Case 2:11-cv-00456-JAT Document 1 Filed 03/08/11 Page 1 of 14

1 Garrick L. Gallagher/Bar No. 009980

Debora L. Verdier/Bar No. 018676
2 Shanks Leonhardt/Bar No. 025595
SANDERS & PARKS, P.C.
3 1300 SCF Tower
3030 North Third Street
4 Phoenix, AZ 85012-3099
5 Garrick L. Gallagher
Direct Phone: (602) 532-5720
6 Direct Fax: (602) 230-5053
Garrick.Gallagher@SandersParks.com
7 Debora.Verdier@SandersParks.com
Shanks.Leonhardt@SandersParks.com
8
Attorneys for Plaintiff Westchester Fire
9 Insurance Company
10 UNITED STATES DISTRICT COURT
11 DISTRICT OF ARIZONA
12 WESTCHESTER FIRE INSURANCE Case No.
COMPANY, a Pennsylvania corporation,
13
Plaintiff,
14
v. PLAINTIFF WESTCHESTER FIRE
15 INSURANCE COMPANY’S
16 ML LIQUIDATING TRUST, as the COMPLAINT
successor to MORTGAGES LTD., an IN INTERPLEADER
17 Arizona corporation; ML MANAGER, LLC,
as a successor to MORTGAGES LTD., an
18 Arizona corporation; ML SERVICING
COMPANY, as a successor to
19 MORTGAGES LTD., an Arizona
corporation; GERALD K. SMITH as the
20 personal representative of THE ESTATE OF
SCOTT M. COLES; SMC REVOCABLE
21 TRUST DATED DECEMBER 22, 1994;
ASHLEY COLES, an individual;
22 MICHAEL DENNING, an individual;
TODD BROWN, an individual;
23 CHRISTOPHER OLSON, an individual;
JEFFREY NEWMAN, an individual;
24 LAURA MARTINI, an individual;
NECHELLE WIMMER, an individual; YI
25 YANG, an individual; GEORGE
EVERETTE, an individual; PHILLIP
26 SOLLOMI, JR., an individual; MANUEL
 Case 2:11-cv-00456-JAT Document 1 Filed 03/08/11 Page 2 of 14

1 ALEMANY, an individual; JOSEPH LEE,

an individual; ROBERT FURST, an
2 individual; RICHARD ALAN ZEIGLER, an
individual; RYAN WALTER, an individual;
3 ROBERT FACCIOLA, an individual; THE
ROBERT MAURICE FACCIOLA TRUST
4 DATED DECEMBER 2, 1994;
HONEYLOU C. REZNIK, an individual;
5 THE MORRIS REZNIK AND HONEYLOU
C. REZNIK TRUST; JEWEL BOX LOAN
6 COMPANY, INC.; an Arizona corporation;
JEWEL BOX, INC.; an Arizona corporation;
7 H-M INVESTMENTS, LLC; an Arizona
limited liability company; FRED C. HAGEL
8 AND JACQUELINE M. HAGEL
REVOCABLE TRUST DATED MARCH
9 15, 1995; JUDITH A. BAKER, an
individual; VICTIMS RECOVERY, LLC, an
10 Arizona limited liability company.
11 Defendants.

12 Pursuant to Rule 22, Federal Rules of Civil Procedure, and 28 U.S.C. § 1335,
13 Plaintiff Westchester Fire Insurance Company (“Westchester”) hereby files its Complaint
14 in Interpleader against ML Liquidating Trust (“ML Trust”), ML Manager, LLC, ML
15 Servicing Company, the Estate of Scott Coles, SMC Revocable Trust Dated December
16 22, 1994, Ashley Coles, Christopher Olson, Michael Denning, Todd Brown, Jeffrey
17 Newman, Laura Martini, Nechelle Wimmer, Yi Yang, George Everette, Phillip Sollomi,
18 Jr., Manuel Alemany, Joseph Lee, Robert Furst, Richard Alan Zeigler, Ryan Walter
19 (collectively “ML Defendants”), Robert Facciola, The Robert Maurice Facciola Trust
20 dated December 2, 1994, Honeylou C. Reznik, The Morris Reznik and Honeylou C.
21 Reznik Trust, Jewel Box Loan Company, Inc., Jewel Box, Inc., H-M Investments, LLC,
22 Fred C. Hagel and Jacqueline M. Hagel Revocable Trust dated March 15, 1995 and
23 Judith A. Baker, individually and on behalf of others similarly situated (“Facciola
24 Defendants”), and Victims Recovery, LLC (“Victims Recovery Defendants”).
25 Westchester alleges the following:
26

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1 PARTIES

2 1. Plaintiff Westchester is a Pennsylvania corporation that conducts business

3 in Arizona among other states. Westchester issued a Business and Management

4 Indemnity Policy No. BMI20047145 (“the Policy”) to Mortgages Ltd. A copy of the

5 Policy is attached as Exhibit 1.

6 2. Pursuant to the “First Amended Plan of Reorganization dated March 12,

7 2009” and the “Order Confirming Investors Committee’s First Amended Plan

8 Reorganization Dated March 12, 2009” entered May 20, 2009 in the Mortgages Ltd.

9 bankruptcy proceeding, ML Trust is the sole successor to any and all rights of Mortgages

10 Ltd. (the original owner of the Policy) to the Policy and any predecessor policies.

11 Mortgages Ltd. was an Arizona corporation whose principal place of business was

12 Maricopa County, Arizona.

13 3. Upon information and belief, Defendant ML Manager, LLC is a limited

14 liability company that has succeeded to certain rights of Mortgages Ltd., an Arizona

15 corporation whose principal place of business was Maricopa County, Arizona.

16 4. Upon information and belief, Defendant ML Servicing Company is a

17 corporation that has succeeded to certain rights of Mortgages Ltd., an Arizona

18 corporation whose principal place of business was Maricopa County, Arizona.

19 5. Upon information and belief, Defendant Ashley Coles is the widow of

20 Mortgages Ltd.’s deceased CEO Scott Coles who is domiciled and residing in Maricopa

21 County, Arizona.

22 6. Upon information and belief, Defendant Gerald Smith has been named the

23 personal representative of Scott Coles’ estate by the Superior Court of Maricopa County,

24 Arizona. These claims are asserted against Mr. Smith in his capacity as the personal

25 representative of the Estate of Scott Coles pursuant to A.R.S. § 14-3110.

26 7. Upon information and belief, Defendant SMC Revocable Trust Dated

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1 December 22, 1994 is a trust that may hold certain rights on behalf of Scott Coles.

2 8. Upon information and belief, Defendant Christopher Olson is a former

3 employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona.

4 9. Upon information and belief, Defendant Michael Denning is a former

5 employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona.

6 10. Upon information and belief, Defendant Todd Brown is a former employee

7 of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona.

8 11. Upon information and belief, Defendant Jeffrey Newman is a former

9 employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona.

10 12. Upon information and belief, Defendant Laura Martini is a former

11 employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona.

12 13. Upon information and belief, Defendant Nechelle Wimmer is a former

13 employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona.

14 14. Upon information and belief, Defendant Yi Yang is a former employee of

15 Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona.

16 15. Upon information and belief, Defendant George Everette is a former

17 employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona.

18 16. Upon information and belief, Defendant Phillip Sollomi, Jr. is a former

19 employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona.

20 17. Upon information and belief, Defendant Manuel Alemany is a former

21 employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona.

22 18. Upon information and belief, Defendant Joseph Lee is a former employee

23 of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona.

24 19. Upon information and belief, Defendant Robert Furst is a former employee

25 of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona.

26 20. Upon information and belief, Defendant Richard Alan Zeigler is a former

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1 employee of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona.

2 21. Upon information and belief, Defendant Ryan Walter is a former employee

3 of Mortgages Ltd. who is domiciled and residing in Maricopa County, Arizona.

4 22. Upon information and belief, Robert Facciola, The Robert Maurice

5 Facciola Trust dated December 2, 1994, Honeylou C. Reznik, The Morris Reznik and

6 Honeylou C. Reznik Trust, Jewel Box Loan Company, Inc., Jewel Box, Inc., H-M

7 Investments, LLC, Fred C. Hagel and Jacqueline M. Hagel Revocable Trust dated March

8 15, 1995, and Judith A. Baker are residents or citizens of Maricopa County, Arizona

9 and/or they have consented to jurisdiction in the United States District Court for the

10 District of Arizona for their claims related to Mortgages Ltd. by filing Facciola, et al. v.

11 Greenburg Traurig, et al., United States District Court, District of Arizona No. 2:10-CV-

12 01025-MHM (“the Facciola case”). Facciola Defendants are asserting rights under the

13 Policy.

14 23. Upon information and belief, Victims Recovery, LLC is an Arizona limited

15 liability company that is asserting rights under the Policy.

16 JURISDICTION AND VENUE

17 24. This Court has personal jurisdiction over each of the Defendants in this

18 Complaint in Interpleader under the United States Constitution and Arizona’s long-arm

19 statute, Ariz. R. Civ. P. 4.2(a), because the Defendants are domiciled and residing in

20 Arizona and/or they allegedly caused an event to occur in Arizona out of which this claim

21 arises and/or because the Defendants purposefully directed their activities into this forum.

22 25. This Court has subject matter jurisdiction over this matter pursuant to 28

23 U.S.C. §§ 1332 and 1335 because this action is between citizens of different states, the

24 amount in controversy exceeds $75,000, and because the District Court has original

25 jurisdiction over this interpleader claim related to a policy of insurance greater than $500.

26 26. Pursuant to 28 U.S.C. § 1391, the District of Arizona is the proper venue

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1 for this action because all the Defendants are domiciled and reside within Arizona and/or

2 because “a substantial part of the events or omissions giving rise to the claim” occurred

3 in Arizona.

4 FACTS

5 27. Westchester realleges and incorporates by reference the foregoing

6 paragraphs as if they were set forth fully herein.

7 I. Mortgages Ltd.’s Insurance Policy with Westchester

8 28. Westchester issued the Policy to Mortgages Ltd. with a policy period from

9 September 22, 2007 through February 19, 2009 and an extended reporting period until

10 February 19, 2012. Among other things, the Policy contained a Directors and Officers

11 (“D&O”) coverage section that requires Westchester to indemnify Mortgages Ltd. and/or

12 its directors, officers, and employees for certain defined losses arising out of claims made

13 against Mortgages Ltd. and/or its directors, officers, and employees during the policy

14 period and/or extended reporting period. The specific circumstances to which the D&O

15 coverage section applies are set forth in the Policy and relevant endorsements.

16 29. Pursuant to Endorsement No. 13 to the D&O coverage section, Westchester

17 does not have a duty to defend Mortgages Ltd. and/or its directors, officers, and

18 employees against claims.

19 30. The D&O coverage section contains a $3,000,000 aggregate for all “Loss,”

20 a $1,000,000 additional aggregate for “Loss” in certain defined circumstances, and a

21 maximum aggregate of $4,000,000 for this coverage section.

22 31. These limits are, by the Policy’s express terms, inclusive of the insured’s

23 attorneys’ fees and other certain specifically-enumerated amounts defined as “Costs,

24 Charges, and Expenses.” This type of policy is often referred to as a “wasting” or

25 “eroding” policy because the amount of available coverage is continually decreasing by

26 the fees and costs incurred by the insured in defending a claim.

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1 32. Accordingly the D&O coverage section has been reduced by certain

2 defense and indemnity payments made by Westchester such that only $3,740,870

3 remains.

4 II. The ML Litigation

5 33. Upon information and belief, Mortgages Ltd. (“the Company”) formerly

6 operated as a private-mortgage lender in Arizona that originated, sold, and serviced real-

7 estate loans.

8 34. Upon information and belief, the Company declared bankruptcy in 2008

9 after accumulating nearly $1 billion in debt owed to various borrowers, creditors, and

10 investors.

11 35. In the aftermath of Mortgages Ltd.’s collapse, various different investors,

12 borrowers, and regulatory agencies instituted a series of separate litigations (collectively

13 “the ML Litigation”) against, among others, Mortgages Ltd. and some or all of ML

14 Defendants arising out of various allegations, including but not limited to, that Mortgages

15 Ltd. and ML Defendants defrauded investors by, among other things, violating Arizona

16 securities statutes, misrepresenting material information to investors, and operating a

17 Ponzi scheme.

18 36. Upon information and belief, the ML Litigation includes, among others, the

19 following cases alleging claims against Mortgages Ltd. and/or some or all of ML

20 Defendants:

21 a. Marsh v. Greenburg Traurig, Superior Court, Maricopa County No.

22 CV2010-097769;

23 b. Sperber-Porter v. Alemany, Superior Court, Maricopa County No.

24 CV2010-052169;

25 c. Sperber-Porter v. Lee, Superior Court, Maricopa County No.

26 CV2010-052152;

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1 d. Ashkenazi v. Lee, Superior Court, Maricopa County No. CV2010-

2 052206;

3 e. Baldino v. Furst, Superior Court, Maricopa County No. CV2010-

4 052168;

5 f. Jeffrey C. Stone, Inc. v. Greenberg Traurig, United States District

6 Court for the District of Arizona, No. 2:09-cv-02454-MHM;

7 g. Facciola v. Greenburg Traurig, United States District Court for the

8 District of Arizona No. 2:10-CV-01025-MHM;

9 h. Victims Recovery, LLC v. Greenberg Traurig, United States

10 Bankruptcy Court for the District of Arizona, No. 2:10-ap-01214-RJH;

11 i. ML Liquidating Trust v. Denning, United States Bankruptcy Court

12 for the District of Arizona, Nos. 2:10-ap-01098-RJH and 2:10-ap-01131-RJH;

13 j. ML Liquidating Trust v. Yang, United States Bankruptcy Court for

14 the District of Arizona, No. 2:10-ap-01127-RJH;

15 k. ML Liquidating Trust v. Everette, United States Bankruptcy Court

16 for the District of Arizona, No. 2:10-ap-01133-RJH;

17 l. ML Liquidating Trust v. Furst, United States Bankruptcy Court for

18 the District of Arizona, No. 2:10-ap-01126-RJH;

19 m. ML Liquidating Trust v. Zeigler, United States Bankruptcy Court for

20 the District of Arizona, No. 2:10-ap-01132-RJH;

21 n. ML Liquidating Trust v. Walter, United States Bankruptcy Court for

22 the District of Arizona, No. 2:10-ap-1134-RJH;

23 o. Brown v. ML Manager, United States Bankruptcy Court for the

24 District of Arizona, No. 2:10-ap-01876-EWH.

25 p. In the Matter of Mortgages Ltd., Securities, LLC, Securities and

26 Exchange Commission, Administrative File Number 3-13752;

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1 37. These cases allege some or all of the following general categories of claims

2 arising out of these allegations of misconduct:

3 a. Violation of Arizona securities and consumer fraud statutes;

4 b. Negligent misrepresentation and non-disclosure;

5 c. Negligence;

6 d. Breach of fiduciary duty;

7 e. Common law fraud/constructive fraud;

8 f. Illegal enterprise;

9 g. Fraudulent transfers; and

10 h. Aiding and abetting (a) through (g).

11 38. In addition to ML Defendants, most of these claims also target the licensed

12 professionals who assisted in or failed to disclose the financial misconduct of Mortgages

13 Ltd., including but not limited to several large law firms and accounting firms.

14 39. Mortgages Ltd. and ML Defendants sought insurance coverage under the

15 D&O coverage section of the Policy for the ML Litigation, including these various causes

16 of action.

17 III. Westchester’s Denials

18 40. Westchester initially denied coverage for some of the cases within the ML

19 Litigation based upon a variety of Policy provisions and exclusions to the D&O coverage

20 section of the Policy, including but not limited to the exclusions listed below.

21 41. For example, the lender’s liability exclusion states Westchester shall not be

22 liable for any loss:

23 based upon, arising out of, directly or indirectly resulting from, in

consequence of, or in any way involving the actual or alleged
24 purchase, sale, origination, participation, grant, commitment,
restructuring, termination, transfer, repossession or foreclosure of
25
any loan, lease or extension of credit, or the failure to do any of the
26 foregoing, or the rendering of advice in connection with any loan,

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1 lease or extension of credit.

2 42. The securities offering exclusion states Westchester shall not be liable for

3 any loss:
alleging, based upon, arising out of, attributable to, directly or
4 indirectly resulting from, in consequence of, or in any way involving
5 . . . (iii) any equity or debt offering, solicitation, sale, distribution or
issuance of securities of the Company in excess of $100 million
6 during the Policy Period . . . or any activities or transactions dealing
in any way with such issuances of securities.
7
43. The professional services exclusion states Westchester shall not be liable
8
for any loss:
9
alleging, based upon, arising out of, attributable to, directly or
10 indirectly resulting from, in consequence of, or in any way involving
the rendering or failing to render professional services. Provided,
11 however, this exclusion shall not apply to any Claim(s) brought by a
12 securities holder of the Company in their capacity as such.
44. The absolute contract exclusion states Westchester shall not be liable for
13
any loss “alleging, based upon, arising out of, attributable to, directly or indirectly
14
resulting from, in consequence of, or in any way involving the actual or alleged breach of
15
any oral, written, express or implied contract or agreement.”
16
45. After Westchester denied coverage to ML Defendant Christopher Olson in
17
the Facciola case, Facciola Defendants entered into a Damron agreement with Olson
18
relating to the claims they asserted as Plaintiffs against him in the Facciola case. In
19
conjunction with this agreement, Olson stipulated to allow Facciola Defendants to enter
20
judgment against him for $5,000,000 in exchange for a covenant not to execute the
21
judgment against him.
22
46. On August 6, 2010, the Court entered judgment in the Facciola case in
23
favor of Facciola Defendants and against ML Defendant Christopher Olson for
24
$5,000,000.
25
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1 47. Upon information and belief, Facciola Defendants and Victims Recovery

2 Defendants also entered into an agreement with ML Defendant Jeffrey Newman whereby

3 they agreed to dismiss their respective claims against Mr. Newman in exchange for an

4 assignment of all his rights under the Policy.

5 48. Since its initial denial, Westchester has continued to evaluate this matter

6 and Westchester still believes the claims fall squarely within the ambit of the lender’s

7 liability exclusion or would otherwise be barred by virtue of various additional Policy

8 provisions.

9 49. However, in recognition of the various practical considerations, including

10 the potential need to litigate the coverage issues in multiple forums, Westchester

11 withdrew, based solely on such other factors, its denial of coverage and accepted

12 coverage under the D&O coverage section without reservation for ML Defendants for the

13 ML Litigation.

14 IV. Competing Claims in Excess of the Policy Limits

15 50. The various claims in the ML litigation allege upwards of $900 million in

16 damages.

17 51. These amounts far exceed the limits of the D&O coverage section.

18 52. The various individual ML Defendants, Facciola Defendants, and Victims

19 Recovery Defendants all claim an interest in the Policy proceeds that will subject

20 Westchester to multiple and excessive claims beyond the Policy limits, although

21 Westchester has, at all times, acted fairly, reasonably and in good faith toward the

22 Defendants.

23 53. For example, Facciola Defendants seek to assert the $5,000,000 stipulated

24 judgment against Olson against Westchester via a writ of garnishment issued by the

25 Court on August 9, 2010 in the Facciola case.

26

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1 54. Various other ML Defendants also continue to seek ongoing reimbursement

2 of defense and indemnity costs under the D&O coverage section of the Policy for use in

3 the various cases within the ML Litigation.

4 55. As a result of these competing claims to the Policy funds under the D&O

5 coverage section, Westchester filed this Complaint in Interpleader so that the Court can

6 distribute the remaining funds under the D&O coverage section.

7 CAUSE OF ACTION FOR INTERPLEADER

8 56. Westchester realleges the foregoing paragraphs and incorporates all such

9 allegations by reference as if they were set forth fully herein.

10 57. Westchester is unable to ascertain which of the Defendants are entitled to

11 the remaining limits of the D&O coverage section and/or in what amounts.

12 58. Westchester cannot safely pay the remaining funds until it is determined to

13 whom and in what amounts the payments must be made.

14 59. The competing claims and demands of the Defendants are such that

15 Westchester is, or may be, exposed to the risk of multiple liabilities and/or multiple

16 pieces of litigation, although Westchester has, at all times, acted fairly, reasonably and in

17 good faith toward the Defendants.

18 60. Therefore, Westchester is interpleading the remaining funds under the

19 D&O coverage section of the Policy so that the Court can determine to whom and in what

20 amounts these funds should be disbursed.

21 61. Because the D&O coverage section limit has been reduced by

22 reimbursements for defense and indemnity costs, the total amount of the funds available

23 at the time of this filing is $3,740,870 – which represents the only remaining funds under

24 the D&O coverage section.

25 62. Westchester stands ready to unconditionally deposit this amount to the

26 Clerk of the United States District Court for the District of Arizona. Westchester

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1 anticipates filing a motion seeking permission of the Court to deposit the funds with the

2 Clerk upon receipt of the assignment of the case.

3 63. Westchester has no interest in the remaining the D&O coverage section

4 limit and is a mere stakeholder in this action.

5 64. There is not now, nor has there ever been, any collusion between

6 Westchester and any of the Defendants. Westchester has brought this action solely to

7 secure the proper and appropriate distribution of the remaining coverage available under

8 the Policy.

9 65. Without this action, Westchester has no way of protecting itself against

10 multiple and excessive claims to the remaining coverage available under the Policy.

11 WHEREFORE, Plaintiffs pray for Judgment against Defendants as follows:

12 a. That the Defendants, and each of them, be required to litigate between

13 themselves their respective claims to the proceeds under the Policy;

14 b. That the Court enter an order restraining Defendants, and each of them,

15 from instituting or further prosecuting any other proceeding affecting the

16 rights and obligations between and among the parties to the interpleader

17 and their agents until further order of the Court;

18 c. That the Court enter an order directing the proper distribution of the

19 remaining funds within the remaining Policy limits to any or all of the

20 Defendants herein;

21 d. That, upon future request and upon deposit of the remaining Policy limits

22 into the Court, Westchester be discharged from any further participation

23 in this proceeding, and that the Court order and adjudge that Westchester

24 have no further liability of any kind to any of the Defendants herein for

25 the payment of any sum;

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1 e. For such other and further relief as this Court deems reasonable and just

2 under the circumstances.

3
4
5 RESPECTFULLY SUBMITTED this 8th day of March, 2011.

6 SANDERS & PARKS, P.C.

7
By s/Shanks Leonhardt
8 Garrick L. Gallagher
Debora L. Verdier
9 Shanks Leonhardt
3030 North Third Street, Suite 1300
10 Phoenix, Arizona 85012-3099
Attorneys for Plaintiff Westchester Fire
11 Insurance Company
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