Apollo Trust v. BNP Paribas Jersey Trust Corporation Limited
BNP domesticated a Jersey judgment and worldwide freeze order against judgment debtor Edoarda Crociani and instituted proceedings supplementary to reach seven paintings stored in a Miami art vault, impleading Apollo Trust and its trustees, who claimed to own the artwork. The Third District held that BNP's motion alleged sufficient long-arm facts, but that the minimum-contacts/connexity question turns on whether the judgment debtor holds an executable interest in the Miami artwork — a disputed factual issue requiring a limited evidentiary hearing under Venetian Salami and Tabet.
Key facts
- BNP Paribas Jersey Trust Corporation domesticated a Jersey judgment and worldwide freeze order against judgment debtor Edoarda Crociani and sought to reach seven paintings stored in a Miami art vault through supplementary proceedings.
- Apollo Trust and its trustees were impleaded as defendants, claiming to own the artwork; BNP alleged the foreign trust had shipped the artwork to Florida, contracted for storage, obtained Florida insurance, engaged a Florida appraiser, and retained Florida counsel.
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Why it matters
This opinion maps the intersection of proceedings supplementary, domesticated foreign judgments, and long-arm jurisdiction over impleaded nonresident asset holders — a recurring problem in asset-recovery practice… — full analysis with a trial
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