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The Absence of a Single Statute of Limitations for Breach of Fiduciary Duty Claims

In New York, litigants often grapple with the appropriate limitation period to apply to breach of fiduciary claims. There is no single statute of limitations that the courts and the parties can look to. “Rather, the choice of...more

Thorny Issues Concerning the Statute of Limitations for Declaratory Relief and Breach of Fiduciary Duty

Statutes of limitations limit the time within which a defendant can be held liable for any type of alleged wrongdoing. Plaintiffs who do not pursue their rights within the limitations period will find the courthouse doors...more

Collateral Estoppel Held Not To Bar Later-Filed Malpractice Action

In Villaver v. Paglinawan, 2024 N.Y. Slip Op. 04159 (2d Dept. Aug. 7, 2024) (here), the Appellate Division, Second Department reversed the dismissal of a legal malpractice, breach of fiduciary duty, and intentional infliction...more

Fraud Notes: Two Cases and The Examination of Scienter

To state a cause of action for fraud, a plaintiff must allege “a material misrepresentation of a fact, knowledge of its falsity, an intent to induce reliance, justifiable reliance by the plaintiff and damages.” The...more

Enforcement News: Misappropriation of Client Funds and Stock Manipulation

It should come as no surprise that one of the goals of an investment fraud is the theft of customer funds for the scammer’s personal benefit. In legal parlance, this aspect of a fraudulent investment scheme is called...more

Fraudulent Inducement, Merger Clauses and Duplication

A couple of months ago, we examined NW Media Holdings Corp. v. IBT Media Inc., 2023 N.Y. Slip Op. 30875(U) (Sup. Ct., N.Y. County Mar. 22, 2023) (here), a case in which a lower court addressed the question whether the...more

Amended Complaints, New Defendants and the Relation-Back Doctrine

“A” brings an action against “B”. The causes of action asserted against “B” are all timely for statute of limitations purposes. Following discovery, “A” learns that “C” played a material role in the facts and...more

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