Patterson, Belknap, Webb & Tyler LLP v. Bushkin

In Patterson, Belknap, Webb & Tyler LLP v. Bushkin, 1999 WL 1216632, [SD NY 1999] the plaintiff alleged that the defendant participated in fraudulent conveyances to avoid the payment of legal fees owed to plaintiff. The situs of injury was found to be New York, because the alleged tort was directed at and intended to avoid an obligation to plaintiff, a New York entity, and the obligation arose out of the parties' agreement that the plaintiff would perform legal services in New York (id.). The court also noted that the plaintiff was seeking to enforce a previously obtained judgment against the defendant's employer for the recovery of the same fees, and that the judgment was "issued by this Court in New York" (id.). The New York judgment was another reason to situate the situs-of-injury in New York.