Upper Deck v Pirozzi.pdf


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Case 1:17-cv-06685 Document 1 Filed 11/15/17 Page 1 of 31 PageID #: 1

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
THE UPPER DECK COMPANY,
Case No.: 1:17-cv-06685
Plaintiff,
-againstCOMPLAINT
JOSEPH PIROZZI, JACK PIROZZI,
JONATHAN PIROZZI, and THERESA
DEPIETRO,
Defendants.

The Upper Deck Company (“Plaintiff” or “Upper Deck”) by its counsel, Cervini
Swanson LLP, as and for its complaint against defendants Joseph Pirozzi (“Judgment Debtor”),
Jack Pirozzi (“Defendant Father”), Jonathan Pirozzi (“Defendant Son”) and Theresa DePietro
(“Defendant Girlfriend”) (collectively, Defendant Father, Defendant Son and Defendant
Girlfriend are referred to as “Defendant Family”) (collectively, Judgment Debtor and Defendant
Family are referred to as “Defendants”), alleges as follows:
I.

NATURE OF CLAIMS
1.

This action responds to newly-discovered information obtained by Upper Deck

evidencing a systematic (and systematically-concealed) scheme enacted by Judgment Debtor, in
concert with his family members (including Defendant Family) to hinder, delay and defraud
Upper Deck. This ongoing scheme has spanned over nearly a decade, involving, inter alia: (i)
fraudulent transfers of funds and property by Judgment Debtor to and among family members;
(ii) active concealment of these fraudulent transactions by Judgment Debtor with the cooperation
of family members; and (iii) extensive misrepresentations by Judgment Debtor and his family