Sillam v. Labaton Sucharow LLP

District Court, S.D. New York·Decided December 9, 2024·No. 1:21-cv-06675·Unknown

Opinion

UNITED STATES DISTRICT COURT , USDC SDNY SOUTHERN DISTRICT OF NEW YORK DOCUMENT ee ee ELECTRONICALLY FILED GERARD SILLAM and ALDRIC SAULNIER, DOC #s_____ || DATE FILED:___| Plaintiffs, -against- 21 Civ. 6675 (CM)(OTW) LABATON SUCHAROW, LLP, CHRISTOPHER J. KELLER, and LAWRENCE A. SUCHAROW, Defendants. Xx DECISION AND ORDER CONDITIONALLY GRANTING DEFENDANTS’ MOTION TO DISMISS THE COMPLAINT WITH PREJUDICE FOR FAILURE TO COMPLY WITH COURT ORDER McMahon, J.: Plaintiff Gerard Sillam has been a troublesome litigant. Sillam, a French businessman, and French attorney Aldric Saulnier filed this lawsuit in 2021. Defendants are the well-known plaintiffs’ securities law firm Labaton Sucharow, LLP, and two partners in that firm. Back in 2005 or so, the Labaton firm was alleged to have entered into an unethical fee- splitting arrangement with Sillam and a predecessor in interest to Saulnier. The fees (originally in the amount of 15% of Labaton’s earnings on any representation) were to be paid in exchange for Sillam’s referring clients (principally large European investment funds) to Labaton. The referrals were to come from Sillam, and the fees (15% of the total fee earned by Labaton for whatever work it performed) were intended to be earned by and paid to Sillam. The role of the lawyer — first one named Descroubres, then Saulnier — was to serve as intermediary; the lawyer was to accept payment from Labaton, and then to forward the money to Sillam, the intended recipient. Plaintiffs allege that Defendants devised this arrangement in order to circumvent the ethical prohibition against a lawyer’s splitting fees with a non-lawyer — a prohibition with which the two Frenchmen were entirely unfamiliar. The arrangement fell apart several times.’ The first time, it was due to the alleged non- payment of Sillam’s full referral fee. That disagreement, which led to the filing of a lawsuit in

' All of the sordid facts alleged in the complaint, including details about how the deals fell apart and were renegotiated, are recounted in the court’s opinion dismissing Counts II (negligent misrepresentation) and III (aiding and abetting fraudulent inducement) of the Complaint, but denying the motion to dismiss Count I

France, was settled by the signing of two agreements — one between Sillam and Labaton, one between Saulnier and Labaton — in 2009. Among its other terms, the 2009 Settlement required Labaton to aver each year, under oath, for a period of five years, whether the firm had done any work for any client covered by the 2009 Settlement. That information could then be used by Sillam and Saulnier to determine whether they were owed any money pursuant to the terms of the 2009 Settlement Agreements. Defendant Keller, an attorney at law, allegedly filed affidavits in the years covered by the 2009 Settlement Agreements. In each of those affidavits, Keller averred that the firm had not represented any covered client during the preceding year. In this lawsuit, those averrals are alleged to have been false. After the five-year period covered by the 2009 Settlement expired, Labaton suggested that the parties enter into yet another settlement agreement — known as the Universal Settlement — which was ostensibly intended to put an end to the parties’ relationship once and for all, in exchange for the payment of $99,999 to Sillam and other consideration. The Universal Settlement contained a broad general release of all claims. At the time it was signed, Plaintiffs allege that they did not know, and had no reason to know, that Keller’s annual sworn statements were not true. Plaintiffs allege that, had they been aware of the true facts — which were that Labaton had done work for several of the clients covered by the 2009 Settlement Agreements, meaning that Sillam was owed money? — they would never have agreed to the Universal Settlement proposed by Labaton. Indeed, Plaintiffs suggest that the Universal Settlement (the reason for which was unclear, since the 2009 Agreements had expired by their terms) was a plot by Labaton to obtain a release of any claims that might relate to those alleged misrepresentations. Labaton, of course, denies everything. Once the court declined to dismiss Plaintiffs’ claim for fraudulent inducement against Labaton and Keller — and then denied a motion to reconsider — the case was turned over to my colleague, The Hon. Ona T. Wang, for general pretrial supervision. The pre-trial discovery process turned out to be quite contentious, thanks to Sillam, who — while perfectly content to sue Defendants in the United States — turned out not to want to play the litigation game by American rules. Apparently Sillam also failed to play the French litigation game by its rules: Between 2017 and 2020, Sillam (sometimes with Saulnier) commenced at least four civil and criminal proceedings in France, against Labaton, Keller, Sucharow, other Labaton partners, and the lawyers who have represented them in the United States and in France.? The allegations in these various actions closely mirror or duplicate the claims in suit in this court. It is my understanding that the French courts or prosecutors have dismissed these claims for failing to allege any violation of French law, and have sanctioned Sillam in the amount of 115,000 euros for bringing one of those

(fraudulent inducement). That opinion can be found at Docket # 28. Rather than reiterate it | incorporate it by reference. The court’s decision denying Defendants’ motion for reconsideration can be found at Docket # 38. 2 | gather from reviewing the docket sheet that it may be that Labaton did nothing more than file proofs of claim on behalf of certain European funds in lawsuits in various securities fraud lawsuits in which Labaton was not designated as class counsel. (See Dkt. # 109). Whether that is true — and if it is, whether the ministerial act of filing a proof of claim qualifies as reportable work under the 2009 Agreements — appears to be the factual dispute at the crux of this lawsuit. 3 These four proceedings are fully described at Docket #130 at 3-8.

harassing proceedings (the so-called Direct Summons Action, which was dismissed in March 2023 after a full trial) in utter bad faith. 4 But as bad as Sillam’s conduct has been in France, it is his actions before Judge Wang that have led to the present motion. Defendants noticed Sillam’s and Saulnier’s depositions in this action, and specified New York ~ the situs of the lawsuit — as the place where those depositions were to be taken. Sillam and Saulnier moved before the learned Magistrate Judge to be deposed in France, where they live — alleging that they were elderly (in their late 60s, I believe) and were reluctant to travel out of fear of infection with COVID-19 (mind you, this is in 2022 and 2023, when travel had largely resumed). Defendants pointed out that Sillam and Saulnier had purposefully availed themselves of the jurisdiction of this court, and noted that it would be difficult to take meaningful and comprehensive depositions in France because of restrictions imposed by that country under the Hague Convention on the Taking of Evidence Abroad. Defendants also advised Judge Wang about the various French lawsuits to which they had been subjected; they argued that they and their American lawyers worried about being arrested if they had to enter France to examine Plaintiffs in their home country. If this application had been made to me, I would have ordered Plaintiffs to show up in New York for their depositions or risk dismissal of the lawsuit they chose to bring here. When one avails himself of the jurisdiction of an American court, there is absolutely no excuse for not showing up in the United States for discovery governed solely by our rules, which — like it or not — are considerably more liberal than those in European countries, or when taken pursuant to the Hague Convention.

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