Holguin v. Quality Furniture NY LLC
- Analisa Torres
- 1:23-cv-00004
- U.S. District Court · Southern District of New York
- 2
In Holguin v. Quality Furniture NY LLC, Judge Analisa Torres granted plaintiffs’ motion ordering Chase Bank to turn over $5,622.19 from Quality Furniture’s accounts.
The order directly affects the plaintiffs, Chase Bank, and Quality Furniture NY LLC. Chase Bank must turn over $5,622.19 and any additional amounts accruing in Quality Furniture’s accounts to the plaintiffs’ attorneys toward payment of the judgment.
What happened
In Holguin v. Quality Furniture NY LLC, the plaintiffs had already obtained a default judgment against the defendants. They then asked the court to require JPMorgan Chase Bank, N.A. (Chase Bank) to turn over money in Quality Furniture NY LLC’s bank accounts to help pay that judgment.
Chase Bank did not respond after being served with the motion. The court found that Quality Furniture had an interest in the accounts and was entitled to the money. It also found, alternatively, that the plaintiffs’ rights to the money were stronger than Chase Bank’s rights.
Judge Analisa Torres granted the plaintiffs’ motion. She ordered Chase Bank to turn over $5,622.19 and any additional amounts that continue to accrue in Quality Furniture’s accounts to the plaintiffs’ attorneys, toward payment of the judgment. The plaintiffs were also ordered to serve the order on Chase Bank and Quality Furniture by April 22, 2025, and file proof of service.
The detailed version
- Holguin v. Quality Furniture NY LLC · No. 1:23-cv-00004
- Analisa Torres
- Apr. 16, 2025
Background
On January 8, 2025, the Court granted Camilo Holguin, Astrid Coello, and Tomaz Laskawski’s motion for a default judgment against Quality Furniture NY LLC, Bargain House by Quality Furniture Inc., Bargain House by Quality Furniture NY Inc., and Issa Nasrallah. After judgment was entered, the plaintiffs moved for an order requiring JPMorgan Chase Bank, N.A. (Chase Bank) to turn over money held in bank accounts belonging to Quality Furniture, to help satisfy the judgment.
The Court ordered service of the motion on Chase Bank and gave it until April 14, 2025, to respond. The Court received no response. The opinion states that the Court had personal jurisdiction over Chase Bank.
Legal standard
Federal Rule of Civil Procedure 69(a)(1) requires post-judgment efforts to enforce a money judgment to follow the procedure of the state where the federal court is located. The Court therefore applied New York Civil Practice Law and Rules § 5225(b), which governs obtaining money or other personal property held by a third party for a judgment debtor.
The Court explained that this procedure requires two showings. First, the judgment debtor must have an interest in the property the creditor seeks to reach. Second, either the judgment debtor must be entitled to possess the property or the judgment creditor’s rights to it must be superior to those of the person holding it.
Court’s analysis
The Court found that Quality Furniture had an interest in the bank accounts. It also found that Quality Furniture was entitled to possess the money in its own accounts. Alternatively, the Court determined that the plaintiffs’ rights to the accounts were superior to Chase Bank’s rights because the plaintiffs had obtained a valid, unpaid judgment against Quality Furniture and Chase Bank had no legal right to the funds.
Ruling
Judge Analisa Torres determined that a turnover order was warranted and granted the plaintiffs’ motion. Chase Bank was directed to turn over $5,622.19 and any amounts that continue to accrue in Quality Furniture’s bank accounts to the plaintiffs’ attorneys, toward satisfaction of the judgment at ECF No. 87.
The Court ordered the plaintiffs to serve Chase Bank and Quality Furniture with a copy of the order by April 22, 2025, and file proof of service on the docket. The Clerk of Court was directed to terminate the motion at ECF No. 88.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.