SURE: "Defendants, HudsonGray Inc., erroneously named Hudson Gray LLC in the Complaint
("HudsonGray"), and Joseph Wagner ("Wagner"), submit this memorandum of law in support of
their motion, pursuant to CPLR 321 1(a)(1) and 321 1(a)(7), to dismiss all claims asserted against
Wagner and the claims against HudsonGray for breach of contract, tortious interference with a
contract, misappropriation and unfair competition, and usurpation of a corporate opportunity'
alleged in the Complaint filed in this action by plaintiff XA, The Experiential Agency, Inc.,
erroneously named as XA Experiential Agency, Inc. in the Complaint ("XA"). Wagner and
HudsonGray also seek sanctions under 22 NYCRR 130-1.1 for XA' s attempts to deliberately
mislead the Court in its Complaint by relying upon a superseded agreement and failing to attach
the operative release agreement
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