On April 12, 2024, Justice Chan of the New York County Commercial Division issued a decision in Murphy v. PHG Funding LLC, 2024 NY Slip Op. 31473(U), dismissing claims because they used conclusory allegations, explaining:
As a threshold matter, all of defendants’ claims are dismissed because they are conclusorily pled. There are few if any factual allegations anywhere in defendants’ counterclaims, and those that are present do not link to the causes of action in any obvious way. The causes of action sections state bare legal requirements without any specificity or factual backing. Overall, even under the low requirements of notice pleading, defendants’ allegations fail to put any party on notice of the claims against them.
(Internal quotations and citations omitted).