Visual Arts Foundation, Inc. v. Egnasko
Cases that cite this one
5 later published cases cite this decision.
- Hyde v. Okolie (Appellate Division of the Supreme Court of New York 2026)
- Sanders Equities LLC v. Maldonado (New York Supreme Court, Nassau County 2025)
- At Last Sportswear, Inc. v. Byron (Appellate Division of the Supreme Court of New York 2024)
- Wittels v. Sanford (Appellate Division of the Supreme Court of New York 2016)
- Accurso v. Infra-Red Services, Inc. (District Court, E.D. Pennsylvania 2016)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion of the Court
Having been found liable on the aiding and abetting claims, Egnasko’s co-defendants are jointly and severally liable for the damages resulting from Egnasko’s fraud and breaches of fiduciary duty (see Merrill Lynch, Pierce, Fenner & Smith v Arcturus Bldrs., 159 AD2d 283, 284-285 [1990]; American Tr. Ins. Co. v Faison, 242 AD2d 201 [1997]).
The motion court improperly denied plaintiffs request for sanctions in its entirety. The court is directed to conduct a hearing to quantify the damages that plaintiff incurred from those aspects of defendants’ litigation conduct that were “frivolous,” including, impeding discovery, the filing of meritless counterclaims and conduct which was “undertaken primarily to delay or prolong the resolution of the litigation” (22 NYCRR 130-1.1 [c] [2]). We note that, as Louis Egnasko is presently incarcerated, the hearing may be conducted through written submissions (see 22 NYCRR 130-1.1 [d]). Concur — Tom, J.E, Sweeny, DeGrasse, Abdus-Salaam and Manzanet-Daniels, JJ. [Prior Case History: 2011 NY Slip Op 30264(U).]
Case-law data current through September 30, 2026. Source: CourtListener bulk data.