From the response submitted by MacGregor's lawyers... interesting
"AS AND FOR A THIRD CAUSE OF ACTION
(Unjust Enrichment Against All Defendants)
85. Defendants MacGregor and LDSI repeat and reallege their responses to
Paragraphs 1 through 84, supra, as if set forth herein.
86. In a Decision and Order on Motion, entered by the Clerk of the Supreme Court of
the State of New York, Kings County, on October 8, 2019, in the above-captioned action (the
“Order”), the Court dismissed, in its entirety, Plaintiff’s Third Cause of Action for Unjust
Enrichment Against All Defendants. As a result, no response to Paragraph 86 is required.
87. In its Order, the Court dismissed, in its entirety, Plaintiff’s Third Cause of Action
for Unjust Enrichment Against All Defendants. As a result, no response to Paragraph 87 is
required.
88. In its Order, the Court dismissed, in its entirety, Plaintiff’s Third Cause of Action
for Unjust Enrichment Against All Defendants. As a result, no response to Paragraph 88 is
required.
INDEX NO. 504677/2019
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/28/2019"
8 of 26
"AS AND FOR A FOURTH CAUSE OF ACTION
(Money Had and Received Against All Defendants)
89. Defendants MacGregor and LDSI repeat and reallege their responses to
Paragraphs 1 through 88, supra, as if set forth herein.
90. In its Order, the Court dismissed, in its entirety, Plaintiff’s Fourth Cause of Action
for Money Had and Received Against All Defendants. As a result, no response to Paragraph 90
is required.
91. In its Order, the Court dismissed, in its entirety, Plaintiff’s Fourth Cause of Action
for Money Had and Received Against All Defendants. As a result, no response to Paragraph 91
is required.
AS AND FOR A FIFTH CAUSE OF ACTION
(Rescission Against All Defendants)
92. Defendants MacGregor and LDSI repeat and reallege their responses to
Paragraphs 1 through 91, supra, as if set forth herein.
93. State that Paragraph 93 of the Complaint contains statements of law and/or legal
conclusions for which no response is required and otherwise deny the allegations of Paragraph
93 of the Complaint.
94. State that Paragraph 94 of the Complaint contains statements of law and/or legal
conclusions for which no response is required and otherwise deny the allegations of Paragraph
94 of the Complaint.
AS AND FOR A SIXTH CAUSE OF ACTION
(Constructive Trust Against All Defendants)
95. Defendants MacGregor and LDSI repeat and reallege their responses to
96. In its Order, the Court dismissed, in its entirety, Plaintiff’s Sixth Cause of Action
for Constructive Trust Against All Defendants. As a result, no response to Paragraph 96 is
required."
AI
