Armenian Assembly of America, Inc. v. Cafesjian
811 F. Supp. 2d 120
D.D.C.2011Background
- This consolidated suit concerns a DC museum project for the Armenian Genocide and related property interests; after a 12-day bench trial in 2010, the court largely dismissed claims but allowed indemnification issues and a reversion clause ruling to proceed; the court issued a January 2011 Mem. Op finding the Grant Agreement’s reversion clause valid and the claims meritorious only as to indemnification; final judgment was entered May 9, 2011, with one counterclaim still pending before a magistrate; Defendants sought to enforce the judgment and obtain amended findings; the dispute centers on whether AGM&M’s title and the reversion rights extinguish the Assembly’s leasehold in the Families U.S.A. building and related property transfers; the court later denied amendments and denied attorneys’ fees for late document production on trial eve; the lease terms and title transfers occurred through agreements involving Cafesjian, CFF, AGM&M, and TomKat; title to the adjacent properties was conveyed to AGM&M by TomKat/third parties, not by Cafesjian and CFF.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the reversion clause extinguishes the Assembly’s leasehold | Assembly: lease remains; reversion does not defeat lease. | CFF/Cafesjian: reversion terminates Assembly interest, voiding lease. | Defendants’ argument rejected; AGM&M held fee simple; lease transferred. |
| Whether AGM&M’s interest was defeasible | Defendants could extinguish only a defeasible interest; transfer affects lease. | Grant Agreement created a defeasible interest via reversion. | No defeasible estate; deed to AGM&M was fee simple; transfer did not extinguish lease. |
| Whether the court should amend findings or judgment | N/A | N/A | Amendment/alteration denied; findings and judgment reaffirmed. |
| Whether plaintiffs’ late document production warrants attorneys’ fees | Prolonged delays not vexatious; production explained. | Late production justifies fees for vexatious litigation. | No attorneys’ fees awarded for late production. |
Key Cases Cited
- Schooler v. Schooler, 173 F.2d 299 (D.C.Cir. 1948) (deed vs. contract distinction for property transfers)
- Firestone v. Firestone, 76 F.3d 1205 (D.C.Cir. 1996) (Rule 59(e) standards and reconsideration)
- Barzingus v. Wilheim, 306 F.3d 17 (10th Cir. 2010) (reconsideration standards related to arbitration)