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E2019002680
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2019
MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT.

Receipt # 2020899

Book Page CIVIL

Return To: No. Pages: 14

ROBERT A. WOLF
Instrument: EFILING INDEX NUMBER

Control #: 201903220104
Index #: E2019002680

Date: 03/22/2019

RSS CSAIL2016C7-NY PAR, LLC Time: 6:20:14 AM

R2 MEZZ FUND LLC

MORGAN, ROBERT C.
MORGAN, KEVIN J.

State Fee Index Number $165.00

County Fee Index Number $26.00
State Fee Cultural Education $14.25
State Fee Records $4.75 Employee: JM
Management

Total Fees Paid: $210.00

State of New York

MONROE COUNTY CLERK’S OFFICE

WARNING – THIS SHEET CONSTITUTES THE CLERKS
ENDORSEMENT, REQUIRED BY SECTION 317-a(5) &
SECTION 319 OF THE REAL PROPERTY LAW OF THE
STATE OF NEW YORK. DO NOT DETACH OR REMOVE.

ADAM J BELLO

MONROE COUNTY CLERK

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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF MONROE
-----------------------------------------------------------X
RSS CSAIL2016C7-NY PAR, LLC,

Plaintiff, Index No.

Date Purchased:
- against- Date Filed:

R2 MEZZ FUND LLC; ROBERT C. MORGAN;

KEVIN J. MORGAN,
SUMMONS
Defendants.
-----------------------------------------------------------X

TO THE ABOVE-NAMED DEFENDANTS:

YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve

a copy of your answer on plaintiff’s attorneys within 20 days after the service of this summons,

exclusive of the day of service (or within 30 days after the service is complete if this summons is

not personally delivered to you within the State of New York). In case of your failure to appear

or answer, judgment will be taken against you by default for the relief demanded in the

complaint.

Plaintiff designates Monroe County as the place of trial based on the residence and/or

principal place of business of each of the defendants in this action.

Dated: New York, New York

March 21, 2019

TARTER KRINSKY & DROGIN LLP

Attorneys for Plaintiff

By: /s/ Robert A. Wolf

Robert A. Wolf, Esq.
Debra Bodian Bernstein, Esq.
1350 Broadway, 11th Floor
New York, NY 10018
Phone: (212) 216-8000
Facsimile: (212) 216-8001
rwolf@tarterkrinsky.com
dbernstein@tarterkrinsky.com
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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF MONROE
-----------------------------------------------------------X
RSS CSAIL2016C7-NY PAR, LLC,

Plaintiff, Index No.

- against- Date Purchased:

R2 MEZZ FUND LLC; ROBERT C. MORGAN; Date Filed:

KEVIN J. MORGAN,
COMPLAINT
Defendants.
-----------------------------------------------------------X

Plaintiff, RSS CSAIL2016C7-NY PAR, LLC (the “Plaintiff”), by and through its

attorneys, Tarter Krinsky & Drogin LLP, as and for its Complaint against R2 Mezz Fund LLC,

Robert C. Morgan, and Kevin J. Morgan (collectively, the “Defendants”), alleges as follows:

NATURE OF THE CASE

1. This action for fraud and unjust enrichment arises out of false representations

made by the Defendants to Plaintiff’s predecessor-in-interest (whose rights have been assigned to

Plaintiff and/or whose rights Plaintiff is subrogated to), which resulted in the payment of

$2,500,000.00 to Defendant R2 Mezz Fund LLC (“R2 Fund”) for repayment of a purported loan

R2 Fund did not make and to which funds it was not entitled as a result of which Plaintiff has

been damaged.

PARTIES

2. At all times relevant herein, Plaintiff was and is a New York limited liability

company with its principal place of business located at 790 NW 107th Avenue, Suite 400,

Miami, Florida 33172.

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3. At all times relevant herein, Defendant R2 Fund was and is a New York limited

liability company with its principal place of business located at 1080 Pittsford Victor Road, Suite

100, Pittsford, New York 14534.

4. At all times relevant herein, Defendant Robert C. Morgan was and is a resident of

the State of New York residing at 5 Van Voorhis Road, Pittsford, New York 14534.

5. On information and belief, at all times relevant herein, Defendant Kevin J.

Morgan was and is a resident of the State of New York residing at 12 Silco Hill, Pittsford, New

York 14534.

JURISDICTION AND VENUE

6. Jurisdiction is proper in the State of New York because Plaintiff is authorized to

transact business in the State of New York and all Defendants reside in and/or have their

principal place of business in the State of New York.

7. Venue is proper in this Court because all Defendants reside in and/or have their

principal place of business in Monroe County, New York.

FACTUAL BACKGROUND

Entities Involved in the Fraud

8. On information and belief, at all times relevant herein, Defendant Robert C.

Morgan (“Robert Morgan”) was and is the Manager of Morgan Watertown Holdings LLC

(“Watertown Holdings”). On information and belief, Watertown Holdings is the sole member of

Preserve at Autumn Ridge II LLC (“Autumn Ridge”).

9. At all times relevant herein, Autumn Ridge was and still is a Delaware limited

liability company and the owner of the fee estate in and to an improved parcel of real property

located at 14630 Autumn Ridge Lane, Watertown, New York, within the Town of Watertown,

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County of Jefferson (the “Property”). The Property consists of a one hundred fifty-two (152)

unit residential community.

10. At all times relevant herein, the Property was managed by Grand Atlas Property

Management, LLC f/k/a Morgan Management, LLC (“Grand Atlas”), a New York limited

liability company having the same principal place of business as Defendant R2 Fund and

Autumn Ridge.

11. On information and belief, at all times relevant herein, Robert Morgan was and is

an owner of Grand Atlas. On information and belief, Grand Atlas owned R2 Fund. Robert

Morgan, as the owner of Grand Atlas which in turn owned R2 Fund, controlled R2 Fund.

12. On information and belief, at all times relevant herein, Robert Morgan was and is

an owner and the Manager of Watertown Holdings. Robert Morgan, as an owner and the

Manager of Watertown Holdings, which in turn was the sole member of Autumn Ridge,

controlled Autumn Ridge.

13. On information and belief, at all times relevant herein, Defendant Kevin J.

Morgan (“Kevin Morgan”) was the Vice President of Grand Atlas. Kevin Morgan, as a principal

of Grand Atlas which in turn owned R2 Fund, controlled R2 Fund.

14. On information and belief, at all times relevant herein, Kevin Morgan was and is

an owner of Watertown Holdings. Kevin Morgan, as an owner of Watertown Holdings, which in

turn was the sole member of Autumn Ridge, controlled Autumn Ridge.

15. On information and belief, Kevin Morgan is the nephew of Robert Morgan.

Origination of the Loan

16. On or about June 9, 2015, Arbor Commercial Mortgage, LLC (“Original Lender”)

made a loan to Autumn Ridge in the original principal amount of $21,280,000.00 (the “Loan”)

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pursuant to a Loan Agreement dated as of June 9, 2015 (the “Loan Agreement”). A true and

correct copy of the Loan Agreement is attached hereto as Exhibit A.

17. To induce Original Lender to make the Loan to Autumn Ridge, on or about June

9, 2015, Robert Morgan, the Manager of the sole member of Autumn Ridge, executed and

delivered, in his individual capacity, to Original Lender a certain Guaranty Agreement (the

“Guaranty”). A true and correct copy of the Guaranty is attached hereto as Exhibit B.

18. The Loan Agreement, the Guaranty, and such other agreements, documents, and

instruments which evidence, secure, or otherwise were executed in connection with the Loan are

collectively referred to herein as the “Loan Documents.”

19. On or about June 9, 2015, Original Lender assigned the Loan Documents to

Column Financial, Inc. (“Column Financial”). On or about November 22, 2016, Column

Financial assigned the Loan Documents to Wilmington Trust, National Association, as Trustee

for the Registered Holders of CSAIL 2016-C7 Commercial Mortgage Trust, Commercial

Mortgage Pass-Through Certificates, Series 2016-C7 (“Wilmington Trust”). On or about March

11, 2019, Wilmington Trust assigned the Loan Documents to Plaintiff, an entity affiliated with

Wilmington Trust.

20. Plaintiff is the present holder and owner of the Loan Agreement, the Guaranty,

and the other Loan Documents and is an assignee of, and/or is subrogated to the rights of

Original Lender.

Representations Made by Defendants

21. In connection with the origination of the Loan and as part of the Loan application

process, Defendants knowingly submitted to Original Lender false information relating to a

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purported loan made by R2 Fund to Autumn Ridge (the “Fake Mezzanine Loan”), which Fake

Mezzanine Loan did not exist.

22. Defendants created and provided to Original Lender a fake payoff statement that

purported to evidence the existence of the Fake Mezzanine Loan with a principal balance of

$2,500,000.00 (the “Fraudulent Payoff Statement”).

23. Defendants also created and provided to Original Lender a fake closing and

disbursement statement signed by Robert Morgan, listing the Fake Mezzanine Loan as an

expense of Autumn Ridge (the “Fraudulent Closing Statement”). The Fraudulent Payoff

Statement and the Fraudulent Closing Statement are collectively referred to as the “Fraudulent

Documents.” True and correct copies of the Fraudulent Documents are attached hereto as

Exhibit C.

24. Defendants created and tendered the Fraudulent Documents to Original Lender to

induce it to make the Loan to Autumn Ridge.

25. At the time Defendants created and provided to the Original Lender the

Fraudulent Documents, Defendants knew that these documents were fraudulent and that the

information contained in such documents was fabricated and that the Fake Mezzanine Loan did

not exist.

26. Original Lender relied upon Defendants’ representations as to the existence of the

Fake Mezzanine Loan and Defendants’ representations with respect to the information contained

in the Fraudulent Documents in agreeing to extend the Loan to Autumn Ridge and to enter into

the Loan Documents. On information and belief, had Original Lender known that the Fake

Mezzanine Loan did not exist and that the Fraudulent Documents contained false information,

Original Lender would not have made the Loan.

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27. Plaintiff’s assignor, Wilmington Trust, was first made aware of the Fraudulent

Documents submitted by Defendants shortly after December 21, 2018, the date on which Kevin

Morgan, the Vice President of Grand Atlas and the nephew of Robert Morgan, pleaded guilty to

conspiracy to commit bank fraud for providing fraudulent information to lenders for the purpose

of influencing those lenders to make commercial loans to entities controlled by Grand Atlas (the

“Guilty Plea”). A true and correct copy of the transcript of proceedings reflecting the Guilty

Plea is attached hereto as Exhibit D.

28. In his Guilty Plea, Kevin Morgan admitted that he, at the direction of his uncle

Robert Morgan, conspired to defraud financial institutions including Original Lender “to obtain

money from financial institutions by means of false and fraudulent pretenses and

representations.” See Exhibit D, p. 30.

29. Kevin Morgan specifically acknowledged submitting the Fraudulent Payoff

Statement by admitting that he, along with co-conspirators, included in a loan application “a

false and fictitious 2.5 million dollar debt purportedly owed to a Morgan Management1

controlled entity and created a fabricated payoff letter for that debt to increase the amount of the

loan in connection with the property known as Autumn Ridge.” See Exhibit D, p. 33.

30. On information and belief, the “Morgan Management controlled entity” referred

to in the Guilty Plea was Defendant R2 Fund.

31. Kevin Morgan also admitted in his Guilty Plea that “[t]he false information

induced the financial institutions to issue loans for larger amounts than the financial institutions

would have authorized had they been provided the truthful information and that the financial

institutions otherwise would not have issued on requested terms.” See Exhibit D, p. 31-32.

1
In the Guilty Plea, Kevin Morgan is referring to Grand Atlas, formerly known as Morgan Management.

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Default Under the Loan Documents

32. When Autumn Ridge entered into the Loan Agreement with Original Lender,

which Loan Agreement was executed on behalf of Autumn Ridge by Robert Morgan, Autumn

Ridge affirmed that there was “no material fact presently known to [Autumn Ridge] which has

not been disclosed to [Original Lender] which adversely affects, nor as far as [Autumn Ridge]

can foresee, might adversely affect, the Property or business, operations or condition (financial

or otherwise) of [Autumn Ridge].” See Exhibit A, § 4.1.8.

33. As of June 9, 2015, Autumn Ridge violated the Loan Agreement when Autumn

Ridge failed to disclose to Original Lender that it had submitted false information relating to the

Fake Mezzanine Loan made by R2 Fund to Autumn Ridge, which Fake Mezzanine Loan did not

exist. See Exhibit A, § 4.1.8.

COUNT I - FRAUD
(Against R2 Fund, Robert Morgan, and Kevin Morgan)

34. Plaintiff incorporates and realleges Paragraphs 1 through 33 of its Complaint as if

fully set forth herein.

35. On or about June 3, 2015, in connection with the origination of the Loan,

Defendants knowingly submitted to Original Lender false information related to the Fake

Mezzanine Loan, which Fake Mezzanine Loan did not exist.

36. Included among the false information was the Fraudulent Payoff Statement from

R2 Fund dated June 3, 2015, which stated that the principal balance of the Fake Mezzanine Loan

as of June 8, 2015 was $2,500,000.00 and that interest on the Fake Mezzanine Loan had been

paid outside of closing. See Exhibit D.

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37. The Fraudulent Payoff Statement also contained bank account information and

wiring instructions to pay the $2,500,000.00 to R2 Fund with respect to the Fake Mezzanine

Loan. See Exhibit D.

38. Also included among the false information was the Fraudulent Closing Statement

signed by Robert Morgan on behalf of Autumn Ridge, listing the $2,500,000.00 Fake Mezzanine

Loan as an expense of Autumn Ridge and directing the closing agent to make payment to R2

Fund with respect to the Fake Mezzanine Loan.

39. By submitting the Fraudulent Documents, Defendants knowingly, intentionally,

and wantonly misrepresented to Original Lender that an existing mezzanine loan in the amount

of $2,500,000.00 encumbered the Property and needed to be paid off in order to close on the

Loan.

40. In reality, at the time Defendants submitted the false information to Original

Lender, the Fake Mezzanine Loan did not exist and the Defendants knew that the Fake

Mezzanine Loan did not exist.

41. Defendants submitted the false information to Original Lender to deceive Original

Lender and to induce Original Lender to permit a portion of the Loan proceeds in the amount of

$2,500,000.00 to be paid to R2 Fund.

42. In the Guilty Plea, Kevin Morgan admitted that the purpose of submitting the

Fraudulent Payoff Statement was to “increase the amount of the loan in connection with the

property known as Autumn Ridge.” See Exhibit D, p. 33.

43. In reliance on the Fraudulent Documents, Original Lender permitted

$2,500,000.00 of the Loan proceeds to be paid to R2 Fund with respect to the Fake Mezzanine

Loan.

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44. Unbeknownst to Original Lender, the Fake Mezzanine Loan was non-existent and

R2 Fund was not entitled to the $2,500,000.00.

45. On information and belief, had Original Lender known of the false information at

the origination of the Loan, Original Lender would not have made the Loan.

46. Defendants demonstrated wanton dishonesty when they knowingly submitted to

Original Lender false information in order to induce Original Lender to increase the amount of

the Loan in connection with the Property and to permit a portion of the Loan proceeds to be paid

to R2 Fund, for a loan R2 Fund did not make and to which funds R2 Fund was not entitled.

47. Defendants’ dishonesty demonstrates criminal indifference to civil obligations

and resulted in the indictment and subsequent Guilty Plea of Defendant Kevin Morgan for

violation of Title 18 U.S.C. Section 371, conspiracy to commit bank fraud, related to the facts

alleged in this Complaint.

48. Kevin Morgan admitted that he, at the direction of his uncle Robert Morgan,

conspired to defraud financial institutions “to obtain money from financial institutions by means

of false and fraudulent pretenses and representations.” See Exhibit D, p. 30.

49. Kevin Morgan also admitted that he and his co-conspirators “made

misrepresentations to conceal from the lending financial institutions that Morgan Management

used a portion of the loan proceeds for purposes other than that disclosed in the loan

applications, to wit, to maintain or improve other properties managed by Morgan Management

and to satisfy debts associated with other properties managed by Morgan Management.” See

Exhibit D, p. 33.

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50. On information and belief, Robert Morgan and Kevin Morgan were on both sides

of the transaction involving the Fake Mezzanine Loan as they owned and controlled both

Autumn Ridge and R2 Fund.

51. On information and belief, Robert Morgan and Kevin Morgan controlled Autumn

Ridge and R2 Fund so that the entities had no separate will or existence of their own.

52. On information and belief, Autumn Ridge and R2 Fund did not comply with or

otherwise observe the formalities required of limited liability companies.

53. On information and belief, Autumn Ridge and R2 Fund were used by Robert

Morgan and Kevin Morgan for their own personal benefit and for the benefit of other entities

owned and controlled by Robert Morgan and Kevin Morgan.

54. On information and belief, the property and assets of Autumn Ridge and R2 Fund

were used by Robert Morgan and Kevin Morgan for their own personal benefit and for the

benefit of other entities owned and controlled by Robert Morgan and Kevin Morgan.

55. Robert Morgan and Kevin Morgan used Autumn Ridge and R2 Fund for the

specific purpose of committing fraud against Plaintiff’s predecessors in interest respecting whose

rights Plaintiff is an assignee or subrogee.

56. All of the foregoing constitutes fraud against Plaintiff entitling Plaintiff to recover

damages against the Defendants, jointly and severally, in the amount of $2,500,000.00.

57. Because the acts of Defendants were malicious, intentional, fraudulent, and

willful, Plaintiff is entitled to an award of punitive damages against Defendants jointly and

severally in an amount to be determined at trial.

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COUNT II - UNJUST ENRICHMENT (IN THE ALTERNATIVE)

(Against R2 Fund)

58. Plaintiff incorporates and realleges Paragraphs 1 through 33 of its Complaint as if

fully set forth herein.

59. Induced by R2 Fund’s wrongful conduct, Original Lender permitted

$2,500,000.00 of the Loan proceeds to be paid to R2 Fund with respect to the Fake Mezzanine

Loan.

60. Unbeknownst to Original Lender, the Fake Mezzanine Loan was non-existent and

R2 Fund had no entitlement to the $2,500,000.00.

61. R2 Fund received the $2,500,000.00 and has failed to return the money to

Plaintiff or to any of Plaintiff’s predecessors-in-interest.

62. It is against equity and good conscience to permit R2 Fund to retain the benefit of

the $2,500,000.00 as it has no entitlement to the funds.

63. R2 Fund has been unjustly enriched in the amount of $2,500,000.00 to the

detriment of Plaintiff.

64. Accordingly, Plaintiff is entitled to recover from R2 Fund the amount of

$2,500,000.00, together with interest thereon since June 9, 2015.

WHEREFORE, Plaintiff, RSS CSAIL2016C7-NY PAR, LLC, respectfully requests that

this Court enter judgment in its favor and against Defendants R2 Fund, Robert C. Morgan, and

Kevin J. Morgan as follows:

A. On Count I:
(i) awarding Plaintiff compensatory damages jointly and severally against
Defendants in the amount of $2,500,000.00, together with interest
thereon since June 9, 2015; and

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(ii) awarding Plaintiff punitive damages jointly and severally against

Defendants in an amount to be determined at trial; and
(iii) granting Plaintiff such other and further relief as the Court deems
appropriate.
B. On Count II:
(i) awarding Plaintiff compensatory damages jointly and severally against
Defendants in the amount of $2,500,000.00, together with interest
thereon since June 9, 2015; and
(ii) granting Plaintiff such other and further relief as the Court deems
appropriate.
C. On both Counts, reasonable attorneys’ fees and costs.

Dated: New York, New York

March 21, 2019

TARTER KRINSKY & DROGIN LLP

Attorneys for Plaintiff

By: /s/ Robert A. Wolf

Robert A. Wolf, Esq.
Debra Bodian Bernstein, Esq.
1350 Broadway, 11th Floor
New York, NY 10018
Phone: (212) 216-8000
Facsimile: (212) 216-8001
rwolf@tarterkrinsky.com
dbernstein@tarterkrinsky.com

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