Tam-Zegarra v. Pleroma Mgmt, LLC

2025 NY Slip Op 32285(U)
CourtNew York Supreme Court, New York County
DecidedJune 26, 2025
DocketIndex No. 652019/2025
StatusUnpublished

This text of 2025 NY Slip Op 32285(U) (Tam-Zegarra v. Pleroma Mgmt, LLC) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tam-Zegarra v. Pleroma Mgmt, LLC, 2025 NY Slip Op 32285(U) (N.Y. Super. Ct. 2025).

Opinion

Tam-Zegarra v Pleroma Mgmt, LLC 2025 NY Slip Op 32285(U) June 26, 2025 Supreme Court, New York County Docket Number: Index No. 652019/2025 Judge: Lyle E. Frank 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. FILED: NEW YORK COUNTY CLERK 06/26/2025 12:48 PM INDEX NO. 652019/2025 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 06/26/2025

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. LYLE E. FRANK PART 11M Justice ---------------------------------------------------------------------------------X INDEX NO. 652019/2025 FIONA TAM-ZEGARRA, MOTION DATE 06/10/2025 Plaintiff, MOTION SEQ. NO. 001 -v- PLEROMA MGMT LLC,PLEROMA MEDIA INC DECISION + ORDER ON MOTION Defendant. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 001) 6, 7, 8, 9, 10, 11 were read on this motion to/for DISMISSAL .

Upon the foregoing documents, the motion to dismiss is granted in part.

Background

In December of 2024, Fiona Tam-Zegarra (“Plaintiff”) signed an independent contractor

agreement with Pleroma MGMT, LLC (collectively with Pleroma Media Inc the “Defendants”).

The agreement stated that Plaintiff would serve as Head of Communications for Defendants for

the rate of $11,000 a month until the agreement terminated. She alleges that while she performed

under the agreement, Defendants failed to pay her the full amount due. In March of 2025 she

filed a complaint with the New York City Department of Consumer and Worker Protection

alleging violations of the Freelance Isn’t Free Act (“FIFA”). Plaintiff brought the present

proceeding that same month, pleading causes of action sounding in breach of contract, violation

of N.Y.C. Admin. Code 20-929, account stated, unjust enrichment, and quantum meruit.

Standard of Review

It is well settled that when considering a motion to dismiss pursuant to CPLR § 3211,

“the pleading is to be liberally construed, accepting all the facts alleged in the pleading to be true

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and according the plaintiff the benefit of every possible inference.” Avgush v. Town of Yorktown,

303 A.D.2d 340, 341 [2d Dept. 2003]. Dismissal of the complaint is warranted “if the plaintiff

fails to assert facts in support of an element of the claim, or if the factual allegations and

inferences to be drawn from them do not allow for an enforceable right of recovery.”

Connaughton v. Chipotle Mexican Grill, Inc, 29 N.Y.3d 137, 142 [2017].

CPLR § 3211(a)(1) allows for a complaint to be dismissed if there is a “defense founded

upon documentary evidence.” Dismissal is only warranted under this provision if “the

documentary evidence submitted conclusively establishes a defense to the asserted claims as a

matter of law.” Leon v. Martinez, 84 N.Y.2d 83, 88 [1994].

A party may move for a judgment from the court dismissing causes of action asserted

against them based on the fact that the pleading fails to state a cause of action. CPLR

§ 3211(a)(7). For motions to dismiss under this provision, “[i]nitially, the sole criterion is

whether the pleading states a cause of action, and if from its four corners factual allegations are

discerned which taken together manifest any cause of action cognizable at law.” Guggenheimer

v. Ginzburg, 43 N.Y. 2d 268, 275 [1977].

Discussion

Defendants bring the present motion to dismiss all claims except for the breach of

contract cause of action for failure to state a claim. Plaintiff opposes the motion. For the reasons

that follow, the motion is granted as to the fourth and fifth causes of action and denied as to the

rest.

The Complaint Adequately Pleads a Claim Pursuant to N.Y.C. Admin. Code § 20-928

Defendants first argue that the agreement in question does not fall under the purview of

FIFA because the agreement in question does not satisfy the requirements laid out in N.Y.C.

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Admin. Code § 20-928(b)(2). This provision requires that when a hiring party retains the services

of a freelance worker, there must be a written contract containing an itemization of all services to

be provided by the freelance worker. The agreement here simply states that Plaintiff would

“provide services as may be requested.” While Defendants are correct in their observation that

the agreement violates the requirements for freelance worker contracts, they err in concluding

that such a violation necessitates dismissal of Plaintiff’s claims. Plaintiff’s claim for a FIFA

violation is made pursuant to N.Y.C. Admin. Code § 20-933(a)(1), which states that “a freelance

worker alleging a violation of this chapter may bring an action in any court of competent

jurisdiction for damages as described in subdivision b of this section.” Here, Plaintiff has alleged

that the Defendants’ payment practices violated FIFA, a claim that is not negated because the

agreement also violates another provision of FIFA. A written agreement that violates § 20-

928(b)(2) does not remove a freelance worker’s ability to pursue claims under FIFA, it instead

provides another basis for a worker to bring a claim. In other words, the written contract

requirements are not a hurdle that must be met in order for a freelance worker to be entitled to

the protections of FIFA but are instead one of the available protections itself. See, e.g., MJ Lilly

Assoc., LLC v. Ovis Creative, LLC, 221 A.D.3d 805, 805 [2nd Dept. 2023].

The Account Stated Claim is Adequately Pled

Defendants move to dismiss the third cause of action for account stated on the grounds

that Plaintiff has not provided “adequate documentary evidence” to show that an invoice was

sent. In defense of their argument that a copy of an invoice is necessary, Defendants cite to case

law regarding the summary judgment standard, not the pre-answer motion to dismiss stage. See,

e.g., Morrison Cohen Singer & Weinstein, LLP v. Brophy, 19 A.D.3d 161 [1st Dept. 2005]. Here,

Plaintiff has alleged that she “performed work for Defendants in exchange for monthly payments

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of $10,044.00 and constantly demanded payment thereof in writing.” Defendants have not

established that providing copies of the invoices in question is necessary to survive a motion to

dismiss. Defendants also move to dismiss this claim as duplicative of the breach of contract

claim. The First Department has recently clarified that “an account stated claim is an

independent cause of action that is not duplicative of a claim for breach of contract.” Aronson

Mayefsky & Sloan, LLP v. Praeger, 228 A.D.3d 182, 183 [1st Dept. 2024]. Therefore, dismissal

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Related

Leon v. Martinez
638 N.E.2d 511 (New York Court of Appeals, 1994)
Connaughton v. Chipotle Mexican Grill, Inc.
75 N.E.3d 1159 (New York Court of Appeals, 2017)
Guggenheimer v. Ginzburg
372 N.E.2d 17 (New York Court of Appeals, 1977)
Morrison Cohen Singer & Weinstein v. Brophy
19 A.D.3d 161 (Appellate Division of the Supreme Court of New York, 2005)
Avgush v. Town of Yorktown
303 A.D.2d 340 (Appellate Division of the Supreme Court of New York, 2003)
MJ Lilly Assoc., LLC v. Ovis Creative, LLC
200 N.Y.S.3d 403 (Appellate Division of the Supreme Court of New York, 2023)

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Bluebook (online)
2025 NY Slip Op 32285(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/tam-zegarra-v-pleroma-mgmt-llc-nysupctnewyork-2025.