Patterson Belknap Webb & Tyler obtained a judgment in 2013 against non-party for over $2 million arising out of past legal services and served her with a restraining notice in 2013. That restraining notice prohibited non-party from selling or transferring any property until the judgment was satisfied.

Movants helped non-party sell a diamond ring and distribute the proceeds, despite that she purportedly knew about the restraining notice. Plaintiff had not received a single payment and the judgment then exceeded $3 million.