Motion for Summary Judgment in James Moran v. Grand Slam Ventures, Llc, Jon Steinberg, Glenn A. Reiner, Jg Real Estate Ventures, Llc, 'John Does' 1-10 Inclusive, The Last Ten Names Being Fictitious And Unknown To Plaintiff| Trellis.Law

On May 27, 2022 a Motion-Secondary was filed involving a dispute between James Moran, and Glenn A. Reiner, Grand Slam Ventures, Llc, Jg Real Estate Ventures, Llc, 'John Does' 1-10 Inclusive, The Last Ten Names Being Fictitious And Unknown To Plaintiff, Jon Steinberg, for Other Matters - Contract - Other in the District Court of Nassau County.

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FILED: NASSAU COUNTY CLERK 06/24/2022 05:14 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 06/24/2022

SUPREME COURT OF THE STATE OF NEW YORK Return Date July 19, 2022
COUNTY OF NASSAU Hon. Erica L. Prager
-----------------------------------------------------------------------x Index No. 001052/2019
JAMES MORAN,
Plaintiff,

AFFIDAVIT IN SUPPORT
-against-

GRAND SLAM VENTURES, LLC, JON STEINBERG,
GLENN A. REINER, JG REAL ESTATE VENTURES,
LLC, and "JOHN DOES" # 1-10 inclusive, the last ten
names being fictitious and unknown to plaintiff,

Defendants.
-----------------------------------------------------------------------x
STATE OF NEW YORK )
) ss.:
COUNTY OF NASSAU )

I, James Moran, being duly sworn, deposes and says under the penalties of perjury as

follows:

1. I, JAMES MORAN, ("Plaintiff' and/or "Moran"), am the named plaintiff in the

above captioned action, appearing pro se, and, as such, I have personal firsthand knowledge of

the facts and circumstances stated herein.

2. This affidavit is respectfully submitted in support of Plaintiff's instant motion

seeking an Order: a) pursuant to CPLR §3212, granting summary judgment in favor of Plaintiff

on the First, Third, and Fourth Causes of Action of the Verified Complaint; and/orb) pursuant to

CPLR §321l(b) dismissing Defendants' Affirmative Defenses; and/or c) piercing the corporate

veils and adjudging De:fenctams jointly and severally liable for the judgments entered by Plaintiff

against Defendant Grand Slam; and/or d) for such other, further and different relief as this

Honorable Court may deem just, proper and equitable.

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BACKGROUND

3. Plaintiff was in lawful exclusive possession of real property commonly known as

219 Hempstead Turnpike, West Hempstead, New York 11552. (the subject "Property")

4. Defendant Grand Slam Ventures, LLC ("Defendant Grand Slam") commenced an

action seeking to foreclose on a mortgage it held encumbering the subject Property and was

granted a Judgment of Foreclosure and Sale and at the public auction, held on August 13, 2013,

provided the winning bid of $550,000.00. (the "foreclosure action" 1)

5. After providing the winning bid, and before being issued a Referee's Deed, on

August 27, 2013 Defendant Grand Slam entered upon the subject Property, without any legal

right or court order, illegally evicted Plaintiff therefrom and removed/seized Plaintiffs personal

property valued at $92,540.00 which consisted of, inter alia, industrial machinery utilized for

Plaintiffs woodworking business; thereby essentially putting Plaintiff out of business.

6. On September 23, 2013, after illegally evicting Plaintiff and removing/seizing

Plaintiffs personal property, Defendant Jon Steinberg ("Defendant Steinberg") and Defendant

Glenn A. Reiner ("Defendant Reiner") formed Defendant JG Real Estate Ventures, LLC.

("Defendant JG Real Estate") (See, Exhibit "1 ")

7. On September 26, 2013, after Defendant Grand Slam illegally evicted Plaintiff

from the subject Property and converted his personal property, Defendant Steinberg, as a

member of both Defendant Grand Slam and Defendant JG Real Estate executed an Assignment

of Bid at Foreclosure Sale assigning Defendant Grand Siam's winning bid of $550,000.00 to

De:renctant JG Keal Estate in consideration o:r $10.00. (the subject ..conveyance" or ..trans:fer")

(See, Exhibit "2")

1 Moran was a named defendant in the foreclosure action which was eventually dismissed and discontinued insofar
as asserted against Moran.

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8. A Referee's Deed to the subject Property was issued to Defendant JG Real Estate

on September 26, 2013 and recorded on October 9, 2013. (See, Exhibit "3")

9. On February 14, 2014 the Court, in the foreclosure action, granted Defendant

Grand Slam's unopposed motion determining the fair and reasonable market value of the subject

Property to be $550,000.00 as of August 13, 2013. (See, Exhibit "4")

10. On August 26, 2014 Plaintiff commenced an action against Defendant Grand

Slam for its trespass upon the subject Property, the wrongful eviction of Plaintiff therefrom and

the conversion of Plaintiffs personal property which was assigned Nassau County Index

Number 008291/2014. (the "prior action")

11. On October 20, 2015 Defendant JG Real Estate conveyed the subject Property to

A2 Consulting and Management LLC. (See, Exhibit "5")

12. Defendant Grand Slam defaulted in the prior action and Plaintiff was granted a

default judgment as to liability and the Appellate Division, Second Department, reversed a

subsequent Order that had vacated Defendant Grand Slam's default. See, Moran v. Grand Slam

Ventures, LLC, 160 A.D.3d 944, 75 N.Y.S.3d 252 (2d Dept., 2018)

13. On September 28, 2018 a Judgment in the amount of $1,415.00 was entered in

favor of Plaintiff and against Defendant Grand Slam representing costs awarded to Plaintiff by

the Appellate Division, Second Department. (See, Exhibit "6")

14. After an inquest to determine Plaintiffs damages was held in the prior action, the

Court, [Pineda-Kirwan, J.] by Order dated April 26, 2019, determined Defendant Grand Slam

was liable to Plaintiff for damages as of August 27, 2013, prior to the transfer of the subject

Property on September 26, 2013, in the amount of "$250,000 together with interest from August

27, 2013, and costs and disbursements." (See, Exhibit "7")

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15. A Judgment was entered on May 9, 2019 in favor of Plaintiff and against

Defendant Grand Slam in the amount of $381,216.42, inclusive of interest from August 27, 2013

and costs and disbursements. (See, Exhibit "8")

16. On June 28, 2019, in an effort to collect the Judgments, (the "supplementary

proceedings") in accordance with CPLR §5223 and CPLR §5224(a)(l) & (22, Plaintiff served

subpoenas upon Defendant Grand Slam and Defendant Reiner, then a non-party, seeking the

production of, inter alia, banking records and requiring that they appear for their respective

depositions. (See, NYSCEF 2 Doc. #34)

17. Defendant Reiner refused and failed to appear on August 12, 2019 in accordance

with a second subpoena served upon him on July 29, 2019 requiring his appearance for

examination and the production of, inter alia, banking records. (See, NYSCEF Doc. #35)

18. On September 3, 2019 the Court in the prior action [Pineda-Kirwan, J.] denied

Defendants' second ex-parte application seeking to quash the subpoena served upon Defendant

Reiner. (See, NYSCEF Doc. #36)

19. Defendant Steinberg appeared on October 30, 2019 and testified that he is a

member of both Defendant Grand Slam and Defendant JG Real Estate and that on September 26,

2013 Defendant Grand Slam assigned the subject Property to Defendant JG Real Estate in

consideration of $10.00 and that Defendant JG Real Estate subsequently sold the subject

Property to A2 Consulting and Management LLC. (See, Exhibit "9" at page 26 lines 21-23)

20. Defendant Steinberg failed to produce banking records as was required by the

subpoena and testified that De:rendant Reiner was in possession o:r De:fenctant JG Real tstate's

banking records. (See, Exhibit "9" at page 46 lines 5-9)

2New York State Courts Electronic Filing James Moran v. Grand Slam Ventures, LLC, Jon Steinberg, Glenn A.
Reiner, JG Real Estate Ventures, LLC, et al, Nassau County Index No. 001052/2019

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21. Defendant Steinberg's deposition was adjourned with the agreement that

Defendant Steinberg obtains Defendant Grand Slam's and Defendant JG Real Estate's banking

records and appears for the continuation of his examination. (See, Exhibit "9" at pages 62-63

lines 19-25 & 2-10)

22. Defendant Reiner appeared on November 6, 2019 for his deposition and failed to

produce any banking records and refused to answer certain questions. (See, Exhibit "10")

23. After Defendant Reiner failed to produce bank records, as was required by the

subpoena, Plaintiff sought to continue the deposition of Defendant Steinberg as was agreed (See,

Exhibit "9" at pages 62-63 lines 19-25 & 2-10) and Defendant Steinberg's attorney directed him

not to appear. (See, NYSCEF Doc. #39)

24. As of the date of this affidavit, the above mentioned Judgments entered against

Defendant Grand Slam remain wholly unsatisfied.

PLAINTIFF'S INSTANT VERIFIED COMPLAINT

25. Plaintiff commenced this action on September 25, 2019 naming Defendants

Grand Slam, Steinberg, Reiner and JG Real Estate as defendants (collectively "Defendants")

alleging, inter alia, that the conveyance of the subject Property to Defendant JG Real Estate was

fraudulent under Debtor and Creditor Law article 10 and seeking to pierce the corporate veils.

(See, Exhibit "11 ")

26. All Defendants appeared by Siegel & Reiner, LLP by service of a Verified

Answer admitting a majority of the background narrated above and asserting five affirmative

defenses. (See, Exhibit "12")

27. On December 6, 2019 Defendants were served with Plaintiff's discovery demands

including, but not limited to, Plaintiff's First Demand for Discovery and Inspection which

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required Defendants to produce, inter alia, banking records (See, NYSCEF Doc. #21) and

Plaintiffs First Set oflnterrogatories to Defendants. (See, NYSCEF Doc. #22)

28. On December 17, 2019 a preliminary conference was held and a Preliminary

Conference Order ("PC Order") was entered setting specific dates for discovery to be completed,

and this case was put on an expedited track. (See, NYSCEF Doc. #23)

29. Pursuant to the terms of the PC Order, Defendants were required to respond to

Plaintiffs discovery demands by January 17, 2020 which Defendants failed and/or refused to do.

(See, NYSCEF Doc. #23)

30. On January 24, 2020 an early settlement conference was held and this Court

[Libert, J] issued an Order requiring Defendants to respond to Plaintiffs discovery demands by

February 3, 2020 (See, NYSCEF Doc. #25) so that the parties would have their respective

discovery responses prior to depositions which were scheduled to take place on February 10, 12

and 13, 2020. (See, NYSCEF Doc. #24 at page 6 lines 23-25)

31. On January 31, 2020, in compliance with the PC Order, Plaintiff responded to

Defendants' discovery demands. (See, NYSCEF Doc. #6- sub Exhibit "10")

32. On February 7, 2020 I called Defendants' attorney, Mr. Del Valle, and inquired as

to when responses to Plaintiffs demands would be served and Mr. Del Valle responded by

stating that he had no idea when and if responses would be served and that his clients are "big

boys" and refused to fix a time when or to indicate that responses would be forthcoming.

33. On February 11, 2020 Plaintiff moved, by Order to Show Cause, to strike

Defendants· Verified Answer for their willfUl failure to comply with Plaintitrs discovery

demands, the PC Order and the Court's Order dated January 24, 2020. (See, NYSCEF Doc. #6)

34. Defendants' cross-moved for a Protective Order. (See, NYSCEF Doc. #7)

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35. On August 30, 2021 this Court [Sullivan, J.] issued an Order granting Defendants'

cross-motion seeking a protective order to extent of requiring Defendants to respond to

Plaintiffs documents demands numbered 1, 5, 6, 8, 18, 22, 23, 25, 43 and 47, and Plaintiffs

Interrogatories numbered 1, 2, 5, 6, 13, 14, 16, 17, 23 and 24. (See, NYSCEF Doc. #5)

36. The Court's Order dated August 30, 2021 is the subject of Plaintiffs motion

seeking an Order, pursuant to CPLR §2221 (f), granting Plaintiff leave to reargue and renew

which is currently pending before this Court (See, NYSCEF Doc. #'s 3-16) and pending

Plaintiffs appeal to the Appellate Division, Second Department, which has been perfected.

(Appellate Division Docket No.: 2021-07308)

37. On October 22, 2021 Defendants provided responses to Plaintiffs discovery

demands that are incomplete, cursory, superficial, woefully inadequate and/or totally

unresponsive. (See, NYSCEF Doc. #'s 27 & 28)

38. Specifically, Defendants failed to produce any banking records for the years 2012

through 2014 claiming that they are not in possession of same (See, NYSCEF Doc. #27 at ,r,r8 &

25) and responded to Plaintiffs interrogatory number 24, which required a statement of the

consideration given and/or received for the transfer of the subject Property, by stating "See,

Exhibit G to Defendants' Response to Plaintiffs Demand for Discovery and Inspection of even

date." (emphasis in original) (See, NYSCEF Doc. #28 at i!24)

39. Defendants' "Exhibit G" consists of 1) documents related to what appears to be

tax lien searches and taxes then due on the subject Property, without any indication if such were

paid, by whom and/or when; 2) an invoice :from Dreygo Development LLC, dated November 21,

2017 without any indication if such was paid, by whom and/or when; and 3) the Assignment of

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Bid transferring the subject Property from Defendant Grand Slam to Defendant JG Real Estate.

(See, NYSCEF Doc. #27)

40. Defendants also failed and refused to produce any documents related to the

conveyance of the subject Property from Defendant JG Real Estate to A2 Consulting and

Management LLC. (See, Exhibit "5" and NYSCEF Doc. #27)

41. On February 9, 2022 a conference was held with this Court whereat Defendants'

Counsel asserted that Defendants would be producing an affidavit from a bank representative

describing the efforts Defendants made to retrieve the required bank records, how long bank

records were retained by the bank, if they were destroyed by the bank when and if a litigation

hold was issued by Defendants.

42. Defendants' Counsel also asserted that Defendants would provide an affidavit

properly responding to Plaintiffs interrogatory number 24 which required a statement of the

consideration given and/or received for the conveyance of the subject Property.

43. On March 29, 2022, Plaintiff memorialized the above in a letter to Defendants'

Counsel dated March 29, 2022 and inquired of Defendants' Counsel as to when Defendants

would be complying with Court's Order, dated August 30, 2021. (See, NYSCEF Doc. #30)

44. Defendants have failed to produce an affidavit by a bank representative and

instead produced Defendant Reiner' s affidavit sworn to April 14, 2022 which is another

incomplete, cursory, superficial and woefully inadequate response to Plaintiffs interrogatory

numbered 24. (See, NYSCEF Doc. #31)

45. De.fendants· spoliation 01 evidence and willful failure to comply with the Coun·s

Order dated August 30, 2021 is the subject of Plaintifrs motion seeking sanctions which is

currently pending before this Court. (See, NYSCEF Doc. #'s 17-41)

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46. Notwithstanding, the Assignment of Bid provides: "For value received, in the

amount of $10.00, the undersigned does hereby assign ... " and does not include language such

as" ... and other good and valuable consideration" (See, Exhibit "2")

4 7. In fact, Defendant Steinberg testified under oath m the supplementary

proceedings that the only consideration given for the subject Property was $10.00.

Q. JG Real Estate Ventures acquired the property from Grand Slam
Ventures for $10, the winning bid, correct?
A. Yes.
Q. Did JG Real Estate Ventures invest any other money into the
property?
A. I don't believe so.

Q. Grand Slam transferred the winning bid, the property, to JG Real
Estate Ventures for $1 0?
A. Yes.
Q. You had testified there was no other consideration?
A. Correct.

Q. So JG Real Estate Ventures took no loss. They pay nothing for the
property, $10 for the property?
A. Correct.
(See, Exhibit "9" at page 48 lines 15-21 and page 50 lines 6-11 and 18-21)

48. Defendant Reiner's affidavit sworn to April 14, 2022 alleges "Defendants JG, Mr.

Steinberg, and I" paid various tax liens and real property taxes for the subject Property for a total

amount of $104,593.19, paid the insurance premium for the subject Property in the amount of

$3,950.00, paid $69,365.00 to have the subject Property cleaned and repaired and " ... paidthe

investors in the mortgage held by Grand Slam on the property to relieve Grand Slam of the

obligation." (See, NYSCEF Doc. #31)

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49. When questioned in the supplementary proceedings, Defendant Reiner was asked

the following questions and gave the following responses:

Q. Did you have any other involvement with Grand Slam Ventures
other than acting as their attorney?
A. No.
Q. Do you ever invest any money in Grand Slam Ventures?
A. No.
Q. Did you ever loan any money to Grand Slam Ventures?
A. No.
Q. Did you ever pay any bills or expenses on behalf of Grand Slam
Ventures?
A. Not that I remember.
Q. I would ask the same questions with regards to your law firm. Did
your law firm ever pay any bills or expenses with regards to Grand
Slam Ventures?
A. We may have laid out money but we were probably reimbursed but
I don't remember off the top of my head.
Q. Did your law firm invest any money?
A. No.
Q. Loan any money?
A. No.
Q. So the only thing is you might have paid some bills or expenses on
behalf of them?
A. We often will pay client disbursements and get reimbursed
afterwards.
Q. Would what would those disbursements be for court costs?
A. Court costs, filing fees, formation of documents. Court services.
Q. Anything outside that area?
A. No, not typically.
Q. Would you have paid any taxes or insurance?
A.No.

(See, Exhibit "10" at pages 7-8 lines 7-25 and 2-22)

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50. Defendant Steinberg also testified under oath in the prior action that Defendant

Reiner did not invest any money in Defendant Grand Slam or Defendant JG Real Estate.

Q. Did Glen Reiner invest money in Grand Slam Ventures?
A. No.
Q. Did he invest money in JG Real Estate Ventures?
A. No.
(See, Exhibit "13" at page 132 lines 5-10)

51. It should be noted, when questioned in the supplementary proceedings, Defendant

Reiner testified under oath that the consideration given was "mostly real estate taxes".

Q. And what was the assignment of bid for? What consideration was given for it,
I should say?
A. There was substantial obligations owed on the property that JG had agreed to
assume.
Q. What obligations were those?
A. Mostly real estate taxes.
Q. And how much were those real estate taxes?
A. Approximately over 100, approximately 100 and something thousand dollars.
Q. So when JG Real Estate Ventures became the owner of the property it paid the
real estate taxes?
A. Sometime thereafter, yes.
Q. Was there any other consideration given?
A. Not that I can recall at this moment.

(See, Exhibit "10" at Pages 14-15 Lines 17-25 & 2-13)

52. Defendants have failed to produce documents relating to and/or evidencing the

consideration given and/or received relating to any conveyance and/or transfer of the subject

Property in response to Plaintiffs document demand number 47 (See, NYSCEF Doc. #21 at if47)

as required by the Court's Order dated August 30, 2021. (See, NYSCEF Doc. #5)

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53. Notwithstanding, Defendants' intentional and willful destruction of relevant

evidence, i.e.,Defendant Grand Siam's and Defendant JG Real Estate's banking records, and

their willful failure to comply with Plaintiffs discovery demands and Order's of this Court, there

is no issue of fact in this case.

54. As demonstrated in Plaintiffs accompanying Memorandum of Law, Plaintiff is a

creditor as defined by former Debtor and Creditor Law section 270 as of August 27, 2013, the

conveyance of the subject Property on September 26, 2013 to Defendant JG Real Estate was

without "fair consideration" as defined by former Debtor and Creditor Law section 272 and the

conveyance of the subject Property rendered Defendant Grand Slam insolvent within the

meaning of former Debtor and Creditor Law section 271.

55. Further, after wrongfully converting Plaintiffs personal property, Defendants

Reiner and Steinberg stripped Defendant Grand Slam of its only asset of salable value leaving it

an empty shell and judgment proof with the intent to defraud Plaintiff and/or hinder the

collection of any judgment Plaintiff would obtain as a result of Defendants' tortuous acts.

56. In fact, Defendant Steinberg testified on direct examination by his attorney during

the inquest held in the prior action as follows:

Q. And does JG Real Estate Ventures have any relationship
with the building located at 219 Hempstead Turnpike?
A. I believe the attorney had me transfer title from Grand Slam
to JG
Q. Do you know why that was?
A. I do not.

(See, Exhibit "14" at pages 27-28 lines 22-25 and 1-3)

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57. On cross examination Defendant Steinberg testified that Defendant Reiner ran

Defendant Grand Slam.

Q. There's a lot of things you're not aware of. Who ran Grand
Slam Ventures?
A. My attorney.
Q. Who?
A. Glenn Reiner.
Q. What's Glenn Reiner?
A. He's my attorney.
Q. Do you know what's Glenn Reiner?
What firm does he work for?
A. Siegel & Reiner.
(See, Exhibit "14" at page 31 lines 16-25)

58. As noted above, Defendant Steinberg also testified under oath that Defendant

Reiner did not invest any money in Defendant Grand Slam or Defendant JG Real Estate (See,

Exhibit "13" at page 132 lines 5-10)

59. Defendant Reiner has submitted a Reply Affidavit swearing that " ... the sole

impetus for forming JG was so that Mr. Steinberg and I could have an equal share of the

Premises" and " ... the reason that JG was formed was so that Mr. Steinberg and I could own the

Premises jointly, and for that purpose only." (See, Exhibit "15" - Defendant Reiner's Reply

Affidavit sworn to March 17, 2020 at ,r,r38 & 40)

60. As a result of Defendants actions, Plaintiff has been injured; first by the wrongful

eviction of Plaintiff from the subject Property and the conversion of Plaintiffs personal property

and then by the fraudulent transfer of the subject Property impairing the ability of Plaintiff to

collect on the judgments duly entered in his favor against Defendant Grand Slam.

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WHEREFORE, plaintiff JAMES MORAN respectfully requests that this Honorable

Court enter an Order;

a) pursuant to CPLR §3212, granting summary judgment in favor of Plaintiff on the

First, Third and Fourth Causes of Action of the Verified Complaint; and/or

b) pursuant to CPLR §321 l(b) dismissing Defendants' Affirmative Defenses;

c) piercing the corporate veils and adjudging Defendants jointly and severally liable

for the judgments entered by Plaintiff against Defendant Grand Slam; and/or

d) for such other, further and different relief as this Honorable Court may deem just,

proper and equitable.

Dated: June 24, 2022
Bethpage, New York

Plaintiff pro se
28 Carrie Avenue
Bethpage, New York 11 714
Tel: (516) 302-6581
Email: jim.catlawl@gmail.com

Sworn to before me this
24th day of June, 2022
DEBRA A. BUCKING
Notary Public, State of New York
No. 4976675, ~al.8'1ffolaw:r
comm. Expires: 1/221

To: Siegel & Reiner, LLP
Attorneys for Defendants
130 East 59 th Street, 12th Floor
New York, New York 10022
Tel: (212) 447-5599
Email: rdelvalle@siegelreiner.com

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Case Info

Judge

Francis Ricigliano Track Judge’s New Case

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Document Filed Date

June 24, 2022

Case Filing Date

May 27, 2022

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Motion-Secondary: James Moran v. Grand Slam Ventures, Llc, Jon Steinberg, Glenn A. Reiner, Jg Real Estate Ventures, Llc, 'John Does' 1-10 Inclusive, The Last Ten Names Being Fictitious And Unknown To Plaintiff

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