On September 28, 2021, the First Department issued a decision in Slabakis v. Poyiadjis, 2021 NY Slip Op. 05110, holding that the scope of a boilerplate general release raised issues of fact precluding dismissal based on the release, explaining:
Whether the claims at issue were encompassed by the general release, which was a boilerplate release that did not describe in any detail the claims intended to be released, was an issue of fact that precluded dismissal.
(Internal citation omitted.)