Based on alleged misrepresentations, plaintiff Francesco Zanghi and his company Zanghi LLC made investments in pizzerias in Italy and the United States between June and November 2018. On Jan. 30, 2024, the court learned of a familial relationship between Zanghi and his counsel Andrea Natale.

Zanghi’s deposition testimony and emails from Natale in 2018 and 2019 raised concerns over Natale’s direct involvement in contested issues in the instant case. To ensure that Natale’s participation did not violate New York State Rule of Professional Conduct 3.7(a), the “attorney-witness rule,” U.S. District Judge Naomi Reince Buchwald of the Southern District of New York ordered Natale to show cause why he should not be disqualified.