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WESTCHESTER FIRE INSURANCE COMPANY v. ML LIQUIDATING TRUST et al Complaint

ATTENTION: It is possible that this information may no longer be current and therefore may be inaccurate. The index contains both open and closed cases and is not a complete list of cases in which an ACE Insurance Group company is involved. This information is provided to give interested persons an idea of the issues disputed in the indexed cases. For a full understanding of a case, one should read the rest of the court file, including the response. For the most up-to-date and complete information on a case, visit www.pacer.gov or contact the clerk of the relevant court.

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Case 2:11-cv-00456-JAT Document 1
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Garrick L. Gallagher/Bar No. 009980 Debora L. Verdier/Bar No. 018676 Shanks Leonhardt/Bar No. 025595 SANDERS & PARKS, P.C. 1300 SCF Tower 3030 North Third Street Phoenix, AZ 85012-3099 Garrick L. Gallagher Direct Phone: (602) 532-5720 Direct Fax: (602) 230-5053 Garrick.Gallagher@SandersParks.com Debora.Verdier@SandersParks.com Shanks.Leonhardt@SandersParks.com Attorneys for Plaintiff Westchester Fire Insurance Company UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Case No.
12 WESTCHESTER FIRE INSURANCE COMPANY, a Pennsylvania corporation, 13 Plaintiff, 14 v. 15 16 ML LIQUIDATING TRUST, as the successor to MORTGAGES LTD., an 17 Arizona corporation; ML MANAGER, LLC, as a successor to MORTGAGES LTD., an 18 Arizona corporation; ML SERVICING COMPANY, as a successor to 19 MORTGAGES LTD., an Arizona corporation; GERALD K. SMITH as the 20 personal representative of THE ESTATE OF SCOTT M. COLES; SMC REVOCABLE 21 TRUST DATED DECEMBER 22, 1994; ASHLEY COLES, an individual; 22 MICHAEL DENNING, an individual; TODD BROWN, an individual; 23 CHRISTOPHER OLSON, an individual; JEFFREY NEWMAN, an individual; 24 LAURA MARTINI, an individual; NECHELLE WIMMER, an individual; YI 25 YANG, an individual; GEORGE EVERETTE, an individual; PHILLIP 26 SOLLOMI, JR., an individual; MANUEL
PLAINTIFF WESTCHESTER FIRE INSURANCE COMPANY’S COMPLAINT IN INTERPLEADER
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1 ALEMANY, an individual; JOSEPH LEE, an individual; ROBERT FURST, an 2 individual; RICHARD ALAN ZEIGLER, an individual; RYAN WALTER, an individual; 3 ROBERT FACCIOLA, an individual; THE ROBERT MAURICE FACCIOLA TRUST DECEMBER 2, 1994; 4 DATED HONEYLOU C. REZNIK, an individual; 5 THE MORRIS REZNIK AND HONEYLOU C. REZNIK TRUST; JEWEL BOX LOAN 6 COMPANY, INC.; an Arizona corporation; JEWEL BOX, INC.; an Arizona corporation; 7 H-M INVESTMENTS, LLC; an Arizona limited liability company; FRED C. HAGEL JACQUELINE M. HAGEL 8 AND REVOCABLE TRUST DATED MARCH 9 15, 1995; JUDITH A. BAKER, an individual; VICTIMS RECOVERY, LLC, an 10 Arizona limited liability company. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Defendants. Pursuant to Rule 22, Federal Rules of Civil Procedure, and 28 U.S.C. § 1335, Plaintiff Westchester Fire Insurance Company (“Westchester”) hereby files its Complaint in Interpleader against ML Liquidating Trust (“ML Trust”), ML Manager, LLC, ML Servicing Company, the Estate of Scott Coles, SMC Revocable Trust Dated December 22, 1994, Ashley Coles, Christopher Olson, Michael Denning, Todd Brown, Jeffrey Newman, Laura Martini, Nechelle Wimmer, Yi Yang, George Everette, Phillip Sollomi, Jr., Manuel Alemany, Joseph Lee, Robert Furst, Richard Alan Zeigler, Ryan Walter (collectively “ML Defendants”), Robert Facciola, The Robert Maurice Facciola Trust dated December 2, 1994, Honeylou C. Reznik, The Morris Reznik and Honeylou C. Reznik Trust, Jewel Box Loan Company, Inc., Jewel Box, Inc., H-M Investments, LLC, Fred C. Hagel and Jacqueline M. Hagel Revocable Trust dated March 15, 1995 and Judith A. Baker, individually and on behalf of others similarly situated (“Facciola Defendants”), and Victims Recovery, LLC (“Victims Recovery Defendants”). Westchester alleges the following:
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PARTIES Plaintiff Westchester is a Pennsylvania corporation that conducts business Westchester issued a Business and Management
in Arizona among other states.
Indemnity Policy No. BMI20047145 (“the Policy”) to Mortgages Ltd. A copy of the Policy is attached as Exhibit 1. 2. Pursuant to the “First Amended Plan of Reorganization dated March 12,
2009” and the “Order Confirming Investors Committee’s First Amended Plan Reorganization Dated March 12, 2009” entered May 20, 2009 in the Mortgages Ltd. bankruptcy proceeding, ML Trust is the sole successor to any and all rights of Mortgages Ltd. (the original owner of the Policy) to the Policy and any predecessor policies. Mortgages Ltd. was an Arizona corporation whose principal place of business was Maricopa County, Arizona. 3. Upon information and belief, Defendant ML Manager, LLC is a limited
liability company that has succeeded to certain rights of Mortgages Ltd., an Arizona corporation whose principal place of business was Maricopa County, Arizona. 4. Upon information and belief, Defendant ML Servicing Company is a
corporation that has succeeded to certain rights of Mortgages Ltd., an Arizona corporation whose principal place of business was Maricopa County, Arizona. 5. Upon information and belief, Defendant Ashley Coles is the widow of
Mortgages Ltd.’s deceased CEO Scott Coles who is domiciled and residing in Maricopa County, Arizona. 6. Upon information and belief, Defendant Gerald Smith has been named the
personal representative of Scott Coles’ estate by the Superior Court of Maricopa County, Arizona. These claims are asserted against Mr. Smith in his capacity as the personal representative of the Estate of Scott Coles pursuant to A.R.S. § 14-3110. 7. Upon information and belief, Defendant SMC Revocable Trust Dated
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December 22, 1994 is a trust that may hold certain rights on behalf of Scott Coles. 8. Upon information and belief, Defendant Christopher Olson is a former
employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona. 9. Upon information and belief, Defendant Michael Denning is a former
employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona. 10. Upon information and belief, Defendant Todd Brown is a former employee
of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona. 11. Upon information and belief, Defendant Jeffrey Newman is a former
employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona. 12. Upon information and belief, Defendant Laura Martini is a former
employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona. 13. Upon information and belief, Defendant Nechelle Wimmer is a former
employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona. 14. Upon information and belief, Defendant Yi Yang is a former employee of
Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona. 15. Upon information and belief, Defendant George Everette is a former
employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona. 16. Upon information and belief, Defendant Phillip Sollomi, Jr. is a former
employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona. 17. Upon information and belief, Defendant Manuel Alemany is a former
employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona. 18. Upon information and belief, Defendant Joseph Lee is a former employee
of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona. 19. Upon information and belief, Defendant Robert Furst is a former employee
of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona. 20. Upon information and belief, Defendant Richard Alan Zeigler is a former
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employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona. 21. Upon information and belief, Defendant Ryan Walter is a former employee
of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona. 22. Upon information and belief, Robert Facciola, The Robert Maurice
Facciola Trust dated December 2, 1994, Honeylou C. Reznik, The Morris Reznik and Honeylou C. Reznik Trust, Jewel Box Loan Company, Inc., Jewel Box, Inc., H-M Investments, LLC, Fred C. Hagel and Jacqueline M. Hagel Revocable Trust dated March 15, 1995, and Judith A. Baker are residents or citizens of Maricopa County, Arizona and/or they have consented to jurisdiction in the United States District Court for the District of Arizona for their claims related to Mortgages Ltd. by filing Facciola, et al. v. Greenburg Traurig, et al., United States District Court, District of Arizona No. 2:10-CV01025-MHM (“the Facciola case”). Facciola Defendants are asserting rights under the Policy. 23. Upon information and belief, Victims Recovery, LLC is an Arizona limited
liability company that is asserting rights under the Policy. JURISDICTION AND VENUE 24. This Court has personal jurisdiction over each of the Defendants in this
Complaint in Interpleader under the United States Constitution and Arizona’s long-arm statute, Ariz. R. Civ. P. 4.2(a), because the Defendants are domiciled and residing in Arizona and/or they allegedly caused an event to occur in Arizona out of which this claim arises and/or because the Defendants purposefully directed their activities into this forum. 25. This Court has subject matter jurisdiction over this matter pursuant to 28
U.S.C. §§ 1332 and 1335 because this action is between citizens of different states, the amount in controversy exceeds $75,000, and because the District Court has original jurisdiction over this interpleader claim related to a policy of insurance greater than $500. 26. Pursuant to 28 U.S.C. § 1391, the District of Arizona is the proper venue
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for this action because all the Defendants are domiciled and reside within Arizona and/or because “a substantial part of the events or omissions giving rise to the claim” occurred in Arizona. FACTS 27. Westchester realleges and incorporates by reference the foregoing
paragraphs as if they were set forth fully herein. I. Mortgages Ltd.’s Insurance Policy with Westchester 28. Westchester issued the Policy to Mortgages Ltd. with a policy period from
September 22, 2007 through February 19, 2009 and an extended reporting period until February 19, 2012. Among other things, the Policy contained a Directors and Officers (“D&O”) coverage section that requires Westchester to indemnify Mortgages Ltd. and/or its directors, officers, and employees for certain defined losses arising out of claims made against Mortgages Ltd. and/or its directors, officers, and employees during the policy period and/or extended reporting period. The specific circumstances to which the D&O coverage section applies are set forth in the Policy and relevant endorsements. 29. Pursuant to Endorsement No. 13 to the D&O coverage section, Westchester
does not have a duty to defend Mortgages Ltd. and/or its directors, officers, and employees against claims. 30. The D&O coverage section contains a $3,000,000 aggregate for all “Loss,”
a $1,000,000 additional aggregate for “Loss” in certain defined circumstances, and a maximum aggregate of $4,000,000 for this coverage section. 31. These limits are, by the Policy’s express terms, inclusive of the insured’s
attorneys’ fees and other certain specifically-enumerated amounts defined as “Costs, Charges, and Expenses.” This type of policy is often referred to as a “wasting” or “eroding” policy because the amount of available coverage is continually decreasing by the fees and costs incurred by the insured in defending a claim.
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32.
Accordingly the D&O coverage section has been reduced by certain
defense and indemnity payments made by Westchester such that only $3,740,870 remains. II. The ML Litigation 33. Upon information and belief, Mortgages Ltd. (“the Company”) formerly
operated as a private-mortgage lender in Arizona that originated, sold, and serviced realestate loans. 34. Upon information and belief, the Company declared bankruptcy in 2008
after accumulating nearly $1 billion in debt owed to various borrowers, creditors, and investors. 35. In the aftermath of Mortgages Ltd.’s collapse, various different investors,
borrowers, and regulatory agencies instituted a series of separate litigations (collectively “the ML Litigation”) against, among others, Mortgages Ltd. and some or all of ML Defendants arising out of various allegations, including but not limited to, that Mortgages Ltd. and ML Defendants defrauded investors by, among other things, violating Arizona securities statutes, misrepresenting material information to investors, and operating a Ponzi scheme. 36. Upon information and belief, the ML Litigation includes, among others, the
following cases alleging claims against Mortgages Ltd. and/or some or all of ML Defendants: a. CV2010-097769; b. CV2010-052169; c. CV2010-052152; Sperber-Porter v. Lee, Superior Court, Maricopa County No. Sperber-Porter v. Alemany, Superior Court, Maricopa County No. Marsh v. Greenburg Traurig, Superior Court, Maricopa County No.
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d.
Ashkenazi v. Lee, Superior Court, Maricopa County No. CV2010-
e.
Baldino v. Furst, Superior Court, Maricopa County No. CV2010-
f.
Jeffrey C. Stone, Inc. v. Greenberg Traurig, United States District
Court for the District of Arizona, No. 2:09-cv-02454-MHM; g. Facciola v. Greenburg Traurig, United States District Court for the
District of Arizona No. 2:10-CV-01025-MHM; h. Victims Recovery, LLC v. Greenberg Traurig, United States
Bankruptcy Court for the District of Arizona, No. 2:10-ap-01214-RJH; i. ML Liquidating Trust v. Denning, United States Bankruptcy Court
for the District of Arizona, Nos. 2:10-ap-01098-RJH and 2:10-ap-01131-RJH; j. ML Liquidating Trust v. Yang, United States Bankruptcy Court for
the District of Arizona, No. 2:10-ap-01127-RJH; k. ML Liquidating Trust v. Everette, United States Bankruptcy Court
for the District of Arizona, No. 2:10-ap-01133-RJH; l. ML Liquidating Trust v. Furst, United States Bankruptcy Court for
the District of Arizona, No. 2:10-ap-01126-RJH; m. ML Liquidating Trust v. Zeigler, United States Bankruptcy Court for
the District of Arizona, No. 2:10-ap-01132-RJH; n. ML Liquidating Trust v. Walter, United States Bankruptcy Court for
the District of Arizona, No. 2:10-ap-1134-RJH; o. Brown v. ML Manager, United States Bankruptcy Court for the
District of Arizona, No. 2:10-ap-01876-EWH. p. In the Matter of Mortgages Ltd., Securities, LLC, Securities and
Exchange Commission, Administrative File Number 3-13752;
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37.
These cases allege some or all of the following general categories of claims
arising out of these allegations of misconduct: a. Violation of Arizona securities and consumer fraud statutes; b. Negligent misrepresentation and non-disclosure; c. Negligence; d. Breach of fiduciary duty; e. Common law fraud/constructive fraud; f. Illegal enterprise; g. Fraudulent transfers; and h. Aiding and abetting (a) through (g). 38. In addition to ML Defendants, most of these claims also target the licensed
professionals who assisted in or failed to disclose the financial misconduct of Mortgages Ltd., including but not limited to several large law firms and accounting firms. 39. Mortgages Ltd. and ML Defendants sought insurance coverage under the
D&O coverage section of the Policy for the ML Litigation, including these various causes of action. III. Westchester’s Denials 40. Westchester initially denied coverage for some of the cases within the ML
Litigation based upon a variety of Policy provisions and exclusions to the D&O coverage section of the Policy, including but not limited to the exclusions listed below. 41. For example, the lender’s liability exclusion states Westchester shall not be
liable for any loss: based upon, arising out of, directly or indirectly resulting from, in consequence of, or in any way involving the actual or alleged purchase, sale, origination, participation, grant, commitment, restructuring, termination, transfer, repossession or foreclosure of any loan, lease or extension of credit, or the failure to do any of the foregoing, or the rendering of advice in connection with any loan,
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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 44. 43. for any loss: 42. any loss:
lease or extension of credit. The securities offering exclusion states Westchester shall not be liable for alleging, based upon, arising out of, attributable to, directly or indirectly resulting from, in consequence of, or in any way involving . . . (iii) any equity or debt offering, solicitation, sale, distribution or issuance of securities of the Company in excess of $100 million during the Policy Period . . . or any activities or transactions dealing in any way with such issuances of securities. The professional services exclusion states Westchester shall not be liable alleging, based upon, arising out of, attributable to, directly or indirectly resulting from, in consequence of, or in any way involving the rendering or failing to render professional services. Provided, however, this exclusion shall not apply to any Claim(s) brought by a securities holder of the Company in their capacity as such. The absolute contract exclusion states Westchester shall not be liable for
any loss “alleging, based upon, arising out of, attributable to, directly or indirectly resulting from, in consequence of, or in any way involving the actual or alleged breach of any oral, written, express or implied contract or agreement.” 45. After Westchester denied coverage to ML Defendant Christopher Olson in
the Facciola case, Facciola Defendants entered into a Damron agreement with Olson relating to the claims they asserted as Plaintiffs against him in the Facciola case. In conjunction with this agreement, Olson stipulated to allow Facciola Defendants to enter judgment against him for $5,000,000 in exchange for a covenant not to execute the judgment against him. 46. On August 6, 2010, the Court entered judgment in the Facciola case in
favor of Facciola Defendants and against ML Defendant Christopher Olson for $5,000,000.
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47.
Upon information and belief, Facciola Defendants and Victims Recovery
Defendants also entered into an agreement with ML Defendant Jeffrey Newman whereby they agreed to dismiss their respective claims against Mr. Newman in exchange for an assignment of all his rights under the Policy. 48. Since its initial denial, Westchester has continued to evaluate this matter
and Westchester still believes the claims fall squarely within the ambit of the lender’s liability exclusion or would otherwise be barred by virtue of various additional Policy provisions. 49. However, in recognition of the various practical considerations, including
the potential need to litigate the coverage issues in multiple forums, Westchester withdrew, based solely on such other factors, its denial of coverage and accepted coverage under the D&O coverage section without reservation for ML Defendants for the ML Litigation. IV. Competing Claims in Excess of the Policy Limits 50. damages. 51. 52. These amounts far exceed the limits of the D&O coverage section. The various individual ML Defendants, Facciola Defendants, and Victims The various claims in the ML litigation allege upwards of $900 million in
Recovery Defendants all claim an interest in the Policy proceeds that will subject Westchester to multiple and excessive claims beyond the Policy limits, although Westchester has, at all times, acted fairly, reasonably and in good faith toward the Defendants. 53. For example, Facciola Defendants seek to assert the $5,000,000 stipulated
judgment against Olson against Westchester via a writ of garnishment issued by the Court on August 9, 2010 in the Facciola case.
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54.
Various other ML Defendants also continue to seek ongoing reimbursement
of defense and indemnity costs under the D&O coverage section of the Policy for use in the various cases within the ML Litigation. 55. As a result of these competing claims to the Policy funds under the D&O
coverage section, Westchester filed this Complaint in Interpleader so that the Court can distribute the remaining funds under the D&O coverage section. CAUSE OF ACTION FOR INTERPLEADER 56. Westchester realleges the foregoing paragraphs and incorporates all such
allegations by reference as if they were set forth fully herein. 57. Westchester is unable to ascertain which of the Defendants are entitled to
the remaining limits of the D&O coverage section and/or in what amounts. 58. Westchester cannot safely pay the remaining funds until it is determined to
whom and in what amounts the payments must be made. 59. The competing claims and demands of the Defendants are such that
Westchester is, or may be, exposed to the risk of multiple liabilities and/or multiple pieces of litigation, although Westchester has, at all times, acted fairly, reasonably and in good faith toward the Defendants. 60. Therefore, Westchester is interpleading the remaining funds under the
D&O coverage section of the Policy so that the Court can determine to whom and in what amounts these funds should be disbursed. 61. Because the D&O coverage section limit has been reduced by
reimbursements for defense and indemnity costs, the total amount of the funds available at the time of this filing is $3,740,870 – which represents the only remaining funds under the D&O coverage section. 62. Westchester stands ready to unconditionally deposit this amount to the Westchester
Clerk of the United States District Court for the District of Arizona.
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anticipates filing a motion seeking permission of the Court to deposit the funds with the Clerk upon receipt of the assignment of the case. 63. Westchester has no interest in the remaining the D&O coverage section
limit and is a mere stakeholder in this action. 64. There is not now, nor has there ever been, any collusion between
Westchester and any of the Defendants. Westchester has brought this action solely to secure the proper and appropriate distribution of the remaining coverage available under the Policy. 65. Without this action, Westchester has no way of protecting itself against
multiple and excessive claims to the remaining coverage available under the Policy. WHEREFORE, Plaintiffs pray for Judgment against Defendants as follows: a. That the Defendants, and each of them, be required to litigate between themselves their respective claims to the proceeds under the Policy; b. That the Court enter an order restraining Defendants, and each of them, from instituting or further prosecuting any other proceeding affecting the rights and obligations between and among the parties to the interpleader and their agents until further order of the Court; c. That the Court enter an order directing the proper distribution of the remaining funds within the remaining Policy limits to any or all of the Defendants herein; d. That, upon future request and upon deposit of the remaining Policy limits into the Court, Westchester be discharged from any further participation in this proceeding, and that the Court order and adjudge that Westchester have no further liability of any kind to any of the Defendants herein for the payment of any sum;
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e.
For such other and further relief as this Court deems reasonable and just under the circumstances.
RESPECTFULLY SUBMITTED this 8th day of March, 2011. SANDERS & PARKS, P.C. By s/Shanks Leonhardt Garrick L. Gallagher Debora L. Verdier Shanks Leonhardt 3030 North Third Street, Suite 1300 Phoenix, Arizona 85012-3099 Attorneys for Plaintiff Westchester Fire Insurance Company
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