Opinion

Eletson Holdings Inc.

Court
United States Bankruptcy Court, S.D. New York
Filed
Dec 30, 2025
Cited by
0 cases
Authority
More cited than 37.9%

“[W]e construe the [attorney-client] privilege narrowly because it renders relevant information undiscoverable . . . The burden of establishing the applicability of the privilege rests with the party invoking it.”

How later courts described this case

  • “[W]e construe the [attorney-client] privilege narrowly because it renders relevant information undiscoverable . . . The burden of establishing the applicability of the privilege rests with the party invoking it.”

Written by the judges who cited it.

The opinion

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF NEW YORK FOR PUBLICATION

esto xX

In re: Chapter 11

ELETSON HOLDINGS INC..,! : Case No. 23-10322(JPM)

Debtor. :

eX

MEMORANDUM OPINION AND ORDER DENYING MOTION OF ROLNICK

KRAMER SADIGHI LLP, LASSIA INVESTMENT COMPANY, GLAFKOS TRUST

COMPANY, FAMILY UNITY TRUST COMPANY, AND ELAFONISSOS SHIPPING

CORPORATION TO QUASH OR, IN THE ALTERNATIVE, FOR A PARTIAL

PROTECTIVE ORDER

! Prior to November 19, 2024, the debtors in these cases were: Eletson Holdings Inc., Eletson

Finance (US) LLC, and Agathonissos Finance LLC (the “Debtors’”). On March 5, 2025, the Court

entered a final decree and order closing the Chapter 11 cases of Eletson Finance (US) LLC and

Agathonissos Finance LLC. Commencing on March 5, 2025, all motions, notices, and other

pleadings relating to any of the Debtors shall be filed in the Chapter 11 case of Eletson Holdings

Inc. The Debtor’s mailing address is c/o Herbert Smith Freehills Kramer (US) LLP, 1177 Avenue

of the Americas, New York, New York 10036.

JOHN P. MASTANDO III

UNITED STATES BANKRUPTCY JUDGE

I. INTRODUCTION

On September 22, 2025, this Court entered a judgment (“September 22, 2025 Judgment”)

in favor of Eletson Holdings, Inc. (“Holdings”) against Family Unity Trust Company, Glafkos

Trust Company, and Lassia Investment Company (“Former Majority Shareholders”); Vasilis

Hadjieleftheriadis; Konstatinos Chatzieleftheriadis, Ioannis Zilakos, Niki Zilakos, Adrianos

Psomadakis-Karastamatis, Eleni Giannakopoulous, Panos Paxinoz, and Emmanel Andreulaks

(“Purported Provisional Board”); Elafonissos Shipping Corporation (“Elafonissos”) and Keros

Shipping Corporation (collectively, “Former Minority Shareholders”); and Laskarina Karastamati

(collectively with all proceeding, save Holdings, “Judgment Debtors”). Dkt No. 1836.2

Before the Court is the Motion of Rolnick Kramer Sadighi LLP, Lassia Investment

Company, Glafkos Trust Company, Family Unit Trust Company, and Elafonissos Shipping

Corporation to Quash or, in the Alternative, for a Partial Protective Order (“Motion”) filed

November 21, 2025. Dkt. No. 1888. In support of the Motion is the declaration of Justin Harris

(“Harris Declaration”). Dkt. No. 1889. The Motion seeks to quash subpoenas – or, in the

alternative, to limit their scope – issued by Holdings to Rolnick Kramer Sadighi LLP (“RKS”) and

Reed Smith LLP (“Reed Smith”) to assist in collecting the September 22, 2025 Judgment.

The Court is further in receipt of Holdings’ opposition to the Motion (“Opposition”) filed

December 5, 2025. Dkt. No. 1904. In support of the Opposition is the declaration of Jaclyn Grodin

(“Grodin Declaration”). Dkt. No. 1905.

2 All references to “Dkt. No.” absent a separate case name and number refer to docket entries in

this case. References to “Dkt. No.” that include a separate case name and number, as in Avalon

Holdings Corp. v. Guy Gentile, Case No. 18-cv-7291 (DLC) (RLJ), Dkt. No. 359-1, refer to the

docket entries in the case name and number included.

The Court is also in receipt of the reply in support of the Motion (“Reply”) filed by RKS,

the Former Majority Shareholders, and Elafonissos (together with the Former Majority

Shareholders, the “Former Foreign Shareholders,” and collectively, with RKS, “Movants”) filed

December 12, 2025. Dkt. No. 1916. In support of the Reply is the declaration of Richard Bodnar.

Dkt. No. 1917.

The Court held a hearing on the Motion on December 19, 2025.

II. JURISDICTION

The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 1334 and 157(a) and

(b)(1) and the Amended Standing Order of Reference dated January 31, 2012 (Preska, C.J.). This

is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(L).

III. BACKGROUND

The Motion begins by noting that Elafonissos moves to quash based on lack of personal

jurisdiction, and for the subsequent bases to be described below only upon a finding that that this

Court has personal jurisdiction over Elafonissos.3 Motion at 1 n.2.

The Motion then argues that the Former Foreign Shareholders have standing to oppose the

subpoena issued to Reed Smith, because that subpoena seeks information concerning the funds or

assets of the Judgment Debtors, which includes the Former Foreign Shareholders, and that

information will be used to collect a debt from the Former Foreign Shareholders. Motion at 6–7.

3 Elafonissos raised this personal jurisdiction challenge in its March 27, 2025 motion to reconsider

two of this Court’s prior sanctions orders. Dkt. No. 1569. The Court denied the motion on July

2, 2025, holding that the Court had personal jurisdiction over Elafonissos, as Elafonissos had

received actual notice of this Court’s orders and proceedings, Elafonissos had voluntarily appeared

before the Court and consented to its jurisdiction, and Elafonissos had sufficient minimum contacts

with this forum. Dkt. Nos. 1714 (07/07/25 Or.), 1721 (Tr. of 07/02/25 Hr’g) at 13, 28–47.

Elafonissos appealed, Dkt. No. 1725 (Notice of Appeal), and that appeal is pending in the District

Court.

Next, the Motion argues that the subpoenas are null and void under New York Civil

Practice Law and Rules (“C.P.L.R.”) § 5224, because the subpoenas fail to comply with the

certification requirement of § 5224(a)(3)(i), and § 5224(a)(3)(ii) states that a failure to comply with

§ 5224(a)(3)(i) renders the subpoenas null and void. Id. at 7–9. Specifically, the Motion argues

that the certifications in the subpoenas state their compliance with § 5224, but fail to state their

compliance with New York General Business Law (“G.B.L.”) § 601, which is also required by §

5224(a)(3)(i). Id. at 8. Further, the Motion argues that the subpoenas substituted the phrase “one

or more of the Judgment Debtors” in place of “debtor” in the following phrase of the certification

required by § 5224(a)(3)(i): “I have a reasonable belief that the party receiving this subpoena has

in their possession information about the debtor” (all caps formatting removed). Id. at 8–9. The

Motion asserts that Holdings lacks this requisite, reasonable belief, as “RKS represents only the

four [Former] Foreign Shareholders,” “Reed Smith has only represented the bankruptcy debtors,

none of which are Judgment Debtors,” and “RKS has no affiliation with most of the fourteen

debtors the Subpoenas target, and Reed Smith may not have any either.” Id. at 9.

The Motion further argues that the subpoena as to RKS seeks “to impair RKS’s ability to

represent the [Former] Foreign Shareholders–including in the appeal of the very orders and

judgments the Subpoena purports to be related to.” Id. at 10. The Motion argues that the subpoena

improperly targets RKS to “manufacture” a conflict of interest between it and its clients, by asking

RKS to disclose client information learned during the course of its representation, and that

Holdings alternatively could have subpoenaed the Former Foreign Shareholders themselves

(which Holdings eventually did), or “counterparties” to their business deals. Id. (citing Astraea

NYC LLC v. Rivada Networks, Inc., 592 F. Supp. 3d 181, 183 (S.D.N.Y. 2022)). The Motion also

argues that the timing of the subpoenas, “right after” RKS appealed the September 22, 2025

Judgment, “strongly suggests” a plan to “reduce the likelihood of appellate review and introduce

uncertainty into the attorney-client relationship.” Id. at 10–12.

Alternatively, if this Court enforces the subpoenas, the Motion asks for a protective order

limiting their scope, arguing that the subpoenas are overbroad in instructing RKS and Reed Smith

to provide information concerning all fourteen Judgment Debtors, even though RKS only

represents four, concerning time before RKS’s representation in this case and extending into the

future. Id. at 12–13. Further, the Motion argues that the requested information – “any and all”

entities, accounts, or assets associated with any Judgment Debtor; “any transfers” from a Judgment

Debtor; and “any deposits or escrowed assets” the firm is aware of that may be returned to any

Judgment Debtor – is overbroad, especially as it is not limited to non-privileged information. Id.

at 13. Accordingly, the Motion requests a limitation on the subpoenas “to tailor their requests

more narrowly and eliminate from their scope any information that may be privileged or

excessive.” Id. at 14.

In response, Holdings first argues that the language in the subpoenas’ certifications is

appropriate. Opposition at 3 (citing Avalon Holdings Corp. v. Guy Gentile, Case No. 18-cv-7291

(DLC) (RLJ), Dkt. No. 359-1). Holdings distinguishes the authorities cited by RKS, arguing that

none “stand for the proposition that the Information Subpoenas are invalid for any minor deviation

from the language of the statute, which of course is not the law.” Id. at 4. In any event, Holdings

asserts that RKS’s argument is now moot, as the declaration of Jaclyn Grodin included with the

Opposition “includes a supplemental attorney certification . . . that tracks the langue of C.P.L.R. §

5224(a)(3)(i).” Id. (citing Grodin Declaration at ¶ 9). Holdings contends that it “has a reasonable

belief that both Reed Smith and RKS each have relevant information about each of the fourteen

Judgment Debtors.” Id. (emphasis removed). The Opposition further notes that the “Motion

should also be denied because the [Movants] failed to meet and confer in a ‘good faith effort,’” as

RKS failed to raise the argument during the meet-and-confer that the subpoenas were invalid based

on the language in the certifications. Id. n. 3.

The Opposition next argues that the subpoenas are “narrowly tailored to seek information

from RKS and Reed Smith to collect a debt from the judgment debtors.” Id. at 5–6. Further, the

Opposition argues that RKS and Reed Smith, despite being counsel, are proper targets for

discovery. Id. at 6 (citing Avalon Holdings Corp. v. Gentile, 350 F.R.D. 8, 14 (S.D.N.Y. 2025)).

Further, the Opposition argues that the subpoenas do not target privileged information; rather, the

subpoenas properly seek “information concerning payments made by the Judgment Debtors, the

dates, amounts, accounts from which such payments were made, and the escrow accounts held on

behalf of the Judgment Debtors.” Id. at 7. Lastly, the Opposition argues that the subpoenas do

not undermine appellate review, especially as the Judgment Debtors failed to seek a stay of the

September 22, 2025 Judgment, and thus it is immediately enforceable notwithstanding any appeal.

Id. at 7–8.

The Reply repeats RKS’s argument that the subpoenas are null and void based on their

purportedly deficient certifications. Reply at 2–4, 6–7. The Reply also repeats RKS’s argument

that Holdings lacks the reasonable belief necessary to issue the subpoenas, as neither RKS nor

Reed Smith “has ties to all fourteen of the judgment debtors.” Id. at 4–5. The Reply argues that

Avalon Holdings Corp. does not supply precedent for upholding the certification’s language, as

the court there did not “decide or even consider the sufficiency of any subpoena certification,” as

it was not raised by the parties. Id. at 5–6. The Reply also argues that the subpoenas are void ab

initio, and cannot be “retroactively validated” by a new declaration “supplying a supplemental

attorney certification that tracks the statute.” Id. at 7–8. Further, the Reply argues that Holdings

misrepresents RKS’s good faith efforts at the meet-and-confer over the subpoenas, and that the

meet-and-confer was in any event futile given the parties’ disagreement as to whether the

subpoenas are void. Id. at 8–9. The Reply also repeats RKS’s argument that the subpoenas

“insert[] conflicts of interest into RKS’s ongoing representation of the Foreign Shareholders.” Id.

at 9–11. And lastly, the Reply repeats RKS’s request for a protective order. Id. at 11–12.

IV. LEGAL ANALYSIS

A. Legal Standard

“[B]road post-judgment discovery in aid of execution is the norm in federal and New York

state courts.” EM Ltd. v. Republic of Argentina, 695 F.3d 201, 207 (2d Cir. 2012). “Post-judgment

discovery is governed by Federal Rule of Civil Procedure 69, which provides that ‘[i]n aid of the

judgment or execution, the judgment creditor . . . may obtain discovery from any person –

including the judgment debtor – as provided in these rules or by the procedure of the state where

the court is located.’” Id. (quoting Fed. R. Civ. P. 69(a)(2)). “The scope of discovery under Rule

69(a)(2) is constrained principally in that it must be calculated to assist in collecting on a

judgment.” Id. “New York state’ s post-judgment discovery procedures, made applicable to

proceedings in aid of execution by Federal Rule 69(a)(1), have a similarly broad sweep.” Id. “The

New York Civil Practice Law and Rules provide that a ‘judgment creditor may compel disclosure

of all matters relevant to the satisfaction of the judgment.’” Id. (quoting C.P.L.R. § 5223). “[A]s

in all matters relating to discovery, the district court has broad discretion to limit discovery in a

prudential and proportionate way.” Id.

“Discovery of a judgment debtor’s assets is conducted routinely under the Federal Rules

of Civil Procedure.” First City, Texas-Houston, N.A. v. Rafidain Bank, 281 F.3d 48, 54 (2d Cir.

2002). “A judgment creditor is entitled to discover the identity and location of any of the judgment

debtor’s assets, wherever located.” Id. (quoting National Service Industries, Inc. v. Vafla Corp.,

694 F.2d 246, 250 (11th Cir. 1982) (citation modified)). “[Under Rule 69(a),] the judgment

creditor must be given the freedom to make a broad inquiry to discover hidden or concealed assets

of the judgment debtor.” Id. (citation omitted).

B. Motion to Quash

For the reasons discussed below, the Court agrees with Holdings and the Motion is

DENIED.

First, RKS makes two principal contentions that the subpoenas are null and void under

C.P.L.R. § 5224: first, that the certifications in the subpoenas state their compliance with Section

5224, but fail to state their compliance with G.B.L. § 601, which is required by Section

5224(a)(3)(i), Motion at 8; and second, that the subpoenas substituted the phrase “one or more of

the Judgment Debtors” in place of “debtor” in the certification required by § 5224(a)(3)(i), Motion

at 8–9.

Section 5224(a)(3)(i) requires the following certification to be included with information

subpoenas:

I hereby certify that this information subpoena complies with rule 5224 of the Civil

Practice Law and Rules and Section 601 of the General Business Law that I have a

reasonable belief that the party receiving this subpoena has in their possession

information about the debtor that will assist the creditor in collecting the judgment.

§5224(a)(3)(i) (all caps formatting removed).

Holdings’ subpoenas contain the following certifications:

I hereby certify that this Information Subpoena complies with Rule 5224 of the

(New York) Civil Practice Law and Rules and that the undersigned have a

reasonable belief that the party receiving this Subpoena has in their possession

information about one or more of the Judgment Debtors that will assist the

Judgment Creditor in collecting the Judgment.

Dkt. Nos. 1889-1 (Ex. A Harris Declaration) at 3, 1889-2 (Ex. B Harris Declaration) at 3.

RKS is thus correct that the certifications contain two changes from the language in the

statute. The first is the omission of a reference to G.B.L. § 601, and the second the substitution of

the phrase “one or more of the Judgment Debtors” in place of “debtor.” RKS is also correct that

§ 5224(a)(3)(ii) provides that “if an information subpoena, served on an individual or entity other

than the judgment debtor, does not contain the certification provided for in subparagraph (i) of this

paragraph, such subpoena shall be deemed null and void.”

G.B.L. § 601 enumerates twelve prohibited practices of a creditor or the creditor’s agent.

“If such principal creditor or agent sends more than fifty information subpoenas per month,”

subsection 11 contains record-keeping requirements, including that:

[c]ontemporaneous records shall be kept that set forth with specificity the grounds

for such principal creditor or agent’s reasonable belief, which must be certified and

accompany each information subpoena pursuant to rule fifty-two hundred twenty-

four of the civil practice law and rules, that the party receiving the subpoena has in

its possession information about the debtor that will assist the creditor in collecting

his or her judgement.

G.B.L. § 601(11). That subsection further provides for a civil, monetary penalty in an action

brought by the Attorney General for failure to comply with this subsection, “[i]n addition to any

other penalty that may be imposed.” Id.

The parties have not addressed G.B.L. § 601(11) specifically. Whether Holdings’ omission

that the information subpoenas comply with G.B.L. § 601 renders the subpoenas null and void is

an issue this Court need not reach, because, as Holdings argues, Opposition at 4 (citing Grodin

Declaration at ¶ 9), Holdings has now certified with respect to each subpoena that they comply

with G.B.L. § 601. Moreover, and discussed further below, insofar as § 601(11) requires that the

issuer of a subpoena “set forth with specificity the grounds” of his reasonable belief and to

accompany those grounds with the subpoena, Holdings has now also done so. Grodin Declaration

at ¶ 10. The Court also agrees with Holdings that this is an issue that the parties could have

resolved through a genuine, good-faith effort to meet-and-confer over the subpoenas. Opposition

at 4 n.3. The Court also notes that Holdings is correct that one District Court in the Southern

District of New York has denied a law firm’s motion for a protective order involving a subpoena

whose certification also omitted reference to G.B.L. § 601, seeking information concerning a

former client and judgment debtor. Opposition at 3; Avalon Holdings Corp. v. Gentile, 350 F.R.D.

8, 14 (S.D.N.Y. 2025); Avalon Holdings Corp. v. Guy Gentile, Case No. 18-cv-7291 (DLC) (RLJ),

Dkt. No. 359-1 at 3. RKS is correct, Reply at 5–6, that the Court in Avalon Holdings did not

address the language of the certification specifically, because the issue was not raised by the

parties, but this Court finds nonetheless that the case supports Holdings’ arguments.

The Motion’s second assertion is without merit. That the original certifications in the

subpoenas substituted “one or more of the Judgment Debtors,” or, as in the updated certification

provided by the Grodin Declaration, “each of the Judgment Debtors,” in place of “debtor” – in

other words, that the certifications pluralized debtor because in this case there is not one judgment

debtor but in fact fourteen – is not a basis to conclude that the “information subpoena[s] . . . do[]

not contain the certification provided for in subparagraph (i) of this paragraph,” C.P.L.R. §

5224(a)(3)(ii), and this is thus not a basis to conclude that the subpoenas are null and void and

should be quashed.

The Motion also argues that Holdings lacks the reasonable belief required by Section

5224(a)(3)(i), as “RKS represents only the four [Former] Foreign Shareholders,” that “Reed Smith

has only represented the bankruptcy debtors, none of which are Judgment Debtors,” and that “RKS

has no affiliation with most of the fourteen debtors the Subpoenas target, and Reed Smith may not

have any either.” Motion at 9. The Court notes that Holdings has now elaborated on the basis of

its belief: RKS is counsel to the Former Foreign Shareholders; Reed Smith is former counsel to

Holdings,4 which was owned by the Former Foreign Shareholders; eight of the Judgment Debtors

were members of the purported provisional board of Holdings, which was appointed upon an

application by Elafonissos and others; Laskarina Karastamati is a former director of Holdings who

also directs or previously directed Lassia Investment Company; and Vasilis Hadjieleftheriadis is a

former director of Holdings who also directs or previously directed Glafkos Trust Company.

Grodin Declaration at ¶ 10; see also Dkt. No. 1564 (Tr. of 3/12/25 Hr’g) at 72 (finding that the

former majority shareholders, the former minority shareholders, the purported provisional board,

the purported Provisional Holdings, and Hadjieleftheriadis failed to cooperate in good faith to

implement and consummate the confirmation plan). Moreover, to the extent that RKS or Reed

Smith have knowledge as to some but not all of the Judgment Debtors, they can easily so assert in

their responses to the subpoenas – this is not a basis to quash the subpoenas at the outset. And as

cited above, “broad post-judgment discovery in aid of execution is the norm in federal and New

York state courts.” EM Ltd., 695 F.3d at 207.

Although RKS acknowledges that there is no prohibition on issuing subpoenas to counsel,

Reply at 9, the Motion argues that the subpoena as to RKS seeks “to impair RKS’s ability to

represent the [Former] Foreign Shareholders–including in the appeal of the very orders and

judgments the Subpoena purports to be related to,” Motion at 10 (citing Astraea NYC LLC v.

Rivada Networks, Inc., 592 F. Supp. 3d 181, 183 (S.D.N.Y. 2022)). As an initial point, the Court

agrees with Holdings that the Judgment Debtors failed to seek a stay of the September 22, 2025

4 Reed Smith has also at a minimum purported to represent purported Provisional Eletson

Holdings. See December 10, 2024 Statement, Dkt. No. 1293; February 4, 2025 Letter, Dkt. No.

1407; see also In re Eletson Holdings Inc., 2025 U.S. Dist. LEXIS 187947, at *28, 33, 37 (S.D.N.Y.

Sept. 22, 2025) (“It is necessary first to understand the background of Provisional Holdings in

order to rule on its legal existence. The moniker was first introduced in the Bankruptcy Proceedings

by Reed Smith . . . to describe ‘[t]he provisional board of directors of Eletson Holdings, Inc.’ as it

had purportedly been constituted in the Piraeus proceedings in Greece.”).

Judgment, and thus it is immediately enforceable notwithstanding any appeal. Opposition at 7–8.

In addition, Astraea does not establish that Movants have met their burden on the Motion. Motion

at 10; Reply at 9–10; Pritchard v. County of Erie (In re County of Erie), 473 F.3d 413, 418 (2d

Cir. 2007) (“[W]e construe the [attorney-client] privilege narrowly because it renders relevant

information undiscoverable . . . The burden of establishing the applicability of the privilege rests

with the party invoking it.”); see, e.g, Bennett v. Cuomo, 2024 U.S. Dist. LEXIS 106523, at *22

(S.D.N.Y. June 12, 2024) (“On a motion to quash asserting that privilege prevents disclosure, the

party invoking a privilege bears the burden of establishing its applicability to the case at hand.”

(citation modified)).

The court in Astraea granted a motion to quash an information subpoena issued by a

judgment creditor to the judgment debtor’s former law firm. Astraea NYC LLC, 592 F. Supp. at

183. The court observed that Federal Rule of Civil Procedure 69(a)(2) “says nothing about

discovery from the debtor’s law firm,” that the statute’s language, “‘[a]ny person’[,] would not

ordinarily be taken as including ‘any law firm,’” given the attorney-client privilege, and that “the

words ‘any person’” did not “overcome the force and value of the policy that the lawyer may not

reveal the confidences of her client, even though the client himself may well be compelled to

disclose them.” Id. at 182–83. The court concluded that “[t]he proper procedure is not an ill-

conceived inquiry of defendant’s attorneys seeking information they learned in the course of the

case, but to direct relevant questions to the defendant.” Id. at 183.

As Holdings argues, the subpoena in Astraea is distinguishable from the subpoenas at issue

here, as the subpoena in Astraea sought privileged information. Opposition at 6; ASTRAEA NY

LLC v. Rivada Networks, Inc., 21-cv-10493-LLS, Dkt. No. 23-1 at 5–6 (“describe in full detail the

contents of . . . [any] contracts” held with the judgment debtor; “describe in full detail the nature

of . . . [your] representation” of the judgment debtor, past and present). Here, by contrast, as RKS

acknowledges, “most of the questions . . . specifically seek information concerning the funds or

assets of the Judgment Debtors.” Motion at 7; Opposition at 7 (The subpoenas seek “disclosure

from RKS and Reed Smith of information concerning payments made by the Judgment Debtors,

the dates, amounts, accounts from which such payments were made, and the escrow accounts held

on behalf of the Judgment Debtors.”). The remaining questions concern information such as the

Judgment Debtors’ addresses and other contact information. See Dkt. Nos. 1889-1 (Ex. A Harris

Declaration) at 4–5, 1889-2 (Ex. B Harris Declaration) at 4–5. “As a general rule, a client’s

identity and fee information are not privileged.” Lefcourt v. U.S., 125 F.3d 79, 86 (2d Cir. 1997);

see also In re Grand Jury Subpoena Served upon Doe, 781 F.2d 238, 247–48 (2d Cir. 1986)

(“While consultation with an attorney, and payment of a fee, may be necessary to obtain legal

advice, their disclosure does not inhibit the ordinary communication necessary for an attorney to

act effectively, justly, and expeditiously. For this reason . . . disclosure of fee information and

client identity is not privileged even though it might incriminate the client.”); see also, e.g., Avalon

Holdings Corp., 350 F.R.D. at 9, 14 (denying a law firm’s motion for a protective order over a

subpoena issued as to information such as “payment of attorney’s fees, including the means and

sources of payment” from a former client and judgment debtor).

V. CONCLUSION

For the reasons stated above, the Motion is DENIED.

IT IS SO ORDERED.

Dated: December 30, 2025 /s/ John P. Mastando III

New York, New York HONORABLE JOHN P. MASTANDO III

UNITED STATES BANKRUPTCY JUDGE

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

A word about cookies

We need a few to keep you signed in and the library working. The rest help us see which pages people use and where they get stuck. They stay off unless you say yes.