New York does not recognize an independent cause of action for civil conspiracy, which may only be asserted to connect actions of separate defendants to an underlying tort. In order to assert a civil conspiracy claim, the complaint must allege a cognizable cause of action, agreement among the conspirators, an overt act in furtherance of the agreement, intentional participation by the conspirators in furtherance of a plan or purpose, and damages. Bare, conclusory allegations of conspiracy are insufficient.
Kovkov v. Law Firm of Dayrel Sewell, PLLC, NY Slip Op 02166 (1st Dep't April 2, 2020)
Here is the decision.
