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Brinckerhoff v. JAC Holding Corp.

Appellate Division of the Supreme Court of New York, First Department
Jul 1, 1999
263 A.D.2d 352 (N.Y. App. Div. 1999)

Summary

holding that under N.Y. C.P.L.R. § 202, plaintiffs' derivative claims accrued in "Georgia, since that is where [the corporation] had its principal office and where [the corporation's] alleged monetary damages would be felt"

Summary of this case from Aboushanab v. Janay

Opinion

July 1, 1999.

Appeal from order, Supreme Court, New York County (Barry Cozier, J.), entered October 2, 1998, which, inter alia, denied defendants' motion to dismiss the complaint as time-barred and for failure to state a cause of action, unanimously affirmed, with costs.

PRESENT: Sullivan, J.P., Nardelli, Tom, Saxe and Friedman, JJ.


Plaintiffs, minority shareholders of Hoover Group, Inc. a Deleware corporation, commenced a derivative action on behalf of the corporation against its directors, alleging breach of fiduciary duty and corporate waste in connection with the corporation's sale of its 41% stock interest in JAC Products, Inc. for what is allegedto be grossly inadequate consideration. We agree with the motion court that pursuant to New York's borrowing statute, CPLR 202, the applicable Statute of Limitations is that of Georgia, since that is where Hoover had its principle office and where Hoover's alleged monetary damages would be felt (see, Knieriemen v. Bache Halsey Stuart Shields, 74 A.D.2d 290, 296, appeal dismissed 50 N.Y.2d 1021, 1059; Prefabco, Inc. v. Olin Corp., 71 A.D.2d 587; Federal Deposit Ins. Corp. v. Cohen, *9, 1996 WL 87248, 4 [SD NY, Feb. 29, 1996, Stanton, J.]). Under the applicable Georgia limitations period, plaintiffs' action was timely commenced.

Hoover's board of directors appointed a special committee to investigate adn report on the challenged transaction. The motion court correctly found that plaintiffs had met their burden of raising a reasonable doubt as to the adequacy of the special committee's investigation because the committee was not advised by independant counsel, but rather by an attorney who had represented hoover in connection with the challenged transaction (see, Stepak v. Addison, 20 F.3d 398, 405; In re PAR Pharm., Inc., Deriviative Litig., 750 F. Supp. 641, 647). Moreover, the report of the special committee was a mere two pages in length with respect to the subject transaction, and failed to document the special committee's procedures, reasoning and conclusions, thus effectively insulating its investigation from scrutiny by the courts (see, In re PAR Pharm., Inc. Derivative Litig., 750 F. Supp. 641, supra).


Summaries of

Brinckerhoff v. JAC Holding Corp.

Appellate Division of the Supreme Court of New York, First Department
Jul 1, 1999
263 A.D.2d 352 (N.Y. App. Div. 1999)

holding that under N.Y. C.P.L.R. § 202, plaintiffs' derivative claims accrued in "Georgia, since that is where [the corporation] had its principal office and where [the corporation's] alleged monetary damages would be felt"

Summary of this case from Aboushanab v. Janay

holding that plaintiffs raised reasonable doubt as to the reasonableness of demand committee's investigation because the committee was not represented by independent counsel but rather by an attorney who had represented the corporation in connection with the challenged transaction

Summary of this case from Bender v. Schwartz

choosing as the place of accrual the state where the out-of-state company had its principal place of business and where the monetary damages would be felt

Summary of this case from Ritchie Capital Mgmt. v. JP Morgan Chase & Co.

considering two-page report that failed to document committee's procedures, reasoning, and conclusions in determining that plaintiff raised reasonable doubt as to reasonableness of investigation

Summary of this case from Bender v. Schwartz
Case details for

Brinckerhoff v. JAC Holding Corp.

Case Details

Full title:PETER R. BRINCKERHOFF et al., Respondents, v. JAC HOLDING CORPORATION et…

Court:Appellate Division of the Supreme Court of New York, First Department

Date published: Jul 1, 1999

Citations

263 A.D.2d 352 (N.Y. App. Div. 1999)
692 N.Y.S.2d 381

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