Universitas Educ., LLC v. Nova Group, Inc

In Universitas Educ., LLC v. Nova Group, Inc. (2014 WL 3883371, [SD NY 2014]), the plaintiff brought claims pursuant to DCL 273, 275, and 276, seeking to make defendants turn over assets transferred from a judgment debtor. Although the complained-of transfers, which were performed in another state, took place before the plaintiff obtained its judgment, the person responsible for the transfers knew at the time that the creditor was asserting a right to the assets and was considering litigation. The court determined that "the situs of the injury is New York, because the fraudulent conveyances impeded Petitioner's ability to enforce its New York judgment" (id.).