Vyas v. Polsinelli, PC

CourtDistrict Court, M.D. Florida
DecidedMay 18, 2022
Docket8:22-cv-00071
StatusUnknown

This text of Vyas v. Polsinelli, PC (Vyas v. Polsinelli, PC) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vyas v. Polsinelli, PC, (M.D. Fla. 2022).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

SANKET VYAS, as liquidating agent for and on behalf of Q3I, L.P.,

Plaintiff, v. Case No. 8:22-cv-71-VMC-CPT POLSINELLI PC, and RICHARD B. LEVIN,

Defendants. ________________________________/ ORDER This matter is before the Court on consideration of the Motion to Dismiss filed by Defendants Polsinelli PC and Richard B. Levin (Doc. # 40), filed on April 4, 2022. Plaintiff Sanket Vyas filed a response in opposition on May 2, 2022. (Doc. # 45). For the reasons described below, the Motion is denied. I. Background This case involves a now-defunct cryptocurrency trading club, Q3I, L.P. (Doc. # 37 at ¶ 1). Q3I used an algorithm for cryptocurrency trading created by a man named Michael Ackerman. (Id. at ¶ 17). Although Ackerman represented that his algorithm was “wildly successful,” in actuality it did not result in the returns he advertised. (Id. at ¶¶ 17, 20). According to the amended complaint, Ackerman defrauded Q3I by reporting false returns in the cryptocurrency exchange accounts and then using those false returns to take “profits” from Q3I pursuant to a profit participation agreement. (Id. at ¶¶ 2, 4). Due to Ackerman’s fraud, Q3I lost nearly all of the $35 million the limited partners paid into the club. (Id.

at ¶ 2). Plaintiff Vyas is the liquidating agent for Q3I. (Id. at 1). Vyas alleges that Defendant Levin was an attorney at the law firm of Defendant Polsinelli when he was hired in 2019 to “provide legal advice to Q3I to benefit and protect Q3I.” (Id. at ¶ 6). At the time, Levin was the chairman of the firm’s FinTech and Regulatory Practice, and Polsinelli promoted Levin as widely recognized for his expertise in the fields of digital currency and blockchain technology. (Id. at ¶¶ 25, 26). After Levin and Polsinelli were retained, a bank

involved with Q3I began to question some of the withdrawals being made, so Q3I’s Fund Administrator, Denis McEvoy, asked Levin to provide an opinion “concerning Q3I’s position regarding the propriety of the way in which [a] fiduciary account was being handled.” (Id. at ¶ 34). Levin and Polsinelli allegedly informed McEvoy that they were “entirely comfortable” with the transfers and the way the accounts were being handled. (Id. at ¶ 35). According to Vyas, “[t]he only way the transfers [from the fiduciary account] might not have been harmful to Q3I was if Ackerman’s reported trading returns were accurate. Yet, Levin prepared Q3I’s opinion without verifying the accuracy

of Ackerman’s reported returns.” (Id. at ¶ 7). Vyas alleges that had Levin and Polsinelli performed the required due diligence, they would have “easily” discovered Ackerman’s false representations. (Id. at ¶ 8). Based on these allegations, Vyas brings claims of professional negligence (Count I), negligent misrepresentation (Count II), and breach of fiduciary duty (Count III) against both Levin and Polsinelli. (Id. at 10- 16). On April 4, 2022, Polsinelli and Levin filed the instant Motion to Dismiss the amended complaint. (Doc. # 40). Vyas has responded (Doc. # 45), and the Motion is ripe for review.

II. Legal Standard On a motion to dismiss pursuant to Rule 12(b)(6), this Court accepts as true all the allegations in the complaint and construes them in the light most favorable to the plaintiff. Jackson v. Bellsouth Telecomms., 372 F.3d 1250, 1262 (11th Cir. 2004). Further, the Court favors the plaintiff with all reasonable inferences from the allegations in the complaint. Stephens v. Dep’t of Health & Human Servs., 901 F.2d 1571, 1573 (11th Cir. 1990). But, [w]hile a complaint attacked by a Rule 12(b)(6) motion to dismiss does not need detailed factual allegations, a plaintiff’s obligation to provide the grounds of his entitlement to relief requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do. Factual allegations must be enough to raise a right to relief above the speculative level.

Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)(internal citations omitted). Courts are not “bound to accept as true a legal conclusion couched as a factual allegation.” Papasan v. Allain, 478 U.S. 265, 286 (1986). The Court must limit its consideration to well-pleaded factual allegations, documents central to or referenced in the complaint, and matters judicially noticed. La Grasta v. First Union Sec., Inc., 358 F.3d 840, 845 (11th Cir. 2004). III. Analysis A. In Pari Delicto Doctrine Defendants argue that the in pari delicto doctrine bars this action. (Doc. # 40 at 3, 7-11). Under Florida law, the doctrine of in pari delicto operates to bar legal remedies where both parties are equally in the wrong or where the plaintiff’s wrongdoing exceeds the defendant’s wrongdoing. O’Halloran v. PricewaterhouseCoopers LLP, 969 So. 2d 1039, 1041 (Fla. 2d DCA 2007); Turner v. Anderson, 704 So. 2d 748, 751 (4th DCA 1998). In other words, “to assert an in pari delicto defense, a defendant must show that the plaintiff bears at least substantially equal responsibility for the violations he seeks to redress.” Bailey v. TitleMax of Ga.,

Inc., 776 F.3d 797, 802 (11th Cir. 2015) (citation and quotation marks omitted). It is an equitable doctrine that precludes a plaintiff who has participated in wrongdoing from recovering damages resulting from that wrongdoing. Off. Comm. of Unsecured Creditors of PSA, Inc. v. Edwards, 437 F.3d 1145, 1152 (11th Cir. 2006). Although the doctrine is an affirmative defense, affirmative defenses may be raised in a motion to dismiss under Rule 12(b)(6) so long as the defense clearly appears on the face of the complaint. See Quiller v. Barclays Am./Credit, Inc., 727 F.2d 1067, 1069 (11th Cir. 1984) (“Generally, the

existence of an affirmative defense will not support a motion to dismiss, [but] a complaint may be dismissed under Rule 12(b)(6) when its own allegations indicate the existence of an affirmative defense, so long as the defense clearly appears on the face of the complaint.”). According to the amended complaint here, Q3 Holdings, LLC, was the general partner of Q3I and was entitled to a 50% profit share from the club’s trades. (Doc. # 37 at ¶ 22). And Ackerman was entitled to 33% of Q3 Holdings’ share. (Id.). Ackerman allegedly used his trumped-up returns to “dupe” Q3 Holdings into effectuating a transfer of what it believed to be 50% of the profits to Q3 Holdings, and from there Ackerman

would take his cut. (Id. at ¶ 23). Defendants argue that Q3 Holdings, the sole general partner of Q3I, committed the fraud but that the amended complaint improperly paints the fraud as belonging entirely to Ackerman. (Doc. # 40 at 5). Thus, because Q3 Holdings was itself involved in the fraud, and because Vyas, as the liquidating agent, is the successor-in-interest to Q3 Holdings, he cannot recover under the doctrine of in pari delicto. (Id.

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