Bhatnagar v. Jones Lang LaSalle Americas, Inc. (D.C. Apartment Tower NOI Fraud Suit)
Developer Rishi Bhatnagar and property owner 9 New York Ave LLC sued Jones Lang LaSalle Americas, Inc. in the Circuit Court of Cook County on August 21, alleging JLL fraudulently inflated its stabilized net operating income projection for a 14-story apartment tower at 9 New York Avenue NW in Washington, D.C. specifically to help the deal clear a construction lender's minimum debt-yield covenant. The complaint alleges JLL's $2,036,354 NOI figure implied a $50,997,681 valuation, but the property sold in April 2026 for only about $30.5 million, close to the developer's own original 2020 estimate, and seeks more than $12 million in damages. JLL points to a separate letter agreement it says limits any claims to a brokerage-fee dispute, which the plaintiffs contest.
Why it matters
Tests whether a brokerage's borrower-side income projections, prepared to help a deal clear a lender's underwriting threshold, can expose the firm to fraud liability beyond an ordinary negligent-underwriting claim. Because construction and bridge lenders routinely rely on the sponsor's own broker to generate the NOI figures used to size a loan, the dispute is a cautionary marker for developers, lenders, and brokerages about projections that conveniently clear a covenant threshold and then substantially miss in practice.
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