Cummo v Kerzner 2025 NY Slip Op 31632(U) May 5, 2025 Supreme Court, New York County Docket Number: Index No. 650773/2024 Judge: David B. Cohen Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 650773/2024 NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 05/05/2025
SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. DAVID B. COHEN PART 58 Justice ---------------------------------------------------------------------------------X INDEX NO. 650773/2024 VANESSA CUMMO, KESH HAIRCARE HOLDINGS LLC MOTION DATE 05/22/2024 Plaintiffs, MOTION SEQ. NO. 002 -v- JUSTIN KERZNER, THE HOLDING COMPANY OF SPORTING CONTACT, INC. (D/B/A SPORTING DECISION + ORDER ON CONTACT), MOTION Defendants. ---------------------------------------------------------------------------------X
The following e-filed documents, listed by NYSCEF document number (Motion 002) 31, 32, 34, 35 were read on this motion to/for DISMISS .
Defendants Justin Kerzner and The Holding Company of Sporting Contact Inc. d/b/a
Sporting Contact (Sporting Contact) (together, defendants), move, pursuant to CPLR 3211(a)(1)
and (7), to dismiss the amended complaint filed by plaintiffs Vanessa Cummo and Kesh Haircare
Holdings LLC (KHH) (together, plaintiffs), and, pursuant to CPLR 325(d), to transfer this action
to Civil Court. Plaintiffs oppose the motion in all respects.
I. PROCEDURAL BACKGROUND AND FACTS
Plaintiffs commenced this action against defendants for defendants’ failure to pay
plaintiffs earned wages in the amount of $55,000, in violation of New York Labor Law §190, et
seq., or alternatively, for defendants’ breach of contract, and quasi-contract (NYSCEF 28).
The Contractor Agreement (NYSCEF 28)
On February 1, 2023, KHH entered into a contractor agreement with Sporting Contact
(Contract), which identified Kerzner as Sporting Contact’s Chief Executive Officer (CEO), KHH
as the Chief Operating Officer (COO), and Cummo as KHH’s “managing-member,” who would
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perform the contractual obligations on behalf of KHH. Each party was an “independent
contractor, and not a partner, joint venture, or agent of the other.” KHH’s responsibilities
included maintaining Sporting Contact’s end-to-end supply chain, retail operations, customer
service relations, inventory management, labor management, and scheduling, hiring, and creating
training programs for new hires. KHH was also responsible for teaming with Sporting Contact’s
finance partner to create budgets and forecasts, and for taking general ownership and
accountability of the product and its financial margins, among other tasks.
KHH charged a flat monthly fee of $18,500, from which Sporting Contact would not
withhold any taxes. Either party could terminate the Contract at any point upon thirty days'
notice. In the event of KHH’s termination without cause, Sporting Contact would pay “all
unpaid and undisputed amounts for services completed prior to termination,” including a
termination severance payment, the amount of which varied based on the duration of KHH’s
service with Sporting Contact. As part of additional compensation, KHH had the right to
purchase up to 1.75% of Sporting Contact’s common stock.
Amended Verified Complaint (NYSCEF 26)
Plaintiffs assert that, despite the Contract designating Cummo as COO and independent
contractor, in practice, she was defendants’ employee and is thus entitled to lost wages under
New York law. Her classification as an employee was shown by defendants’ significant control
over her work, including setting her schedule, controlling her job duties, and providing her with
work equipment. In addition, she was assigned and used an official company email and worked
primarily from Sporting Contact’s office or retail store.
Plaintiffs further argue that Cummo did not qualify for any exemptions under New York
labor law because her role did not involve executive, administrative, or professional duties. Her
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primary job duties turned out to be routine, mechanical, or physical work and involved operating
Sporting Contact’s retail store, which did not require specialized skills or education.
Furthermore, unlike an executive, she did not have the authority to hire, fire, or make strategic
business decisions.
Despite fulfilling all contractual obligations, on November 2, 2023, Cummo was
terminated from her position with Sporting Contact without cause. Plaintiffs pleaded that
Cummo “performed all aspects of her contract with defendants and did not breach the contract in
any respect.” Plaintiffs allege that defendants failed to pay Cummo $55,500 and that they made
demands for payments, but defendants refused.
Other Pertinent Facts
On June 21, 2023, Sporting Contact and KHH entered into a restricted stock purchase
agreement, under which KHH acquired the right to 17,500 shares of Sporting Contact common
stock, subject to vesting and other requirements (NYSCEF 8).
As of March 7, 2024, KHH had no certificate of authority on file with the Secretary of
State of the State of New York to do business in New York as a foreign Limited Liability
Company (NYSCEF 5). On April 19, 2024, KHH filed for a certificate of authority, which was
approved on April 22, 2024 (NYSCEF 27).
In support of their motion, defendants submitted unaffirmed snapshots of Slack messages
between “Justin Kerzner,” “Vanessa,” and others, discussing Vanessa’s vacation plans, her
dental procedures, and whether she worked remotely or from Sporting Contact’s headquarters
(NYSCEF 10-2, 14). Defendants also submitted snapshots of emails showing general
discussions between Cummo and Kerzner regarding business goals, as well as spreadsheets
showing unidentified charts and data (NYSCEF 10-18).
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II. DISCUSSION
KHH Standing
Defendants allege that because KHH is a foreign LLC and was conducting business in
New York without a certificate of authority, pursuant to LLC Law § 808(a), it lacks standing to
maintain this action.
Plaintiffs oppose, asserting that KHH’s failure to obtain a certificate of authority before
initiating this action is not fatal and that the issue is moot because it has since registered as a
foreign corporation.
Defendants argue that, although KHH obtained a certificate of authority, it has neither
pleaded nor indicated it will comply with its remaining filing obligations under New York law.
Paragraph (a) of New York Limited Liability Company Law § 808 provides that a foreign
limited liability company without a certificate of authority “may not maintain any action, suit or
special proceeding in any court of this state unless and until such limited liability company shall
have received a certificate of authority in this state.” However, a LLC’s “failure to obtain a
certificate of authority to do business in New York before initiating the action is not a fatal
jurisdictional defect” (Basile v Mulholland, 73 AD3d 597 [1st Dept 2010]; see RMS Residential
Properties, LLC v Naaze, 28 Misc 3d 843 [Dist Ct, Nassau County 2010] [staying legal
proceedings until foreign LLC received certificate of authority from secretary of state]).
Although plaintiffs did not have a certificate of authority on file at the time of
commencing this action, such a defect is not fatal because they have since obtained a certificate
pursuant to LLC Law § 802(a). Defendants’ allegation that plaintiffs may fail to comply with
New York LLC law in the future is premature and speculative. Accordingly, plaintiffs have
standing, and defendants’ motion to dismiss, as it relates to LLC Law § 808(a), is denied.
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CPLR 3211 Standard
CPLR 3211(a)(1) states that “[a] party may move for judgment dismissing one or more
causes of action asserted against him on the grounds that … a defense is founded upon
documentary evidence[.]” Dismissal pursuant to CPLR 3211(a)(1) is warranted only if the
documentary evidence submitted “utterly refutes plaintiff's factual allegations” (Kolchins v
Evolution Markets, Inc., 128 AD3d 47 [1st Dept 2015]), and if, giving the plaintiff the benefit of
every possible inference, the documentary evidence conclusively establishes a defense to the
asserted claims as a matter of law (Weil, Gotshal & Manges, LLP v Fashion Boutique of Short
Hills, Inc., 10 AD3d 267 [1st Dept 2004]).
To dismiss a complaint under CPLR 3211(a)(7), the pleading must be given a liberal
construction. The court is required to “accept the facts as alleged in the complaint as true, accord
plaintiffs the benefit of every possible favorable inference, and determine only whether the facts
as alleged fit within any cognizable legal theory” (Leon v Martinez, 84 NY2d 83 [1994]; Weil,
Gotshal & Manges, LLP, 10 AD3d at 271; see 511 W. 232nd Owners Corp. v Jennifer Realty
Co., 98 NY2d 144 [2002]).
Documentary Evidence
Defendants contend that the submitted emails and messages exchanged between Cummo
and Kerzner qualify as documentary evidence, and that they demonstrate Cummo’s exempt
status from protection under the NYLL, requiring dismissal of her claims for benefits and wage
supplements.
Plaintiffs oppose, arguing that the submitted emails and messages do not qualify as
documentary evidence as a matter of law. They further contend that whether Cummo worked as
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an employee or independent contractor is a fact inquiry not properly considered at this stage of
the action.
Defendants reply, arguing that in a pre-answer motion to dismiss, emails and messages of
the type at issue here qualify as documentary evidence.
“To qualify as ‘documentary,’ the paper's content must be essentially undeniable and . . .,
assuming the verity of [the paper] and the validity of its execution, will itself support the ground
on which the motion is based (Amsterdam Hosp. Group, LLC v Marshall-Alan Assoc., Inc., 120
AD3d 431, 432 [1st Dept 2014] [internal citations omitted]). Emails may be considered
documentary evidence if those papers are “essentially undeniable” (id.), but dismissal is only
warranted if the emails “utterly refute” a plaintiff’s claim (see Kolchins 128 AD3d 47, 58).
Here, defendants rely on unaffirmed snapshots of emails and messages between Cummo
and Kerzner, allegedly showing Cummo’s vacation plans, personal appointments, work location
considerations, and business discussions. While defendants argue that the content of the
documents is undeniable, the documents do not utterly refute plaintiffs’ claim that Cummo was
an employee and that the Contract was a sham. And while the documents may raise credibility
issues regarding whether Cummo acted as an independent contractor, an employee, or Sporting
Contact’s COO, they do not conclusively establish that her employment duties fit a specific
classification. Therefore, the submitted emails and messages do not constitute the type of
documentary evidence contemplated by CPLR 3211(a)(1) (Opt. Communications Group, Inc. v
Worms, 217 AD3d 458 [1st Dept 2023] [holding that emails and evidence submitted by
defendants did not qualify as documentary evidence and were insufficient for purposes of
dismissal under CPLR 3211 because they did not utterly refute allegations in complaint]).
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Accordingly, defendants’ arguments relying on the submitted emails and messages as
documentary evidence are not considered in relation to this motion.
First Cause of Action; NYLL § 190, et seq,
Plaintiffs’ first cause of action, by Cummo against defendants, alleges violations of the
New York Labor Law for failing and refusing to pay Cummo’s earned wages and severance pay
in the amount of $55,500.
Cummo as an Independent Contractor
In the amended complaint, plaintiffs contend that although the Contract labels Cummo as
an “Independent Contractor,” she was, in fact, an employee as defined under the NYLL and
entitled to the alleged wages and severance pay.
Defendants argue that documentary evidence proves Cummo was an outsourced
independent contractor because she was free to pursue other employment opportunities, created
her own schedule, and was explicitly designated as an independent contractor in the Contract.
Plaintiffs oppose, arguing that despite the Contract’s language, Cummo was an employee
and that the Contract was a sham designed to allow defendants to avoid their obligations as the
employer.
Defendants oppose, reasserting their previous arguments.
Section 190(2) of the NYLL defines an “employee” as “any person employed for hire by
an employer in any employment.” Factors that courts consider when determining whether a
worker is an independent contractor or employee “include whether the worker: (1) worked at
[her] own convenience, (2) was free to engage in other employment, (3) received fringe benefits,
(4) was on the employer’s payroll and (5) was on a fixed schedule.” (Bynog v. Cipriani Grp.,
Inc., 1 NY3d 193, 198 [2003]). NYLL’s primary emphasis is on the degree of control exercised
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by the purported employer over the results produced by the plaintiff/employee, or the means
used to achieve the results (Bynog, 1 NY3d at 198).
Although the Contract labeled Cummo as an independent contractor, defendants’
assertions that Cummo was an outsourced contractor who controlled her work and was free to
engage in separate business ventures rely primarily on the emails and messages as documentary
evidence not considered by the court, as stated above.
Defendants’ remaining allegations concerning Cummo’s payment structure—that she
invoiced KHH rather than being on Sporting Contact’s payroll, and that no taxes were
withheld—are undisputed but not dispositive in determining her employment classification
(Chaouni v Ali, 105 AD3d 424 [1st Dept 2013] [employer not withholding taxes and issuing
1099 forms instead of W-2 forms is only one of many factors considered under NYLL]).
Therefore, defendants’ motion to dismiss based on Cummo’s alleged status as an
independent contractor is denied.
Cummo as an Owner and Employer
Defendants contend that even if Cummo was not an independent contractor, she was an
owner and employer, exempt from protection under the NYLL. They argue that Cummo’s role
as COO, which included overseeing labor management, scheduling, and hiring, exempts her
from NYLL protections. Additionally, defendants assert that Cummo’s ownership interest in
Sporting Contact further supports that she was an owner rather than an employee.
In opposition, plaintiffs reassert that the scope of Cummo’s job responsibilities, as
outlined in the Contract, misrepresented the tasks she actually performed for Sporting Contact,
and that Kerzner controlled her supervisory responsibilities. They also contend that Cummo’s
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small ownership stake in Sporting Contact does not preclude her from being classified as an
employee and receiving protections under the NYLL.
Defendants reply that the relevant inquiry is whether Cummo, as a shareholder, exercised
sufficient control over the business to be classified as an employer rather than an employee under
the NYLL. They maintain that ownership is a factor supporting employer classification.
An “employer includes any person, corporation, limited liability company, or association
employing any individual in any occupation, industry, trade, business or service” (Labor Law §
190). Courts use the “economic reality” test to determine whether the definition of “employer”
has been met under the NYLL, weighing whether the alleged employer “(1) had the power to
hire and fire the employees; (2) supervised and controlled employee work schedules or
conditions of employment; (3) determined the rate and method of payment; (4) and maintained
employment records” (Matter of Carver v State, 26 NY3d 272, 280 [2015]).
Although defendants assert that Cummo performed tasks characteristic of an employer,
such as hiring, firing, and scheduling, these claims are unsupported by any evidence. Plaintiffs
maintain that the supervisory role Cummo had over Sporting Contact employees was overseen
and controlled by Kerzner. Furthermore, while defendants submitted a restricted stock purchase
agreement showing that Cummo purchased 1.75% of the company’s stock, they do not cite any
authority stating such ownership denies an employee’s protections under the NYLL. Although
defendants correctly note that shareholding is a factor in determining whether Cummo is an
employer or owner, it alone is not dispositive.
Accordingly, defendants’ motion to dismiss, based on Cummo’s alleged status as an
employer or owner, is denied.
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Cummo as an Executive and/or Administrative Professional
Defendants argue that Cummo is barred from any claim under the NYLL because
documentary evidence plainly shows that her tasks performed were those of an executive rather
than an employee. Cummo’s classification as an executive or professional is further supported
by her title of COO and her $18,500 per month fee.
In reply, plaintiffs reassert their previous arguments that despite the Contract giving her
the title of COO, she was required to perform more manual, employee-like work, and the
Contract was a sham designed to avoid employer responsibilities under the NYLL.
Defendants reassert their previous arguments and contend that Cummo’s role, as defined
in the Contract, aligns with the statutory criteria for exemption from NYLL protections.
Except where expressly excluded, executives are considered employees under the NYLL
(Pachter v Bernard Hodes Group, Inc., 10 NY3d 609 [2008]). Under Section 190(7), “any
person employed in a bona fide executive, administrative or professional capacity whose
earnings are in excess of one thousand three hundred dollars a week” is exempt from coverage
under Section 191 (see Eden v. St. Luke’s-Roosevelt Hosp. Ctr., [1st Dept 2012]).
Section 191 governs the payment of wages by setting forth rules by which employers
make payments and the methods of compensation. While Section 190(7) creates an exemption
for how employers pay executives, determined by the executive's weekly earnings in excess of
one thousand three hundred dollars a week, this earnings threshold alone is not sufficient to
establish this exemption. Rather, it depends on the employee's classification as an executive or
professional, and thus the primary duties performed (Meregildo v Diaz, 154 AD3d 630 [1st Dept
2017] [employee found not to be an exempt executive because her duties were not primarily
managerial]). “The fact that an employee performs nonexempt work does not disqualify
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an employee from exempt status [under the NYLL] if she concurrently performs exempt
functions and her ‘primary duties’ qualify for exemption” (Mohammed v Start Treatment &
Recovery Centers, Inc., 64 Misc 3d 1 [App Term 1st Dept 2019]).
Here, defendants rely on plaintiffs’ assertions that Cummo operated Sporting Contact’s
retail store, managed banking and security accounts, and had access to financial statements to
demonstrate she was an executive under the NYLL. While such allegations may support
classifying Cummo as an executive or administrator, these tasks alone do not “resolve all factual
issues to the asserted claims as a matter of law” (Kolchins, 128 AD3d 47, 58). In any event,
Cummo contends that Kerzner maintained authority over all final decisions and that her primary
functions and duties were those of an employee, not a COO or executive. Therefore, even
though Cummo earned more than one thousand three hundred dollars per week, whether her
primary duties were that of an employee or an executive, continues to be in dispute.1
Accordingly, defendants’ motion to dismiss as it relates to Cummo’s alleged status as an
executive or administrative professional is denied.
Benefits and Wages under NYLL § 193
In the amended complaint, plaintiffs argue that defendants violated the NYLL by failing
to pay Cummo $55,500 in wages.
Defendants contend that Cummo seeks compensation for payments that do not fall under
the NYLL, specifically benefits and supplemental payments, which are not considered wages.
They also argue that the nonpayment of Cummo’s October 2023 fee was not a wage deduction
because she was terminated for non-performance, thereby eliminating KHH’s claims to notice or
1 NYLL Section 190(7) was amended in March 2023 to increase the weekly earnings from nine hundred dollars to one thousand three hundred dollars a week. 650773/2024 CUMMO, VANESSA ET AL vs. KERZNER, JUSTIN ET AL Page 11 of 16 Motion No. 002
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severance pay. Lasty defendants assert that Cummo cannot use the NYLL to recover any
benefits or wage supplements because KHH is the named party in the Contract
Plaintiffs oppose, reasserting that the allegations in the complaint must be taken as true,
and therefore, the factual dispute about damages is irrelevant at this stage of the case.
Defendants reply, rearguing that plaintiffs fail to state a claim because they do not specify
what services Cummo performed, when she performed them, or how she calculated the $55,500
owed. They further claim that plaintiffs’ admission of Cummo not performing the services
outlined in the Contract constitutes a material breach, justifying Sporting Contact’s termination
of the Contract for cause.
Labor Law § 193(1)(b) provides that “[n]o employer shall make any deduction from the
wages of an employee” (NYLL §193). “Wages” are defined as the “earnings of an employee for
labor or services rendered” and include “benefits or wage supplements,” as defined in Section
198(c) with exceptions not relevant here (NYLL §190[1]). The “wholesale withholding of
payment” is not a “deduction” within the meaning Labor Law § 193 (Kolchins v Evolution
Markets, Inc., 182 AD3d 408 [1st Dept 2020] [failure to pay a “Production Bonus” was a
“wholesale withholding of payment,” and not a deduction], see Perella Weinberg Partners LLC
v Kramer, 153 AD3d 443 [1st Dept 2017]).
Here, the parties’ allegations that Sporting Contact withheld wage and benefit
supplements hinges directly on Cummo’s employment classification as an employee rather than
an independent contractor or executive. As discussed above, defendants have not provided
sufficient documentary evidence to utterly refute plaintiffs’ claim regarding Cummo’s
employment classification. Cummo’s classification as an employee or independent contractor
will determine whether Sporting Contact’s failure to pay the October 2023 fee constitutes a
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violation of the wage and benefit provisions of the NYLL or alternatively was a wholesale
withholding of payment (see Labor Law § 193). Similarly, whether Cummo was entitled to
notice, or severance pay, again, depends on her employment classification (id.; see also Fraiberg
v 4Kids Entertainment, Inc., 75 AD3d 580 [2d Dept 2010] [although plaintiff was generally
covered by protections of Labor Law article 6, as a bona fide executive, she could not assert
claim to compel payment of severance package]).
Defendants' argument that Cummo materially breached the Contract, while discussed
below is unavailing because plaintiffs pleaded in their amended complaint that Cummo
“performed all aspects of her Contract with Defendants and did not breach the Contract in any
respect.”
Accordingly, defendants’ motion to dismiss regarding wage and supplemental benefits
claims is denied.
Second Cause of Action: Breach of Contract
In the second cause of action for breach of contract, by KHH against Sporting Contact,
plaintiffs plead in the alternative, arguing that if the court determines Cummo was an
independent contractor, defendants breached their employment contract with KHH, resulting in
damages.
Defendants contend that because plaintiffs concede in the amended complaint that
Cummo did not perform the duties outlined in the Contract, KHH, as the named contractor,
failed to perform and thus materially breached the Contract, barring it from a breach of contract
claim. Defendants further assert that even absent KHH’s material breach, Sporting Contact had
cause to terminate the Contract for its poor performance. Lastly, defendants assert that KHH
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fails to identify what specific provisions of the Contract were breached, and therefore, the breach
of Contract claim must be dismissed.
Plaintiffs oppose, reasserting their previous arguments.
To plead a breach of contract, a plaintiff must allege: (1) “the existence of a contract”; (2)
“plaintiff’s performance thereunder”; (3) “defendant’s breach thereof”; and (4) “resulting
damages” (Second Source Funding, LLC v Yellowstone Cap., LLC, 144 AD3d 445, 445-46 [1st
Dept 2016]).
Here, plaintiffs have pleaded all elements of a valid contract claim—namely, that despite
the language classifying KHH as an independent contractor being a sham, a valid contract
existed; that Cummo fully performed her duties on behalf of KHH for Sporting Contact; and that
defendants breached the Contract when Cummo was terminated from her employment, resulting
in damages. Assuming KHH is an independent contractor, its entitlement to notice or termination
pay depends on whether defendants had cause to terminate the Contract, the supporting facts of
which have not been presented at this stage in the pleadings. Similarly, defendants' allegation
that KHH’s poor performance constituted a material breach relies on emails and messages as
documentary evidence, which are not considered in this pre-answer motion. Because the court
must accept all facts in the amended complaint as true, defendants’ motion to dismiss plaintiffs’
second cause of action fails.
Third and Fourth Causes of Action; Quantum Meruit and Unjust Enrichment
For the third and fourth causes of action, plaintiffs pleaded quantum meruit and unjust
enrichment. They assert that if the Contract is deemed unenforceable, they are still entitled to
recover the reasonable value of the services provided, which they value at $55,500. Plaintiffs
argue that defendants benefited from these services without compensating them, resulting in
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unjust enrichment. Therefore, under both theories, plaintiffs seek compensation in the amount of
$55,500.
Defendants contend that plaintiffs’ quantum meruit and unjust enrichment claims should
be dismissed as duplicative of the breach of contract claim because the dispute is governed by a
valid contract. They further assert that plaintiffs cannot recover under quasi-contract theories, as
severance or notice pay is not compensation for services rendered, and Sporting Contact was not
unjustly enriched. Even if these claims were viable, defendants assert that the maximum
potential recovery is under $10,000, making Supreme Court jurisdiction improper.
Plaintiffs are not precluded from bringing an action for “breach of contract and, as
alternative theories, quantum meruit, and unjust enrichment” (Loheac v Children's Corner
Learning Ctr., 51 AD3d 476 [1st Dept 2008]). Here, because plaintiffs may plead quantum
meruit and unjust enrichment as alternative theories, defendants’ motion to dismiss as
duplicative is denied.
Transfer Request
Under CPLR 325(d), the Supreme Court may transfer a case to a lower court when it is
evident that the damages fall within the lower court's jurisdictional limits (see Genson v Sixty
Sutton Corp., 74 AD3d 560 [1st Dept 2010] [transfer to lower court is appropriate when it
becomes evident that amount in controversy is within courts jurisdictional limits]). Because it is
not evident that plaintiffs’ damages are less than $50,000 and thus fall within the Civil Courts
jurisdictional limits, defendants’ request to transfer the case to Civil Court is denied.
Accordingly, it is hereby
ORDERED that defendants’ motion to dismiss is denied in its entirety; and further
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ORDERED that defendants are directed to file an answer within 20 days of the service of
this decision and order with notice of entry; and further it is
ORDERED that the parties are directed to appear for a preliminary conference on June
10, 2025, at 9:30 a.m. at 71 Thomas Street, Room 305, New York, New York, 10013 and that the
parties are to be fully prepared to discuss settlement on the date of the conference.
5/5/2025
DATE DAVID B. COHEN, J.S.C.
CHECK ONE: CASE DISPOSED X NON-FINAL DISPOSITION
□ GRANTED X DENIED GRANTED IN PART OTHER
APPLICATION: SETTLE ORDER SUBMIT ORDER
□ CHECK IF APPROPRIATE: INCLUDES TRANSFER/REASSIGN FIDUCIARY APPOINTMENT REFERENCE
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