Major League Baseball Properties, Inc. -against- Corporacion de Television y…
Major League Baseball Properties, Inc. -against- Corporacion de Television y Microonda Rafa, S.A., et al.
- Vyskocil
- 1:19-cv-08669
- U.S. District Court · Southern District of New York
- 7
In Major League Baseball Properties v. Corporacion de Television, Judge Vyskocil denied MLB’s turnover motion without prejudice to renewal over $1,078.94.
Major League Baseball Properties, Inc.’s effort to collect its judgment was unsuccessful on this motion; the $1,078.94 in Telemicro funds held in Yankwitt LLP’s attorney trust account was not ordered turned over.
What happened
Major League Baseball Properties, Inc. v. Corporacion de Television y Microonda Rafa, S.A., et al. concerns MLB’s effort to collect a judgment exceeding $6 million after an arbitration award over Telemicro’s unpaid broadcast-rights payments. MLB asked the court to turn over $1,078.94 held in Yankwitt LLP’s attorney trust account for Telemicro.
The court found that Telemicro had an interest in the funds because money in an attorney trust account generally remains the client’s property. But MLB did not show that Telemicro was entitled to possess the money or that MLB’s rights were stronger than Yankwitt’s rights. The court therefore denied the turnover request.
Judge Mary Kay Vyskocil denied the motion without prejudice to renewal and directed the Clerk of Court to terminate the relevant docket entry.
The detailed version
- Major League Baseball Properties, Inc. -against- Corporacion de Television y… · No. 1:19-cv-08669
- Vyskocil
- Sept. 15, 2025
Background
Major League Baseball Properties, Inc. (MLB) had a contract with Corporación de Televisión y Microonda Rafa, S.A. (Telemicro) concerning Telemicro’s rights to broadcast MLB content in the Dominican Republic. After Telemicro failed to make payments, MLB terminated the contract and demanded arbitration. An arbitration award was entered in MLB’s favor, and this Court confirmed the award and entered a judgment exceeding $6 million.
MLB then sought to enforce that judgment. In the motion addressed by this order, MLB requested turnover of $1,078.94 in Yankwitt LLP’s attorney trust account. MLB asserted that the money belonged to Telemicro and had not been earned by Yankwitt. MLB had frozen the funds using a restraining notice. Yankwitt and Telemicro were served, and neither opposed the motion; MLB represented that Yankwitt had no objection.
Legal Standard
Federal Rule of Civil Procedure 69(a) requires proceedings used to enforce a federal 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 section 5225(b), which governs recovery of property held by someone other than the judgment debtor.
Under section 5225(b), a judgment creditor must satisfy two steps. First, it must show that the judgment debtor has an interest in the property. Second, it must show either that the judgment debtor is entitled to possess the property or that the judgment creditor’s rights are superior to the rights of the person holding it. The court explained that a Rule 69(a) turnover motion may be brought by motion and is treated like a summary-judgment motion. Even when the opposing party does not respond, the moving party must establish that the undisputed facts support judgment as a matter of law.
Court’s Analysis
The court found that MLB satisfied the first step. The account statement showed that Yankwitt’s trust account contained $1,078.94 deposited by Telemicro that Yankwitt had not earned. The court explained that funds in an attorney trust account generally remain the client’s property. Thus, Telemicro had an interest in the funds, and Yankwitt was a third party holding property in which the judgment debtor had an interest.
The motion failed at the second step. MLB provided no facts or argument showing whether Telemicro could retrieve the balance from the trust account. The court explained that having an interest in property does not necessarily mean that the judgment debtor is entitled to possess it. Because MLB did not establish Telemicro’s right to possession, it did not show that there was no genuine dispute of material fact on that issue.
MLB also did not argue or cite authority showing that its rights to the funds were superior to Yankwitt’s rights. The court rejected the idea that Yankwitt’s lack of opposition automatically established MLB’s superior right. A judgment creditor must still prove that the undisputed facts entitle it to relief under the law.
Disposition
Judge Mary Kay Vyskocil denied MLB’s motion for turnover without prejudice to renewal. The Clerk of Court was requested to terminate docket entry 181.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.