Syncora Holdings Ltd (fka SYCRF)

[DennyCrane550]

Ok, new filings in Alinda/MacQuarie and New ReOrg Piece on Greenpoint/Lehman


Here is MacQuarie:

http://iapps.courts.state.ny.us/iscroll/SQLData.jsp?IndexNo=651258-2012

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quinn emanuel trial lawyers | new york
51 Madison Avenue, 22nd Floor, New York, New York 10010-1601 | TEL [phone] FAX [phone]
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quinn emanuel urquhart & sullivan, llp
LOS ANGELES | SAN FRANCISCO | SILICON VALLEY | CHICAGO | WASHINGTON, DC | LONDON | TOKYO | MANNHEIM | MOSCOW | HAMBURG | PARIS |
SYDNEY | MUNICH
March 10, 2016
VIA NYSCEF AND HAND DELIVERY
The Honorable Anil C. Singh
Supreme Court of the State of New York
New York County, Commercial Division
60 Centre Street, Room 218
New York, NY 10013
Mot. Seq. No. 005
Re: Syncora Guarantee Inc. v. Alinda Capital Partners LLC, et al., Index No. 651258/2012
Dear Justice Singh:
We represent plaintiff Syncora Guarantee Inc. (“Syncora”) in the above-captioned matter and enclose
a copy of the transcript from the parties’ February 24, 2016 conference with the Court regarding
Syncora’s motion for leave to file and unredact the First Amended Complaint (Mot. Seq. No. 005).
We also write to inform the Court that, after consultation with Lisa Horowitz, counsel for the nonparty
witness referred to in the First Amended Complaint, we have agreed to withdraw our motion to
unredact the First Amended Complaint solely as to the identification of the non-party witness
referred to in paragraphs 62 and 64, and are prepared to redact that individual’s name from the copy
of the First Amended Complaint filed on the public docket.1
Syncora otherwise fully maintains its motion for leave to file and unredact all other allegations
contained in the First Amended Complaint.
Respectfully submitted,
/s/ Rex Lee
Rex Lee
Encl.
cc: Mark A. Kirsch, Esq. and Lisa Horowitz, Esq. (via email)
1 Accordingly, we have also redacted the individual’s name from the copy of the transcript enclosed here.
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK CIVIL TERM PART 45
iii-1-Z _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___X
SYNCQRA GUARANTEE, INC ,
- Plaintiff
— against —
ALINDA CAPITAL PARTNERS, LLC, AMERICAN ROADS, LLC
MACQUARIE SECURITIES (USA), INC., and JOHN S.
LAXMI
Defendants.
I‘$II'1'I11111-I--Z--1Z-3-I-_-11¢11¢1_—.|_-..|||||$._._.._.._-|,|._,__—._1_,_X
INDEX NUMBER 551258/12
60 Centre Street
New York, New York
February 24, 2015
B E F O R E:
HONORABLE ANIL SINGH,
Supreme Court Justice.
A P P E A R A N C E S:
QUINN EMANUEL URQUHART & SULLIVAN, ESQS.
Attorneys For Plaintiff
51 Madison Avenue
New York, New York 10010
BY: JOHN PICKHARDT, ESQ.
REX LEE, ESQ.
DAVID FARBER, ESQ.
GIBSON DUNN & CRUTCHER, LLP
Attorneys For Defendant
Maoquarie Securities (USA), Inc.
200 Park Avenue
New York, New York 10166-0193
BY: MARK A. KIRSCH, ESQ.
CHRISTOPHER N. JORALEMON, ESQ.
DAVID GOWLAY-BUCK, ESQ.
CONTINUED NEXT PAGE...
Gloria Ann Brandon, Sr. Court Reporter
FILED: NEW YORK COUNTY CLERK 03/10/2016 04:40 PM INDEX NO. 651258/2012
NYSCEF DOC. NO. 195 RECEIVED NYSCEF: 03/10/2016
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GEORGE BIRNEAUI‘-‘I, PLLC
Attorney for Non Party Witness —
230 Park Avenue
New York, New York 10169
BY: LISA S. HORUWITZ, ESQ.
Gloria Ann Brandon,
Senior Court Reporter.
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THE COURT: Remain seated.
On the record.
I have before me a motion by the Plaintiff
for leave to file an unredacted first amended
complaint, and the Defendant, Macquarie, doesn't
oppose the filing of the first amended complaint, but
objects to the filing of an unredacted complaint, so
my first question is addressed to counsel for the
Plaintiff;
Why after you enter into a confidentiality
order, a stipulation and order, should I now allow
you to file an unredacted complaint?
MR. PICKHARDT= Good morning, your Honor.
John Pickhardt from Quinn, Emanuel, Urquhart
N Sullivan on behalf of the Plaintiff, Syncora
Guarantee.
Your Honor, the parties did as customary
enter into a protective order governing the exchange
of materials, which really requires that the parties
maintain confidentiality over documents that either
of the parties considers in good faith to be subject
reasonably to confidentiality. That presents a very
different question than the question as is before the
Court today, which is whether now that Syncora is
planning, or has requested, it's not opposed to
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filing an amended pleading should that amended
pleading be available to the public, and the
presumption is under New York law that it is,
notwithstanding the fact that the parties may have
confidentiality provisions that govern the exchange,
the private exchange of documents between them in the
litigation, and in fact, your Honor, the burden is on
the defendant to --
THE COURT: So, to cut to the chase, you
don't believe that the part of the stipulation with
respect to confidentiality, which designates certain
matters confidential, which relate to the conduct of
the parties‘ business, you don't think that section
applies at all?
MR. PICKHARDT: Your Honor, I don't. That's
what the Court's determination today should turn on.
I think it should turn on the standard for sealing
governed by the New York law as opposed to whether
this properly fit within the protective order,
notwithstanding that we don't think this information
properly fit within the protective order.
THE COURT: So, if I were to agree with you
and use the public interest good cause standard, why
do you believe that the information that the
Defendants seek to seal doesn't affect their business
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in any way; proprietary information, et cetera?
MR. PICKHARDT: Your Honor, the easiest answer
there, and the one that I, frankly, think is
dispositive is that this is incredibly stale
information. All of the facts that we are talking
about are a decade old, and the Defendant --
THE COURT: So, it's historical in nature?
MR. PICKHARDT: It's historical in nature, and
they have made conclusory statements in their papers,
just lawyer statements; I would note no affidavit, or
evidentiary support on which the Court can rely.
They have some relevance. They can't cite a single
case anywhere where the Court has agreed that
information that's a decade old is still commercially
sensitive so as to establish the good cause that is
required in order for information to be kept out of
the public domain.
On top of that, your Honor, we would be happy
to hand up if it would be helpful to the Court a
demonstrative that shows you the information that
they're looking to have kept under seal. It is page
after page of information that really concerns
allegations of fraud. It concerns allegations of
information that was concealed from my client when it
was considering whether to provide insurance to the
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Defendant on these toll roads. It doesn't concern
them, unless their core business is fraud. It
doesn't concern their ongoing business practices, so
you now, regardless, even if this was conduct that
occurred last year, it still wouldn't meet the
standard, but the fact that it occurred ten years ago
is just dispositive. In fact, to find a case that
even states a standard that information that may be
historical still may have some continuing relevance,
they reach out to a case in Pennsylvania, because
they can't find a New York case, that says it.
What they don't cite from that case, even
that case says, presumptively, information that's
more than three years old, or older is no longer
commercially relevant. That's consistent with the
present ruling that came down from Judge Bransten
where she found that the information in the
Country—Wide case, it was only information from the
last 22 years. This is all pre-financial crisis
information, and Macquarie is suggesting that the
current is the same that they were doing pre-crisis.
They have bigger problems than this particular
motion. This is simply really an effort by the
Defendant to try to keep under wraps information that
they don't want revealed to the public because it's
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embarrassing. It describes in detail information,
you know, that we have seen in discovery.
Now that demonstrates that they were aware of
erroneous information that was part of their models
that they fed to Syncora, and concealed the fact that
they knew it was false at the time. That is what
they don't want out in the public.
There's case upon case, including the
Mosallem case, which is probably the one most on
point here, which clearly says the fact that
something may be embarrassing may be a reason why
they don't want it released into the public. That
certainly doesn't establish the good cause standard
that they have the burden of showing in order to
establish that it can be kept under seal.
THE COURT: Thank you.
Counsel?
MR. KIRSCH: Thank you, your Honor.
THE COURT: So, really the first question to
you is, does the good cause standard apply here, or
should the stipulation and order apply to the relief,
in essence, that you are asking for?
MR. KIRSCH: The stipulation --
Your Honor, first let me introduce myself;
Mark Kirsch for Gibson Dunn.
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The stipulation -— let me start by noting
that Macquarie has approached the confidentiality
issues with a scalpel, not an ax.
The complaint, as your Honor has seen, is
41 pages long. It has 105 paragraphs. We're seeking
to redact nine paragraphs in total, and seven in
part. We have had meet and confer discussions with
Syncora to see if there was compromise available.
Without getting into the back and forth, and the meet
and confer, as your Honor can see today, Syncora was
unwilling to permit redaction of even a single word.
Your Honor noted there's a protective order
in the case. Justice Schweitzer entered that order
in 2013. The parties have complied with it for the
last few years.
THE COURT: Why does the protective order
apply to the proceedings?
MR. KIRSCH: The protective order doesn't make
a distinction at all.
In fact, Paragraph 3 of the protective order
says, "It protects material detrimental to the
conduct of that parties‘ business." There's no
distinction anywhere in that document between
documents supposedly privately exchanged in discovery
and pleadings, or any other sort of public
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dissemination. It's all treated the same as the
public dissemination because the nature of it doesn't
change. Depending on whether it's exchanged
privately, or put on the front page of the New York
Times, there's no reason for the stipulation not to
govern.
I would say, your Honor, we think Syncora is
trying to take advantage of the fact that we gave
them the information after signing the stipulation,
having Justice Schweitzer enter it. Now they want to
publish it in a factual record that is barely under
construction. There's a lot of information that's
plainly confidential. I could go through it. The
fact that it's old is not dispositive. Macquarie is
the leading infrastructure deal maker in the world.
Actually, they're in the same business today as they
were ten years ago. How they model with or without
side funds, how they might wish to price, that is as
confidential today as it was ten years ago.
I would say, also there's a reference in the
THE COURT: Let's just sort of —— if I was
to agree with Plaintiff's counsel that the good cause
standard applies, convince me that there's good cause
to seal.
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MR. KIRSCH: Sure, your Honor.
If your Honor believes that the good cause
applies, then some of the paragraphs we wish to
redact should not be redacted. Some of those
paragraphs cannot meet that standard. Some of them
do.
THE COURT: Be specific.
MR. KIRSCH: Sure.
May I focus on the ones that I think do?
THE COURT: Absolutely.
MR. KIRSCH: Your Honor, look at Paragraph 70
for example.
MR. PICKHARDT: Would your Honor like a
compilation of the redactions?
THE COURT: I do have an unredacted version
that was given to me as a courtesy.
MR. KIRSCH: I'm sure you do, but we'll hand
one up if that's okay.
Your Honor, may I approach?
THE COURT: Sure.
Thank you.
MR. KIRSCH: Thank you, your Honor.
So, if you look at Paragraph 70, you see
there's a reference to Macquarie modeling a proposed
return on investment, and whether that was a good
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return. What Macquarie thinks is a good return
inherently is a confidential piece of information.
In that same paragraph, your Honor, there's
information about how Macquarie modeled, internally
proposed capital structure for the deal; you see how
much equity, how much subordinated debt, how much are
the proceeds of the bonds, what the relative
proportions of them would be. That's quite
proprietary.
If your Honor were to look at Paragraph 72,
that discusses, for example, what sensitivities
Macquarie applied to its analysis of the proposed
transaction.
Now, if your Honor were to see Paragraph 71
it discusses a proposed sales price if Macquarie was
going to sell these toll roads at issue to a
Macquarie affiliated fund. How Macquarie might
choose to discuss a deal with affiliates would be of
enormous interest because of the price. When you
talk with affiliated funds, you might talk about it
differently, or come to a different agreement than
you would if you were talking to a third-party.
Third-parties would love to know that: what's the
inside price. It's true on apartments. It's true on
condominiums. It's true on toll roads. The paragraph
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is the fund's reaction to that price of the proposal.
If your Honor would look at Paragraph 68, it
references internal discussions with a Macquarie
affiliate about what price the assets might really he
worth, so if one were looking, one would see pricing
in the market at the time of the discussion, but
internal discussions about price, if there's a
difference, that would be of great interest to future
competitors, or future investors.
THE COURT: Then it was historical
information in the sense that it was pre-recession?
MR. KIRSCH: Absolutely, your Honor.
Your Honor, there's also one other reference
I would like to raise.
In a couple of paragraphs, there's a
reference to a non-party witness. The name has been
redacted from the copy filed with the Court. The
courtesy copy, the copy that you have is unredacted.
THE COURT: What paragraph is that?
MR. KIRSCH: Paragraphs 62 and 64, your Honor.
There was a person referred to there as a
member of the Macquarie deal team. He no longer is
employed by Macquarie. We thought there was no
reason he had to be identified by name and accused of
fraud.
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Now his counsel is here today for the
non-party witness. Lisa Horowitz is here
representing him, but there's no good reason for his
name to be bandied about in the complaint.
There's other information, your Honor, that
simply alleges various forms of misconduct on behalf
of Macquarie. Rather than rewarding Syncora for
entering into a protective order, getting our most
private documents, and then splashing the contents
publically in the face of that protective order, we
ask your Honor to keep this respectfully redacted
until fact discovery is closed, or we can resist it.
At that point in time when you have a full factual
record, and the nature of the information might be
clear to your Honor, your Honor might view it
differently, but once it's out, it's out.
We say, respectfully, can we close this to
the close of fact discovery in four months?
The case has been going on for four years now
we would say, respectfully, with no harm done.
THE COURT: Thank you, counsel.
MR. KIRSCH: Thank you.
MR. PICKHARDT: Yes, your Honor.
with respect to the specific paragraphs that
counsel has cited to you, there's a couple of issues
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there.
l4
The first is, even to the extent that the
Court were to credit that argument, the only thing
that would be redacted out of those paragraphs as
counsel has suggested are the actual numbers
themselves, not the entire paragraphs.
THE COURT: Why don't you
more basic point; when you entered
confidentiality order before Judge
on that confidentiality order, you
address counsel's
into a
Schweitzer, based
get documents, and
then you use the documents presumably to amend your
pleading, so is a predicate for what you are doing
here everything that you obtained through that
confidentiality order?
MR. PICKHARDT: No, your Honor, I don't think
that's the case.
THE COURT: Would you have amended, or would
you have amended your complaint had you not received
the documents?
when you started the discussion, you did say
to me that discovery has turned up, essentially --
you didn't use the term "rampant fraud," but did you
suggest they were committing fraud?
MR. PICKHARDT: Yes, your Honor, but the
nature of the protective order is not a promise that
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going forward, to the extent that materials that are
exchanged are relevant to the public proceedings
before the Court, that the parties are not going to
seek to allow that information to be addressed in
public. As your Honor well knows, trials happen
every day where there were protective orders in the
case, and there are documents that go across the
trial that have the word "confidentiality" stamped on
them because that's how they were exchanged.
THE COURT: Fair enough.
But, the procedural posture of this case is
very different than if and when we get to trial.
MR. PICKHARDT: Fair enough, your Honor.
THE COURT: Presumably, then defendants
would be able to counter the arguments as to fraud,
et cetera, and then there would be, from their
perspective at least, a more balanced picture to be
shown.
MR. PICKHARDT: Your Honor, there's going to
be a more balanced picture shown.
As Defense Counsel has indicated in their
papers, they intend to move to dismiss. There's
already been documents that have been exchanged. If
they think there's another story here to be told with
respect to this complaint, we are going to see it in
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front of your Honor on the motion to dismiss.
Frankly, your Honor, if the Court was to
grant this request, it is going to make the motion to
dismiss process also cumbersome because we're going
to have to be dealing with Swiss cheese briefs in
front of the Court.
THE COURT: Well, I'm not persuaded by that
argument because I have enough cases where there are
sealing orders, and there's very easy ways to address
that.
MR. PICKHARDT: Your Honor, more
fundamentally, as the Court said in Mosallem, the
fact that a document has been marked as confidential
is of little moment with respect to whether it meets
the good cause standard. In that case, the Court
applied the good cause standard, and it is,
notwithstanding the existence of a protective order,
the defendants‘ burden to have requested information
kept out of the public record. To persuade the Court
that it met its burden, it must do so by presenting,
if it is not apparent from the face of the document
itself, evidence of that good cause, which it has not
done.
It is certainly not apparent from the face of
the document that facts and figures of this general
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type of nature from ten years ago meet the good cause
standard of being commercially sensitive, so frankly,
we have not been able to find, as I indicated
earlier, a single precedent of a Court treating this
type of historical information, you know, as
sufficient to meet the good cause standard under New
York law.
When we entered into the protective order,
counsel certainly was not unfamiliar with the fact
that to the extent that there is information that is
pertinent to the public proceeding, it's going to be
the good cause standard under New York law that
applies. They were not somehow duped into, you know,
some misunderstanding as to the fact that information
that is exchanged that has been marked as
confidential may some day, to the extent it is
relevant to a proceeding, become public.
My client was aware of that, and we
understand that. We have produced information that
we have requested be maintained confidential pursuant
to the protective order. We understand that will,
ultimately, only be the case to the extent that
Macquarie finds it relevant if we can meet the good
cause standard. That's how this process has
continued to work, given the presumption that when we
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have open Court proceedings, that unless there is a
compelling reason why information should not be
public, that it is public.
We think they simply have not met the
burden here.
With respect to the individual who is
mentioned, his role in this transaction is already a
matter of public record.
THE COURT: But, what's the problem with
redacting his name? You can understand someone
running a business could be sensitive about their
name being associated with fraud.
MR. PICKHARDT: Absolutely, your Honor, and
frankly, he should be concerned about that, and we
don't disagree that it would be his honestly held
desire that this information not be public, and if
the Court instructs us to redact just his name from
those paragraphs, it is not going to do severe,
create severe problems with respect to the
presentation of the case, so this is not a big deal.
I will say that, that also doesn't meet any
of the established standards for good cause. What
is being alleged here is literally quoting from
e-mails that he sent. That's what's being described
In fact, I don't say this individual engaged in
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fraud. All we are doing is quoting from e-mails that
he sent at the time, so we don't think there's some
salacious accusations that are somehow unfairly, you
know, being presented against him, but if the Court
out of sensitivity to this particular former employee
is concerned about him being connected to what is
very flagrant conduct by the Defendant that is at
issue here, again, it's not going to create a huge
problem for us to redact just his name.
THE COURT: Okay, thank you.
MR. KIRSCH: May I be heard briefly, your
Honor?
THE COURT: Very briefly. I gave your
adversary the last word.
MR. KIRSCH: Thank you.
All I'm going to say, for us it's just a
matter of fairness to revisit this at the end of the
fact discovery in four months.
Thank you.
THE COURT: Why don't you address that last
point about counsel's alternative position, you know,
what's the harm four months from now for the Court to
revisit the issue?
MR. PICKHARDT: Well, your Honor, the burden
is not on us to allege what the harm is. What
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counsel is trying to do is, frankly, shift the burden
here.
THE COURT: Well, no. Counsel is trying, at
least from what I hear him saying, there will be a
fuller picture developed, and at that point the issue
can be addressed.
MR. PICKHARDT: Your Honor, we believe that
this case, which concerns fraudulent conduct by the
Defendant, these are claims for fraud and negligent
misrepresentation that have already been upheld, are
a matter of public relevance and concern. That's
what the Mosallem case held, as well. That was a
case that concerned kickbacks by a corporation. The
Court said notwithstanding those kickbacks happened
ten years, that's a matter of public concern. We
think the case addresses those same public interests.
They will also implicate those cases today, and in
four months, we think in the interim we are going to
have a briefing on a motion to dismiss. We may have
argument on a motion to dismiss, so this is an active
and continuing issue, and we don't think that they
have met the standards to argue that these things
should be under seal, and if they don't meet the good
cause standard because they have some public
relevance, then they have public relevance and should
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not be subject to a sealing order. Whether that
sealing order be temporary or --
THE COURT: I'm going to reserve decision.
MISS HOROWITZ: Lisa Horowitz.
Your Honor, can I be heard for the non-party
witness?
THE COURT: Go ahead.
MISS HOROWITZ: We just want to say that he is
not now, nor has he ever been a party. He left
Macquarie's employ over five years ago and set up his
own small investment firm. He has worked very hard
to establish that firm in a very competitive industry
where reputation is very important. He is right now
in a very sensitive point in that business with three
deals. In this age of digital media searchs and
sounds bytes taken out of context, although I
maintain that, unequivocally, there was no wrongdoing
on his part, this could get blown up into a story
that would cause catastrophic economic damage to his
business. He might not be able to recover, and his
employees who have no connection to these parties, or
transaction, or anything would be very badly damaged
in the process, so you know, they refer to him in
paragraph 62 of the complaint as Macquarie's lead
manager on the project. I think that specificity,
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without actually having to name him by name, it
doesn't impede them in pursuing their claims at all
to do that.
I think as a nonparty witness may be the good
cause standard is not really the one to -- it's for
more of a privacy standard. I ask that the Court,
please --
THE COURT: Counsel, do you want to respond
to that?
MR. PICKHARDT: Sure, your Honor.
To the extent there is a privacy standard, I
think counsel is correct that when you are talking
about individuals, the Courts only look to the
privacy standard.
THE COURT: Is not just an individual; a
non-party.
MR. PICKHARDT: And the non—parties.
This is similar to the Bank of America case,
but what the Courts have held is that information,
not just the identity of the individual, it's bank
account numbers, envelope numbers, that sort of
private health information, that sort of information
is what Courts have historically considered to be
within the scope of what can be protected as a
privacy interest for an individual.
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I think here we're talking about statements
that were made in e-mails ten years ago, two
statements.
THE COURT: We're not talking about
statements. We're talking about the standard to
redact the name
MR. PICKHARDT: No. Correct, your Honor, but
I'm saying as far as what's attributed to this
individual, (A) his role, (B) it's statements that he
made, that's not the sort of information for which
Courts have historically, in New York, have said
there's a privacy interest in that individual that
can be concealed, or sealed, that they were the
individual who made those statements that are
contained in document.
So, again, your Honor, I don't want to sort
of belabor this
that individual
because we have
relevant player
e-mails that we
point; our intent here is not to drag
through the mud for some reason
some interest in doing so. He is a
here. He was the author of some
think are, ultimately, going to be
very relevant and important for the Court. That's
why, you know, the allegations are in there, so I
don't think the
we're -— if the
standard has been met, but you know,
Court was to order that his name be
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redacted, as I said earlier, we don't think there's
some grand problem to the administration of the case
that would ensue.
THE COURT: Okay, thank you.
I'll reserve decision.
We're on for compliance, as well.
Is there anything that needs to be discussed
about that?
Off the record.
(Whereupon, a discussion was held off the
record.)
THE COURT: Counsel, I want a copy of the
motion.
Plaintiff, it's your motion, so please, order
the motion.
'!::\r1lr'k'k':':":l':|r'.|\'
Certified to be a true and accurate transcription of the
minutes taken in the above-captioned matter.
S1,}-..-f....»*
I Gloria/Ann Brandon,
Senior Court Reporter
Gloria Ann Brandon, Sr. Court Reporter
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