VCS Venture Securities, LLC v. Scottsdale Insurance Company

CourtDistrict Court, E.D. New York
DecidedAugust 14, 2025
Docket2:24-cv-05498
StatusUnknown

This text of VCS Venture Securities, LLC v. Scottsdale Insurance Company (VCS Venture Securities, LLC v. Scottsdale Insurance Company) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
VCS Venture Securities, LLC v. Scottsdale Insurance Company, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

VCS VENTURE SECURITIES, LLC, d/b/a New Age Venture Capital, ROCCO MICHAEL MASELLI, ADAM MAGGIO, MEMORANDUM & ORDER Plaintiffs, 2:24-CV-05498 (HG) v.

SCOTTSDALE INSURANCE COMPANY,

Defendant.

HECTOR GONZALEZ, United States District Judge: Plaintiffs VCS Venture Securities, LLC (“VCS”), Rocco Michael Maselli, and Adam Maggio sued Defendant Scottsdale Insurance Company (“Scottsdale”), alleging that Scottsdale wrongfully denied them coverage under a broker-dealer financial services professional liability insurance policy (the “Policy”) for a claim brought against Plaintiffs as part of a Financial Industry Regulatory Authority arbitration (the “FINRA Claim”). ECF No. 1-1 at 6–16 (“Compl.”). Scottsdale now seeks to dismiss the Complaint for failure to state a claim pursuant to Rule 12(b)(6). ECF No. 17-1 (Mot. to Dismiss). For the reasons that follow, the Court GRANTS Scottsdale’s motion. BACKGROUND A. Factual History1 Plaintiff VCS is a New York limited liability company that operates as a broker-dealer for financial services and maintains its principal place of business in Nassau County. Compl.

1 The Court “recite[s] the substance of the allegations as if they represented true facts, with the understanding that these are not findings of the [C]ourt, as [I] have no way of knowing at this stage what are the true facts.” In re Hain Celestial Grp., Inc. Sec. Litig., 20 F.4th 131, 133 (2d Cir. 2021). Unless otherwise indicated, when quoting cases and the parties’ papers, the Court ¶ 6. Plaintiff Maggio is a principal and owner of VCS. Id. ¶ 7. Plaintiff Maselli is a broker at VCS. Id. ¶ 8. Defendant Scottsdale is an Ohio-domiciled insurer authorized to transact business and issue policies in New York. Id. ¶ 9. Scottsdale issued the Policy to VCS, effective from September 10, 2022, through October 10, 2023, with a $1 million aggregate limit. Id. ¶ 10. The

Policy includes coverage for damages resulting from “Wrongful Acts” committed in connection with financial services rendered by the insureds. Id. ¶¶ 10–11. On September 12, 2023, James A. Stamulis filed the FINRA Claim against Plaintiffs, alleging that Maselli directed him to engage in speculative trading, including selling call options and purchasing high-risk stocks, which led to significant losses. Id. ¶ 12; ECF No. 1-1 at 70–114 (“FINRA Claim”) at 114.2 Stamulis alleges that he transferred his account from Baxter Brothers to Joseph Stone Capital LLC (“JSC”), where Maselli was a broker and Maggio was a principal, and later to VCS, which he claims effectively succeeded JSC. Compl. ¶¶ 12, 14; FINRA Claim ¶ 5. He further contends that Maselli induced him to open a new account at E*TRADE and engaged in high-risk commodities and options trading on behalf of Stamulis. Compl. ¶ 14.

According to Stamulis, Plaintiffs—acting through Maselli—engaged in excessive and unsuitable margin trading and maintained complete control over his accounts despite knowing that he relied

omits all internal quotation marks, alteration marks, emphases, footnotes, and citations. The Court refers to the pages assigned by the Electronic Case Files system (“ECF”).

2 In addition to the Complaint, the Court also references the Policy and the FINRA Claim, both of which were attached to the Complaint. See ECF No. 1-1. The Court may consider any statements or documents incorporated in a complaint by reference at the motion to dismiss stage. See Nicosia v. Amazon.com, Inc., 834 F.3d 220, 230–31 (2d Cir. 2016) (concluding that “statements or documents incorporated in [the complaint] by reference” are properly considered on a motion to dismiss); see also Sharde Harvey, DDS, PLLC v. Sentinel Ins. Co., No. 20-cv- 3350, 2021 WL 1034259, at *3 (S.D.N.Y. Mar. 18, 2021) (“In insurance disputes in particular, courts may consider the insurance policies themselves, even if they are not attached to the plaintiff’s complaint.”); Pearson Cap. Partners LLC v. James River Ins. Co., 151 F. Supp. 3d 392, 401 (S.D.N.Y. 2015) (considering the complaint in the underlying action for which the plaintiff sought coverage in an insurance dispute at the motion to dismiss stage). entirely on them for investment decisions. Id. ¶¶ 15–16. The FINRA Claim asserts causes of action for violations of federal securities laws, breach of contract, common law fraud, breach of fiduciary duty, negligence, and gross negligence, and seeks approximately $500,000 in damages, plus additional monetary and equitable relief. Id. ¶ 17.

Plaintiffs deny the allegations and assert that Stamulis was an experienced investor who approved all transactions and received regular account statements. Id. ¶ 18. Plaintiffs tendered the claim to Scottsdale for defense and indemnification under the Policy, but Scottsdale disclaimed coverage. Id. ¶¶ 19–20. Plaintiffs allege that the FINRA Claim falls within the Policy’s coverage for financial services-related “Wrongful Acts” and that Scottsdale has a duty to defend them. Id. ¶¶ 21–27. Plaintiffs further assert that the claim was timely reported during the Policy period and that all Plaintiffs qualify as insureds under the Policy. Id. ¶¶ 28, 31. Plaintiffs claim to have incurred approximately $30,000 in legal expenses to date as a result of Scottsdale’s refusal to defend them, and they expect additional defense costs going forward. Id. ¶ 30.

On August 6, 2024, this case was removed to this Court from the New York Supreme Court, Nassau County, pursuant to this Court’s diversity jurisdiction under 28 U.S.C. § 1332. See ECF No. 1. On October 29, 2024, Scottsdale moved to dismiss for failure to state a claim. ECF No. 17-1. On December 4, 2024, Plaintiffs filed their opposition. ECF No. 19. On December 18, 2024, Scottsdale filed its reply, and the motion is now fully briefed. ECF No. 20. LEGAL STANDARD “To survive a motion to dismiss under Rule 12(b)(6), the complaint must plead ‘enough facts to state a claim to relief that is plausible on its face.’” Johnson v. Mount Sinai Hosp. Grp., No. 23-466, 2024 WL 3289475, at *1 (2d Cir. July 3, 2024) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim is plausible ‘when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.’” Matson v. Bd. of Educ., 631 F.3d 57, 63 (2d Cir. 2011) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). Although all allegations contained in the complaint are assumed to be

true, this tenet is “inapplicable to legal conclusions.” Iqbal, 556 U.S. at 678. DISCUSSION I. California Insurance Law Governs “A federal action based upon diversity jurisdiction, brought to recover under an insurance policy, is governed by state law.” Vam Check Cashing Corp. v. Fed. Ins. Co., 787 F. Supp. 2d 264, 268 (E.D.N.Y. 2011), aff’d, 699 F.3d 727 (2d Cir. 2012). “Federal courts sitting in diversity generally apply the choice-of-law rules of the forum state, and New York law gives full effect to the parties’ choice-of-law provisions.” Lee-Jordan v. Allstate Indem. Co., No. 18-cv-6755, 2019 WL 3066408, at *2 n.2 (S.D.N.Y. July 12, 2019).

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