The case of the day is Desiano v. Envision Foods, Inc. (Mass. Super. Ct. 2017). I love this one. Ralph Desiano had a Florida money judgment for nearly $200,000 against Envision. Desiano’s case against Envision had nothing to do with Massachusetts, and Envision was not subject to general personal jurisdiction here, either. But Envision was a creditor of Cosi, Inc., a Massachusetts corporation. The Cosi debt was, in fact, Envision’s only asset. Cosi owed Desiano $500,000. Desiano sued Envision in Boston on the Florida judgment, and it named Cosi as a reach-and-apply defendant (i.e., he asked the court to order Cosi to pay part of the money it owed to Envison to Desiano instead, in satisfaction of the judgment debt). Envision moved to dismiss…

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