Hain Capital Holdings, LLC v. Paulette D. Marquis, Individually and as Trustee of the Paulette D. Marquis Revokable Living Trust

Summary

The United States District Court for the District of New Jersey granted Hain Capital Holdings, LLC’s motion for default judgment against Paulette D. Marquis, individually and as trustee of the Paulette D. Marquis Revokable Living Trust. The court found liability on claims for breach of contract, fraud, and declaratory judgment based on the alleged prior sale of bankruptcy claim rights. The court referred the issue of damages to a magistrate judge for a proof hearing.

Holdings

1. Because Defendants defaulted, the well-pleaded allegations concerning liability were accepted as true, and default judgment was entered for Plaintiff on its breach-of-contract, fraud, and declaratory-judgment claims.
2. Default established liability but did not establish the amount of damages; Plaintiff was required to prove damages to a reasonable degree of certainty.
3. The allegations concerning the Participation Agreement's indemnification provision established Marquis's liability for damages stemming from her breach, including the losses covered by that provision.

Questions Presented

1. Whether default judgment should be entered against Marquis individually and as trustee on Plaintiff's breach-of-contract claim.
2. Whether default judgment should be entered on Plaintiff's fraud claim based on Marquis's alleged concealment of the prior sale of the claim rights.
3. Whether default judgment should be entered on Plaintiff's declaratory-judgment claim based on the Participation Agreement's indemnification provision.
4. Whether Plaintiff had sufficiently proven the amount of damages for entry of a damages judgment.

Disposition

other