LB Judgment Holdings, LLC v. Boschetti
A judgment creditor pursuing proceedings supplementary against impleaded alter-ego entities and alleged fraudulent transferees recorded notices of lis pendens against seventeen properties; the trial court discharged them and separately set eighteen bonds totaling over $18 million. The Third District reversed the discharge, holding the creditor established the required 'fair nexus' through a good-faith, viable alter-ego/fraudulent-transfer claim, affirmed the denial of the impleaded entities' motion to quash service and dismiss for lack of personal jurisdiction, and affirmed the bond amounts (including the separate attorneys' fee bond) while limiting fees to those incurred in obtaining discharge and giving the creditor ten days to post.
Key facts
- Judgment creditor LB Judgment Holdings, LLC recorded notices of lis pendens against seventeen properties owned by impleaded alter-ego entities and alleged fraudulent transferees in proceedings supplementary against judgment debtor Boschetti.
- The trial court discharged all lis pendens notices and set eighteen separate bonds totaling over $18 million as a condition of maintaining the supplementary proceeding.
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Why it matters
This is a leading recent Third District treatment of lis pendens in the judgment-collection context, confirming that alter-ego and fraudulent-transfer claims in proceedings supplementary can support a lis pendens and… — full analysis with a trial
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