Deutsche Bank AG v. Sebastian Holdings, Inc., 331 Conn. 379

Deutsche Bank obtained a bench judgment in the Queen’s Bench Division (England) against Sebastian Holdings, Inc. for trading losses (≈ $243 million) and later obtained a postjudgment order holding Alexander Vik (Sebastian’s sole shareholder/director) personally liable for certain litigation costs under §51 Senior Courts Act.
Sebastian did not pay the English judgment; Deutsche Bank filed suit in Connecticut to enforce the foreign judgment and to pierce Sebastian’s corporate veil to hold Vik personally liable for the unsatisfied judgment.
Connecticut complaint pleaded two counts: (1) declaratory relief / veil piercing (alter-ego) against Vik; and (2) recognition/enforcement of the foreign money judgment under Connecticut’s Uniform Foreign Money Judgments Recognition Act.
Parties filed cross motions for summary judgment based on preclusion: Deutsche Bank argued collateral estoppel (English court’s findings established Vik as alter ego); Sebastian and Vik argued res judicata (plaintiff should have raised veil-piercing in the English action).
Trial court denied both summary judgment motions; the Appellate Court affirmed, holding veil-piercing not barred by res judicata and that the English court’s factual findings were nonessential (so collateral estoppel did not apply); the Connecticut Supreme Court affirmed the Appellate Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether collateral estoppel bars Vik from relitigating alter-ego because English court made findings establishing his control	English court’s factual findings definitively established Vik as Sebastian’s alter ego; those findings are binding	Findings were not essential to the English judgment on breach; thus not entitled to preclusive effect	Denied: English findings were nonessential to the judgment; collateral estoppel did not apply
Whether res judicata bars Deutsche Bank’s veil-piercing claim because it could have been raised in the English action	Veil-piercing could and should have been litigated in England; claim is precluded	Veil-piercing is a different, separate theory to enforce an unsatisfied judgment and was not required to be litigated previously	Denied: veil-piercing claim is distinct from contractual liability adjudicated in England; res judicata does not bar the Connecticut action
Preclusive effect of §51 postjudgment costs findings in England	Postjudgment findings assessing costs against Vik should have preclusive effect here	§51 proceedings differ procedurally and addressed different issues; not identical to present issues	Denied: §51 findings were not equivalent and do not carry the necessary procedural protections to be binding here

Deutsche Bank AG v. Sebastian Holdings, Inc., 174 Conn. App. 573 (Conn. App. 2017) (Appellate Court opinion affirming denial of both parties’ summary judgment motions)
Santorso v. Bristol Hospital, 308 Conn. 338 (Conn. 2013) (interlocutory appeal recognized from denial of summary judgment based on res judicata or collateral estoppel)
Recall Total Information Management, Inc. v. Federal Ins. Co., 317 Conn. 46 (Conn. 2014) (adoption of lower court opinion as statement of issues and law)
Brenmor Properties, LLC v. Planning & Zoning Commission, 326 Conn. 55 (Conn. 2017) (court may adopt appellate opinion as proper statement of issues and applicable law)