On June 14, 2022, the First Department issued a decision in Taxi Medallion Loan Trust III v. Brown Eyes Cab Corp., 2022 NY Slip Op. 03879, holding that an agreement’s recital that it was negotiated, executed, and delivered in New York was sufficient to create personal jurisdiction in New York, explaining:
Plaintiffs made a showing that the out-of-state defendants were transacting business within the state, as is necessary to establish personal jurisdiction under CPLR 302(a)(1). The relevant settlement agreements signed by the borrowers and by the guarantors of the loans explicitly state that they were negotiated, executed, and delivered in New York. Furthermore, since we are reinstating the claims as against the out-of-state defendants, the otherwise well-pleaded fraudulent conveyance claims asserted against Lina Garber, 3210 101 Warren, and 22-05 Realty, which were dismissed because of the jurisdictional dismissal of the claims against necessary party Symon Garber, are reinstated.
(Internal citations omitted).