CFSP 2024-AHP1 81-83 Seaman Avenue LLC v. 81 Seaman Realty LLC
- Ronnie Abrams
- 1:25-cv-04113
- U.S. District Court · Southern District of New York
- 2
In CFSP 2024-AHP1 81-83 Seaman Avenue LLC v. 81 Seaman Realty LLC, Judge Abrams ordered supplemental letters on diversity jurisdiction.
The parties to the action, including CFSP 2024-AHP1 81-83 Seaman Avenue LLC and the defendants, must address the Court’s questions about diversity jurisdiction in supplemental letters.
What happened
CFSP 2024-AHP1 81-83 Seaman Avenue LLC v. 81 Seaman Realty LLC involves the plaintiff’s motion to appoint a receiver. The court scheduled an initial conference and oral argument for August 14, 2025.
The court ordered the parties to file supplemental letters by August 11 addressing whether the federal court has diversity jurisdiction, which depends in part on the parties’ citizenship. The letters must address whether the plaintiff takes the citizenship of its sole member, Computershare Trust Company, N.A., or of the mortgage trust’s beneficiaries or certificateholders.
Judge Ronnie Abrams also directed the parties to discuss whether the trust is a traditional trust or a business trust and whether a rule concerning trustees applies when the trustee is only the plaintiff LLC’s sole member. The order did not decide whether diversity jurisdiction exists or whether to appoint a receiver.
The detailed version
- CFSP 2024-AHP1 81-83 Seaman Avenue LLC v. 81 Seaman Realty LLC · No. 1:25-cv-04113
- Ronnie Abrams
- Aug. 7, 2025
Background
The Court had scheduled an initial conference and oral argument on Plaintiff’s motion to appoint a receiver for August 14, 2025.
Jurisdictional Question
The Court required the parties to file supplemental letters no later than August 11, 2025, addressing whether the Court has diversity jurisdiction. The parties must specifically explain whether Plaintiff’s citizenship is determined by the citizenship of Computershare Trust Company, N.A., its sole member, or by the beneficiaries or certificateholders of the CFSP 2024-AHP1 Mortgage Trust, for which Computershare serves as trustee.
The parties must also address whether the mortgage trust is a traditional trust or a “business trust” under the framework of Americold Realty Trust v. Conagra Foods, Inc., and whether Navarro Savings Association v. Lee applies when the trustee is merely the sole member of a plaintiff LLC and is not suing in its own name. The Court also cited a Second Circuit decision suggesting that Navarro applies only when the trustee sues in its own name.
Order
Judge Ronnie Abrams ordered the supplemental jurisdictional letters. The opinion does not decide whether diversity jurisdiction exists, does not resolve the trust-citizenship questions, and does not rule on the motion to appoint a receiver.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.