Repicci v. Jarvis

CourtDistrict Court, W.D. New York
DecidedNovember 7, 2022
Docket1:17-cv-00132
StatusUnknown

This text of Repicci v. Jarvis (Repicci v. Jarvis) is published on Counsel Stack Legal Research, covering District Court, W.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Repicci v. Jarvis, (W.D.N.Y. 2022).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

DR. JOHN A. REPICCI, LORRAINE REPICCI, JULIE STONE, as Trustee of the John A. Repicci Irrevocable Life Insurance Trust, and JULIE STONE, as Trustee of the Repicci Irrevocable Family Trust,

Plaintiffs,

v. DECISION AND ORDER 17-CV-132S CHRISTOPHER R. JARVIS,

Defendant.

I. INTRODUCTION

In this diversity action, plaintiffs Dr. John A. Repicci, his wife, Lorraine Repicci, and their daughter, Julie Stone, in her capacity as trustee of two Repicci family trusts (collectively, “Plaintiffs”), assert state-law claims against defendant Christopher R. Jarvis arising from wealth- and estate-planning services Jarvis provided the Repiccis beginning in the early 2000s. Presently before this Court are Jarvis’s motion for summary judgment (Docket No. 65) and Plaintiffs’ cross-motion for partial summary judgment (Docket No. 76). For the following reasons, Jarvis’s motion is granted, and Plaintiffs’ motion is denied. II. BACKGROUND A. Facts1 Dr. Repicci is an orthopedic surgeon and the inventor of a non-invasive knee procedure. (Docket No. 65-1, ¶ 1; Docket No. 73, ¶ 1.) In 2000, he called Jarvis for

assistance in transferring his retirement assets to his heirs without incurring income or estate taxes. (Docket No. 65-1, ¶ 5; Docket No. 73, ¶ 5.) Jarvis and his firm specialized in providing consulting services to physicians in a variety of areas, including wealth management and insurance, and Jarvis agreed to work with Dr. Repicci. (Docket No. 65- 1, ¶ 4; Docket No. 73, ¶ 4.) At the time, Dr. Repicci held individual retirement accounts (IRAs) worth approximately $4 million. (Docket No. 65-1, ¶ 6; Docket No. 73, ¶ 6.) It was determined that without development of a plan, the bulk of these assets would be subject to considerable estate, gift, and income taxes upon Dr. Repicci’s death, which would leave a significantly reduced sum for his heirs. (Docket No. 65-1, ¶ 6; Docket No. 73, ¶ 6.) A

plan was therefore developed to have Dr. Repicci transfer his IRAs into a newly-created Profit Sharing Plan, which would then use the pre-tax funds in the IRAs to purchase two high-value life insurance policies, which in turn would be transferred to a trust for the benefit of Dr. Repicci’s family.2 (Docket No. 65-1, ¶¶ 6, 9; Docket No. 73, ¶¶ 6, 9; Docket

1 The facts are taken from Jarvis’s statement of undisputed facts (Docket No. 65-1), Plaintiffs’ response to that statement (Docket No. 73), and the exhibits provided in support of the parties’ respective motions. Contrary to the local rules, Plaintiffs failed to file a separate statement of undisputed facts in support of their cross-motion, which serves as an independent basis for denial. See L. R. Civ. P. 56 (a)(1). Nonetheless, they included facts with some record citations in their memorandum (Docket No. 73-19, pp. 4-10), which this Court has considered.

2 The parties dispute Dr. Repicci’s level of involvement in formulating this plan. Jarvis maintains that he formulated the plan jointly with Dr. Repicci, see Docket No. 65-1 ¶ 6; Docket Item 79 at 9 n.1, while Plaintiffs claim that Jarvis alone formulated the plan, with Dr. Repicci simply agreeing to it, see Docket No. 73, ¶ 6. No. 73-3.) It was estimated that execution of this plan would yield $2 million in tax savings. (No. 65-1, ¶ 9; Docket No. 73, ¶ 9.) According to Plaintiffs, Dr. Repicci agreed to this plan, but made clear to Jarvis that he wanted the insurance policies to be guaranteed and in force until he turned 100

years old. (Docket No. 73, ¶ 12; Docket No. 73-14, at p. 24:1-3 (Jarvis stating that he was aware of “Dr. Repicci’s expressed desire to maintain coverage to at least age 100[.]”); but see id. at 64:11-14 (“I don’t have a—remember [it] being John’s explicit intent [to have insurance up to age 100], it was just the numbers in illustrations.”).) Having agreed on the plan, Jarvis proposed the purchase of two separate life insurance policies. The first was issued by Massachusetts Mutual Life Insurance Company of New York (“Mass Mutual”). (Docket No. 65-1, ¶¶ 10, 12; Docket No. 73, ¶¶ 10, 12.) It carried an initial death benefit of $17.5 million, with the policy illustrations contemplating a future reduction in death benefits. (Docket No. 65-1, ¶ 10; Docket No. 73, ¶ 10.) The ultimate death benefit was guaranteed. (Docket No. 65-1, ¶ 10; Docket

No. 73, ¶ 10.) The second policy—the one at issue here—was issued by Lincoln Life & Annuity Company of New York (“Lincoln”) (referred to as the “Policy” or “‘026 Policy”). (Docket No. 65-1, ¶ 12; Docket No. 73, ¶ 12.) It carried a $25 million death benefit, but unlike the Mass Mutual policy, was guaranteed for only 13 years. (Docket No. 65-1, ¶ 12; Docket No. 73, ¶ 12.) At the time, however, it was believed based on assumptions in the compliance-approved illustrations that the Policy would last till Dr. Repicci turned 100 years old. (Docket No. 65-1, ¶ 12.) Lincoln, however, would not guarantee it. (Id.) Jarvis proposed the purchase of these two policies to Dr. Repicci and his wife in a letter dated October 1, 2002. (Docket No. 73-2.) After answering some of the Repiccis’ questions, see Docket No. 73-4, Jarvis also sent a letter of explanation, dated October 9, 2002, to the Repiccis’ accountant, Hyman B. Polakoff. (Docket No. 73-5.) In that letter, Jarvis addressed concerns about the non-guaranteed nature of the ‘026 Policy. In a

section titled “Legal Disclosure,” Jarvis stated: In the Guaranteed portions of the illustrations, the insurance companies have to, by law, show what the highest possible . . . expenses could be (under the law) AND they have to show the lowest interest crediting rate. . . . [I]t would be impossible for 15 years of minimum crediting and maximum . . . [expenses] to sneak up on us. We see what happens every year. John, Lorraine and I will know each and every year what their policy is being credited. If we see two or three bad years in a row, then we will address the problem immediately so no major problem arises for them or their children.”

(Id. p. 2.) Jarvis further explained that there were options available to the Repiccis if the value of the ‘026 Policy fell due to “bad returns for a few years.” (Id. p. 3.) Those options consisted of the following: 1.) Change insurance companies[;]

2.) Reduce the face amount of insurance to reduce mortality expenses . . .[;]

3.) Calculate how much additional premium would have to be paid to continue with the $10+ million of death benefit to offset the bad years we had[;]

4.) See how many years we are losing from 2 or 3 bad years. It is possible that 2 or 3 bad years only reduce the coverage to end at age 95. We can recalculate how we are doing every year. In fact, every annual policy statement shows you where you are relative to your initial purchase and projects what you might expect—given the conditions at that time. (Id. p. 3.) Jarvis concluded the letter as follows: I understand why you and John were concerned with an illustration that shows the policies running out in 12-15 years. I am comfortable that the illustrations based on current assumptions that show John and Lorraine’s polices lasting beyond Age 100, are a very accurate depiction of what is likely to happen to this policy. Further, in the unlikely event of minimum returns and maximum mortality and administrative expenses, there are options that can protect John and Lorraine’s cash flow and their children’s estate.

(Id.) About one month later, on November 12, 2002, Jarvis followed up with a letter to Dr. Repicci explaining that a future “internal exchange” of the non-guaranteed ‘026 Policy to Lincoln’s guaranteed product in two or three years would be advisable in order to secure a guaranteed death benefit. (Docket No.

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