirteenth, fourteenth, and fifteenth affirmative defenses. Plaintiff contends that many of these

defenses fail because they are conclusory and are unsupported by any factual allegations. It

contends that it wants to streamline discovery by dismissing meritless affirmative defenses.

With respect to the eleventh, thirteenth fourteenth and fifteenth affirmative defenses,

plaintiff observes that these should be dismissed because they are composed of a single sentence

and do not contain any other facts. Plaintiff argues that the rest of the answer does not provide

any support for them. It also contends that the remaining defenses should be dismissed because

they are without merit.

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In opposition, defendant claims that an affirmative defense should not be dismissed

unless it prejudices plaintiff. It contends that the instant motion is premature because discovery is

in its early stages and it has not yet received any discovery from plaintiff.

In reply, plaintiff argues that it need not show prejudice in order to dismiss affirmative

defenses. It points out that the prejudice issue applies to situations in which a party raises a

defense in the context of a summary judgment motion that was not previously asserted.

Discussion

The Appellate Division, First Department has held that “bare legal conclusions are

insufficient to raise an affirmative defense” (Robbins v Growney, 229 AD2d 356, 358 [1st Dept

1996] [dismissing affirmative defenses]). Contrary to defendant’s arguments in opposition, the

standard on a motion to dismiss affirmative defenses concerns whether the defense “is totally

devoid of merit” (Hauptner v Laurel Dev., LLC, 65 AD3d 900, 903 [1st Dept 2009]). The Court

need not consider whether there is any prejudice to plaintiff. The cases defendant cites related to

prejudice concerning defenses raised for the first time in the summary judgment context (see

Edwards v New York City Tr. Auth., 37 AD3d 157, 158 [1st Dept 2007]; Brodeur v Hayes, 305

AD2d 754, 755 [3d Dept 2003] [“Even an unpleaded defense may be raised on a summary

judgment motion, as long as it would not be likely to surprise the adverse party or raise issues of

fact not previously apparent”]).

Sixth and Eleventh Defenses

The sixth affirmative defense contends that plaintiff waived any right to the ring or the

sale proceeds from the ring because it failed to intervene in a federal case filed in the Southern

District of New York. The eleventh affirmative defense alleges that “The Plaintiff lacks standing

to assert the claims set forth in the Complaint” (NYSCEF Doc. No. 64 at 6).

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The Court dismisses both of these defenses. Defendant did not adequately explain how

plaintiff’s purported knowledge of a federal action between Ms. Stewart and her daughter-in-law

constitutes a waiver of its right to bring the instant matter. Defendant claimed in opposition that

plaintiff knew “that if the defendant in the Jewelry Case (Michele Stewart a/k/a Michele Bouman

Stewart) prevailed in that case and established ownership of the subject diamond ring, the

Plaintiff would have no rights with respect to the ring” (NYSCEF Doc. No. 77 at 7). But this

hypothetical is of no moment because, as plaintiff correctly observes, the federal action resulted

in a settlement and so it is unclear how plaintiff’s failure to intervene forecloses this case.

And the fact is that the alleged fraudulent transfer here occurred in December 2017 which

was before the federal case was even commenced in 2018; this means that defendant’s purported

liability arose well before that other dispute.

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Related

Yonkers Contracting Co. v. Port Authority Trans-Hudson Corp.
712 N.E.2d 678 (New York Court of Appeals, 1999)
Edwards v. New York City Transit Authority
37 A.D.3d 157 (Appellate Division of the Supreme Court of New York, 2007)
Hauptner v. Laurel Development
65 A.D.3d 900 (Appellate Division of the Supreme Court of New York, 2009)
Robbins v. Growney
229 A.D.2d 356 (Appellate Division of the Supreme Court of New York, 1996)
Brodeur v. Hayes
305 A.D.2d 754 (Appellate Division of the Supreme Court of New York, 2003)
Patterson Belknap Webb & Tyler LLP v. Hoganwillig, PLLC
2025 NY Slip Op 31728(U) (New York Supreme Court, New York County, 2025)

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Bluebook (online)
2025 NY Slip Op 31728(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/patterson-belknap-webb-tyler-llp-v-hoganwillig-pllc-nysupctnewyork-2025.