SP Investment Fund I v. Walsh CA2/5

CourtCalifornia Court of Appeal
DecidedJune 12, 2025
DocketB332702
StatusUnpublished

This text of SP Investment Fund I v. Walsh CA2/5 (SP Investment Fund I v. Walsh CA2/5) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SP Investment Fund I v. Walsh CA2/5, (Cal. Ct. App. 2025).

Opinion

Filed 6/12/25 SP Investment Fund I v. Walsh CA2/5 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION FIVE

SP INVESTMENT FUND I, LLC, B332702, B334212

Plaintiff and Appellant, (Los Angeles County Super. Ct. No. v. 20STCV49845)

PATRICK WALSH, as Executor, etc., et al.,

Defendants and Respondents.

APPEAL from a judgment and order of the Superior Court of Los Angeles County, Kevin C. Brazile, Judge. Affirmed. Greenberg Glusker Fields Claman & Machtinger, Daniel G. Stone, and Vera Serova for Plaintiff and Appellant. Buchalter, Robert Collings Little, and Gabriel G. Green for Defendants and Respondents. This case, which comes to us after the trial court’s grant of a defense motion for summary judgment, concerns the ostensible sale of a limited partnership interest. We primarily consider (under Pennsylvania law) whether a purchase agreement that grants the buyer of a limited partnership interest the immediate ability to exercise certain powers concerning the partnership— without complying with the partnership agreement’s provisions governing how a partnership interest may be transferred—is illegal as contrary to the express policy of law.

I. BACKGROUND A. SPI and Levinson Enter into a Purchase Agreement Gil Seton Jr. (Seton) is a principal of plaintiff and appellant SP Investment Fund I, LLC (SPI). In early June 2013, Seton, on SPI’s behalf, sent defendant and respondent Fred Levinson (Levinson) a letter enclosing a form purchase and sale agreement (the purchase agreement) to buy Levinson’s interest in Colonial Oaks Limited Partnership (Colonial Oaks) for $55,000.1 The purchase agreement was drafted by SPI. Levinson, at the time, held a 12% limited partnership interest in Colonial Oaks. Levinson signed the purchase agreement on June 10, 2013, and SPI sent Levinson a check for $55,000, which he deposited.

1 Levinson died during the pendency of the litigation, and Patrick Walsh, in his capacity as executor of Levinson’s estate, was substituted in his place. For the sake of simplicity, we refer to Levinson and his estate as Levinson throughout the opinion.

2 1. The terms of the purchase agreement At the outset, the purchase agreement states, “[Levinson] agrees to sell to [SPI] and [SPI] agrees to purchase from [Levinson] the Partnership Interest,” which it defines as “All of [Levinson’s] Rights and Claims relating to . . . Colonial Oaks Limited Partnership, a Pennsylvania Limited Partnership,” in exchange “for the Purchase Price pursuant to the Terms attached hereto, which are a part of this Agreement.” The attached terms and conditions divided Levinson’s Rights with respect to Colonial Oaks into “Economic Rights,” and “Partnership Rights.” The “Economic Rights” included Levinson’s rights to “Economic Benefits,” which were defined as “monetary amounts or property paid, distributed, or owed as capital, profit, income, loss or otherwise.” “Partnership Rights” were defined to include Levinson’s “right to vote as a partner in” the partnership, his “right to review books and records of” the partnership, and his “rights as a beneficiary of fiduciary duties owed by the partnership and/or other partners” in the partnership. The “Effective Date” of the agreement, June 7, 2013, was the date on which Levinson was to deliver to SPI an assignment of his rights. An assignment was attached to the purchase agreement pursuant to which Levinson assigned to SPI his “entire interest(s)” in Colonial Oaks. Levinson signed the assignment and SPI was to hold the assignment in trust until the “Closing Date” of the purchase agreement. Under the purchase agreement, Levinson agreed to perform a series of “Additional Covenants,” all of which he was required to commence performing as of the signing of the agreement. One of these covenants obligated Levinson “before, on, and after the Closing Date” to “refrain [except without SPI’s consent] from

3 selling, assigning, transferring . . . or otherwise disposing of . . . all or any part of the Partnership Interest and from disclosing the existence, pricing and/or provisions of the” purchase agreement. Another required Levinson, again “before, on, and after the Closing Date,” to “receive in trust for [SPI] and forthwith to turn over to [SPI] . . . all Economic Benefits received by [Levinson] on or after the Effective Date.” A third mandated, once again “before, on and after the Closing Date,” to “promptly deliver and communicate to [SPI] . . . any information[,] documents, correspondence, conversations, etc. relating to the Partnership and/or Partnership Interest . . . .” Finally, “before the Closing Date” of the purchase agreement, Levinson was required to “consult with [SPI] with respect to all opportunities to vote, elect or act with regard to the Partnership or the Partnership Interest and then to vote, elect, or act as, and only as, [SPI] requests” and to “consult with [SPI] whenever [Levinson] learns of any potential action that will or might adversely affect the physical condition of the assets and/or financial condition or value of the Partnership or Partnership Interest and then to take such action as, and only as, [SPI] requests . . . .” The purchase agreement also provided two avenues for closing the contemplated sale of Levinson’s Colonial Oaks partnership interest. The first involved closing with the “Necessary Approvals.” The “Necessary Approvals” were “any approvals, consents, or other actions of the Partnership . . . that are necessary for [SPI] to receive, exercise, and/or enjoy the full benefit of all or any portion of the Partnership Interest.” The second involved “Closing Without Necessary Approvals.” If SPI elected to close without the “Necessary Approvals,” SPI would

4 hold the assignment in trust, and Levinson would continue to perform the “Additional Covenants.” The covenant that required Levinson to provide SPI with notice of all opportunities to vote and to vote in accordance with SPI’s wishes before the Closing Date expressly applied “after the Closing Date” if SPI “waived any Necessary Approvals.” The assignment executed with the purchase agreement states it “shall not assign, transfer, or convey to Assignee any portion of such Partnership Interest as to which any approvals, consents, or other actions or inactions of the Partnership . . . as are necessary for Assignee to receive, exercise, and/or enjoy the full benefit of such portion of the Partnership Interest (“Necessary Approvals”) have not been obtained [sic].” It also provides that if the Necessary Approval(s) were “obtained after the effective date hereof and/or in the future is no longer required to be obtained, the portion of the Partnership Interest associated with the Necessary Approval(s) shall be deemed to be included in this Assignment as of the date of receipt and/or non-necessity of the applicable Necessary Approval(s).” On December 5, 2014, SPI sent Levinson a letter closing the purchase agreement without the Necessary Approvals.

2. The parties’ evidence regarding other relevant events In 2014, Seton contacted Colonial Oaks and requested SPI to be admitted as a limited partner.2 Around the same time, SPI

2 In a later email to Seton, counsel for Colonial Oaks stated they initially believed, based on Seton’s representations, that he was Levinson’s attorney.

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SP Investment Fund I v. Walsh CA2/5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sp-investment-fund-i-v-walsh-ca25-calctapp-2025.