Summons: Lucky D Nordee v. Lynette C Grube

On September 27, 2022 a Summons was filed involving a dispute between Lucky D Nordee, and Lynette C Grube, for Torts - Motor Vehicle in the District Court of Erie County.

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FILED: ERIE COUNTY CLERK 09/27/2022 11:52 AM INDEX NO. 811596/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/27/2022

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ERIE
---------------------------------------------------------------------------X Index No.
In the Matter of the Petition of
ODYSSEA-ABE83, LLC, for
Approval of Transfer of Structured Settlement Payment
Rights In Accordance with New York GOL §5-1701,

-against- VERIFIED
PETITION

ALLSTATE ASSIGNMENT COMPANY,
ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK,
and ELAINE TAYLOR
----------------------------------------------------------------------------X

Petitioner, ODYSSEA-ABE83, LLC ("ODYSSEA"), by its attorney, Greg Saber,

on notice to respondents, ELAINE TAYLOR, ALLSTATE ASSIGNMENT COMPANY

and ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK, alleges as follows:

1. This is a special proceeding pursuant to the Structured Settlement

Protection Act, General Obligations Law §5-1701 et seq. seeking approval of the transfer

of certain structured settlement payment rights due under a structured settlement

agreement, in accordance with 26 U.S.C. §5891 et seq. and GOL §5-1701 et seq (the

"Act"). The proposed transfer seeks approval, as authorized by the statute, for the sale of

the following: 1 lump sum payment of $70,000.00 due on May 28, 2040;

1 lump sum payment of $150,000.00 due on May 28, 2045; and

1 lump sum payment of $290,000.00 due on May 28, 2050; (the "Assigned Payments").

2. The New York GOL §5-1705(a) mandates the filing of this matter

by Order to Show Cause (Exhibit "A").

3. The Petitioner, ODYSSEA, with its principal place of business located in

California, is a "Transferee" as defined in GOL §5-1701(t).

4. The Respondent, ELAINE TAYLOR (“TAYLOR”), is a "Payee" as defined in

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GOL §5-1701(h). The Payee is entitled to receive a structured settlement payment stream

that is the subject of this Application.

5. Payee is pro se in this matter. Counsel for Petitioner makes no representations

on behalf of the Payee, his/her interests or the terms or suitability of this transaction as the

same relates to Payee. Upon information and belief, Payee does not have an appointed

guardian or conservator and Payee contends that he or she has the mental capacity to enter

this transaction.

6. Jurisdiction exists in this Court because TAYLOR resides in ERIE County.

7. Certain entities are deemed to be "interested parties" to this Petition as

defined in GOL §5-1701(f); pursuant to GOL §5-1705(c) they are to be served at least 20

days prior to the Petition being heard with copies of said Petition and the notice of Petition

or Order to Show Cause, as the case may be.

7. The interested parties noticed of the special proceeding herein are:

i. Upon information and belief, the Payee is prepared to testify before this
Court regarding the proposed transfer and the needs surrounding it;
ii. ALLSTATE ASSIGNMENT COMPANY is a "Structured Settlement
Obligor" as defined in GOL §5-1701(n) with respect to the structured
settlement payment rights at issue in this proceeding; and
iii. ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK is the
"Annuity Issuer" as defined in GOL §5-1701(a) in connection with the
structured settlement payment rights at issue in this proceeding.
8. TAYLOR, as she disclosed to ODYSSEA, is 27 years old and has one minor

dependent.

9. The Payee is the recipient of structured settlement payments as through a

settlement contract resulting from a personal injury lawsuit related to lead paint poisoning,

which provided for a series of deferred cash payments under a "structured settlement" as

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defined in GOL §5-1791(l) and 26 U.S.C. §5891(c)(1). A Schedule of Payments listing

the payments due under the annuity contract is annexed hereto as Exhibit “B”.

10. Pursuant to 26 U.S.C. §5891(a), any transfer of structured settlement

payment rights pursuant to a Transfer Agreement entered into after the effective date

subjects the Transferee (i.e., the purchaser of the structured settlement payment rights) to

an excise tax unless the transfer has been approved by, inter alia, by a court of the state in

which the Payee of the structured settlement is domiciled through the issuance of a

"Qualified Order," which is defined as an order issued pursuant to the terms of a statute

regulating the transfer of structured settlement transfer rights enacted by the state in which

the Payee is domiciled or the settled case was litigated. The Structured Settlement

Protection Act, GOL §5-1701 et seq. is such a statute.

11. New York Insurance Law §3212(d) provides that any purported

limitations upon transfer in an annuity contract funding a structured settlement are

ineffective if the transfer has been approved pursuant to GOL §5-1701 et seq.

12. The Payee executed a "Transfer Agreement" as defined in GOL §5-

1701(r), wherein he/she agreed to sell, assign or transfer to ODYSSEA rights to certain

payments remaining under the settlement agreement. A copy of the said proposed Transfer

Agreement is annexed hereto as Exhibit "C". Pursuant to and consistent with the Act and

the Transfer Agreement, the Petitioner, in its exclusive role as a buyer of structured

settlement payments, provided no services whatsoever to the Payee including, but not

limited to, not providing any legal, tax, or financial advice. No fees or costs are owed or

paid by the Payee in conjunction with the sale of the Assigned Payments to the Transferee.

13. Pursuant to the Transfer Agreement, the Payee seeks to sell, assign or

transfer to ODYSSEA rights to the Assigned Payments as defined above.

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14. It is a condition of the Transfer Agreement that the transfer be approved by

a court and an order entered, that must be recognized and honored by ALLSTATE

ASSIGNMENT COMPANY, the structured settlement obligor and ALLSTATE LIFE

INSURANCE COMPANY OF NEW YORK, the annuity issuer.

15. Petitioner is informed and believes and upon that basis alleges that the

underlying structured settlement that established the annuity at issue in the present case

contained language that restricted and/or prohibited the right and/or power to assign the

Assigned Payments in question.

16. All disclosure requirements of GOL §5-1703 have been complied with by

providing, not less than ten (10) days prior to the date on which the Payee executed the

Transfer Agreement by first class mail and certified-mail, return-receipt requested and/or

postal office priority mail, the disclosure statement in 14-point bold type containing

disclosures in plain language the information required therein, namely;

a. the amount and due date of the structured settlement payments to be

transferred;

b. the aggregate amount of such payments;

c. the discounted present value of the payments to be transferred which

shall be identified as the "calculation of current value of the transferred

structured settlement payments under federal standards for valuing

annuities", and the amount of the applicable federal rate used in

calculating such discounted present value;

d. the price quote from the original annuity issuer or, if such price quote is

not readily available from the original annuity issuer, then a price quote

from two other annuity issuers that reflects the current cost of

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purchasing a comparable annuity for the aggregate amount of payments

to be transferred;

e. the gross advance amount and the annual discount rate, compounded

monthly, used to determine such figures;

f. an itemized listing of all commissions, fees, costs, expenses and charges

payable by the Payee or deductible from the gross amount otherwise

payable to the Payee and the total amount of such fees;

g. the net advance amount including the statement: "The net cash payment

you receive in this transaction from the buyer was determined by

applying the specified discount rate to the amount of future payments

received by the buyer, less the total amount of commissions, fees, costs,

expenses and charges payable by you";

h. the amount of any penalties or liquidated damages payable by the Payee

in the event of any breach of the Transfer Agreement by the Payee; and

i. a statement that the Payee has the right to cancel the Transfer

Agreement, without penalty or further obligation, not later than the third

business day after the date the Transfer Agreement is signed by the

Payee.

The Disclosure Statement and proof of its mailing via United States postal service priority

mail and receipt by the Payee, as reflected in the Disclosure Statement, is attached hereto

as Exhibit "D".

17. Pursuant to 26 U.S.C. 5891, the Court in approving the transfer must find:

a. the transfer is in the best interests of the Payee, taking into account
the welfare and support of the Payee's dependents, if any; and

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b. the transfer does not contravene any applicable federal or state
statute or the order of any court or responsible administrative or
government authority.
18. Pursuant to GOL §5-1701 et seq., the Court in approving the transfer must

find:

a. the transfer complies with all requirements of the Structured
Settlement Protection Act, GOL §5-1701 et seq.;
b. the transfer is in the best interests of the Payee taking into account
the welfare and support of the Payee's dependents, if any, (for the
reasons identified in the affidavit of the Payee annexed hereto as
Exhibit "E", upon information and belief, the Payee believes that
the transfer is in the Payee's best interest taking into account the
welfare and support of the Payee's dependents).
c. The Payee has been advised in writing by the Transferee to seek
independent professional advice regarding the transfer and has
either received such advice or knowingly waived such advice in
writing; (Exhibit "F")
d. The transfer does not contravene any applicable federal or state
statute or the order of any court or other government or responsible
administrative authority; and
e. The Transfer Agreement and all disclosures are written in plain
language and in compliance with GOL § 5-702.
19. Except as referenced elsewhere in the Petition, no previous application has

been made to this or any other Court for the relief sought herein.

20. Upon information and belief, the Payee is aware of other transferees and

that those transferees could make alternative offers.

21. The controlling statute is attached herewith as Exhibit "G"

22. A list of the Payee's dependents, as identified to the Petitioner by the Payee,

is attached herewith as Exhibit "H".

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23. Upon information and belief, Payee has previously attempted and/or

completed the following structured settlement transfers:

a. Index No. 812691/2016 filed in Supreme Court of New York,

County of Erie by Peachtree Settlement Funding, LLC. Upon information and

belief this petition was approved. A true and correct copy of the court order is

attached herewith as Exhibit "I".

b. Index No. 813680/2016 filed in Supreme Court of New York,

County of Erie by Suga Shrine, LLC. Upon information and belief this petition

was dismissed.

c. Index No. 809165/2017 filed in Supreme Court of New York,

County of Erie by J.G. Wentworth Originations, LLC. Upon information and belief

this petition was approved. A true and correct copy of the court order is attached

herewith as Exhibit "J".

d. Index No. 807247/2018 filed in Supreme Court of New York,

County of Erie by J. G. Wentworth Originations, LLC. Upon information and

belief this petition was approved. A true and correct copy of the court order is

attached herewith as Exhibit “K”.

f. Index No. 803028/2019 filed in Supreme Court of New York,

County of Erie by J.G. Wentworth Originations, LLC. Upon information and belief

this petition was approved. A true and correct copy of the court order is attached

herewith as Exhibit "L".

g. Index No. 809616/2020 filed in Supreme Court of New York,

County of Erie by J.G. Wentworth Originations, LLC. Upon information and belief

this petition was denied.

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h. Index No. 813117/2020 filed in Supreme Court of New York,

County of Erie by J.G. Wentworth Originations, LLC. Upon information and belief

this petition was denied.

i. Index No. 801987/2021 filed in Supreme Court of New York,

County of Erie by DRB Capital, LLC. Upon information and belief this petition

was denied.

j. Index No. 806296/2021 filed in Supreme Court of New York,

County of Erie by J.G. Wentworth Originations, LLC. Upon information and belief

this petition was denied.

k. Index No. 806031/2021 filed in Supreme Court of New York,

County of Erie by DRB Capital, LLC. Upon information and belief this petition

was denied.

d. Index No. 802226/2022 filed in Supreme Court of New York,

County of Erie by J.G. Wentworth Originations, LLC. Upon information and belief

this petition was dismissed.

e. Index No. 806402/2022 filed in Supreme Court of New York,

County of Erie by Peachtree Settlement Funding, LLC. Upon information and

belief this petition was denied.

Additional transfers may have been attempted or completed but after good faith

efforts Petitioner is not able to locate any additional filings.

24. The undersigned respectfully requests a hearing in this matter to address

any questions or concerns of the Court.

WHEREFORE, pursuant to GOL §5-1701, et seq., Petitioner, ODYSSEA, hereby

respectfully requests that this Court enter an Order approving the transfer, based upon

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findings that (i) it is in compliance with the requirements of 26 U.S.C. §5891 and GOL §5-

1701 et seq.

Dated: September 26, 2022
Respectfully Submitted,

/s/ Greg Saber__________________
Greg Saber/Petitioner's Attorney

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ERIE
----------------------------------------------------------------------------X
In the Matter of the Petition of
ODYSSEA-ABE83, LLC,
Petitioner(s),

For Approval of Transfer of Structured Settlement Payment ATTORNEY'S
Rights In Accordance with New York GOL §5-1701, VERIFICATION

-against-

ALLSTATE ASSIGNMENT COMPANY,
ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK,
and ELAINE TAYLOR,
Respondents
----------------------------------------------------------------------------X

GREG SABER, an attorney duly admitted to practice in the Courts of the State of New
York, affirms the following, upon information and belief, under the penalties of perjury:

I am the attorney of record for the Petitioner, Odyssea-Abe83, LLC, in the above-entitled
action.

I have read the foregoing Order to Show Cause and Verified Petition and know the contents
thereof; the same is true to my own knowledge except as to the matters therein stated to be alleged
on information and belief, and that as to those matters, I believe them to be true.

This verification is made by your affirmant and not by Petitioner because said Petitioner
does not maintain its principal place of business within New York County, New York, which is
the county where your affirmant maintains offices.

The grounds of your affirmant's belief as to all matters not stated upon affirmant's
knowledge are correspondence had with Petitioner, information contained in said Petitioner's file,
which is in your affirmant's possession, and other pertinent data relating thereto.

Dated: September 26, 2022

/s/ Greg Saber__________
Greg Saber, Esq.

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SUPREME COURT OF THE STATE OF NEW YORK INDEX NO.
COUNTY OF ERIE
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X

In the Matter of the Petition of
ODYSSEA-ABE83, LLC,
Petitioner(s),

For Approval of Transfer of Structured Settlement Payment
Rights In Accordance with New York GOL §5-1701,

-against-

ALLSTATE ASSIGNMENT COMPANY,
ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK,
and ELAINE TAYLOR,
Respondent(s).
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X

_________________________________

ORDER TO SHOW CAUSE, VERIFIED PETITION AND EXHIBITS
_________________________________

Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney duly admitted to practice in the
courts of New York State, certifies that, upon information and belief and reasonable inquiry, the
contentions contained in the annexed documents are not frivolous.

Dated: September 26, 2022 Signature: /s/ Greg Saber_______
Greg Saber, Esq.

GREG SABER, ESQ.
Attorney(s) for Petitioner(s)
264 W. 40th St.
Ste. 403
New York, NY 10018
(800) 449-6311 – Telephone
(800) 922-6312 – Facsimile

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Exhibit A

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Page 1

isNexis'
Le
1 of 2
DOCUMENTS

NEW YORK CON3OLIDATED LAW SliRVICE
Copyright©2011 Matthew
a member of the Bender, inc.
LexisNexis(TM) Group
Allrightsreserved
t* THIS SECTION IS CURRENT
. THROUGH 2011 RELEASED '"
'" *" CHAPTERS
1-54,57-78
. GENERAL
ARTICLE'.S. OBLlOATIONS LAW
CREATION, DEPINTrlON AND BNFORCBMB1fr OF CONTRACrUAL
TITLE 17. STRUCTURED OBLICATIONS
SBTILEMENT PROTECTION ACT
Go to the New YorkCode Archive Directory
'
NY CLS Gen OMig § 5-1705(2011)
§ 5-1705.Procedu e forapprovalof transfers

(a) An action
forapproval ofa transfer
of a structured
order to show settlementshall be by a special
cause. proceedingbrought on onlyby

(b) Such proceeding
shallbe commenced to obtain approval
of a transfer of structured
proceeding shall
be commenced: settlement
payment rights.Such

(i) in the supreme
courtof the county
in which the payee resides:or
in any court
(ii) which approvedthe structured settlement
agreement.

(c) A copy of
the]Iig1]order to show cause and petition
shall
be served upon allinterested
before the time
at which the petition partiesat least
twentydays
is noticed to be heard. A
response shall be served at least seven da ys
petition
is noticed
to be heard. before the

(d) A petition
forapproval ofa transfer
of structured settlement
payment rights shall include:
(i) a copy
ofthe transfer
agreement;
(ii) a copy
ofthe disclosurestatement and proof of notice
of that statement required under section
tle: (fig 5-1703 of this ti-
1]
a listing
(iii) of each ofthe payce's dependents, together
with each dependent's age; and
(iv) a statement·setting
forthwhether there have been any previous
transfers or applications
tured setGement payment for transfer
ofthe struc-
rights
and givingdetails of all such transfers or
applications
for Iransfer.

IIISTORY:
Add, L 2002,ch 537. § 2, eff
July 1, 2002 (see 2002 note below);
amd, L 2010, ch 511, § I,
eff Jan 1, 2011.

NOTES:

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t
NY CIS Gen Oblig§ 5-1705 Page 2

2010
Recommenda,ions of the
The Cornmittee AdvisoryCommittee on Civil
recommends the amendmeni of Practice
far as it New Yorkh
governs thei procedure General
for court Obligations
Law Title
By way of obtaining approvalforthe transfer of a 17, enactedin 2002,inso-
background, in a structured structured settlement.
ment. Itather,
all:or'.a settlement the recipient
portionare paid out in does not receive all the
Usuallya atruc
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Exhibit E

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AFFIDAVIT OF ELAINE TAYLOR IN SUPPORT OF PETITIONER'S
PETITION FOR APPROVAL FOR TRANSFER OF STRUCTURED
SETTLEMENT PAYMENT RIGHTS

I,Elaine Taylor, am over the age of eighteen. I have personal knowledge of all

facts stated in thisAffidavit, and ifcalled as a witness, I could and would competently

testify as follows:

1. I am the Payee in this action. This Affidavit is made in support of

Petitioner's Petition to approve the transfer of structured settlement payment rights

between myself, Elaine Taylor, and Odyssea-Abe83, LLC.

2. I have agreed to sell my interest in certain structured settlement payment

rights under an annuity contract to Odyssea-Abe83, LLC, and itsdesignated assignee.

The annuity payments I am entitled to receive are listed in the Agreement to Transfer

Structured Settlement Payment Rights ("Purchase Agreement"), and attached to the

Petition.

3. I believe itis in my best interest to enter into the Purchase Agreement. The

original structured settlement entered into by me was intended as compensation for a

personal injury claim. When I was a minor, I was the victim of lead poisoning. There are

no longer any reoccurring medical problems related to the original injury and no

continuing need to provide for future medical expenses.

4. I am 27 years old, single and have the following dependents: E'miyah Carr

Taylor (2 y/o). I work full-time in home care help for Good Samaritan and earn $14.00

per hour or approximately $2,400.00 per month. I do not rely on the structured settlement

payment rights I am transferring for my day-to-day living expenses.

5. If approved, a portion of the funds from this transaction will be used for

pursuing a cosmetologist certification through the school of Cosmetology in Chautauqua.

The program isten months long and estimated to cost $11,000.00. Once I have my

certification, I intend to start a hair salon business with the guidance of my mentors. I will

also need to use a portion of the funds to cover my livingexpenses while I go to school.

The remainder of the funds will be used to cover my rent ($850.00 per month), cable, gas,

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cell phone bills,and car insurance payments. I will also need to be able to provide

support my child's expenses while not working. Therefore, I feel itis in my best interest

to enter into this transaction with the Petitioner and sell a portion of my underlying

annuity payments, so that I can have the financial means to provide for this purpose.

6. I am proposing to assign lump sum payments beginning May 2040. As

these payments are due more than 17 years from now, I do not depend on the annuities

for my current well-being or livelihood. The funds I receive from the transaction, as

referenced in the Purchase Agreement, can be better utilized today rather than waiting

several years from now.

7. I have previously assigned a portion of my structured settlement payment

rights with my most recent transfer completed in June 2018.

8. Prior to entering into this transaction with Odyssea-Abe83, LLC, I

requested that the beneficiary under my annuity be changed to my own personal estate.

Thus, there are no additional beneficiaries under the annuity policy that would qualify as

interested parties to thisaction entitled to receive notice of this action.

9. I received and read a separate written disclosure statement from Odyssea-

Abe83, LLC in compliance with the New York Structured Settlement Protection Act on

August 24, 2022, which was received 10 days prior to execution of the Transfer

Agreement.

10. I am aware and understand that I am not represented by Odyssea-Abe83,

LLC. I further understand that Greg Saber represents Odyssea-Abe83, LLC and that I

have been advised in writing to seek independent professional advice, in regard to the

assignment of my structured settlement payment rights to Odyssea-Abe83, LLC and its

successors and or assigns. I hereby waive that advice.

11. I have received and reviewed copies of (1) the Agreement to Transfer

Structured Settlement Payment Rights offered by Odyssea-Abe83, LLC; and (2) a copy

of the required disclosures.

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Case Info

Judge

Henry J. Nowak Track Judge’s New Case

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Document Filed Date

September 27, 2022

Case Filing Date

September 27, 2022

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Summons: Lucky D Nordee v. Lynette C Grube

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