IN THE DISTRICT COURT OF THE VIRGIN ISLANDS                    
                 BANKRUPTCY DIVISION                                 
               ST. CROIX, VIRGIN ISLANDS                             
In re:                             )    Chapter 7                         
                              )                                      
CARIBBEAN AUTO MART OF             )                                      
ST. CROIX, INC.                    )    Case No. 13-10003 (MFW)           
                              )                                      
                              )                                      
     Debtor.                  )                                      
_____________________________      )                                      
                              )                                      
ANNELLE KNIGHT, ESTHER NEWTON,     )                                      
FITZROY WILLIAMS, PAULINE PETER,   )                                      
JANET RIVERA, RAMS AUTO REPAIR,    )                                      
DEREK CAMBRIDGE, ASHEEM CHARLES,   )                                      
MONIQUE XAVIER, MICHAEL FELIX,     )    Adv. No. 18-01001 (MFW)           
BERNARD HAMILTON,                  )                                      
and LEON RICHARDSON,               )                                      
                              )                                      
     Plaintiffs,              )                                      
                              )                                      
                              )                                      
v.                            )                                      
                              )                                      
CARIBBEAN AUTO MART OF ST. CROIX,  )                                      
Inc., CAG INTERNATIONAL, INC.,     )                                      
d/b/a CARIBBEAN AUTO GROUP,        )                                      
                              )                                      
     Defendant.               )    Rel. Docs. 40, 58, 60             
                       OPINION1                                      
Before the Court is the Motion for Summary Judgment filed by         
the Defendant, CAG International, Inc., d/b/a Caribbean Auto              
Group (“CAG”).  The dispute is whether CAG, the non-debtor parent         
of Caribbean Auto Mart of St. Croix (CAMSTX) (the “Debtor”),              
disregarded corporate entity separateness, pre-petition,                  
1    This Opinion constitutes the findings of fact and                    
conclusions of law of the Court pursuant to Rule 7052 of the              
Federal Rules of Bankruptcy Procedure.                                    
warranting substantive consolidation of CAG and the Debtor.  The          
Plaintiffs oppose the Motion.2  For the reasons stated below, the         
Court will grant CAG’s Motion.                                            

I.   BACKGROUND                                                           
A.   Factual History                                                 
On March 5, 2001, three individuals, William Lambert,                
Charles Lambert, and Sydne Hilton (collectively, the “Initial             
Shareholders”) incorporated the Debtor, a car dealership on St.           
Croix, U.S. Virgin Islands, for the purpose of acquiring the              
assets of an existing automobile dealership and leasing a                 
commercial facility upon which to operate a General Motors                
franchise.  (Adv. D.I. 40, at Ex. A ¶¶ 1.1 & 1.2.)3  Between 2001         
and 2007, the Initial Shareholders incorporated several other             
entities.  (Id., at Ex. A ¶¶ 1.1, 5.2, 5.3, & 5.6.)  These                
entities included two real estate investment vehicles: Triple C           
Inc. (“Triple C”) and CT Real Estate Investments Inc., and five           
dealerships: (i) Lambert Hilton Inc., d/b/a Toyota of St. Thomas;         

2    The Amended Complaint (Adv. D.I. 35) includes Esther Newton          
as a Plaintiff.  Newton’s claim was settled and dismissed in the          
Superior Court of the Virgin Islands on April 26, 2016, and, as a         
result, she did not join the Plaintiffs’ Opposition to CAG’s              
Motion for Summary Judgment.  (Adv. D.I. 58.)                             
3    References to the record are: “D.I. #” for pleadings filed           
in the main bankruptcy proceeding (no. 13-10003) and “Adv. D.I.           
#” for pleadings filed in the adversary proceeding (no. 18-               
01001).                                                                   
                           2                                         
(ii) Caribbean Auto Mart, Inc. (St. Thomas); (iii) Lambert                
Brothers Inc., d/b/a Toyota of St. Croix; (iv) Chrysler-Dodge-            
Jeep of St. Croix, Ltd.; and (v) the Debtor.  The Initial                 
Shareholders collectively owned 100% of the stock in each                 
corporation and were the only directors on their respective               
boards.  (Id.)                                                            
On January 2, 2007, CAG was incorporated to serve as the             
parent holding company for the seven corporations.  The Initial           
Shareholders contributed their stock in each of the seven                 
entities to CAG in exchange for their pro rata share of CAG’s             
stock.  (Id., at Ex. A ¶¶ 5.5 & 5.6; Adv. D.I. 58, at Ex. 29A.)           
The Plaintiffs are unsecured creditors holding tort and/or           
contract claims against the Debtor including claims for wrongful          
termination, sale of defective vehicles, fraud, failure to                
maintain leased property in good repair, breach of good faith and         
fair dealing, breach of implied contract of employment, and               
fraudulent misrepresentations in insuring and financing vehicles.         
None of the Plaintiffs’ claims have been reduced to judgment.             
B.   Procedural History                                              

On March 5, 2013 (the “Petition Date”), the Debtor filed a           
voluntary petition under chapter 7.  On November 2, 2013, the             
chapter 7 trustee (the “Trustee”) filed a Report of No                    
Distribution.  The U.S. Environmental Protection Agency (“EPA”)           
filed an objection to the Trustee’s Report on November 20, 2013,          
                           3                                         
and sought discovery to determine whether there was any basis for         
a cause of action against the Debtor and non-debtor parent, CAG,          
for fraudulent transfers, substantive consolidation, or piercing          
the corporate veil.  (D.I. 59.)  The Plaintiffs joined in the             
EPA’s objection.  (D.I. 63.)  The Court granted the EPA’s                 
discovery request (allowing the Plaintiffs to participate).               
Following discovery, the EPA, the Debtor, and CAG filed a motion          
for approval of a settlement agreement, which the Court granted           
on August 17, 2016.  (D.I. 158 & 164.)  Thereafter, the                   
Plaintiffs filed a motion for discovery under Rule 2004 of the            
Federal Rules of Bankruptcy Procedure on the grounds that the EPA         
had not finished reviewing documents and had not conducted any            
depositions.  (D.I. 165.)  On February 9, 2017, the Court allowed         
the Plaintiffs to conduct limited discovery (namely,                      
depositions).  (D.I. 174.)                                                
On March 16, 2018, the Plaintiffs filed a complaint alleging         
that the Debtor, CAG, and CAG’s majority shareholder, William             
Lambert, ought to be substantively consolidated either because:           
“(i) pre-petition, [the entities] disregarded separateness so             

significantly their creditors relied on the breakdown of entity           
borders and treated them as one entity, or (ii) post-petition,            
their assets and liabilities are so scrambled that separating             
them is prohibitive and hurts all creditors.”  (Adv. D.I. 1.)  In         
re Owens Corning, 
419 F.3d 195, 211-12
 (3d Cir. 2005).                    
                           4                                         
Alternatively, the Plaintiffs sought to pierce the corporate veil         
under the alter ego theory.  (Adv. D.I. 1.)  The Defendants filed         
motions to dismiss.  (Adv. D.I. 22 & 23.)                                 
After a hearing on February 14, 2019, the Court dismissed            
all claims against William Lambert because the complaint failed           
to allege that the Plaintiffs viewed Lambert as the Debtor’s              
alter ego and dismissed all claims against CAG except the claim           
for substantive consolidation under the first test articulated in         
the Owens Corning decision.  (Adv. D.I. 31 & 34.)  The Court              
cautioned, however, that there is a high bar for proving                  
substantive consolidation with a non-debtor.  (Id.)                       
The Plaintiffs thereafter filed an amended complaint (the            
“Amended Complaint”).  (Adv. D.I. 35.)  CAG responded with its            
Motion for Summary Judgment on May 28, 2020.  (Adv. D.I. 40.)             
The Plaintiffs filed their Opposition on August 24, 2020, and CAG         
filed its Reply on September 8, 2020.  (Adv. D.I. 58 & 60.)               
Briefing is complete, and the matter is now ripe for decision.            

II.  JURISDICTION                                                         

The Court has subject matter jurisdiction over this                  
adversary proceeding, which is a core proceeding concerning the           
administration of the estate and liquidation of its assets.  
28 U.S.C. §§ 1334
(b), 157(b)(2)(A) & (O).                                    

                           5                                         
The Court has authority to render a final judgment if the            
parties consent.  See Wellness Int’l Network, Ltd. v. Sharif, 
575 U.S. 665
, 683-85, 685 n.13 (2015) (holding that even if the               
bankruptcy court lacks constitutional authority to enter a final          
order, the parties can consent to a final order expressly or              
implicitly); In re Tribune Media Co., 
902 F.3d 384, 396
 (3d Cir.          
2018) (holding that the claimant impliedly consented to entry of          
a final order by the bankruptcy court, where he filed several             
pleadings without objection to the court’s authority to enter a           
final order); True Traditions, LC v. Wu, 
552 B.R. 826, 836-39
             
(N.D. Cal. 2015) (holding non-debtor defendant impliedly                  
consented to final ruling after it filed a motion for summary             
judgment in a fraudulent transfer action without objecting to             
entry of a final order).                                                  
In this case, CAG expressly consented to the entry of a              
final judgment by the Court in its first responsive pleading.             
The Plaintiffs implicitly consented by filing a complaint seeking         
entry of a final judgment in their favor and by filing a response         
to CAG’s Motion for Summary Judgment without objecting to the             

entry of a final order by the Court, as required by the national          
and local rules.  Fed. R. Bankr. P. 7008, 7012(b); VI Local               
Bankruptcy Rule 7004-2.                                                   


                           6                                         
III. DISCUSSION                                                           
A.   Standard of Review                                              
     1.   Summary Judgment                                           
Summary judgment shall be granted “if the movant shows that          
there is no genuine dispute as to any material fact and the               
movant is entitled to judgment as a matter of law.”  Fed. R. Civ.         
P. 56(a); Fed. R. Bankr. P. 7056.  Material facts are those facts         
that might affect the outcome of the litigation.                          
Once the moving party has established a prima facie case,            
the burden shifts to the non-moving party to present evidence             
beyond mere “speculation and conclusory allegations” in “the              
pleadings, depositions, answers to interrogatories, and                   
admissions on file, together with the affidavits, if any” that            
the factfinder could use in reasonably finding for the non-moving         
party.  Celotex Corp. v. Catrett, 
477 U.S. 317, 323
 (1986)                
(citing Fed. R. Civ. P. 56(c)).  The Court construes all evidence         
in the record in the light most favorable to the non-moving               
party.  Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 
475 U.S. 574, 587
 (1986) (citing United States v. Diebold, Inc., 
369 U.S. 654, 655
 (1962)).                                                    
     2.   Substantive Consolidation                                  
          a.   General Authority                                     
Substantive consolidation is an equitable remedy arising             
under federal common law.  Owens Corning, 
419 F.3d at 206
 (citing         
                           7                                         
Sampsell  v.  Imperial  Paper  &  Color  Corp.,  
313 U.S. 215
   (1941)). 
Under  the  Bankruptcy  Code,  the  power  to  order  substantive 
consolidation  of  bankruptcy  estates  is  derived  from  the  court’s 
general  equitable  powers.   Owens  Corning,  
419 F.3d at 208
  n.14 
(acknowledging  that  substantive  consolidation  is  a  remedy  that 
may  be  available  in  a  bankruptcy  case  although  finding  that  the 
facts  of  the  case  did  not  warrant  it). 
 While  they  apply  slightly  different  standards,  virtually 
every  Circuit  has  recognized  that  substantive  consolidation  of 
debtors  is  available  in  a  bankruptcy  case.    See,  e.g.,  In  re 
Bonham,  
229 F.3d 750
   (9th  Cir.  2000);  In  re  Giller,   
962 F.2d 796, 799
  (8th  Cir.  1992);  In  re  Hemingway  Transp.,  Inc.,   
954 F.2d 1
, 
li  n.15   (lst  Cir.  1992);  Eastgroup  Props.  v.  Southern  Motel 
Ass’n,  Ltd.,   
935 F.2d 245
   (llth  Cir.  1991);  S.I.  Acquisition, 
Inc.  v.  Eastway  Delivery  Serv.,  Inc.   (In  re  S.I.  Acquisition, 
Inc.),  
817 F.2d 1142
,  1144  n.2   (5th  Cir.  1987).    See  also  In  re 
Augie/Restivo  Baking  Co.,  Ltd.,  
860 F.2d 515
,  518   (2d  Cir.  1988) 
(finding  facts  of  that  case  did  not  justify  consolidation  but 
acknowledging  it  was  an  available  remedy  in  bankruptcy  cases);  In 
re  Auto-Train  Corp.,  Inc.,  
810 F.2d 270, 276
  (D.C.  Cir.  1987) 
(same);  In  re  Gulfco  Invest.  Corp.,  
593 F.2d 921
   (10th  Cir.  1979) 
(same). 
             b.     Non-Debtor  Consolidation 
 The  Third  Circuit  left  open  the  possibility  that  bankruptcy

courts  could  consolidate  non-debtors  with  debtors.   Owens 
Corning,  
419 F.3d at 208
  n.13.   Many  other  courts  have  held  that 
a  court  can  grant  substantive  consolidation  of  debtors  and  non- 
debtors.    See,  e.g.,  Bonham,  229  F.3d  at  769-71;  Off.  Comm.  of 
Unsecured  Creditors  v.  Comvest  Grp.  Holdings   (In  re  HH 
Liquidation,  LLC),  Adv.  No.  16-51204   (KG),  
2017 WL 4457404
,  at  *3 
(Bankr.  D.  Del.  Oct.  4,  2017)   (holding  that  it  had  jurisdiction 
to  consolidate  a  non-debtor  with  a  debtor);  Morse  Operations, 
Inc.  v.  Robins  LE-COCQ,  Inc.   (In  re  Lease-A-Fleet,  Inc.),  
141 B.R. 869, 873-74
   (Bankr.  E.D.  Pa.  1992)   (finding  authority  to 
consolidate  debtor  with  a  non-debtor  but  concluding  the  facts  in 
that  case  did  not  support  it). 
 The  courts  have  set  a  high  burden  for  granting  substantive 
consolidation  of  a  debtor  with  non-debtors,  inter  alia,  to  avoid 
the  circumvention  of  the  strict  standards  for  filing  involuntary 
petitions  or  harm  to  creditors  of  the  non-debtor.   lLease-A-Fleet, 
141 B.R. at 872-74
.    See  also  Simon  v.  ASIMCO  Techs.,  Inc.   (In  re 
Am.  Camshaft  Specialties,  Inc.),  
410 B.R. 765, 786, 791
   (Bankr. 
E.D.  Mich.  2009)   (granting  motion  to  dismiss  complaint  for 
substantive  consolidation  with  non-debtor  because  trustee  failed 
to  state  sufficient  facts  to  support  a  claim  that  was  plausible 
on  its  face). 
 The  effect  of  substantive  consolidation  is  to  merge  all 
assets  and  liabilities  of  individual  entities  into  a  single

survivor such that “claims of creditors against separate debtors          
morph [into] claims against the consolidated survivor.”  Owens            
Corning, 
419 F.3d at 205
 (quoting Genesis Health Ventures, Inc.           
v. Stapleton (In re Genesis Health Ventures, Inc.), 
402 F.3d 416, 423
 (3d Cir. 2005)).  “[B]ecause substantive consolidation is             
extreme (it may affect profoundly creditors’ rights and                   
recoveries) and imprecise, this ‘rough justice’ remedy should be          
rare[ly used].”  Owens Corning, 
419 F.3d at 211
.                          
          c.   Standard in the Third Circuit                         
Whether to order substantive consolidation requires a fact-          
intensive inquiry on a case-by-case basis.  The Third Circuit has         
articulated two alternative tests for granting substantive                
consolidation, only the first of which is at issue in this case:          
“(i) [whether] pre-petition, [the entities sought to be                   
consolidated] disregarded separateness so significantly [that]            
their creditors relied on the breakdown of entity borders and             
treated them as one legal entity.”  
Id. at 211
.                           
Under this test, the proponent of substantive consolidation          
must show both (1) “corporate disregard creating contractual              

expectations of creditors that they were dealing with [the                
entities to be consolidated] as one indistinguishable entity” and         
(2) “in their prepetition course of dealing, they actually and            
reasonably relied on [the] supposed unity [of these entities].”           
Id. at 212
 (emphasis added).                                              
                          10                                         
The test for reliance is both subjective (“actually relied”)         
and objective (“reasonably relied”).  In re Lisanti Foods, Inc.,          
C.A. No. 04–3868, 
2006 WL 2927619
, at *8 (D.N.J. Oct. 11, 2006);          
aff’d, 
241 F. App’x 1
 (3d Cir. 2007).                                     
Furthermore, those opposing consolidation can defeat a               
proponent’s prima facie case by presenting evidence that other            
creditors relied on the separate existence of the entities to be          
consolidated and would be adversely affected by substantive               
consolidation.  Owens Corning, 
419 F.3d at 212
.                           
B.   Application                                                     
     1.   Corporate Disregard                                        
Under the first element, the Plaintiffs must demonstrate             
that the Debtor and CAG ignored their corporate separateness.             
See, e.g., Owens Corning, 
419 F.3d at 212
; Lisanti, 
2006 WL 2927619
, at *8.                                                           
The Plaintiffs offer a list of activities by CAG and the             
Debtor that they argue demonstrate this disregard.  CAG responds          
that it was not involved in many of the listed activities and the         
others are typical activities of corporate families.  Therefore,          

CAG argues it should not be subject to substantive consolidation.         
          a.   Activities before CAG Incorporated                    
The Plaintiffs reference several activities and                      
interrelationships between the Debtor and its other affiliates            

                          11                                         
that occurred before CAG was incorporated in 2007.4  CAG argues           
these activities cannot possibly be evidence that CAG disregarded         
corporate separateness.  The Court agrees with CAG that                   
activities which occurred before its formation cannot be evidence         
of corporate disregard between CAG and the Debtor.                        
          b.   Activities Involving Affiliates Other than            
               CAG                                                   
The Plaintiffs contend that activity between the Debtor and          
other affiliates that occurred after CAG was incorporated is              
evidence of corporate disregard.  These activities include: (i) a         
lease between the Debtor and Keystone Properties (an entity               
controlled by a CAG minority shareholder) with excessive rent             
(Adv. D.I. 58, at Ex. 23B); (ii) a consignment agreement between          
the Debtor and another CAG affiliate in July 2012 (Adv. D.I. 58,          
at Ex. 24); (iii) redistribution to the Debtor of customer                
payments for fleet vehicles allegedly owed to other CAG                   
affiliates (Adv. D.I. 40, at Ex. 17 & Ex. A ¶ 8.3); (iv) a                
transfer by the Debtor of ten vehicles to another CAG affiliate           

4    These activities include: (i) the Debtor guaranteeing loans          
for Triple C in 2001 (Adv. D.I. 40, at Ex. 3), (ii) the Debtor            
obtaining floor plan financing from a lender controlled by                
Charles Lambert in 2002 and 2004 (D.I. 29; Adv. D.I. 40, at Exs.          
11 & 12), (iii) the Debtor providing back-office services                 
(payroll, insurance, HR and management) to other affiliates, pre-         
2007 (Adv. D.I. 40, at Ex. A), (iv) the alleged                           
undercapitalization of the Debtor in 2001 (Adv. D.I. 35, at ¶             
40), and (v) the Debtor causing customers to issue notes payable          
jointly to it and the other affiliates, for obligations due to            
the Debtor alone (Adv. D.I. 58, at Ex. 3).                                
                          12                                         
in February 2013 (Adv. D.I. 58, at Ex. 27D); and (v) the payment          
of late rent to Triple C immediately before the bankruptcy case           
was filed (Adv. D.I. 58, at p. 9; Adv. D.I. 35, at ¶ 120.).               
CAG argues that these transactions are not evidence of               
corporate disregard between CAG and the Debtor because CAG was            
not a party to any of them.                                               
The Court agrees that, because CAG was not a party to the            
alleged transactions, they are not evidence of corporate                  
disregard between the Debtor and CAG.  (Adv. D.I. 58, at Exs.             
23B, 24, & 27D; Adv. D.I. 40, at Ex. 17.)                                 
          c.   Intercompany Transfers in the Ordinary Course         
The Plaintiffs argue, however, that there were intercompany          
transfers and unaccounted payments made between CAG, the Debtor,          
and the other affiliates, within ninety days of the bankruptcy            
filing, which supports the conclusion that CAG “siphoned” money           
from the Debtor.  For example, the Plaintiffs assert that the             
Debtor could not account for checks issued by the Debtor within           
ninety days of the Petition Date, relying on email correspondence         
between CAG and the EPA during the initial discovery phase in             

2014.  (Adv. D.I. 58, at Ex. 28H.)  The Court does not find that          
an inability to respond to a question posed by the EPA during             
discovery is compelling evidence of disregard of corporate                
separateness.  Notwithstanding that email, the EPA ultimately             
settled its dispute with the Debtor.  (D.I. 158 & 164.)                   
                          13                                         
The Plaintiffs also rely on an internal spreadsheet that             
they contend shows that the Debtor made payments on intercompany          
transfers without properly accounting for them.  (Adv. D.I. 58,           
at Ex. 33.)  CAG responds that the internal spreadsheet, which            
lists outstanding payables for exchanges of parts and services            
among the affiliates, was an internal report maintained by CAG            
and actually demonstrates that CAG, the Debtor, and the other             
affiliates engaged in intercompany exchanges in the normal course         
of business that were reimbursed.  (Adv. D.I. 40, at Ex. A.)              
CAG presented further evidence that all transfers from the           
Debtor to CAG within ninety days of the Petition Date and since           
its incorporation were made in the ordinary course of business            
for value.  (Adv. D.I. 40, at Exs. 14, 19, 27, & Ex. A ¶¶ 6 & 11;         
Adv. D.I. 47, at Ex. 4 ¶¶ 12 & 22; Adv. D.I. 58, at Ex. 29.)              
Additionally, CAG presented evidence that the Debtor was able to          
remain operational despite losing money for six years because CAG         
(as parent), and related entities, Triple C (the Debtor’s                 
landlord), and FSFS (the Debtor’s floor plan financier), offered          
loans and concessions that an arms-length counterparty would not          

have offered.  (Adv. D.I. 58, at Exs. 23C & 25A-D.)                       
The Court concludes that, rather than show a disregard, the          
evidence presented demonstrates that corporate separateness was           
maintained.  The intercompany transfers were accounted for in the         
Debtor’s records and in board resolutions authorizing the Debtor          
                          14                                         
to issue promissory notes on some of the outstanding transfers.           
(Adv. D.I. 58, at Exs. 25C, 25D, 28D, & 33.)                              
The Court further concludes that the alleged transactions            
between the Debtor and the affiliates (other than CAG) are not            
evidence of a disregard of corporate entity separateness between          
CAG and the Debtor for several additional reasons.  First, CAG            
was not a party to many of the alleged intercompany transfers.            
(Adv. D.I. 58, at Exs. 23B, 24, 27D, & 33; Adv. D.I. 40, at Exs.          
17 & 27.)  Second, the Plaintiffs have not presented any credible         
evidence that any funds were improperly “siphoned” from the               
Debtor to CAG.  On the contrary, CAG presented evidence that all          
transfers made by the Debtor to CAG or its affiliates were                
payments made in the ordinary course of business for goods or             
services provided by them to the Debtor.  (Adv. D.I. 40, at Ex. A         
¶ 7.)  The failure of the Plaintiffs to present any rebuttal              
evidence in support of their allegations is fatal to their                
argument at the summary judgment stage.  Fed. R. Civ. P.                  
56(e)(3).  See, e.g., Ford v. Bureau of Prisons, 
570 F. App’x 246
, 250 n.1 (3d Cir. 2014) (affirming grant of summary judgment          

because plaintiff failed to rebut, through affidavits or other            
evidence, the moving party’s evidence).                                   
          d.   Activities Typical in Corporate Families              
CAG also contends that many of the examples that the                 
Plaintiffs cite are activities engaged in by many corporate               
                          15                                         
entities which do not support substantive consolidation.  The             
Plaintiffs argue, however, that many of these activities have             
been found in other cases to satisfy the first test for                   
substantive consolidation.  These include: (i) having the same            
directors, officers, and management at each entity in the family;         
(ii) consolidating accounting, tax filing, payroll, and training          
services; (iii) sharing employees between entities (and                   
permitting sales at any dealership to count toward the sales              
quota of any entity’s employee); (iv) carrying group liability            
insurance, which lists each entity as just a different “location”         
of the same company; and (v) operating under the same or similar          
tradenames, while advertising as “a family of dealerships.”5              
See, e.g., In re ADPT DFW Holdings, LLC, 
574 B.R. 87, 102-04
              
(Bankr. N.D. Tex. 2017); Lisanti, 
2006 WL 2927619
, at *1.                 
CAG does not dispute that these activities are extant in             
this case but argues that those facts, alone, are insufficient to         
establish corporate disregard of separateness.  CAG argues that           
it consolidated certain back-office services (accounting, human           
resources, and management) for convenience, efficiency, and lower         

costs.  It also contends that buying joint insurance for all              
entities allowed them to obtain substantial discounts.  CAG notes         
5    The Plaintiffs note that several dealer term sheets and              
customer financing applications list “CAG” in the header with the         
specific dealership also displayed in the center.  (Adv. D.I. 58,         
at Ex. 2.)                                                                
                          16                                         
that even before it was incorporated, the Debtor and the other            
affiliates shared many of these same services for the same                
reasons.  (Adv. D.I. 40, at Ex. A ¶ 6; Adv. D.I. 58, at Ex. 2.)           
CAG also presented evidence that all the back-office services             
were reimbursed by the other affiliates for whom the services             
were performed, on a pro rata basis.  (Adv. D.I. 40, at Ex. 14 &          
Ex. A ¶ 6.)  CAG argues, and the record reflects, that non-               
executive employees were moved among the affiliate dealerships            
but not between the Debtor and CAG.  (Adv. D.I. 58, at Ex 28D.)           
Finally, while the corporate family filed consolidated income tax         
returns, CAG presented evidence that each entity kept separate            
accounting records.  (Adv. D.I. 40, at Exs. 18-23 & Ex. A ¶ 6.2.)         
CAG further argues that many companies share officers and            
directors, consolidate services for cost-saving purposes, and             
refer to the affiliates as a family of companies, without                 
creating a basis for substantive consolidation.  See, e.g.,               
United States v. Bestfoods, 
524 U.S. 51, 69
 (1998) (acknowledging         
that the presence of common directors and officers typically does         
not, alone, warrant corporate veil piercing); Japan Petroleum Co.         

(Nigeria) Ltd. v. Ashland Oil, Inc., 
456 F. Supp. 831, 841
 (D.            
Del. 1978) (holding that parent was not liable for subsidiary’s           
contract breach despite the presence of common directors and              
officers, an umbrella insurance policy, representations that              
subsidiary is a division of parent, and shared intercompany               
                          17                                         
services for administrative convenience, such as consolidated             
payroll).                                                                 
The Court agrees with CAG that the factors cited by the              
Plaintiff are insufficient evidence that corporate separateness           
was disregarded in this case.  See, e.g., R2 Investments, LDC v.          
World Access, Inc. (In re World Access, Inc.), 
301 B.R. 217, 276
          
(Bankr. N.D. Ill. 2003) (denying substantive consolidation                
despite (i) inter-company transfers and claims, (ii)                      
incorporation of the subsidiary by the parent, (iii) consolidated         
financial statements, administrative functions, and insurance,            
and (iv) common ownership, management, directors and officers,            
because these facts are typical of most affiliated corporations           
and do not demonstrate that vendors dealt with the entities as a          
single unit); Lease-A-Fleet, 
141 B.R. at 876, 878
 (denying                
substantive consolidation despite overlapping directors, shared           
office space, intercompany loans without documentation, and the           
disregard of formalities when sharing services).                          
The corporate disregard inquiry is fact-intensive, and no            
one factor weighs greater than another.  In fact, the Third               

Circuit rejected the use of so-called alter-ego checklists as             
they “fail to separate the unimportant from the important. . . .”         
Owens Corning, 
419 F.3d at 210
.                                           
In this case, the Court concludes that the facts do not              
support a finding of corporate disregard.  While entities in the          
                          18                                         
corporate  family  had  similar  trade  names,  the  proper  corporate 
names  were  used  on  corporate  documents,  including  customer 
financing  applications.    (Adv.  D.I.  58,  Ex.  2.)    While  the 
entities  had  overlapping  officers  and  directors,  CAG  presented 
evidence  that  the  Debtor  and  CAG  observed  corporate  formalities 
by  holding  separate  board  meetings,  issuing  separate  board  and 
shareholder  resolutions,  documenting  inter-company  loans,  and 
maintaining  separate  bank  accounts  and  books  and  records.    (Adv. 
D.I.  58,  at  Exs.  25A-D;  Adv.  D.I.  50,  at  Ex.  21;  Adv.  D.I.  47,  at 
Ex.  4;  Adv.  D.I.  40,  at  Ex.  A  &  Exs.  18-23.)    Thus,  the  Court 
concludes  that  the  evidence  presented  by  the  Plaintiffs  is 
insufficient  to  establish  corporate  disregard.   See  Japan 
Petroleum,  
456 F. Supp. at 841
;  World  Access,  
301 B.R. at 276
; 
Lease-A-Fleet,  
141 B.R. at 876, 878
.   Cf.  ADPT,  
574 B.R. at 102
 
(granting  substantive  consolidation  where  entities  failed  to 
maintain  separate  bank  accounts). 
 Similarly,  while  the  entities  in  this  case  shared  services 
and  other  resources,  that  too  does  not  justify  substantive 
consolidation  because  it  is  very  common  and  done  for  legitimate 
business  reasons,  such  as  cost-cutting  and  efficiency.    Further, 
CAG  presented  evidence  that  any  services  it  or  the  Debtor 
provided  were  reimbursed  by  the  corresponding  affiliate.    (Adv. 
D.I.  40,  at  Ex.  AW  6.1.)   See  Japan  Petroleum,  
456 F. Supp. at 844
.   Compare  In  re  Opus  East  LLC,  
528 B.R. 30, 49, 64
   (Bankr.  D. 

                                 
19 Del. 2015
) (finding evidence of shared services that were                 
reimbursed — corporate accounting, human resources, legal risk            
management, payroll, office services, and tax services — did not          
warrant corporate veil piercing) with Lisanti, 
2006 WL 2927619
,           
at *7 (granting substantive consolidation where shared services           
were not reimbursed).                                                     
In summary, the Court concludes that the facts on which the          
Plaintiffs rely to establish that CAG and the Debtor ignored              
corporate separateness are either unproven or are insufficient to         
establish a basis for substantive consolidation.                          
     2.   Reliance                                                   
Even if the Plaintiffs had established that CAG and the              
Debtor ignored corporate separateness, the Plaintiffs must still          
demonstrate that their reliance on that disregard was actual and          
reasonable.  The Plaintiffs argue that they reasonably relied on          
the corporate “sameness” or unity of the Debtor and CAG when              
deciding where to purchase a vehicle or seek employment.  (Adv.           
D.I. 58, at Exs. 2-6.)                                                    
          a.   Before CAG was Incorporated                           

CAG responds that eight of the eleven Plaintiffs could not           
have relied on the corporate “sameness” of the Debtor and CAG             
when deciding where to purchase a vehicle or seek employment              
because CAG was not incorporated until January 2, 2007, after             
those eight Plaintiffs had already commenced their relationship           
                          20                                         
with the Debtor.6  (Adv. D.I. 40, at Ex. A & Ex. 13.)                     
The Plaintiffs respond that if the entity engaging in the            
disregard of corporate boundaries, pre-2007, was not CAG, then it         
was a “CAG Affiliate,” because the Initial Shareholders were the          
owners and board members for each of the seven entities as well           
as CAG, after it was incorporated in 2007.                                
The Court rejects the Plaintiffs’ argument.  An essential            
element of the test for substantive consolidation is the                  
creditor’s actual reliance on the supposed unity of the Debtor            
and the entity to be consolidated.  Owens Corning, 
419 F.3d at 212
.  Because CAG did not exist at the time their relationship            
with the Debtor commenced, these eight Plaintiffs have not                
established that they relied on the corporate unity of the Debtor         
and CAG.  See, e.g., Am. Camshaft, 
410 B.R. at 789
 (dismissing            
complaint for substantive consolidation where there were no               
allegations of creditor reliance on corporate disregard).                 
Consequently, the Court will grant summary judgment in favor of           
CAG on these eight Plaintiffs’ claims for substantive                     
consolidation.                                                            

6    Those eight Plaintiffs are: (i) Derek Cambridge (became an           
employee in 2005); (ii) Annelle Knight (became a customer in May          
2006); (iii) Bernard Hamilton (became an employee in 2004); (iv)          
Michael Felix (became an employee in 2004); (v) Pauline Peter             
(became a customer in 2005); (vi) Janet Rivera (a non-customer            
involved in an accident with a customer of the Debtor in 2005);           
(vii) Fitzroy Williams (became a customer in 2005); (viii) Rams           
Auto Repair (entered a lease agreement with Debtor in 2005).              
                          21                                         
          b.   Post-Petition Corporate Conduct                       
CAG further argues that the three remaining Plaintiffs, who          
commenced their relationship with the Debtor after CAG was                
incorporated, rely on evidence of post-petition activities7 to            
support their claim for substantive consolidation.  CAG contends          
that post-petition activities are irrelevant to determining               
whether the Plaintiffs relied on the alleged disregard of                 
corporate entity separateness between CAG and the Debtor pre-             
petition when the Plaintiffs’ relationship with the Debtor                
commenced.  The Plaintiffs respond that the post-petition                 
activities are evidence of the effect of CAG’s pre-petition               
control over the Debtor and the disregard of entity separateness.         
The Court agrees with CAG that post-petition activities are          
not relevant to the reliance factor required by Owens Corning.            
419 F.3d at 212
.  Rather, what is relevant are the activities of          
the Debtor and CAG on which the Plaintiffs actually relied at the         
time they entered into their relationship with the Debtor, which          
occurred pre-petition.  
Id.
  See also Mary Elisabeth Kors, Alter          
Egos: Deciphering Substantive Consolidation, 
59 U. Pitt. L. Rev. 7
    These post-petition activities include: (i) one of the               
Debtor’s landlords, Keystone Properties (owned by a minority              
shareholder of CAG), relet the Debtor’s automotive body shop to           
CAG at a substantially reduced rate ($500 per annum versus                
$12,000 per month charged to the Debtor); (ii) communications             
among CAG executives regarding what debts to include on the               
Debtor’s bankruptcy schedules; and (iii) the invoicing of the             
Debtor’s bankruptcy legal costs to CAG. (Adv. D.I. 58, at Exs.            
23D, 20, & 27B-C.)                                                        
                          22                                         
381, 430 (1998) (arguing that factors on which creditors have not         
relied are irrelevant to determination of substantive                     
consolidation).  Therefore, the Court’s inquiry focuses on those          
pre-petition activities on which the three remaining Plaintiffs           
actually relied.                                                          
          c.   Actual Reliance by Remaining Plaintiffs               
The three remaining Plaintiffs — Monique Xavier, Asheem              
Charles, and Leon Richardson — became customers of the Debtor             
after CAG was incorporated in 2007.  While they all filed                 
complaints, no one has a judgment.                                        
Xavier and Charles allege that the Debtor sold them the              
wrong vehicle and recorded the wrong VIN number on their sale             
agreement and insurance paperwork, which forced them to accept a          
lesser model when the error was discovered.  (Adv. D.I. 58, at            
Ex. 17.)  Their claim is for fraud, misrepresentation, and breach         
of contract.  (Id.)  Richardson alleges that the Debtor sold him          
a previously owned defective vehicle, while representing that it          
was new, and that the Debtor failed to honor his warranty.  (Adv.         
D.I. 58, at Ex. 13.)                                                      

Only Monique Xavier submitted an affidavit to support her            
contention that she relied on the unity of the Debtor and CAG.            
It states, in part:                                                       
     I made the decision to purchase a vehicle from                  
Caribbean Auto Group and its family of dealerships                   
based on the relationships they indicated they had with              
                          23                                         
Scotia Bank [one of the Debtor’s lenders] and Marshall               
and Sterling [the Debtor’s insurance provider] and the               
fact that by going to Caribbean Auto Group’s sale I                  
could choose from a variety of car manufacturers.                    
     The representations as to the relationship with                 
Scotia Bank and Marshall and Sterling were not specific              
only as to [the Debtor].  It was clear that Caribbean                
Auto Group made the representation as to applying to                 
its family of dealerships. . . .                                     
(Adv. D.I. 58, at Ex. 4.)                                                 
Xavier further stated in her response to CAG’s                       
interrogatories, attached to her affidavit, that:                         
     I understood Caribbean Auto Mart, St. Croix Dodge               
Jeep and Chrysler, and Caribbean Auto Group to be one                
company.  I dealt with the same employees at Caribbean               
Auto Mart and St. Croix Doge [sic] Jeep and Chrysler                 
there was no difference between the companies.  I                    
understood Caribbean Auto Group to be the same.  All of              
the named groups were located at the same place.  They               
were all just divisions of one company.  And therefore,              
they were all privy to the same information and                      
directives.                                                          
(Id.)                                                                     
CAG argues that the affidavit and interrogatory response are         
inadmissible evidence that Monique Xavier actually relied on the          
unity of CAG and the Debtor.  CAG argues that the statements are          
conclusory, not based on fact or personal knowledge.  Instead,            
CAG contends that the statements are mere speculation and                 
personal opinion that Xavier would have declined to purchase a            
vehicle from the Debtor had she known the Debtor was not the same         
entity as CAG.  Fed. R. Civ. P. 56(c)(4) & 12(f).  See, e.g.,             
Automatic Radio Mfg. Co. v. Hazeltine Rsch., Inc., 
339 U.S. 827
,          
                          24                                         
831 (1950) (finding that the allegation of patent misuse in the           
affidavit was based solely on information and belief and                  
therefore did not comply with the requirements of Fed. R. Civ. P.         
56).  Therefore, CAG argues that the Court must disregard or              
strike the affidavit.                                                     
The Court disagrees with CAG.  This case is distinguishable          
from Automatic Radio, because in that case reasonable reliance on         
corporate disregard was not one of the elements of patent misuse.         
339 U.S. at 830-31.  In contrast, it is an element necessary for          
substantive consolidation.  Owens Corning, 
419 F.3d at 212
;               
Lisanti, 
2006 WL 2927619
, at *8.  Xavier’s affidavit is relevant          
to the issue of whether she actually relied on a belief that CAG          
and the Debtor were unified at the time she purchased the                 
vehicle.  That belief was based on interactions with employees of         
the Debtor and, as a customer of the Debtor, she certainly had            
personal knowledge of corporate advertisements, which are facts           
supported by the record.  (Adv. D.I. 58, at Exs. 2, 4, & 17 ¶ 8.)         
CAG further contends that Xavier does not articulate any             
harm she suffered as a result of any reliance on her perception           

of corporate unity between the Debtor and CAG.  CAG argues that           
her alleged reliance on corporate unity in becoming a customer            
did not relate in any way to the ultimate harm she suffered               
(being required to accept a different vehicle because the Debtor          
mishandled the paperwork on the one she bought).                          
                          25                                         
The Court disagrees with CAG’s argument.  Actual reliance            
for substantive consolidation purposes merely requires a                  
demonstration that the Plaintiff relied on the unity of the               
Debtor and CAG in becoming a creditor.  The creditor is not               
required to establish that she was specifically harmed by a               
misuse of the corporate form to warrant the remedy of substantive         
consolidation.  See, e.g., In re Tureaud, 
59 B.R. 973, 976
 (N.D.          
Okla. 1986) (affirming grant of substantive consolidation over            
creditor’s argument that a finding of fraudulent formation is             
necessary for substantive consolidation); Munford, Inc. v. TOC            
Retail, Inc., (In re Munford, Inc.), 
115 B.R. 390
 (Bankr. N.D.            
Ga. 1990) (denying motion to dismiss because substantive                  
consolidation does not require an allegation that the entity to           
be consolidated with the debtor was formed with intent to hinder,         
delay or defraud creditors).                                              
Therefore, the Court concludes that Xavier’s affidavit               
supports her assertion that she actually relied on the unity of           
the Debtor and CAG at the time she entered into a relationship            
with the Debtor.                                                          

          d.   Reasonable Reliance                                   
CAG argues, however, that even if Xavier could demonstrate           
actual reliance, it was not reasonable.  CAG presented evidence           
that several of the Debtor’s financial and trade creditors relied         
on the Debtor’s separate existence when extending credit or doing         
                          26                                         
business with it.8                                                        
The Plaintiffs respond that substantive consolidation will           
not prejudice any specific creditor, but, on the contrary, will           
benefit all creditors of the Debtor by curing any hardships CAG           
created in siphoning the Debtor’s profits and assets and leaving          
it a shell company.                                                       
The Court rejects the Plaintiffs’ argument.  Substantive             
consolidation is not appropriate where only one creditor relied           
on a belief that the corporations were unified, if several other          
creditors relied on the fact that the entities were separate.             
Other creditors’ reliance on separateness demonstrates that the           
lone proponent’s reliance on corporate sameness is unreasonable.          
Compare In re Macrophage, Inc., No. CIV.06 3793 JBS, 
2007 WL 708926
, at *6 (D.N.J. Mar. 2, 2007) (affirming denial of                  
substantive consolidation where only one creditor considered the          
entities as one) with In re S B Bldg. Assocs. Ltd. P’ship, 
621 B.R. 330
, 371 (Bankr. D.N.J. 2020) (granting substantive                  
consolidation where virtually all parties treated the entities as         
unified).                                                                 

8    For example, Falcon Financial, LLC, extended credit to               
Triple C and required that the Debtor guarantee that loan.  (D.I.         
58, at Ex. 22A.)  General Motors had a separate franchise                 
dealership agreement with the Debtor, which precluded other               
affiliates from selling GM vehicles.  (Adv. D.I. 40, at Ex. A ¶           
2.9.)  One of the Debtor’s trade vendors, Snap-On, bargained for          
a default guaranty from CAG on trade payables incurred by the             
Debtor.  (Adv. D.I. 47, at Ex. 4.)                                        
                          27                                         
In this case, CAG presented evidence that several other              
entities treated the Debtor and CAG as separate entities, whereas         
the Plaintiffs presented evidence that only one creditor, Xavier,         
relied on a belief they were the same.  While the Plaintiffs              
argue that Richardson and Charles relied on separateness, no              
evidence of that was presented by affidavit or otherwise.  Fed.           
R. Civ. P. 56(e)(3).  See, e.g., Ford v. Bureau of Prisons, 
570 F. App’x at 250
 (affirming grant of summary judgment because              
plaintiff failed to rebut the moving party’s assertion of fact            
through affidavits or other evidence).9  The Court, therefore,            
concludes that Xavier’s reliance was not reasonable.                      
          e.   Harm to other Creditors                               
CAG also argues that it has presented evidence to support an         
affirmative defense to substantive consolidation, namely, that            
other creditors of the Debtor will be harmed by substantive               
consolidation.  CAG argues that if the Court substantively                
consolidates CAG with the Debtor, then creditors of the Debtor,           
like Snap-On, which obtained a guarantee of the Debtor’s                  
obligation from CAG, would have to share any distribution of              

CAG’s assets with other creditors of the Debtor who did not               
9    The Court also finds it significant that the Trustee did not         
move for substantive consolidation at any point during this               
bankruptcy case, which is further evidence that Xavier was alone          
in her reliance on corporate disregard.  As noted, the EPA                
initially argued that substantive consolidation might be                  
warranted, but settled its claims after conducting discovery.             
                          28                                         
bargain for such a guaranty.  (Adv. D.I. 47, at Ex. 4.)                   
The Court agrees that CAG has presented sufficient evidence          
to support an affirmative defense to any substantive                      
consolidation of the Debtor with CAG.  Owens Corning, 
419 F.3d at 212-13
 (refusing to substantively consolidate in light of an              
unsecured creditor’s bargained-for loan guaranty, a credit                
enhancement that other creditors did not have).  See also                 
Augie/Restivo, 860 F.2d at 519 (denying substantive consolidation         
where creditor who had relied on separateness would be harmed).           
Finally, the Court finds that the two cases cited by the             
Plaintiffs in favor of substantive consolidation are                      
distinguishable.  ADPT, 
574 B.R. at 102-04
; Lisanti, 
2006 WL 2927619
, at *8.  In both cases, the courts found a disregard of           
corporate entity separateness.  Additionally, both cases dealt            
with substantive consolidation of multiple debtor entities rather         
than the consolidation of a debtor with a non-debtor.  As noted           
above, substantive consolidation of a debtor with a non-debtor            
should be used sparingly and has a higher burden of proof than            
debtor-to-debtor consolidation.  Am. Camshaft, 
410 B.R. at 786
;           

Lease-A-Fleet, 
141 B.R. at 872-74
.  The Court finds that the              
Plaintiffs have not met that high burden in this case.                    



                          29                                         
IV.   CONCLUSION 
 The  Court  concludes  that  the  Plaintiffs  have  failed  to  prove 
(i)  that  the  Debtor  and  CAG  disregarded  corporate  separateness, 
and  (ii)  that  the  Plaintiffs  actually  and  reasonably  relied  on 
the  unity  of  CAG  and  the  Debtor.    Further,  the  Court  finds  that 
CAG  has  proven  its  affirmative  defense  that  other  creditors,  who 
relied  on  the  corporate  separateness  of  the  Debtor  and  CAG,  will 
be  harmed  by  substantive  consolidation.    For  these  reasons,  the 
Court  will  grant  summary  judgment  in  favor  of  CAG. 
 An  appropriate  Order  follows. 

Dated:  June  11,  2021             BY  THE  COURT: 

                               United  States  Bankruptcy  Judge 

                                 30