Slowinski v. Garriga

CourtUnited States Bankruptcy Court, S.D. New York
DecidedOctober 7, 2025
Docket24-09014
StatusUnknown

This text of Slowinski v. Garriga (Slowinski v. Garriga) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Slowinski v. Garriga, (N.Y. 2025).

Opinion

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK -------------------------------------------------------------x In re: Chapter 7 TIFFANY M. GARRIGA Case No. 24-35345 (KYP) Debtor. -------------------------------------------------------------x TIMOTHY SLOWINSKI,

Plaintiff,

-against- Adv. Pro. No. 24-09014 (KYP)

TIFFANY M. GARRIGA

Defendant. -------------------------------------------------------------x

MEMORANDUM DECISION AND ORDER (1) GRANTING IN PART AND DENYING IN PART PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT, AND (2) GRANTING PLAINTIFF’S MOTION TO STRIKE UNAUTHORIZED SUR-REPLY FILED BY DEFENDANT

APPEARANCES:

TIMOTHY SLOWINSKI Pro Se Plaintiff 224 State Street Hudson, NY 12534

LAW OFFICE OF MITCHELL H. SPINAC Counsel to Defendant 325 Wall Street P.O. Box 3748 Kingston, NY 12402 By: Mitchell H. Spinac, Esq. Of Counsel

HONORABLE KYU YOUNG PAEK UNITED STATES BANKRUPTCY JUDGE INTRODUCTION In November 2022, plaintiff Timothy Slowinski (“Slowinski”) obtained a $177,800.00 judgment in state court against debtor-defendant Tiffany Garriga (“Garriga”). Slowinski commenced this adversary proceeding1 against Garriga seeking a determination that the debt owed to him is nondischargeable pursuant to 11 U.S.C.

§ 523(a)(4) and (a)(6) and has now moved for summary judgment on those claims (“Motion for Summary Judgment”).2 Slowinski has also moved to strike a sur-reply brief filed by Garriga. (“Motion to Strike Sur-Reply”).3 Garriga opposes both motions.4 For the reasons stated, the Motion for Summary Judgment is GRANTED IN PART AND DENIED IN PART, and the Motion to Strike Sur-Reply is GRANTED. JURISDICTION This Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Amended Standing Order of Reference (M-431), dated January 31, 2012 (Preska, C.J.) referring bankruptcy cases and proceedings to the Bankruptcy Judges of the Southern District of New York. This is a core proceeding under 28 U.S.C. § 157(b)(2)(I).

1 See Adversary Complaint, dated May 24, 2024 (“Complaint”) (ECF Doc. # 1). “ECF Doc. # _” refers to documents filed on the electronic docket of this adversary proceeding. “ECF p. _” refers to the page number imprinted across the top of the page by the Court’s electronic filing system. 2 See Plaintiff’s Memorandum of Points and Authorities in Support of Motion for Summary Judgment, dated Mar. 5, 2025 and docketed on Apr. 24, 2025 (“Slowinski Brief”) (ECF Doc. # 49-3); see also Plaintiff’s Response to Defendant’s Opposition to Plaintiff’s Motion for Summary Judgment, dated Apr. 21, 2025 (“Slowinski Reply”) (ECF Doc. # 45). 3 See Motion to Strike Defendant’s Unauthorized Sur-Reply, dated Apr. 24, 2025 (ECF Doc. # 48). 4 See Memorandum of Law in Opposition to Summary Judgment, dated Apr. 16, 2025 (“Garriga Brief”) (ECF Doc. # 44); see also Memorandum of Law in Opposition to Motion to Strike, dated Apr. 25, 2025 (ECF Doc. # 50). BACKGROUND5 A. Events Leading to the State Court Action Slowinski and Garriga entered into a romantic relationship in 2013. (Slowinski Affirmation ¶ 8.) At the time, Slowinski operated an art gallery at a property he owned in Hudson, New York (“Art Gallery”) and lived in a property in Phoenicia, New York

with his two children (“Phoenicia Property”). (Id. ¶¶ 10-11.) Garriga lived in a public- housing apartment in Hudson, New York with her two children. (Id. ¶ 9.) In 2014, Slowinski and Garriga discussed getting married and living together in a single home with their four children. (Id. ¶ 14.) In furtherance of those plans, Slowinski sold his Phoenicia Property and deposited the sale proceeds into his bank account. (Id. ¶ 15.) Slowinski purchased an engagement ring, and, on February 7, 2015, he proposed to Garriga, and she accepted. (Id. ¶ 16.) On February 18, 2015, Slowinski purchased a property located at 224 State Street, Hudson, New York (“Hudson Property”) and paid the purchase price as well as all fees and costs related to the purchase and closing. (Id. ¶¶ 2, 17-18.) Slowinski added Garriga as a co-owner on the deed, and they owned the Hudson Property as tenants in common.

(Id. ¶ 17; id., Ex. 2 (Bargain & Sale Deed showing co-ownership as tenants in common).)

5 The background is culled from the following sources: (i) Plaintiff’s Affirmation in Support of the Motion for Summary Judgment, signed on Mar. 5, 2025 (“Slowinski Affirmation”) (ECF Doc. # 49-1) and the exhibits appended thereto (ECF Doc. ## 39-2 through 39-27), (ii) Plaintiff’s Statement of Undisputed Facts in Support of the Motion for Summary Judgment, dated Mar. 5, 2025 (“Slowinski Fact Statement”) (ECF Doc. # 49-2), (iii) Affidavit of Tiffany M. Garriga in Opposition to Motion for Summary Judgment, signed on Apr. 16, 2025 (“Garriga Affidavit”) (ECF Doc. # 44-1), and (iv) matters for which the Court may take judicial notice. Slowinski and Garriga’s relationship began to break down shortly after the engagement, and in the fall of 2015, Garriga told Slowinski that she was no longer interested in marriage. (Id. ¶¶ 21-24.) The Hudson Property was not habitable at the time of purchase and required extensive renovations. (Id. ¶¶ 30-31.) During 2015 and 2016, Slowinski hired local

laborers to assist with demolition, paid contractors to perform certain of the renovations, and performed other renovations himself. (Id. ¶¶ 33-34; id., Ex. 9 (pictures showing renovation work).) When the proceeds from the sale of the Phoenicia Property became depleted, Slowinski obtained a $50,000 home equity line of credit in June 2016 to continue renovation of the Hudson Property. (Id. ¶ 33; id., Ex. 10 (HELOC loan agreement).) In or around August 2017, Garriga received a letter from the Hudson Housing Authority citing potential violations of federal housing regulations because she was living in public housing without having reported her co-ownership of the Hudson Property. (Id. ¶ 35.) To avoid conflict with the housing authority, Garriga insisted on moving into the Hudson Property. (Id. ¶ 37.) Slowinski resisted this plan because

renovations to the Hudson Property were ongoing, and there was no certificate of occupancy for the house. (Id.)6 In November 2017, Garriga and her daughter moved into the Hudson Property over Slowinski’s objection. (Id. ¶¶ 38-39.) At the time,

6 Slowinski drafted a response letter to the housing authority asserting that the Hudson Property was not a reportable asset of Garriga because she had not contributed financially to the purchase and renovation of the house. (Slowinski Affirmation, Ex. 11 (draft letter, dated Sept. 3, 2017, from Slowinski to Hudson Housing Authority).) Garriga refused to send the letter and insisted on moving into the Hudson Property instead. (Id. ¶¶ 36-37.) Slowinski and his two children were temporarily living in a backroom of the Art Gallery. (Id. ¶ 40.) The Hudson Property had three levels: (1) an unfinished half basement, (2) a first floor with a kitchen, living room, two bedrooms and a bathroom, and (3) a second floor with three bedrooms and a bathroom. (Id. ¶ 44.) When Garriga moved in, she

encouraged Slowinski to complete renovation work for the first floor. (Id. ¶ 45.) Once completed, she occupied the first floor with her daughter. (Id. ¶¶ 45-46.) Garriga then engaged in behavior that severely limited Slowinski’s ability to renovate or otherwise use the Hudson Property including by doing the following: • threatening to damage or dispose of Slowinski’s belongings if he stored them in, or moved them into, the Hudson Property (id.

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Slowinski v. Garriga, Counsel Stack Legal Research, https://law.counselstack.com/opinion/slowinski-v-garriga-nysb-2025.