Wells Fargo Bank, National Association v. Patel

CourtDistrict Court, S.D. New York
DecidedMarch 18, 2025
Docket1:24-cv-01162
StatusUnknown

This text of Wells Fargo Bank, National Association v. Patel (Wells Fargo Bank, National Association v. Patel) is published on Counsel Stack Legal Research, covering District 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
Wells Fargo Bank, National Association v. Patel, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK WELLS FARGO BANK, NATIONAL ASSOCIATION, as Trustee, for the Benefit of the Holders of Benchmark 2019-B13 Mortgage Trust Commercial Mortgage Pass-Through Certificates, Series 2019- B13, 24 Civ. 1162 (KPF) Plaintiff, OPINION AND ORDER -v.-

SONIAL PATEL and MONICA PATEL, Defendants. KATHERINE POLK FAILLA, District Judge:

Plaintiff filed two different lawsuits in two different courts against two sets of defendants for alleged breaches of agreements in a series of loan documents (collectively, the “Loan Documents,” discussed further infra). At issue in the instant case is the order, if any, in which the two litigations should proceed. Plaintiff Wells Fargo Bank, National Association, as Trustee, for the Benefit of the Holders of Benchmark 2019-B13 Mortgage Trust Commercial Pass-Through Certificates, Series 2019-B13 (“Plaintiff” or “Lender”) brings this action against Sonial Patel and Monica Patel (“Defendants” or “Guarantors”), seeking to recover for breaches of one of the Loan Documents, the Guaranty of Recourse Obligations (the “Recourse Guaranty”), executed by Defendants. In particular, Plaintiff alleges that Defendants have failed to perform their obligations under the Recourse Guaranty, and accordingly requests that this Court, inter alia, award Plaintiff the full amount currently due under the Loan Documents as well as amounts that accrue through the entry of judgment in this case. Prior to filing this case, however, Plaintiff filed another proceeding related

to the Loan Documents in the Circuit Court of Jefferson County, Alabama (the “Alabama Action”), against SJP Investment Partners, LLC (“Borrower”). In the Alabama Action, Plaintiff claimed that Borrower had defaulted on its obligations under certain of the Loan Documents and sought (i) appointment of a receiver over property associated with the Hotel Indigo Birmingham (the “Hotel”), located at 1023 20th Street South, Birmingham, Alabama 35205 (the “Property”), which serves as collateral under some of the Loan Documents; (ii) sequestration of rents, revenues, income, issues, and profits derived from

the Property; and (iii) attorneys’ fees incurred in pursuit of those remedies. The state court case remains pending. Now before this Court is Defendants’ motion (i) to dismiss or stay this case pursuant to the Colorado River abstention doctrine in light of the Alabama Action; alternatively, (ii) to stay the case until after trial in the Alabama Action; and/or (iii) to dismiss a portion of the Complaint pursuant to Federal Rule of Civil Procedure 12(b)(6). For the reasons set forth in the remainder of this Opinion, the Court denies Defendants’ requests that it dismiss or stay the case

pursuant to the Colorado River doctrine or that it dismiss part of the Complaint pursuant to Rule 12(b)(6), but grants in part Defendants’ request for a stay pursuant to this Court’s discretionary authority. BACKGROUND1 A. Factual Background 1. The Parties The parties to this action are a subset of the parties to the Loan Documents, namely, Lender and Guarantors. Lender is a trust, and its trustee

is Wells Fargo Bank, National Association; both are citizens of South Dakota. (Compl. ¶¶ 1, 7, 8). Guarantors, citizens of the state of Georgia, are the guarantors of certain obligations under the Loan Documents that will be discussed further in the remainder of this section. (Id. ¶¶ 3, 9).

1 This Opinion draws its facts, in part, from the Complaint (“Compl.” (Dkt. #1)), and its exhibits, including the promissory note (“Note” (Compl., Ex. A)); the loan agreement (“Loan Agreement” (id., Ex. B)); the guaranty of recourse obligations (“Recourse Guaranty” (id., Ex. I)); the complaint in the Alabama Action (“Alabama Compl.” (id., Ex. J)); Borrower’s state court counterclaims (“Alabama Counterclaims” (id., Ex. L)); a notice of acceleration of indebtedness sent to Borrower (id., Ex. M); and a demand for payment under the Recourse Guaranty (id., Ex. N). Because “[a] motion to dismiss based on Colorado River is considered as a motion to dismiss for lack of subject matter jurisdiction pursuant to Rule 12(b)(1) of [the] Federal Rules of Civil Procedure,” Iacovacci v. Monticciolo, No. 18 Civ. 7984 (JFK), 2019 WL 2074584, at *3 (S.D.N.Y. May 9, 2019), the Court also draws jurisdictional facts from the Declaration of Monica Patel in support of Defendants’ motion to dismiss or stay (“Patel Decl.” (Dkt. #20)), and from the exhibits appended to the Declaration of John Dana submitted in support of Defendants’ motion to dismiss or stay (“Dana Decl., Ex. [ ]” (Dkt. #19)) and the Declaration of Elinor Murarova submitted in opposition to Defendants’ motion to dismiss or stay (“Murarova Decl., Ex. [ ]” (Dkt. #25)). On this point, Defendants are permitted to offer extrinsic evidence showing lack of subject matter jurisdiction on a motion brought under Federal Rule of Civil Procedure 12(b)(1). See Nicholas v. Trump, 433 F. Supp. 3d 581, 584 n.2 (S.D.N.Y. 2020) (citing Carter v. HealthPort Techs., LLC, 822 F.3d 47, 57 (2d Cir. 2016)). Moreover, the exhibits appended to the Dana and Murarova Declarations include filings on the docket of the Alabama Action, which filings are public records of which the Court may take judicial notice. See Mangiafico v. Blumenthal, 471 F.3d 391, 398 (2d Cir. 2006) (explaining that “docket sheets are public records of which” courts may take judicial notice); Fed. R. Evid. 201. For ease of reference, the Court refers to Defendants’ memorandum of law in support of their motion to dismiss or stay as “Def. Br.” (Dkt. #21); to Plaintiff’s memorandum of law in opposition to the motion to dismiss or stay as “Pl. Opp.” (Dkt. #24); and to Defendants’ reply memorandum of law in further support of their motion to dismiss or stay as “Def. Reply” (Dkt. #27). 2. The Loan Documents On August 30, 2019, DBR Investments Co. Limited (the “Original Lender”) made a loan (the “Loan”) in the principal amount of $10,710,000 to Borrower. (Compl. ¶ 13; see generally Loan Agreement). The Loan is evidenced

by a promissory note dated August 30, 2019, made by Borrower to Original Lender in the original principal amount of $10,710,000 (the “Note”). (Compl. ¶ 14; see generally Note). In connection with the Loan, Borrower and Original Lender also entered into a loan agreement (the “Loan Agreement”), dated as of August 30, 2019, which describes the loan transaction and various security interests securing the Loan. (Compl. ¶ 15; see generally Loan Agreement). Borrower and Original Lender also executed a Cash Management Agreement, dated as of August 30, 2019 (the “Cash Management Agreement”). (Compl.

¶ 20 & Ex. D). The Loan is secured by a Mortgage, Assignment of Leases and Rents and Security Agreement, dated as of August 30, 2019 (the “Mortgage”). (Compl. ¶ 21 & Ex. E). The Mortgage was recorded on September 4, 2019, in the records of the Office of the Judge of Probate of Jefferson County, Alabama, and covers the Property. (Id. ¶¶ 21-22). Borrower also executed an Assignment of Leases and Rents (the “Assignment of Rents”) to Original Lender, dated as of August 30, 2019. (Id. ¶ 24 & Ex. F). Finally, on or about August 30, 2019,

Defendants executed the Recourse Guaranty. (Id. ¶ 28; see generally Recourse Guaranty).

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Wells Fargo Bank, National Association v. Patel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wells-fargo-bank-national-association-v-patel-nysd-2025.