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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

In Pari Delicto … What Does That Mean?

In Seitz v. Marcum LLP, 2024 N.Y. Slip Op. 51141(U) (Sup. Ct., N.Y. County Aug. 30, 2024) (here), Justice Robert R. Reed of the New York County Commercial Division addressed the doctrine of in pari delicto, which “bars a...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

Intent is Important in Determining Third-Party Beneficiary Status

“A third-party beneficiary … is a person or entity that receives benefits from a contract between two other parties, even though they are not a party to the contract.” The concept of a third-party beneficiary stems from the...more

The Relation-Back Doctrine Under CPLR 203(c) and (f)

It is well-settled that leave to amend a pleading is to be freely granted. Leave may be denied, however, if the proposed amendment is palpably insufficient or patently devoid of merit, or if it would cause undue prejudice to...more

Enforcement News: SEC Charges Bank With Misleading Investors About The Strength Of Its BSA/AML Compliance Program And Its...

The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions. The BSA is designed to, among...more

Agreement to Arbitrate All Disputes Arising From The Agreement Includes Malpractice Claims

Arbitration is an alternative form of dispute resolution where the parties voluntarily agree that a neutral person will resolve any legal disputes between them, instead of a judge or jury in a court of law. It is encouraged...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

Breach of Contract Claim Sustained Where Plaintiff Offered a Facially Reasonable Reading of The Contract

The foundation of virtually every business and commercial transaction is a contract. It is difficult to imagine a transaction for the purchase or sale of goods, the merger or acquisition of a business, or the provision of...more

Enforcement News: SEC Files Complaint in Connection with a $300 Million Ponzi Scheme and Affinity Fraud

By: Jeffrey M. Haber On many occasions, we have written about Ponzi schemes that have been the subject of enforcement actions brought by, and/or settlements with, the Securities and Exchange Commission (“SEC” or the...more

The Assignment Of Litigation Rights And Champerty

It is not often that we examine a case involving the doctrine of champerty. The last time we did so was on March 8, 2023 (here). We also examined the champerty doctrine in 2021 (here), 2020 (here), and 2016 (here)....more

First Department Reminds Practitioners that “proofreading is an essential, indispensable tool in the drafting of contracts”

It should go without saying that people make mistakes. After all, people are human, and humans make mistakes. When people draft a document, especially a lengthy or complex one, it is not uncommon for a mistake to be...more

Fraud Claim Held Not Duplicative of a Single Page Contract

A common theme in commercial litigation is the assertion of a breach of contract claim and a fraudulent inducement claim. A plaintiff claiming a breach of contract must show (1) the existence of a contract; (2) the...more

Settlement Agreement Found To Be an Instrument for The Payment of Money Only Sufficient to Grant Summary Judgment In Lieu of...

In past articles, we have examined a motion under CPLR § 3213... CPLR § 3213 is a procedural mechanism that allows a party to make a motion for summary judgment before filing a complaint in actions based upon “an instrument...more

Failure to Plead Fraud with Particularity, A “Single Shot Transaction” and the Lemon Law

In today’s article, we examine Eva Chen Fine Jewelry, Inc. v. Recovery Racing IX, LLC, 2023 N.Y. Slip Op. 06511 (2d Dept. Dec. 20, 2023) (here), a case involving common law fraud, New York’s lemon law and Section 349 of New...more

Pleading With Particularity: Defamation Causes of Action

As readers of this Blog know, we often write about the pleading requirements under the Civil Practice Law and Rules (“CPLR”). In that regard, many of our articles involve cases in which CPLR 3016(b) is at issue – the...more

Pleading Reasonable Reliance Is “Always Nettlesome”

By: Jeffrey M. Haber In TD Bank, N.A. v. Keenan, 2023 N.Y. Slip Op. 06158 (2d Dept. Nov. 29, 2023) (here), the Appellate Division, Second Department examined the often “nettlesome” question of whether a plaintiff claiming...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

Third-Party Beneficiaries and Contract Interpretation

In Stagen v. Neu, 2023 N.Y. Slip Op. 06105 (1st Dept. Nov. 28, 2023), the Appellate Division, First Department addressed an issue of contract interpretation involving a word in a settlement agreement that most readers would...more

Group Pleading, Failure to Plead Fraud with Particularity and Duplication: A Dismissal Trifecta

As we have often explained in the articles in which we have examined fraud claims, to withstand a motion to dismiss, the plaintiff must plead fraud with particularity as required under CPLR § 3106(b), cannot lump all the...more

Enforcement News: SEC Brings Enforcement Action in Connection EB-5 Immigrant Investor Program

In July of this year, we wrote about a fraud action involving the EB-5 Immigrant Investor Program (“EB-5 Program” or “Program”) (here). Under the EB-5 Program, investors are eligible for permanent residency status in the U.S....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

Enforcement News: SEC Obtains Emergency Relief To Halt An Affinity Fraud That Raised Nearly $130 Million

Affinity fraud is a type of investment fraud. In this form of fraud, the person committing the fraud preys upon members of an identifiable group, such as a religious or ethnic community, the elderly, or a professional group....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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